The Internal Revenue Service (the IRS) recently issued Notice 2026-5 which provides guidance on changes to health saving accounts (HSAs) enacted by the One Big Beautiful Bill Act (OBBBA).

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.