- The CFPB is examining potential consumer protection violations, not simply revisiting the OCC’s supervisory findings. The agency is reviewing whether account closures or restrictions may have violated ECOA, FCRA requirements or prohibitions against unfair, deceptive or abusive acts or practices.
- Account-closure documentation could become a key source of legal exposure. Dhaliwal explains that institutions should assess whether documented reasons accurately reflect why an account was restricted or closed, including whether consumer reports factored into the decision and whether stated reasons satisfy applicable notice requirements.
- The implications extend beyond the nine banks under review. Although fintechs were not named in the OCC report, Dhaliwal notes that changes to sponsor banks’ account-closure policies and documentation standards could flow through to fintech program agreements and decision-making processes.
Article
CFPB Opens Debanking Investigation Into Nine Large National Banks
Forbes
Written by A.J. S. Dhaliwal
October 16, 2026Estimated Read Time: 1 min
Key Takeaways
In his Forbes article, “CFPB Opens Debanking Investigation Into Nine Large National Banks,” A.J. Dhaliwal examines the Consumer Financial Protection Bureau’s investigation into whether nine major national banks violated federal consumer financial laws when closing or restricting customer accounts. He analyzes the potential application of the Equal Credit Opportunity Act, Fair Credit Reporting Act and UDAAP provisions, and explains why banks and their fintech partners should closely examine account-closure practices and documentation as regulatory scrutiny intensifies.
Read more here.