About OCA
A Coalition for Financial Access
The Open Commerce Alliance is a cross-industry organization advocating for equal access to financial infrastructure. If a business is legal, it deserves banking.
What We Are
The Open Commerce Alliance (OCA) is a 501(c)(4) social welfare organization and non-partisan cross-industry coalition advocating for equal access to financial infrastructure for lawful businesses. As a 501(c)(4), OCA may engage in lobbying and political advocacy in furtherance of its policy mission.
OCA's core position: if a business activity is legal, financial institutions, payment processors, and card networks should not be able to deny basic financial services based solely on the nature of that business.
OCA is not a trade association for any single industry. We represent the shared interest of businesses across multiple lawful-but-disfavored sectors that face systemic exclusion from payment processing and banking services despite operating fully legally. The OCC's December 2025 preliminary report documented nine such sectors at the bank level alone, but we stand for any affected industry.
What We Are Not
- Not a lobbying group for any single industry. OCA's coalition approach is intentional. Financial exclusion is a structural problem that transcends any one sector's interests. The breadth of our coalition is part of our argument.
- Not anti-regulation. OCA supports appropriate financial regulation — BSA/AML compliance, consumer protection, fraud prevention, and the existing regulatory framework for banking and payment services. We ask only that legal business category not be treated as a risk factor in the absence of actual risk.
- Not partisan. The debanking problem has been acknowledged across the political spectrum. Operation Choke Point was criticized by both parties. Financial access is not a left-right issue, and OCA engages across partisan lines.
- Not asking banks to ignore risk. Fraud, chargebacks, and actual financial risk are legitimate banking considerations. We are asking that the legal nature of a business not be conflated with financial risk.
Our Approach
OCA engages through existing regulatory and legislative processes:
- Building cross-industry coalition relationships to demonstrate the breadth and structural nature of the problem
- Producing policy analysis and public communications
- Engaging with Congressional offices on legislative approaches to payment network obligations
We are deliberate about the tone of this advocacy. This is not a protest movement.
The Policy Context
The debanking problem has received increasing attention across the political spectrum. Executive Order 14331 ("Guaranteeing Fair Banking for All Americans," August 7, 2025) reflects recognition of the problem at the executive level. The OCC's December 2025 "Preliminary Findings from the OCC's Review of Large Banks' Debanking Activities" documented that the nation's nine largest banks maintained formal restrictions on nine industry sectors based on reputation risk and values alignment. The OCC/FDIC proposed rule on reputation risk (90 FR 48825) represents a direct policy response to these findings.
But the most significant gatekeeping happens at the card network and processor level, where Visa, Mastercard, Stripe, Square, and others maintain their own content-based restrictions, independent of any regulatory requirement. No existing regulator has clear, exercised authority over these restrictions.
OCA exists to advocate for closing that gap: through CFPB enforcement authority, Congressional legislation establishing common carrier obligations, or both.