For many consumer finance operators, keeping a bank account open can be as much of a challenge as underwriting or collections. Owners of payday, title and installment lending, check cashing and money transfer businesses know how disruptive an unexpected account closure or a declined application can be, especially when it comes with little explanation. A new federal report now puts the account-access practices of the largest banks under a spotlight.
On October 14, 2026, the Office of the Comptroller of the Currency (OCC) published the final findings of its supervisory review of debanking, announced in News Release 2026-90. The review covered the nine largest national banks the OCC supervises: JPMorgan Chase Bank, Bank of America, Citibank, Wells Fargo Bank, U.S. Bank, Capital One, PNC Bank, TD Bank and BMO Bank.
What the OCC found. The agency concluded that from 2020 through September 2025, all nine banks had policies that could deny or limit financial services based on customers’ political or religious beliefs or their lawful business activities. It pointed in particular to broad “reputation risk” policies that, in its view, lacked clear standards and objective, risk-based criteria. It also found that the banks kept public and nonpublic restrictions on access for certain industry sectors. The OCC says it reviewed nearly 100,000 complaints and roughly 420,000 pages of bank documents to reach these conclusions.
An important caveat for our industry. The OCC’s December 2025 preliminary findings listed “payday and payroll lending, consumer debt collection, and repossession agencies” as one of the restricted categories, and noted that several banks grouped auto title lenders and other high-interest consumer lenders into that same category. The final report does not carry that category forward. Its list of restricted sectors, which the OCC describes as not exhaustive, names six: oil and gas exploration, development or production in the Arctic; coal mining or coal-powered plants; firearms or ammunition manufacturing or distribution; construction or operation of detention facilities; tobacco or e-cigarette manufacturing, distribution or online retail; and digital asset activities. The final report does not name payday lenders, title lenders, check cashers or money services businesses.
What comes next. The OCC describes its fair-access work as ongoing. It says it is considering further rulemaking to keep banks from discriminating on the basis of political or religious beliefs and to address the role of reputation risk in bank decisions. It also says it will keep evaluating account termination practices and may issue additional guidance or regulations. Comptroller Jonathan V. Gould said the agency will assess further changes to the regulatory and supervisory framework that applies to the largest banks.
The same day, the Consumer Financial Protection Bureau (CFPB) announced that it will investigate whether the banks featured in the OCC’s report, and others, have complied with federal consumer financial laws. The CFPB said its reviews look at the Equal Credit Opportunity Act and the Fair Credit Reporting Act, particularly their adverse action notice requirements, along with unfair, deceptive or abusive acts or practices.
What it could mean for operators. Even though the final report does not single out consumer lending, its direction matters to our industry. Regulators are telling the largest banks that account decisions should rest on an individual, objective assessment of risk rather than on an industry label or worries about public perception. If that standard takes hold, a well-run storefront or online lender may find it easier to open an account, or to make its case when an existing relationship comes under review. It is too early to know how much bank behavior will actually change, and the report itself did not announce enforcement actions against any bank.
Be the customer a bank can say yes to. If banks are expected to judge customers on measurable risk, the operators in the best position are those who can show their controls clearly. For most businesses in this space, that means current licenses, a documented BSA/AML program, consistent Currency Transaction Report (CTR) and Suspicious Activity Report (SAR) processes, OFAC screening records, and reporting that can be produced quickly when a bank runs due diligence or an examiner asks for it.
Fair access does not mean relaxed anti-money-laundering expectations. Banks still have their own Bank Secrecy Act obligations, and they will continue to look closely at customers that handle cash, checks and money transfers. Clean, consistent records make that review faster and easier for both sides.
This is where everyday systems matter. In Tier3, compliance workflows are built into the same platform tellers and servicing teams already use, including OFAC screening, CTR preparation support, SAR workflows, activity logs, audit trails and reporting for compliance officer follow-up. For operators running check cashing software alongside payday loan software or title loan software, keeping lending, check cashing and money transfer activity in one system can make it simpler to answer a banker’s questions with data instead of assurances.
Practical next steps. Operators may want to note when their bank last asked for due diligence materials, confirm that key compliance reports can be pulled on short notice, and check that written policies reflect how the business actually runs today. Qualified compliance counsel or a BSA/AML consultant can help determine what applies to your specific licenses and states.
The OCC’s report is one step in a broader federal push on fair access, and more rules may follow. We will keep watching for developments that affect banking access for consumer lenders and money services businesses.
This article is for general information only and is not legal advice.
Further reading: Consumer Financial Protection Bureau, “CFPB Announces New Initiative to Address OCC-Uncovered Debanking by Large Banks,” October 14, 2026; OCC, “Preliminary Findings from the OCC’s Review of Large Banks’ Debanking Activities,” December 2025; Sidley Austin LLP, “Office of the Comptroller of the Currency Issues Final Report on Debanking,” October 20, 2026