Davis Polk partner and Financial Institutions practice head Margaret Tahyar was quoted in Bank Director discussing forward-looking policies banks should adopt regarding debanking.

Margaret noted, “Adequate record-keeping will be essential going forward. Specific policies on closing deposit accounts may vary at each institution, but banks should implement clear processes to ensure it’s done properly.”

“At a minimum, you would want a policy,” she added. “You would want more than one person in the organization involved. You would want to be doing it for legitimate reasons — credit risk, anti-money laundering risk — and you would want to record it. It’s pretty sensible, practical stuff.” She adds: “Of the many, many hard and tricky things that banks do, this is not tricky.”

“Banks Face Tough Questions on Politicized Debanking,” Bank Director (November 14, 2025) 

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