How to Navigate the Guaranteeing Fair Banking for All Americans Executive Order

The new Guaranteeing Fair Banking for All Americans Executive Order, signed on August 7, 2025, highlights the importance of ensuring that all Americans have fair and equitable access to banking and credit. As a software company dedicated to empowering financial institutions to manage regulatory compliance effectively and unlock new opportunities for growth, RiskExec has always supported the principles of fair access and non-discrimination in banking.

The August 7 Executive Order requires three primary actions from financial institutions subject to the SBA’s jurisdiction and supervision. Within 120 days, financial institutions that fall into this category must:

• Identify all potential clients denied access to financial services provided by the financial institution or any subsidiaries through a politicized or unlawful debanking action; and provide notice to each victim advising of the denied access and the renewed option to engage in such services previously denied.
• Identify all potential clients denied access to payment processing services provided by the financial institution or any subsidiaries through a politicized or unlawful debanking action; and provide notice to each victim advising of the denied access and the renewed option to engage in such services previously denied.
• Make reasonable efforts to identify and reinstate any previous clients of the institution or any subsidiaries denied service through a politicized or unlawful debanking action; and send notice of the reinstatement to the victims.

It is more critical than ever that all decisions to deny or initiate client-bank relationships use fair and equitable banking principles, now that a new level of federal scrutiny over financial institutions is beginning.

We encourage any RiskExec clients subject to SBA jurisdiction and supervision to collaborate internally to address this evolving regulatory focus. In light of this Executive Order and its short timeline, institutions subject to SBA jurisdiction and supervision should begin to collect and examine their recent history of denials and risk-based, non-discriminatory reasons for such actions to ensure they are prepared for any future examinations.

In light of the April 23, 2025 Restoring Equality of Opportunity and Meritocracy Executive Order, which discontinued the use of disparate impact within regulatory exams earlier this year, institutions will likely need to reevaluate their holistic compliance playbooks.

RiskExec’s compliance and business intelligence software platform provides powerful, yet easy-to-use, tools that financial institutions leverage to conduct comprehensive, data-driven analysis of their lending and servicing portfolios. These capabilities are critical for a proactive approach to compliance, ensuring that banking decisions are risk-based and free from bias.

If your institution is unsure about how to action this Executive Order in the next 120 days or assess your risk, get in touch with our team of experts today by submitting a Contact Us form.