Debanking is when a bank closes, limits or refuses an account or service. On 14 October 2026 the Office of the Comptroller of the Currency published a 47-page review finding that the nine largest national banks had done exactly that to customers based on political or religious beliefs. If you run a ministry, a firearms business, or any organisation with a visible position on something contested, the report is worth your attention – not because banking is your problem, but because the same logic applies to every vendor you depend on.
What the debanking report found
The OCC opened its debanking investigation in September 2025, and widened it after an August 2026 executive order directed federal banking regulators to examine whether banks were denying service over political or religious belief. The review drew on roughly 100,000 customer complaints and around 50,000 internal bank documents covering the period from 2020 to September 2025.
Its conclusion was that all nine of the largest national banks it supervises held policies – some public, some not – that restricted access to financial services beyond what ordinary financial risk would justify. Comptroller Jonathan Gould described the findings as “irrefutable evidence” of discrimination against customers and lawful businesses.
The nine banks named are JPMorgan Chase, Bank of America, Citibank, Wells Fargo, U.S. Bank, Capital One, PNC, TD Bank and BMO Bank.
The mechanism is the part worth understanding, because it is the same one that operates elsewhere. The report centres on reputational risk: an internal standard under which a bank assesses not whether a customer is a credit or compliance risk, but whether serving them might embarrass the bank. Reputational risk is vague by design. It does not require a customer to have broken a rule, and it rarely produces an explanation the customer can argue with.
The OCC was explicit that it could not quantify the full extent of what happened, or what it cost the customers affected. It has also said the review is continuing, with further findings on political and religious debanking and referrals to the Attorney General still to come.
Who was affected by debanking
The categories named in the report cut across the political spectrum. Alongside faith-based nonprofits and conservative organisations, the OCC lists media companies, event organisers, legal advocacy groups, abortion-rights organisations, firearms manufacturers, private prisons, electricity providers, and customers with no political dimension at all.
Two threads are worth pulling out, because they describe the kind of organisation that reads this blog.
Ministries. Indigenous Advance Ministries, which had banked with Bank of America since 2015, began receiving closure notices in 2023. Its case contributed to a 2024 Tennessee law prohibiting debanking on religious, political, environmental or cultural grounds. The report also records an account closed by an employee who described the customer in internal notes as a right-wing religious conservative nonprofit, and a foundation refused a line of credit because one of its founders had funded Christian conservative groups.
Firearms businesses. Wells Fargo declined loans to firearms businesses, and separately pressed a payment processor to end its relationship with a religious nonprofit over that nonprofit’s position on same-sex marriage. Firearms manufacturers appear as a restricted sector in bank policies rather than as individual cases.
One detail links both threads and matters more than either: in several instances the bank did not close the account itself. It leaned on an intermediary. WePay, a payment processor JPMorgan acquired in 2017 and has since discontinued, closed accounts for a conservative religious nonprofit and for a merchant selling political apparel. The decision reached the customer through a company they had no direct relationship with.
What the banks say
The banks dispute the characterisation. Their position is that restrictions reflect legal, financial and compliance risk rather than customers’ beliefs, and several have called for clearer regulatory guidance on where the line sits. JPMorgan has stated that its policies prohibit discrimination on political or religious grounds. The Bank Policy Institute, responding on behalf of several institutions, said the industry supports fair access and consistent standards.
That disagreement is unresolved, and this post does not try to resolve it. For a business owner the practical question is narrower, and it does not depend on who is right.
Debanking is a vendor problem, not a banking problem
Banking is where this got investigated, because banking has a regulator with subpoena power and a mandate to look. No equivalent review exists for web hosts, email providers, payment gateways or domain registrars.
But the structure of debanking is identical. Each of those vendors has an acceptable use policy. Most of those policies contain a clause permitting termination for conduct the provider considers harmful to its reputation, or simply at its discretion. That clause does the same work as reputational risk does in banking: it lets a provider end the relationship without having to show you broke a rule.
The difference is that losing a bank is survivable in a way that losing a host is not. A closed account is painful and slow to replace, but your organisation continues to exist while you replace it. When a host terminates, your website goes dark. When an email provider terminates, you lose your archive and every address your members or customers have. When a payment processor terminates, donations and sales stop that day. In each case the asset at risk is one you cannot quickly rebuild.
The WePay detail from the report is the one to sit with. Those customers were not told by their bank that their politics were a problem. A payment company they had never chosen made a decision on the bank’s behalf. Debanking through an intermediary is hard to see coming, and most organisations have no idea how many such companies sit behind their everyday operations – and you cannot assess a risk you cannot see.
Four places to check your debanking risk
None of this requires a consultant. It requires an afternoon and a willingness to read terms you have never read.
