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ARTICLE · 27 NOVEMBER 2020

OCC Proposes Fair Access To Financial Services Requirements

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On November 20, 2020, the Office of the Comptroller of the Currency ("OCC") proposed a new regulation setting forth the obligations of large banks to provide fair access to financial services

United StatesFinance and Banking
Andrew Olmem
Andrew Olmem
Thomas Delaney
Thomas Delaney
Matthew Bisanz
Matthew Bisanz
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On November 20, 2020, the Office of the Comptroller of the Currency ("OCC") proposed a new regulation setting forth the obligations of large banks to provide fair access to financial services ("Proposal") that is designed to prevent large banks from using "category-based risk evaluations to deny customers access to financial services."1

The OCC stated that the Proposal is a response to campaigns by political advocates who seek to achieve policy objectives by pressuring banks to stop providing financial services to customers (engaged in a lawful business) in certain industries or geographic regions. The preamble to the Proposal specifically points to campaigns that have targeted bank lending to firearm manufacturers, family planning organizations, private correctional facilities, and energy companies. In particular, the Proposal cites to a June 2020 letter to federal financial regulators from the Alaskan congressional delegation on the decisions of several

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