OCC Releases Report on Large Banks’ Debanking Activities

Account termination is a risk decision with reputational and regulatory consequences, yet most banks treat closures as operational events rather than governed decisions requiring owner, rationale, evidence, and outcome. When the OCC examines debanking patterns across portfolios, the absence of decision records makes it impossible to distinguish legitimate risk management from arbitrary or discriminatory practice. A system of record produced at the moment of each termination decision—capturing the risk officer who authorized it, the specific factors that triggered it, and the supervisory checkpoint that reviewed it—transforms reactive examination findings into proactive governance. Decisions deserve engineering rigor, and account closures are no exception.