As Winston & Strawn has detailed in earlier articles and alerts, the Trump administration has prioritized addressing “politicized or unlawful debanking” (i.e., when financial institutions close or refuse to open customer accounts based on a customer’s political affiliation, religion, or involvement in legal but politically disfavored industries), using executive orders, agency bulletins, and internal investigative probes to tackle the subject. The administration’s actions are starting to produce measurable results.

On December 5, 2025, the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) issued a joint statement (the Statement) rescinding the Interagency Guidance on Leveraged Lending, issued March 2013 (the 2013 Guidance), as well as the Frequently Asked Questions for Implementing March 2013 Interagency Guidance on Leveraged Lending, issued February 2014 (the 2014 FAQs). The Federal Reserve, which co-signed both documents, has not yet indicated whether it will follow suit, but one would expect larger state-chartered banks that are members of the Federal Reserve System (and thus supervised by the Federal Reserve) to lobby the Federal Reserve for equal treatment on this important issue to maintain a level playing field with their national bank and state-chartered, FDIC-supervised bank competitors.