Featured image: Brian Moynihan, Chairman and CEO of the Bank of America, (AP Photo/Michael Probst)

As we all know, many corporations and some of the vast federal regulatory agencies are not particularly pro-gun or pro-gun rights entities. Not only have they chipped away at our Second Amendment Rights, but also at the lawful commerce in arms and ammunition by denying access to financial services. Just search Operation Choke Point Program that the Obama Administration operated.

A special thanks to Dan Zimmerman over at the website www.TheTruthAboutGuns.com for his well-written heads up regarding the private sector financial services businesses that are clearly anti-gun actors. He has circulated this National Shooting Sports Foundation’s press release asking for induvial and origination comments in support the DEPARTMENT OF THE TREASURY Office of the Comptroller of the Currency proposed rules.

From the NSSF Press release:

“The NSSF®, the firearm industry’s trade association, is urging the public to comment on a Proposed Rule that would bring back fair and equitable access to financial services provided by financial institutions for industries that have suffered politically-driven discrimination. The Office of the Comptroller of the Currency proposed the rule to ensure that decisions are made based on rigorous risk-based analyses, not the political whims of external advocacy groups seeking to make law through the policies of financial institutions.

The OCC has stated, “Nothing in the proposal would require a bank to offer a particular service; the proposal requires only that the financial services offered by a bank to some customers are offered on proportionally equal terms to all customers engaged in lawful activities.”

The firearm and ammunition industry strongly supports the OCC’s proposed rule. NSSF is urging individuals to comment, especially if they share the concern that financial institutions benefitting from taxpayer-subsidized insurances, like the FDIC, and bailouts are improperly and unlawfully discriminating against legal, but politically-disfavored, industries, including firearm and ammunition production and sales, as well as other industries including oil and gas, coal, animal agriculture and private prison industries.

The proposed rule provides the following requirements for large, national banks ($100 billion or more in total assets) to provide fair access:

  1. Make each financial service it offers available to all persons in the geographic market served by the covered bank on proportionally equal terms;
  2. Not deny any person a financial service the bank offers except to the extent justified by such person’s quantified and documented failure to meet quantitative, impartial risk-based standards established in advance by the covered bank;
  3. Not deny any person a financial service the bank offers when the effect of the denial is to prevent, limit, or otherwise disadvantage the person:

(i)            From entering or competing in a market or business segment; or

(ii)           In such a way that benefits another person or business activity in which the covered bank has a financial interest; and

  1. Not deny, in coordination with others, any person a financial service the bank offers.

The public can make their voices heard in the Federal Rule-making process. The deadline for comment submission is Jan. 4, 2021 and can be submitted by accessing this link.

Firearm and ammunition manufacturers, distributors and retailers are devoted to supporting programs that promote the safe, responsible, and legal use of their products. Providing financial products and services to the firearm and ammunition industry is fully compatible with Environmental, Social and Corporate Governance (ESG) goals and policies increasingly implemented at financial institutions.

The firearm and ammunition industry is a legal, law-abiding and responsible partner with regulatory entities, law enforcement, and community groups. Our industry makes the exercise of the Second Amendment possible for over 100 million law abiding Americans. We produced $60 billion in total economic activity and employs roughly 151,000 people and support an additional 181,500 jobs in supplier and ancillary industries.

NSSF’s goal as an industry is to proactively promote Real Solutions for Safer Communities®.

Examples of such solutions include: Project ChildSafe®, Don’t Lie for the Other GuyTM, FixNICS®, Operation Secure Store®, and partnerships with American Foundation for Suicide Prevention and the Dept. of Veterans Affairs.”

Here is a quick and easy link to support this rulemaking. We suggest you use the following verbiage in your support of the rule which you can cut and paste into the available OCC webpage comment section:

“I stand in support of the OCC Rule to mandate that financial institutions benefitting from taxpayer-subsidized insurances, like the FDIC, and bailouts are improperly and unlawfully discriminating against legal, but politically-disfavored, industries, including firearm and ammunition production and sales, as well as other industries including oil and gas, coal, animal agriculture and private prison industries.”

Please make sure that you fill out the form in its entirety and request an email confirmation of your submission.

Shoot Straight, Speak the Truth, and never stop fighting for our Rights.

 

Dave Funk
President
Iowa Firearms Coalition