Digital Chamber Backs Fed Rule to End Crypto Debanking for Good

The Digital Chamber filed a formal comment letter on April 27 backing the Federal Reserve’s proposed rule to permanently strip reputational risk from bank supervision. The Washington-based advocacy group, the largest of its kind in the digital asset space, told the Fed that dropping the standard from guidance alone is not enough. It needs to be locked into rule.

The Federal Reserve’s proposal, identified as Docket No. R-1884, would prohibit the Fed from pushing banks to cut off customers on the basis of their political beliefs, religious views, or involvement in legal industries that regulators deemed unfavorable. The comment deadline closed April 27, 2026.

The Problem With Guidance That Can Be Reversed

Reputational risk has sat inside bank supervision for years. Examiners used it as a catch-all. No hard definition. No measurable threshold. A supervisor could flag a bank’s relationship with a crypto firm as a reputational concern, and banks would quietly cut ties rather than fight it.

The Digital Chamber’s letter makes one core argument: a rule is harder to undo than guidance. A future administration with a different posture on digital assets could revive the same mechanism overnight if all the Fed did was issue a memo. Codification through formal rulemaking changes that.

Fed Vice Chair for Supervision Michelle Bowman said as much when the proposal was published in February. She described documented cases where supervisors leaned on banks to drop customers tied to legally operating but politically unwelcome industries.

“Discrimination by financial institutions on these bases is unlawful and does not have a role in the Federal Reserve’s supervisory framework,” Bowman said.

That statement framed the proposal not as a crypto-specific favor but as a structural correction to how supervision has worked. The Digital Chamber’s letter reinforces that framing.

Where the Rule Stands Now

The FDIC and OCC moved first. On April 7, the two agencies finalized a joint rule that bars them from criticizing or acting against a bank on the basis of reputational risk. That rule takes effect June 6.

FDIC Chairman Travis Hill said the concept had been used to push banks into ending relationships with lawful customers. OCC Comptroller Jonathan V. Gould went further, calling reputational risk a “pretext” that agencies had used for decisions with nothing to do with safety or soundness.

The Federal Reserve’s version is still in proposed form. The April 27 comment deadline passed with submissions from multiple industry groups. The Digital Chamber’s letter joined those from the American Bankers Association and the Blockchain Association, both of which filed letters supporting codification.

What the Digital Chamber adds to the record specifically is the argument around durability. Ashok Pinto, executive vice president of legal and government relations at the Blockchain Association, made a version of the same point in that group’s letter. He wrote that the same supervisory tool turned on crypto under one administration could just as easily be turned on any other lawful sector under the next.

The Broader Debanking Picture

This is not an abstract policy concern. JPMorgan Chase confirmed in early 2026 that it closed more than 50 accounts linked to former President Donald Trump and the Trump Organization following the January 2021 Capitol breach. Jack Mallers, chief executive of payments company Strike, publicly posted in November 2025 that JPMorgan closed all his accounts without stated cause.

The Cato Institute found in January 2026 that most documented debanking cases in the U.S. traced back to government pressure rather than independent bank decisions. That finding shifted the conversation. Banks were not simply managing risk. They were responding to what examiners expected.

The Fed’s proposed rule would formally ban the Board from encouraging or compelling banks to deny services based on those grounds. Stablecoin issuers are expected to be included in the covered organizations once related rulemakings are completed. For African and emerging-market crypto firms seeking U.S. banking access, a durable rule rather than reversible guidance matters. A future policy shift would require going through rulemaking again, not just issuing new examiner instructions.

The Fed has not indicated a timeline for finalizing R-1884. With the comment period now closed, the next step is the Board reviewing submissions before deciding whether to finalize, modify, or withdraw the proposal.