1. Your domain name. This is the one people forget, and the only one that is genuinely unrecoverable. If your registrar suspends a domain, your website and your email both stop, and no amount of backups brings them back. Confirm who your registrar is, that the domain is registered to your organisation rather than to a web designer or a former volunteer, and that the renewal contact is an address someone still reads. Lock the domain if your registrar supports it.
2. Your website and its backups. Ask two questions: can you download a complete copy of your site right now without asking anyone’s permission, and have you ever restored one? A backup you have never tested is an assumption. If your host holds the only copy, a termination and a data loss are the same event.
3. Your email. Email is usually the worst exposure, because the archive is irreplaceable and the addresses are known to everyone you work with. Check whether you can export mailboxes yourself, in a standard format, without a support ticket. Check who controls the domain’s mail records. If your email is bundled with something else – your website builder, your church management software, your CRM – then whatever happens to that product happens to your email.
4. Your payment processing. Find out who actually moves the money. Many giving platforms and shopping carts sit on top of a processor you never signed with, which is exactly the WePay arrangement described in the report. Ask your provider, in writing, which processor underlies your account and what their policy says about termination. If you take donations, a second route – even a dormant one – is worth having.
Read the acceptable use policy
For each of the four, find the provider’s acceptable use policy and search it for the words reputation, sole discretion and at any time. You are not looking for a provider with no such clause; almost none exist. You are looking to know what you have agreed to, and to decide whether you are comfortable with who gets to interpret it.
The honest version of this advice is that no provider can promise never to terminate anyone. What varies is whether the grounds are written down and specific, or vague and discretionary.
Where Liberation fits
We sell hosting, email and payment processing to churches, ministries, firearms businesses and other organisations exposed to debanking and deplatforming, on the wrong side of someone’s reputational risk assessment. So take the following as what it is – our pitch – and check it against our policies rather than taking our word for it.
Our acceptable use policy does not remove customers over lawful speech. Our servers are in the United States and we own the mail infrastructure rather than reselling someone else’s, which means a decision about your mailbox is ours to make and ours to answer for. You can export your site and your mailboxes yourself, at any time, without asking us. Migration from another provider is free, and churches and nonprofits receive a 15% discount.
What we will not claim is immunity. We are a company, we operate under US law, and we can be compelled to act like anyone else. The difference we offer is narrower and more honest than immunity: written grounds rather than discretionary ones, a smaller chain of intermediaries between you and your infrastructure, and a phone number that reaches someone who can explain a decision.
If the report has prompted you to look at your own exposure, the most useful thing we publish is probably not a sales page. Read what to do in the first 48 hours after a site is deplatformed – it applies whoever hosts you. If you run a ministry, our Christian web hosting page sets out how we handle faith-based organisations; if you are in the firearms trade, see 2A-friendly payment processing and gun-friendly web hosting.
If you want to talk it through, call (202) 760-4632 or send us a quick question.
Frequently asked questions
What is debanking?
Debanking is when a bank closes, limits or refuses an account or service. Banks do this routinely for ordinary reasons such as credit risk, fraud or anti-money-laundering rules. The contested question, and the subject of the OCC review, is whether banks have also done it because of a customer’s politics, religion or lawful line of business.
Which banks are named in the OCC report?
The nine largest national banks the OCC supervises: JPMorgan Chase, Bank of America, Citibank, Wells Fargo, U.S. Bank, Capital One, PNC, TD Bank and BMO Bank. The OCC found that all nine held policies restricting service beyond core financial risk during the period reviewed.
Does debanking affect my church or nonprofit directly?
Only if your provider decides it does, which is the problem. Most organisations will never be affected. The report’s value is that it documents how the decisions were made – through vague reputational-risk standards, often applied by an intermediary – so you can check where you are exposed rather than assuming you are not.
Can a web host really shut a site down over its content?
Yes, and the terms you agreed to almost certainly allow it. Nearly every acceptable use policy reserves the right to suspend service at the provider’s discretion. Whether it is ever used that way depends on the provider. The practical protection is not a promise, it is your ability to leave quickly with your data.
What should I do first?
Check your domain registration. It is the single point of failure most organisations overlook, and the only one from which backups cannot save you. Then confirm you can export your website and mailboxes yourself, and find out which company actually processes your payments.
Sources
- Office of the Comptroller of the Currency – the Debanking Review, published 14 October 2026
- American Banker – coverage of the OCC’s preliminary findings and the regulatory response
- MinistryWatch – reporting on the ministries affected, including Indigenous Advance Ministries
Published November 2026. The OCC has said its review is ongoing, with further findings expected. We will update this post as it develops.