America's First Freedom - February 2021 - 12

O FFI C I A L J O UR NA L
Political Report

Trump Rule Restores Banking Fairness

I
By Jason Ouimet
Executive Director,
NRA-ILA

YOUR MEMBERSHIP
DUES ARE NOT
ENOUGH.
If you want to DEFEND your
right to own and carry a
firearm ...

If your FREEDOM to hunt and
shoot is important to you ...
Then you need to SUPPORT
the NRA Institute for
Legislative Action.
We are the only arm of
NRA specifically charged
with defending your
Second Amendment
freedoms on Capitol Hill,
and in state legislatures and
courtrooms across America.
Visit nraila.org to support
NRA-ILA today!

NRA-ILA: (800) 392-8683
NRA-ILA website: nraila.org
For related articles, go to

nrapublications.org.

12

n late November, the Trump administration
provided a lifeline to the gun industry with a
rulemaking that would restore access to the
products and services of America's largest banks.
Modern commercial activity depends on
tools like payment processing and lines of credit.
Gun-control advocates have sought to exploit
this reality by depriving firearms businesses of
the financial services they need to survive.
After all, without companies producing and
selling firearms and ammunition, there can be no
American gun owners.
The most infamous example of this tactic
occurred during the Obama/Biden administration and involved the government itself.
Following the economic crisis of 2008, which
resulted in taxpayer bailouts of large national
banks, Congress passed the Dodd-Frank Wall
Street and Consumer Protection Act of 2010
(Dodd-Frank). The act purported to improve the
resiliency of the U.S. financial markets and to
protect consumers from abuse.
In practice, however, the Obama/Biden
administration used a supposed initiative against
banking fraud to target industries that offended
their sensibilities.
Dubbed Operation Choke Point (OCP), the
scheme was a coordinated effort by banking
regulators purportedly to spur the finance
industry to more actively manage risks posed by
their customers.
Revelations by watchdogs, congressional
investigators, and litigation, however,
demonstrated the regulators were pressuring
banks to reject credit-worthy customers
in legitimate industries on the basis of the
regulators' own ideological objections to them.
These included sales of firearms and
ammunition, both of which were singled out on a
list of " high-risk " merchants the Federal Deposit
Insurance Corporation provided to banks in a
2011 guidance document.
In the circular reasoning of OCP, it wasn't just
the businesses' legality or financial performance
that created the hazard, but the " reputation
risk " they supposedly posed to banks by
provoking the ire of anti-gun activists.
The worst of the activism, however, was
coming from the regulators themselves. They
made it understood that the banks could face
expensive and damaging investigations for
serving disfavored clients.
Banks took heed and soon began avoiding
the " high-risk " industries entirely.
Financially sound and well-performing firearm
companies suddenly found themselves dropped
by their banks or refused new banking services.
The Obama/Biden administration
backpedaled when the scheme came to light.
The 2011 guidance was retroactively modified

FEBRUARY 2021 I AMERICA'S 1ST FREEDOM

and new guidance was issued emphasizing
case-by-case risk management, rather than
debanking of entire industries. The regulators
denied wrongdoing, insisting the banks
misunderstood their intentions.
Yet, anti-gun activists subsequently embraced
OCP's tactics, openly calling for discrimination
against the firearms industry.
In 2018, for example, The New York Times
published an essay that called for the finance
sector to " effectively set new rules for the sales
of guns in America, " arguing, " Collectively
they have more leverage over the gun industry
than any lawmaker. " The essay noted that
various payment processors had dropped gun
companies entirely and that banks could follow
suit, including by dictating what and to whom
firearm companies could sell.
After Democrats took over various congressional committees in the 2018 midterms, hearings were held to publicly berate and browbeat
officers of large national banks, including for
serving firearm-industry clients. While the
Obama/Biden Administration tried to disavow
OCP as a conspiracy theory, newly-emboldened
Democrats were unabashedly insisting that
banks had a " corporate responsibility " to curb
their relationships with the gun industry.
All the while, firearm-related businesses found
their options for financial services shrinking.
The Trump Justice Department officially
repudiated OCP in 2017. The new rulemaking
by the Office of the Comptroller of the Currency
(OCC) goes even further to correct this injustice.
Based on the Dodd-Frank mandate for " fair
treatment of customers, " it would require large
banks to provide access to all the products
they offer to every law-abiding customer who
is able to satisfy predetermined " quantitative,
impartial risk-based standards. " The rule would
also prohibit activists and federally-chartered
banks from conspiring to deprive otherwiseeligible customers of financial services for
political reasons.
Under Obama/Biden, and through the
subsequent efforts of anti-gun activists, the
finance industry was weaponized as a tool of
political oppression.
The Trump administration rulemaking, by
contrast, encourages banks to promote lawful
economic activity and manage financial risk,
while leaving policy decisions about what sorts
of businesses are permissible in the first place to
the political branches and the U.S. Constitution.
This is exactly why all patriotic Americans
should support it ... and why
you can expect the gun-control
lobby and their fellow travelers
in banking boardrooms to
vigorously oppose it.


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America's First Freedom - February 2021

Table of Contents for the Digital Edition of America's First Freedom - February 2021

Contents
America's First Freedom - February 2021 - CW1
America's First Freedom - February 2021 - CW2
America's First Freedom - February 2021 - Cover1
America's First Freedom - February 2021 - Cover2
America's First Freedom - February 2021 - 1
America's First Freedom - February 2021 - Contents
America's First Freedom - February 2021 - 3
America's First Freedom - February 2021 - 4
America's First Freedom - February 2021 - 5
America's First Freedom - February 2021 - 6
America's First Freedom - February 2021 - 7
America's First Freedom - February 2021 - 8
America's First Freedom - February 2021 - 9
America's First Freedom - February 2021 - 10
America's First Freedom - February 2021 - 11
America's First Freedom - February 2021 - 12
America's First Freedom - February 2021 - 13
America's First Freedom - February 2021 - 14
America's First Freedom - February 2021 - 15
America's First Freedom - February 2021 - 16
America's First Freedom - February 2021 - 17
America's First Freedom - February 2021 - 18
America's First Freedom - February 2021 - 19
America's First Freedom - February 2021 - 20
America's First Freedom - February 2021 - 21
America's First Freedom - February 2021 - 22
America's First Freedom - February 2021 - 23
America's First Freedom - February 2021 - 24
America's First Freedom - February 2021 - 25
America's First Freedom - February 2021 - 26
America's First Freedom - February 2021 - 27
America's First Freedom - February 2021 - 28
America's First Freedom - February 2021 - 29
America's First Freedom - February 2021 - 30
America's First Freedom - February 2021 - 31
America's First Freedom - February 2021 - 32
America's First Freedom - February 2021 - 33
America's First Freedom - February 2021 - 34
America's First Freedom - February 2021 - 35
America's First Freedom - February 2021 - 36
America's First Freedom - February 2021 - 37
America's First Freedom - February 2021 - 38
America's First Freedom - February 2021 - 39
America's First Freedom - February 2021 - 40
America's First Freedom - February 2021 - 41
America's First Freedom - February 2021 - 42
America's First Freedom - February 2021 - 43
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America's First Freedom - February 2021 - 46
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America's First Freedom - February 2021 - 54
America's First Freedom - February 2021 - 55
America's First Freedom - February 2021 - 56
America's First Freedom - February 2021 - Cover3
America's First Freedom - February 2021 - Cover4
America's First Freedom - February 2021 - CW3
America's First Freedom - February 2021 - CW4
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