The court filing follows a supervisory review by the Office of the Comptroller of the Currency of more than 100,000 complaints and 50,000 internal records from 2020 to September 2025, conducted under Trump's "Guaranteeing Fair Banking for All Americans" executive order. The regulator concluded that the nine largest national banks it supervises—JPMorgan, Bank of America, Citibank, Wells Fargo, U.S. Bank, Capital One, PNC, TD Bank and BMO Bank—used subjective "reputation risk" policies to deny or restrict financial services based on customers' political or religious views and lawful business activities.
The OCC report identified six industries most affected by the restrictions: digital assets, firearms and ammunition, oil and gas exploration, coal mining and coal power plants, private detention facilities, and tobacco and e-cigarette companies. Investigators also found that banks relied on negative news searches and advocacy groups such as the Southern Poverty Law Center to evaluate customers, including instances where PNC declined a credit line to a media company and TD Bank prepared to deny a Paycheck Protection Program loan to a conservative nonprofit. While no fines have been imposed, the Consumer Financial Protection Bureau opened an investigation and the OCC formally ended reputation risk as a basis for bank supervision.