Access to Banking Is Access to the Right

What the records show

The OCC says it couldn’t measure the full extent of the practice, so what follows are examples, not a tally. They come from the banks’ own emails, policies and risk notes.

Wells Fargo. In 2024, staff called lending to the firearms industry “a controversial and highly partisan issue.”
Citibank. A firearms company asked for help with an IPO. Citi turned it down because the company’s policies didn’t match Citi’s “responsible firearm standards,” including “limitations on the sale of high-capacity magazines and restrictions on firearm sales to individuals under the age of 21.” The company believed its own policy complied with the law.
BMO. Account managers were told to bring firearms customers in line with the bank’s “Firearms and Ammunition Guidance.” Customers who declined were to be transitioned “out of the Bank.” In 2022, BMO kept a maker of empty magazines only on the condition that “tactical” sales stay under 30% of its total.
JPMorgan Chase. Reputation risk staff refused small firearms manufacturers with clean owner backgrounds, positive reviews and no negative news. The note on file: “No new clients permitted per Firmwide Rep Risk [Heightened Risk Sector] Definitions.” The bank also recommended against deposit, card and merchant services for a small ammunition-components maker with federal firearms licenses that supplied the military and law enforcement. In 2024, it declined merchant processing for an existing client moving into modern sporting rifles “due to the client being a firearms manufacturer.”
Capital One. Passed on a gun rights organization “due to optics that we endorsed its position on gun rights.”
TD. Escalated and recommended against a loan of less than $50,000 to a company making civilian components for modern sporting rifles. About four months earlier, its reputation risk committee had endorsed potential guarantees for a large multinational firearms manufacturer. That company later got a multimillion-dollar letter of credit.

The TD example is the one that should bother people. A small, lawful company couldn’t get a $50,000 loan, while a multinational in the same industry got a multimillion-dollar letter of credit. The OCC found these restrictions may have disproportionately hit smaller businesses, and smaller businesses are most of our merchants.

Why banks did it

According to the OCC, this wasn’t about credit risk. It was about reputation risk, meaning worry over how a customer might make the bank look. The OCC named banks’ environmental, social and governance (ESG) policies as the other main driver. At least two banks pointed to “polarizing” or “polarized” public opinion on gun ownership. One warned that ties to certain firearms manufacturers and retailers “could result in significant [f]ranchise risk.”

One bank told the OCC its firearms restrictions reflected “significant external pressures,” including congressional oversight, shareholder resolutions, activist campaigns and scrutiny from state and local officials. Banks also listed “the views of government entities (including the banks’ own regulators)” among the stakeholders they weighed.

The OCC found the banks mostly had no clear, measurable standard for what counted as reputation risk. It also noticed who got a pass. In wealth management, banks were “often finding ways to retain highly lucrative, existing bank clients” even when those clients had public issues. And the customers who were cut off often weren’t told why. Closure notices commonly cited nothing more than a “business decision.”

The result, in the OCC’s words, put banks in a “quasi-legislative position.” They restricted lawful businesses that no legislature had restricted, on behalf of people with no legal power to restrict them.

Why this is a rights question

Government is supposed to protect individual rights. The OCC’s report shows what happens when supervisory pressure, rather than law, decides which lawful customers a bank will serve.

The right to keep and bear arms depends on an industry. Someone has to make, sell, finance and process payment for lawful firearms. Pull the financial infrastructure and the right survives on paper while the market behind it starves.

Since Heller and Bruen, direct restrictions on possession and carry have to pass a demanding constitutional test. Pressure on the infrastructure faces no test at all. There’s no statute to challenge and no court reviewing the decision. A risk committee writes “no new clients permitted,” and that’s the end of it.

This report puts it on paper: regulatory and outside pressure got private banks to do what the law couldn’t.

