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Practice Area
Privacy: Regulated Personal Information (RPI)
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Class Actions & Group Litigation
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Client Alert
|September 12, 2025
|6 Min Read
Debanking Developments: OCC Bulletins Clarify Expectations, but Key Questions Remain
In this alert, Winston’s Financial Services Industry Group examines recent developments in debanking, focusing on two new OCC bulletins that clarify regulatory expectations. While these bulletins provide new insight into how the OCC is addressing debanking under the current administration, they also leave several important questions unanswered.
The OCC’s first bulletin addresses how politicized or unlawful debanking will factor into licensing applications and Community Reinvestment Act evaluations, emphasizing the importance of fair access and treatment. The second bulletin reminds banks of their obligations under the Right to Financial Privacy Act, particularly in light of recent congressional scrutiny, and underscores the need to protect customer financial records unless disclosure is legally required.
What does this mean for you?
Other Results 76 results
Law Glossary
What Is Privacy Compliance Law?
Law Glossary
What Is Data Breach and Data Security Law?
Law Glossary
What Is the General Data Protection Regulation (GDPR) Law?