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Bill intelligence

Banks win right to deny services without regulatory scrutiny

H.R. 2702 — FIRM Act · Filed by Andy Barr (R-KY) · 19 cosponsors · Introduced Apr 8, 2025 · Reported out

65%
Transparency
Typical bill: 85%
35/100
Hidden-provision risk
Typical bill: 15/100
High concernDeregulation of Bank Supervision

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What it does

This bill prohibits federal banking regulators (the Federal Reserve, FDIC, OCC, CFPB, and NCUA) from considering 'reputational risk' when examining and supervising banks and credit unions. Reputational risk is the concern that negative publicity about a bank's practices could harm its reputation or customer base. The bill frames this as preventing regulators from using subjective judgments about public opinion to deny banking services to lawful businesses, citing the 2013 'Operation Choke Point' as an example. Banks and financial service providers would benefit by facing fewer regulatory constraints tied to how their business practices are perceived by the public.

Why we flagged it

The bill's operative mechanism is to strip a supervisory tool (reputational-risk assessment) from federal banking regulators. It is framed as anti-weaponization but functions as a constraint on regulatory discretion, benefiting banks and financial service providers at the expense of supervisory flexibility.

What the text implies

  • Regulators will lose ability to examine whether banks are systematically denying services to entire industries (e.g., cannabis, firearms, payday lending) based on reputational concerns, even if such denials harm market access for lawful businesses and citizens.
  • The carve-out for 'state sponsors of terrorism' and 'foreign terrorist organizations' preserves reputational-risk review only for national-security contexts, creating a two-tier system where public-interest concerns are subordinated to security concerns.
  • Banks may face reduced pressure to maintain compliance infrastructure or customer-due-diligence standards if reputational risk is no longer a supervisory consideration, potentially increasing systemic risk from reputation-driven bank runs or contagion.
  • The bill does not prohibit banks from denying services; it only removes the regulatory tool used to examine or discourage such denials. Citizens and lawful businesses may still be cut off, but with less regulatory visibility or accountability.

Section numbers refer to the bill text the analysis read — linked under Primary records below.

Who it affects

Ordinary citizens lose a regulatory tool designed to prevent banks from cutting off access to lawful but controversial industries (payday lenders, cannabis businesses, firearms dealers, etc.) based on reputational concerns. While the bill frames this as protecting 'lawful businesses,' it removes supervisory discretion to address systemic risks and public-interest harms that may not fit neatly into traditional safety-and-soundness metrics. Citizens also lose transparency: regulators will no longe

Who stands to gain

  • depository institutions (banks and credit unions)
  • financial service providers
  • industries historically subject to reputational-risk reviews (payday lenders, firearms dealers, cann

Named in the bill

Federal Deposit Insurance Corporation (FDIC), Federal Reserve, Office of the Comptroller of the Currency (OCC), Consumer Financial Protection Bureau (CFPB), National Credit Union Administration (NCUA), Operation Choke Point, State Department, Foreign terrorist organizations, State sponsors of terrorism

Where it stands

19 cosponsors: 18 Republicans, 1 Democrats.

  • Apr 8, 2025 — Introduced · Congress.gov: “Introduced in House”
  • Apr 8, 2025 — Referred to House Committee on Financial Services · Congress.gov: “Referred to the House Committee on Financial Services”
  • May 21, 2025 — Markup held in committee · Congress.gov: “Committee Consideration and Mark-up Session Held”
  • May 21, 2025 — Reported out of committee · Congress.gov: “Ordered to be Reported (Amended) by the Yeas and Nays: 33 - 19”

Dates and quoted wording are Congress.gov's action record; the timeline shows status changes, not every procedural step.

Money around this bill

5 lobbying clients named this bill on 7 disclosure filings across 3 quarters, Dec 2025 to Jun 2026. Those filings disclosed $44,430,000 in lobbying spend. A filing names 51 bills on average, so that figure is what each filing reported, not a share belonging to this bill.

More lobbying clients named this bill than 78% of bills with at least one filing.

Andy Barr, the sponsor, reported $2,160,072 in PAC receipts in the 2026 cycle.

  • Chamber of Commerce of the U.S.A. — $37,710,000 on 2 filings
  • American Bankers Association — $5,210,000 on 2 filings
  • Citigroup Washington, Inc. — $1,330,000 on 1 filing
  • American Fintech Council — $110,000 on 1 filing
  • National Pawnbrokers Association — $70,000 on 1 filing

Lobbying Disclosure Act filings through Jul 20, 2026. A filing shows who paid to lobby on a bill it names, not what changed.

How this was measured

Analysis — Quorum's AI read the bill text published by Congress.gov (6,162 characters) on Jul 2, 2026. Section numbers in the findings refer to that text, linked below; transparency and hidden-provision scores are compared against the median of 16,222 analysed bills.

Status and sponsors — Congress.gov's bill record — actions, committee referrals and cosponsors — loaded nightly. The timeline shows status changes, not every procedural action.

Money — Senate Lobbying Disclosure Act filings whose specific-issue field names this bill for quarters ending Dec 2025 to Jun 2026. A filing's amount is reported whole beside the median number of bills a filing names; it is never divided across them. PAC receipts are FEC-reported contributions to the sponsor's candidate committee in the 2026 cycle.

As of — lobbying records through Jul 20, 2026 · page rendered 2026-10-20.

“Banks win right to deny services without regulatory scrutiny” QuorumCivic. https://share.quorumcivic.app/bill/119/hr2702 Report an error

Correlative observation from public records — not evidence of coordination or wrongdoing, and not financial advice.
This page is the record as of today. The app tells you when it changes.
Quorum analysis of the full bill text · 119th Congress · public record

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