The Office of the Comptroller of the Currency has issued new guidance that gives firearm businesses a clearer way to document and challenge politicized debanking by financial institutions. The move, announced April 30, builds on a joint OCC and FDIC final rule that eliminated “reputation risk” as a supervisory tool.

Here is what changed. Bank customers, including FFLs and other firearm industry businesses, can now file complaints about debanking directly with the OCC and FDIC. Those complaints become part of the regulatory record and will be considered when banks seek approval for mergers, charter changes, branch openings, and other significant transactions. The OCC states it may deny or condition approval of a licensing proposal by a bank with a record of politicized or unlawful debanking.

Debanking has been a persistent problem for the firearms industry. Banks have used vague “reputational risk” language to justify closing accounts, denying loans, cutting off payment processing, and refusing basic banking services to lawful, highly regulated businesses whose only offense was selling guns. The practice mirrors the Obama-era Operation Choke Point, which pressured banks away from industries disfavored by the political left. It returned in a privatized form under the Biden administration.

The OCC guidance implements President Trump’s Executive Order 14331, “Guaranteeing Fair Banking for All Americans.” That order states banking decisions must be based on individualized, objective, risk-based analysis rather than politics or ideology.

The joint OCC-FDIC final rule, published April 10 in the Federal Register and effective June 9, 2026, prohibits the agencies from criticizing or taking adverse action against a financial institution based on “reputation risk.” It also bars regulators from requiring, instructing, or encouraging banks to close accounts or deny services based on political, social, cultural, or religious views, or based on politically disfavored but lawful business activities.

Banks can still make legitimate safety-and-soundness decisions. Creditworthiness, compliance obligations, fraud risk, and other real financial risk assessments remain untouched. What they cannot do now is dress up politics as compliance and call discrimination “risk management.”

NSSF senior vice president and general counsel Larry Keane called the OCC guidance “exactly the type of accountability the firearm industry has demanded and worked for years to generate.”