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Despite the Order’s questionable authorized authority, banks should be prepared to interface with their federal regulators concerning perceived debanking actions that will have occurred prior to now and may think about growing methods to guarantee regulators that “politicized or unlawful debanking” will not occur in the future. Given the supervisory scrutiny of banks’ documentation of AML critiques, compliance groups may need to guarantee that the bank’s records fulsomely memorialize the reasons justifying account exit. The different two statutes cited in the Order, the FTC Act and the CFPA, can also prove problematic for regulators looking for to make out a case of politicized or illegal debanking.
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