This isn’t a partisan problem

The same report that documents banking restrictions on the firearm industry also documents the same mechanism across the political spectrum. Banks closed a merchant over pro-Trump merchandise, passed on an organization supporting abortion access, and rated a nonprofit promoting anti-immigration positions as high reputation risk. One bank treated any business engaged in “partisan activity” as presumptively high risk, whichever party it backed. Whichever side you’re on, the problem is the same: banks, under pressure from regulators, deciding which lawful customers are too controversial to serve.

The OCC’s word for access that follows the political climate is “whipsaw.” It warns industries may keep living through it “with the change of each administration or Congress, even in the absence of statutory changes.” A standard that protects a firearms manufacturer protects every lawful business from being dropped over whatever is unpopular this year. Regulators should never abuse their authority by pressuring banks to serve or refuse lawful customers based on politics or an undefined standard like reputation risk.

What has changed, and what hasn’t

Policy moved after states acted. Florida (2023, expanded in 2024), Tennessee (2024) and Idaho (2025) passed fair-access laws, and the OCC concluded those laws likely pushed many banks to drop industry restrictions. BMO told the OCC it had attested to Florida that it had no industry-based prohibitions, firearms included. In April 2026, the OCC and FDIC finalized a rule barring examiners from using reputation risk against banks. Alongside the report, the CFPB announced it will investigate these banks under fair lending, credit reporting and unfair-practices law.

The banks say they’ve already changed course. All nine say they’ve reassessed how they use reputation risk. In February 2025, JPMorgan CEO Jamie Dimon told Fox Business, “We don’t debank people because of political or religious affiliations, but there are a lot of things that can be fixed.” The Bank Policy Institute, which represents the largest banks, said it supports “clear and consistent standards that promote access while maintaining sound risk management.”

Still, a lot hasn’t changed. No bank has fully and publicly acknowledged its past decisions or set up a remediation program. Several have renamed reputation risk as “franchise” or “brand” risk. The OCC hasn’t fined anyone, and Comptroller Jonathan Gould said of the banks’ fixes, “I am not confident that they will be enough.”

The OCC is asking Congress to put this in statute, and we agree. Policy written by one administration can be unwritten by the next. Durable protection means standards that are measurable, impartial and risk-based, set in advance and written into law. The Fair Access to Banking Act (S. 401 and H.R. 987) and the state laws above point that way.

Where Credova stands

None of this is news to us. We’ve seen it firsthand, as a company and through the merchants we work with every day.

Guidefitter ran into it this summer. The Bozeman, Montana company runs a marketplace for more than 200,000 verified outdoor professionals: guides, outfitters, military members and first responders. Every member is credentialed before getting access. Its ACH provider still stepped away, without warning, days before we announced a replacement. We’d already been financing Guidefitter’s members, so we knew the business, and PSQ Payments rebuilt its ACH program quickly. “That they could step in and replace our prior solution quickly and seamlessly was a huge win for Guidefitter and our members,” CEO Bryan Koontz said. Vetting every single member still wasn’t enough to keep a payment provider.

We’ve been on the receiving end ourselves. In 2021, the CFPB opened an investigation into Credova. When the Bureau closed it in August 2025, its chief legal officer wrote that it “exemplifies the type of weaponization against disfavored industries and individuals” and “was not aimed at protecting consumers.”

In our experience, these decisions rarely start with the business itself. They start with the category code. A firearms retailer gets labeled “high risk” before anyone opens its books. Its chargebacks, its repayment history and its years of clean operation never enter the conversation. The OCC’s records describe the same thing: a small ammunition-components maker with federal licenses and no negative news, turned away because of its industry.

We work with these merchants every day, and the category code tells you very little about how a business performs. Its own default and chargeback history tells you a lot.

The other thing we’ve learned: this kind of exclusion doesn’t need a law behind it, and it doesn’t disappear when policy changes. The banks have revised their policies, and some have renamed reputation risk. The pressures that drove these decisions haven’t gone anywhere. That’s why we think the lasting answer is the one the OCC points to: clear, measurable standards, set in advance and written into law.

A law can change what a bank is allowed to do. It can’t make a bank want your business. That’s the gap we work in every day.