OCC Debanking Report: How Big Banks Shut Out Gunmakers

Last updated October 2026 · By Nick Hall, who tracks federal firearms-industry banking policy for USA Gun Shop readers

Quick take: The OCC has published its full debanking report on the nine largest national banks, and the gun industry is all over it. Citibank, JPMorgan, TD and BMO are named in cases where firearms businesses were turned away or told to sell guns the bank’s way. It’s a findings report, not an enforcement action.

• What happened: On October 14, 2026, the OCC released its report on debanking at JPMorgan Chase, Bank of America, Citibank, Wells Fargo, U.S. Bank, Capital One, PNC, TD and BMO.
• Why it matters: The report lists firearms, firearms accessories and ammunition makers and distributors among the restricted sectors and puts bank names next to specific gun-industry decisions.
• What’s next: The OCC says it is considering further rulemaking and will assess changes to the framework that applies to the largest banks.
• Who to watch: Comptroller of the Currency Jonathan V. Gould, and Congress, which the report asks for statutory changes.

Most debanking stories are either one business owner’s word against a form letter (“a business decision”) or a regulator’s press release with no names in it. This one is different. We pulled the full report so you don’t have to, and the firearms cases come with bank names and the banks’ own internal notes.

Table of Contents

What the OCC Debanking Report Covers

The OCC’s News Release 2026-90 says the agency reviewed debanking at the nine largest national banks it supervises, and that “between 2020 and September 2025, all nine banks had such policies.” The review opened on September 5, 2025, with a request for information to the banks, and preliminary findings followed on December 10, 2025.

The paper trail is big. The OCC reviewed nearly 100,000 complaints and received approximately 50,000 documents consisting of approximately 420,000 pages from the banks, plus transaction testing of hundreds of individual onboarding, expansion and termination decisions.

“Today’s report provides irrefutable evidence that the nation’s largest banks have denied, debanked and discriminated against customers and lawful businesses,” said Comptroller of the Currency Jonathan V. Gould.

In April the OCC and FDIC finalized the rule that took reputation risk out of their bank exams, which we covered when the OCC barred reputation-risk debanking of firearms firms. That rule changed how examiners treat banks. This report shows what the banks themselves were doing with reputation risk in the years before it.

The Firearms Section, Bank by Bank

The report lists “FIREARMS, FIREARMS ACCESSORIES, OR AMMUNITION MANUFACTURING OR DISTRIBUTION” as a restricted category and says “Several banks restricted financing to firearms manufacturers or retailers, including those offering assault- or military-style weapons for civilian use.” Note the word several. The all-nine finding covers debanking policies in general, not a gun ban at every bank.

Citibank is the headline case. A customer that owned a company in the firearm industry asked for help with an initial public offering. The bank’s policy required “responsible firearm standards,” including “limitations on the sale of high-capacity magazines and restrictions on firearm sales to individuals under the age of 21,” and Citibank denied the transaction because the company’s policies didn’t match, even though the customer believed its firearm policy complied with applicable law. That’s a bank writing its own under-21 sales rule into the price of service.

BMO wrote it down plainly. Its policy told account managers to work with customers to align with its “Firearms and Ammunition Guidance,” and “[i]f existing customers decline to meet the requirements . . . , Account Managers should work to transition the customer out of the Bank.” In a 2022 credit request from a maker of empty firearm magazines, BMO kept the relationship but required “tactical” sales to stay below 30% of total sales on a trailing twelve-month basis.

Wells Fargo staff in 2024 called lending to the firearms industry “a controversial and highly partisan issue” and noted that “[u]nder the Biden administration, banks could face greater supervisory pressure to move away from lending to the firearms industry.” The bank passed on two prospective firearms-industry customers, concluding that limited revenue potential supported the decision. And Capital One passed on a gun rights organization “due to optics that we endorsed its position on gun rights.”

Small Gunmakers Got Turned Away, a Multinational Got Credit

This is the part I would hand to any FFL who has been told a closure was “a business decision.” The OCC says the policies “may have disproportionately impacted smaller businesses, including smaller manufacturers of firearms and firearm components.”

JPMorgan repeatedly refused certain banking services to small firearms manufacturers. In one case the owners came back clean, online reviews were positive and no negative news turned up, and the reputation risk office still wrote “restricted per [Heightened Risk Sector] Framework” and “No new clients permitted per Firmwide Rep Risk [Heightened Risk Sector] Definitions.” It also recommended against deposit, card and merchant services for a small maker of ammunition components for the Department of War and state and local law enforcement, a business with federal firearms licenses and no negative media.

In 2024 an existing JPMorgan business client planning to build and sell modern sporting rifles asked for merchant processing. The bank declined “due to the client being a firearms manufacturer.”

TD is the cleanest contrast in the whole report, because a small business loan worth less than $50,000 to a company making modern sporting rifle components for civilian use was escalated for reputation risk review, drew a recommendation against approval and went no further, while about four months earlier TD’s reputation risk committee had endorsed potential financial guarantees for a large, multinational firearms manufacturer that later got a multimillion-dollar letter of credit for a contract with a foreign defense ministry. Same industry. Different size of check.

What the Report Does Not Do

It is not an enforcement action. Neither the release nor the report announces a fine, a penalty or an order against any of the nine banks, and nothing in either one reopens a closed account.

The OCC is also careful about its own limits. It says it “was unable to quantify on a comprehensive basis the full extent of debanking,” that the number of times a bank is named “does not reflect its relative volume of problematic decisions,” and that whether the banks complied with state fair access laws “is beyond the scope of this report.”

The banks have moved. Many revised their policies in late 2023 and 2024, and various banks reported the “removal or relaxation of restrictions affecting certain industries such as firearms, tobacco, and digital assets.”

But the OCC says “no bank has fully and publicly acknowledged its past debanking decisions,” and some banks now call reputation risk “franchise” or “brand” risk instead.

One finding matters to anyone buying a gun with a card. At one bank, an employee told customers that bank policy prohibited their declined firearms purchases. No such policy existed, and the declines came from the bank’s fraud models.

Where the OCC Goes From Here

Gould doesn’t sound satisfied. “Notwithstanding certain efforts by the largest banks to rein in these practices, I am not confident that they will be enough,” he said, adding that the OCC “will be assessing further changes to the regulatory and supervisory framework applicable to the largest banks.”

The report lists the tools. The OCC is considering further rulemaking on political and religious discrimination and on reputation risk, it is building a process to spot debanking trends in complaints, and it encourages Congress to make statutory changes. It also says private litigants may play a role by bringing actions under applicable law, and it commits to making sure there are no unreasonable barriers to sharing appropriate information in debanking-related litigation.

For a gun business that thinks it was debanked by a national bank, the report points to one door: HelpWithMyBank.gov, which now carries instructions for reporting debanking concerns. Florida, Tennessee and Idaho have enacted state fair access laws, and the report says those laws likely pushed many banks to rethink their industry restrictions.

The banks wrote it down. The OCC printed it. That’s a different kind of record than a vague closure letter.

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