CFPB Opens Debanking Review of Nine Large Banks After OCC Findings
The Consumer Financial Protection Bureau has opened a review of the nine largest national banks under its supervision for potential violations linked to debanking. The Bureau announced the initiative on Oct. 14, 2026. Debanking here means denying services or closing accounts. CFPB
The action follows a year-long review by the Office of the Comptroller of the Currency, the regulator for national banks. The OCC announced a review of its nine largest banks by asset size in September 2025. It issued preliminary findings in December 2025. OCC On Oct. 14, 2026, the OCC reported that some of the country's largest banks had unfairly denied services to some clients. Reuters
The OCC said nine large lenders used policies that denied, debanked and discriminated against some customers and businesses. Bloomberg
The nine banks under CFPB review are JPMorgan Chase Bank, Bank of America, Citibank, Wells Fargo Bank, U.S. Bank, Capital One, PNC Bank, TD Bank and BMO. The first five were named in the Bureau announcement. CFPB Capital One, PNC Bank, TD Bank and BMO are named as among the nine in later reporting on the review. Forbes
The CFPB is reviewing the nine banks under three existing authorities. They are the Equal Credit Opportunity Act, which bars discrimination in lending, the Fair Credit Reporting Act, which sets rules for credit reports and data accuracy, and the prohibition on unfair, deceptive or abusive acts or practices, known as UDAAP. Forbes Separately, the Bureau announced a next step to address debanking of businesses and individuals on the basis of constitutionally protected rights.
Supervision, enforcement and funding posture
The Bureau said it changed how its Supervision Division conducts exams. It did not detail the exam procedures in the summary release. The change was listed alongside several enforcement prioritization decisions.
The CFPB said it will not prioritize enforcement actions under the Truth in Lending rule on Use of Digital User Accounts to Access Buy Now, Pay Later Loans, 89 Fed. Reg. 47,068 (May 31, 2024). It also will not prioritize enforcement or supervision actions for entities currently outside the stay in Texas Bankers Association v. CFPB, No. 24-40705 (5th Cir.). A third decision covers missed future deadlines to submit registration information under the Registry of Nonbank Covered Persons Subject to Certain Agency and Court Orders.
For compliance teams, the near-term numbers concern dollar thresholds. The CFPB and the Federal Reserve Board announced thresholds for whether certain 2026 consumer credit and lease transactions get protections under Regulation Z, which covers lending, and Regulation M, which covers leases. The CFPB, Federal Reserve Board and OCC announced the 2026 threshold for higher-priced mortgage loans subject to special appraisal requirements will increase from $33,500 to $34,200. The Bureau and the Justice Department also withdrew a joint statement on a creditor's consideration of immigration status under the Equal Credit Opportunity Act.
Two older enforcement files were updated. In the Bureau's Nov. 12, 2021 lawsuit against FirstCash, Inc. and nineteen subsidiaries alleging Military Lending Act violations, the parties reached a settlement and jointly filed a stipulated final judgment and proposed order. The Bureau amended its Jan. 30, 2025 consent order with Wise involving claims of advertising inaccurate fees and failing to disclose exchange rates and other costs.
Data, operations and literacy
The 2025 Home Mortgage Disclosure Act Loan Application Register data is available on the Federal Financial Institutions Examination Council's HMDA Platform. HMDA data is the annual, loan-level record of mortgage applications. It is used for peer benchmarking, model validation and exam preparation.
On operations, CFPB officials met with Bilt to address issues from its transition to a new bank partner and remediation for affected customers. The Bureau also filed a notice in NTEU v. Vought stating the Department of Justice Office of Legal Counsel determined the Bureau may not legally request funds from the Federal Reserve under Dodd-Frank at this time.
On financial education, the Bureau stated support for the new National Strategy for Financial Literacy covering youth financial competency, saving and investing habits, digital financial literacy, and avoiding fraud and scams. CFPB Deputy Director Mark Paoletta provided remarks to the Financial Literacy and Education Commission.
The broader context here is a reallocation of supervisory attention rather than a new statute. ECOA, FCRA and UDAAP are established laws. The test for bank compliance, risk and data teams will be evidence.
In my view, the durable effect may be pressure to make account decisions auditable end to end, from written policy to system rule to examiner-ready record. Account data now sits in separate systems for onboarding, fraud, sanctions and credit. Joining those records is a tractable engineering task, and one that would leave customers and examiners with a clearer account of what happened.
