A new report reveals how large banks abandoned fair access standards in favor of a Chinese-style social credit system, denying financial services to Christians, pro-lifers, conservatives, and businesses in politically disfavored industries.
Imagine a world where you can’t get a job, receive a loan, or use social media because of your beliefs. That’s what happens to citizens with “disapproved beliefs” and low “social credit” in communist China, but it’s also a system that radical progressives worked to replicate in America under the Biden administration.
And they nearly succeeded.
It’s well known by now that social media companies were pressured by the federal government to censor or ban users who shared information or opinions the left didn’t like. And that Americans were fired from their jobs for refusing an experimental and harmful COVID vaccine or for holding to biological reality by declining to use a person’s preferred pronouns.
But behind the scenes, the nation’s largest banks were also working to “debank” Christians and conservatives, as well as anyone else who didn’t adhere to the “right” ideology.
The media and the left called it a conspiracy theory, but a recent report released by the Office of the Comptroller of the Currency (OCC), a branch of the U.S. Department of the Treasury that charters, regulates, and supervises national banks, shows the truth. Between late 2020 and early 2025, scores of businesses and non-profit organizations found themselves cut off from their accounts and critical financial services by nine of America’s largest banks: JPMorgan Chase Bank, Bank of America, Citibank, Wells Fargo Bank, U.S. Bank, Capital One, PNC Bank, TD Bank, and BMO Bank.
This form of cancel culture wasn’t because of too many bounced checks, suspected money laundering, ties to terror organizations, or other risky, suspicious, or illegal activities.
Rather, it was solely because these organizations’ religious affiliation, ideological beliefs, speech, political activity, or the industry they work in posed a “reputational risk” to the banks.
Those impacted included pro-life organizations, constitutional law firms, Christian ministries, firearm merchants, private prisons, traditional energy companies, and businesses that refused to adopt the bank’s preferred political, environmental, and social goals as their own.
The report, titled “Guaranteeing Fair Banking for All Americans,” was commissioned by an executive order from President Trump and investigated nearly 100,000 complaints and 420,000 pages of documents related to the decisions and policies of the nine banks.
Comptroller of the Currency Jonathan V. Gould said that report “provides irrefutable evidence that the nation’s largest banks have denied, debanked, and discriminated against customers and lawful businesses.”
“Reputational Risk” Trumped Historic Policies
Historically, banks have adhered to fair access principles when deciding whether to provide (and continue providing) financial services to customers. That means they performed a careful assessment of each customer “after applying measurable, impartial, risk-based standards” that the institution adopted in advance. Any decisions were made fairly and equally across all customers.
But under the Biden administration, large banks abandoned these policies, according to the OCC report. Instead, they implemented “reputational risk” assessments to determine whether servicing a business could cause negative public backlash or damage the bank’s image. According to the report, these assessments “lacked clear standards and objective, risk-based criteria” and, as a result “disadvantaged certain Americans based on their political, religious or social views or based on their lawful business activities.”
In other words, they effectively “judged” and then rejected prospective or longstanding customers because they held views or engaged in lawful business practices that the bank considered outside the “mainstream.”
The basis for flagging a client as a risk often came from Internet searches: A single negative headline or being designated as a “hate group” by the disgraced Southern Poverty Law Center could quickly spell the end of a banking relationship.
For example, in 2021, the JP Morgan subsidiary WePay, Inc., cited the SPLC hate map to close the account of a customer it described as a “[r]ight wing religious conservative nonprofit with strong anti LGBTQ rhetoric.” WePay created tools to flag and reject customers, including an internal system that would search for terms like “Make America Great,” “MAGA,” and “America First” in a customer’s website, marketing materials, and social media. It closed the account of one merchant for selling “MAGA”-themed products, saying the customer “promote[d] hate, violence, or racial intolerance.”
Capital One flagged a religious organization as high-risk because of its biblical views on social issues like abortion and LGBTQ rights, its “ties to the world of conservative politics,” and its involvement in partisan electoral activity.
TD found that providing a line of credit to a healthcare sharing ministry would pose a risk to its banking reputation because “it is clear that the moral and religious requirements to participate in plans like [this plan] appear to conflict with TD’s values of diversity and inclusion.”
And Citibank refused to help a company operating in the firearms industry with help on an Initial Public Offering (IPO) because it wouldn’t align its firearm sales policies to the bank’s. Among other demands, the bank insisted that the company prohibit firearm sales to individuals under the age of 21, even though federal courts have repeatedly ruled that such restrictions are unconstitutional.
Not everyone in the banking world was on board with this new direction. The report noted that many bank employees and executives raised concerns about the subjective nature of reputational risk policies and its larger impact on the credibility of banks and the banking industry.
