Key Insights from the OCC Report

The Office of the Comptroller of the Currency (OCC) recently uncovered that nine major financial institutions implemented subjective reputation policies adversely affecting recognized legal businesses, particularly those in the digital asset sector.

Digital assets were specifically highlighted among six categories facing bank-imposed restrictions, stirring calls for legislative reforms.

Investigation Overview

Between 2020 and September 2025, the OCC examined the operations of the largest national banks, including names like JPMorgan Chase, Bank of America, Citibank, and Wells Fargo, among others.

The investigation reviewed an extensive collection of nearly 100,000 complaints and meticulously analyzed hundreds of cases along with approximately 420,000 pages of bank documentation.

Findings Related to Digital Assets

Among the significant findings, digital asset companies faced various restrictions, often justified by concerns related to financial crime. The OCC report identified these issues as part of a broader pattern of exclusions based more on industries’ public perceptions rather than individual risk assessments.

Reputation Policies and Their Implications

The OCC determined that all nine banks in their study engaged in reputation assessments that lacked clarity and were influenced by political and societal factors. This led to inconsistent access to banking services based on subjective judgments rather than transparent criteria of risk.

For example, allegations against individual customers sometimes resulted in account closures, while others with significant reputational issues maintained banking relationships. The report also detailed instances where political affiliations influenced banking decisions, showcasing the potential misuse of subjective evaluations.

Potential for Reform

The findings call for a reform in banking practices to ensure fair access to financial services. In light of the report, the OCC has expressed intentions to eliminate reputation risks from its supervisory framework and is contemplating further regulations that would address discrimination practices in bank policies.

Additionally, the OCC has urged Congress to enact legislation that safeguards equitable access to banking services for all lawful businesses.

Conclusion: Future Testing for Crypto Companies

The core question posed by these findings is whether the announced changes will lead to substantial improvements in banking practices. The OCC emphasizes the importance of assessing clients based on objective risk criteria rather than reputational considerations. For cryptocurrency firms, the practical evaluation will lie in their ability to secure banking services under these new guidelines.