US debanking probe names TD Bank and BMO among nine lenders, with implications for Canadian brokers
Two of Canada’s largest lenders, Toronto-Dominion Bank (TD) and the Bank of Montreal (BMO), are among nine institutions named in a new US debanking report — one that found major banks had denied financial services to customers based on their political beliefs or lawful business activities.
The Office of the Comptroller of the Currency (OCC) launched its supervisory review in September 2025 following a presidential executive order titled “Guaranteeing Fair Access to Banking for All Americans.”
The review examined nearly 100,000 complaints and approximately 420,000 pages of documents from all nine banks — JPMorgan Chase, Bank of America, Citibank, Wells Fargo, U.S. Bank, Capital One, and PNC Bank, alongside TD Bank and BMO — and found that all had maintained policies limiting customer access on non-financial grounds at some point between 2020 and September 2025.
Broad reputation risk policies under review
Jonathan V. Gould, Comptroller of the Currency in Washington, described the findings as “irrefutable evidence” that these banks had “denied, debanked and discriminated against customers and lawful businesses.”
He added: “Fair access to financial services is not a mantra — it is a mandate.”
The OCC found that broad, poorly defined reputation risk policies, or those lacking objective and risk-based criteria, were used to restrict client access across sectors including oil and gas exploration, coal mining, firearms and ammunition manufacturing, tobacco and e-cigarette distribution, detention facility operations, and digital assets.
Implications for the broker channel
The OCC’s findings carry immediate weight for Canadian mortgage brokers, for whom both TD and BMO are significant lender partners.
TD Bank, which has moved to sell approximately US$9 billion in US mortgage holdings to comply with an asset cap imposed after its US$3.1 billion anti-money laundering settlement, remains a major broker channel lender in Canada.
According to Canadian Mortgage Professional’s coverage of MortgageFest Canada, Devon Ajram, vice-president, broker services and operations at TD Bank in Toronto, disclosed that close to 50% of the customers TD gains through the broker channel are new to the bank, a measure of just how critical that channel is to the lender’s growth.
BMO, which has been growing its broker presence through its BrokerEdge platform, is also an expanding partner in the channel. Brokers with clients in energy, firearms retail, or digital assets should note that these sectors featured prominently in the OCC’s findings — and as CMP’s earlier reporting on big bank CEO outlooks found, US policy shifts at these lenders have a habit of crossing the border.
Comptroller Gould acknowledged that while some banks had begun moderating these practices, he was “not confident” these steps would be enough. The OCC has signalled it will consider further changes to its regulatory framework for the largest banks.
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