To our clients and friends:
On September 8, 2025, the OCC announced actions, including issuing two Bulletins, to “end the weaponization of the financial system” by “rooting out” activities that “unlawfully debank or discriminate against customers on the basis of political or religious beliefs, or lawful business activities.” Our Legal Update, available here, describes the OCC’s plan to start reviewing banks’ debanking practices in licensing application reviews and CRA evaluations, and the agency’s instructions to banks regarding responding to government information requests and preparing SAR filings. Our Legal Update also offers a number of tips for OCC-supervised institutions prepare for further scrutiny from the agency regarding this issue.
Luse Gorman, PC regularly advises financial institutions on regulatory and compliance developments and enforcement actions from, and licensing applications to, the federal banking agencies. If you have any questions related to this Legal Update, please contact the authors. To learn more about our firm and services, please visit our website.