In arguing to continue a relationship with a client, one bank’s executive stated, “Selective demarketing of just the [company] component is impossible; we would lose the entire relationship and I suspect the owners would not be shy about stating the reasons why to their circle of business associates. The irony of that is, in an attempt to address hypothetical external reputational risk, we would be creating actual severe reputational damage with the party that really matters most, our customer.”
Caving to Outside Pressure
The report noted that reputational risk actions “put banks in a quasi-legislative position of limiting banking services—or imposing values-based conditions on the availability of banking services—for lawful businesses disfavored by some activists and political leaders who lack the legal basis or legislative power to restrict or outlaw these business activities.”
Indeed, outside pressure from activist groups, Congress, executive administrations, media, public opinion, and other banks had an outsized influence on banks’ decisions.
One bank told the OCC that “banks were subject to significant external pressures relating to these activities, including congressional oversight, shareholder resolutions, activist campaigns, and scrutiny from state and local officials.”
That bank said some of its restrictions resulted from “protests and campaigns for restrictions on firearms manufacturers and distributors,” with the bank concluding that “[s]upporting such activities poses protest, headline, and mission related reputational risk.”
That pressure led some banks to refuse to serve entire industries or to limit new clients engaged in lawful business activities. Firearms, energy, and private prisons were among the industries blacklisted by some banks due to this pressure.
For example, one bank wanted to avoid Arctic oil and gas exploration because of pressure from “stakeholders” who had “identified the Arctic as a priority area of concern in part because of actions by the US Congress,” including “a key [bank] investor” who had “increased pressure” on it to adopt a public prohibition.
Bank of America announced it would end lending to private prisons and worked to end a 20-year relationship with a customer due to “pressure from politicians.” The bank also noted pressure from advocacy groups, including some that “wanted us to exit immediately no matter what the cost to us or to our clients.”
JPMorgan Chase issued sweeping restrictions on the firearms industry, including refusing to serve an arms manufacturer that provided ammunition components to the Department of War and local law enforcement.
Small Businesses Bore the Brunt
The report found that many of these banks’ industry restrictions were not applied consistently. In some cases, they applied only to new or small clients, with exceptions for larger or more lucrative customers.
PNC granted such an exception to its Arctic oil and gas restrictions, providing a “top 5” client with credit commitments worth hundreds of millions of dollars.
The report says, “In granting the exception, PNC noted that it had previously evaluated the client in early 2020 under the same policy, but the bank felt at the time that the revenue potential and bank relationship ‘was not strong enough to overcome the [sector policy] violation for a new PNC commitment’ to that client. That said, because the bank had since acquired another financial institution with an existing credit commitment to that same client, ‘depth of the relationship and economics’ had changed enough to support granting a sector exception.”
Meanwhile, TD declined a small business loan of less than $50,000 to a potential client that manufactured components for modern sporting rifles. TD claimed it was seeking to “reduce TD’s exposure” in firearms manufacturing, but four months earlier, it had endorsed financial guarantees and funding obligations to multinational firearms manufacturers.
In the following years, TD extended a multimillion-dollar credit letter for the multinational company to facilitate a contract with a foreign defense ministry.
The OCC noted that the impact went beyond discrimination but “risked hindering competition and innovation in lawful industries and often harmed smaller businesses, in particular.”
Could It Happen Again?
The debanking crisis has largely abated in recent years. Florida, Tennessee, Idaho, and South Carolina responded by passing fair access laws that prohibit banks from discriminating against customers based on beliefs, reputational risk, or similar subjective criteria. Under the Trump administration, many banks have also self-corrected by restoring objective policies.
But as the OCC rightly pointed out, the likelihood of another instance of political “whiplash” is very real; in fact, with progressive Democrats winning Congress and governorships in this week’s mid-term elections, they and their activist base are more likely to push banks to restart their old ideological debanking policies.
Banking executives must resist. Banks are powerful, critical institutions that provide basic and specialized services necessary for people to participate in the free market, whether it’s checking and savings accounts; mortgages and loans; credit card processing; money transfers; or investments, insurance, and financial advice.
To do that properly, a bank must be trustworthy. Allowing itself to be used by political forces as an ideological hatchet man against its own customers may be the fastest and surest way to lose that trust permanently.
Is there a solution? The OCC says it is developing new rules to stop viewpoint discrimination, but it is also strongly encouraging Congress to pass a law protecting the right to fair access to banking for all Americans.
The lame duck Republican Congress has a short window to try to pass a law guaranteeing protection for all banking customers, and they should try to make it happen. The incoming Democrat Congress certainly won’t; in fact, its radical progressive members will likely pressure banks and other corporations to re-adopt the woke standards of the early 2020s.
If it comes to that, bank executives face an existential decision: Will they finally decide to stand up for American fairness and free markets — or again cave to the Chinese-style social credit system? They better choose wisely, as they might not have another chance to get it right.
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