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ARTICLE · 20 APRIL 2026

FDIC, OCC Adopt Debanking Final Rule

Ballard Spahr LLP
Ballard Spahr LLP
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Ballard Spahr LLP

Ballard Spahr LLP

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The FDIC and the OCC have adopted a joint final rule that will prohibit the agencies from criticizing or taking adverse action against a financial institution based on reputation risk.

United StatesFinance and Banking

The FDIC and the OCC have adopted a joint final rule that will prohibit the agencies from criticizing or taking adverse action against a financial institution based on reputation risk. The rule is effective June 6.

The rule will also prohibit the agencies from “requiring, instructing, or encouraging an institution to close customer accounts or take other actions on the basis of a person or entity’s political, social, cultural, or religious views or beliefs, constitutionally protected speech, or solely on the basis of politically disfavored but lawful business activities perceived to present reputation risk,” according to a statement from the agencies.

The rule forbids the agencies from “taking any supervisory action or other adverse action against an institution, a group of institutions, or the institution-affiliated parties of any institution that is designed to punish or discourage an individual or group from engaging in any lawful political, social, cultural, or religious

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