Take Action
Submit a Comment to the CFPB
The Consumer Financial Protection Bureau is accepting public comments on its Consumer Response intake form (Docket CFPB-2026-0005). This is an opportunity to push the CFPB to capture data on payment processor and card network debanking that is essential for any future enforcement.
What this comment period is about
The CFPB is seeking Paperwork Reduction Act (PRA) renewal for its Consumer Response intake form, used to collect consumer and business complaints. This is a procedural renewal, but it is also an opportunity to request substantive changes to what the form captures.
OCA's position: the form should be modified to specifically capture complaints about payment processor and card network account terminations, including the identity of the processor or network, the stated reason for termination, the affected industry, and whether the business was placed on the MATCH list.
Why this matters
Without systematic data on the scale of processor and card network debanking, there is no evidentiary basis for CFPB enforcement or Congressional legislation. The CFPB's existing complaint categories do not effectively capture these issues. Creating a formal intake channel is the foundational step toward building that record.
What your comment should say
Your comment should address the CFPB's Consumer Response intake form and request modifications to capture debanking by payment processors and card networks. Key points to include:
- You support modifying the CFPB Consumer Response intake form to capture payment processor and card network debanking complaints.
- The form should capture the specific processor or card network involved, the stated reason for termination or denial, the affected consumer industry, and any MATCH list placements.
- If you or your business has been affected by financial exclusion, briefly describe the experience. Personal accounts strengthen the record.
- The CFPB has UDAAP authority that may reach these entities, and complaint data is necessary to exercise it effectively.
Comments from affected businesses, industry associations, and individual advocates are all valuable. You do not need to be an attorney or policy professional to submit a public comment.
Submit your comment before March 2, 2026
Go to regulations.gov and search for docket CFPB-2026-0005. Click "Comment" and submit your public comment before the March 2, 2026 deadline.
Open Docket CFPB-2026-0005 on Regulations.gov →Additional Actions
Contact Your Representatives
Congressional action is needed to close the regulatory gap around card network content restrictions. Contact your senators and representatives to:
- Express support for the OCC/FDIC proposed rule eliminating reputation risk from bank supervision (90 FR 48825)
- Ask them to support legislation establishing fair access obligations for payment networks
- Share your experience with financial exclusion, if you have one
Join the Coalition
OCA is a 501(c)(4) organization building a non-partisan, cross-industry coalition of businesses, advocates, and individuals affected by financial exclusion. Coalition members receive:
- Updates on regulatory and legislative developments affecting financial access
- Coordination on comment opportunities and advocacy campaigns
- Connection to other affected businesses and organizations across industries
To join, contact OCA at coalition@opencommercealliance.org.
Or sign up for coalition updates:
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Support Finalization of the OCC/FDIC Proposed Rule
The OCC and FDIC proposed rule (90 FR 48825) would eliminate reputation risk from bank examination and supervision — a direct response to the documented pattern of banks restricting lawful industries based on ideological or political considerations. The OCC's December 2025 preliminary report, which found formal bank policies restricting nine industry sectors based on reputation risk, strengthens the evidentiary basis for finalization.