On October 14, 2025, the Florida Office of Financial Regulation (OFR) published a notice of proposed rulemaking (Notice) to amend certain of its existing anti-debanking rules that implement Florida House Bill 989 (HB 989), which became effective July 1, 2024, and amended Section 655.0323 of the Florida Statutes. If adopted into final form, the proposed amendments would amend Florida Administrative Code Rule 69U-100.323 (Annual Attestation of Compliance) and Rule 69U-100.3231 (Complaint Process Rule).

In this alert, Winston’s Financial Services Industry Group examines the latest developments in regulatory scrutiny of “debanking,” with a particular focus on recent actions following a Trump administration executive order.

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?