Open Commerce Alliance
Equal Access to Financial Infrastructure
Thousands of legal businesses are systematically denied bank accounts and payment processing, not because of fraud or financial risk, but because of what they sell. OCA is a non-partisan coalition that advocates for the structural policy changes needed to end this practice.
A Systemic, Multi-Layer Problem
Financial exclusion of lawful businesses operates across multiple independent gatekeepers. Removing pressure at any single layer doesn't solve the problem, as every layer independently maintains its own restrictions.
Banks
Legal businesses are routinely denied the most fundamental financial product, basic checking accounts, solely because of industry category, not financial risk.
Card Networks
Visa and Mastercard operate Brand Protection Programs restricting entire merchant categories. No federal regulator currently exercises authority over these restrictions.
Payment Processors
Stripe, Square, PayPal, and others maintain their own prohibited business lists. Termination can result in MATCH list placement, an opaque industry blacklist that makes future processing nearly impossible.
What OCA Advocates For
OCA's advocacy is targeted, specific, and grounded in existing regulatory and legislative processes.
- The OCC/FDIC proposed rule eliminating reputation risk from bank supervision
- CFPB intake form changes to capture debanking complaints at the processor and card network level
- Congressional action to establish common carrier obligations for payment networks
Relevant Links
- OCC Preliminary Findings — "Review of Large Banks' Debanking Activities" (Dec. 2025)
- 90 FR 48825 — OCC/FDIC Proposed Rule: Prohibition on Reputation Risk (Oct. 30, 2025)
- CFPB-2026-0005 — Consumer Response Intake Form PRA Renewal (comment deadline March 2, 2026)
- EO 14331 — Guaranteeing Fair Banking for All Americans (Aug. 7, 2025)
What Is OCA?
The Open Commerce Alliance is a 501(c)(4) organization advocating for equal access to financial infrastructure. We are not partisan, not anti-regulation, and not a trade association for any single sector. We support appropriate financial regulation, but not that the nature of a business should be grounds for financial exclusion.
About OCA →