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Bank of America boots charity serving impoverished Ugandans under vague 'risk tolerance' policies

ADF attorneys file consumer complaint with TN attorney general
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Steve Happ, founder of Indigenous Advance Ministries
Steve Happ, founder of Indigenous Advance Ministries, in Uganda (photo courtesy of Indigenous Advance Ministries)

NASHVILLE – Months after Bank of America canceled the accounts of Indigenous Advance Ministries with scant explanation and minimal warning, the Christian nonprofit has filed a consumer complaint with the help of Alliance Defending Freedom. The complaint asks Tennessee Attorney General Jonathan Skrmetti to investigate whether the bank illegally discriminated against the charity because of its religious views.

In operation since 2015, Indigenous Advance partners with Ugandan ministries to provide basic necessities for orphaned and vulnerable children, raise Christian families, and provide vital vocational skills training and mentorship to college students and young adults. Indigenous Advance held deposit and credit card accounts with Bank of America from its founding through April 2023, when it received a series of letters informing it that the bank was closing its accounts within 30 days.

“No American should have to worry that a financial institution will deny them service based on their religious beliefs, but Bank of America appears to have done just that with Indigenous Advance,” said ADF Senior Counsel and Senior Vice President for Corporate Engagement Jeremy Tedesco. “Canceling their account hurts those in need. It also sends a disturbing message to everyone—you can have your beliefs or your bank account, but you can’t have both.”

The initial letters gave no specific reason for the closures, only stating that “upon review of your account(s), we have determined you’re operating in a business type we have chosen not to service at Bank of America.” A later letter said, without explanation, that Indigenous Advance “no longer aligns with the bank’s risk tolerance.” The nonprofit does not advocate for any political causes and has maintained the same mission since it first opened its account with Bank of America.

As the complaint highlights, Bank of America may have violated consumer protection laws against unfair and deceptive practices and its own “Code of Conduct,” which specifies that it promotes “diversity and inclusion” with respect to religion, among other categories, and that every decision concerning customer accounts must reflect this inclusivity.

Indigenous Advance received notice of its account cancelations within months of another Bank of America customer—Christian author, preacher, and podcaster Lance Wallnau—reporting that his account was frozen by the bank. Bank of America told Wallnau that it suspected his account was involved in money laundering and forced him to answer a series of invasive questions to lift the freeze on his account.

Bank of America is not the only major financial institution engaging in this type of behavior. In the past two years, JPMorgan Chase has denied payments or cancelled accounts associated with people and organizations who hold mainstream American values such as former Ambassador Sam Brownback, the Arkansas Family CouncilDefense of Liberty, and former general Michael Flynn, Jr. Also, in 2022, PayPal disabled the account of a group called the Free Speech Union without explanation. PayPal eventually cited its “acceptable use policy,” which allows the company to take action against account holders whose views they find objectionable.

“If a bank is too big to fail, it’s too big for bias,” said ADF Legal Counsel Michael Ross. “State and federal governments grant banks and other financial institutions wide-reaching benefits to ensure everyone has access to essential financial services, not to play politics. Bank of America should respect everyone’s freedom to participate in the marketplace without fear of political or anti-religious bias.”

The unexpected closure of Indigenous Advance’s accounts forced the ministry to divert its attention and resources away from meeting tangible needs—including those of several Ugandan employees—while leaders scrambled to find a new bank. Bank of America’s action came just before an extended trip to Uganda by Memphis-based Indigenous Advance leadership.

“Real people in Uganda rely on us, and they matter,” said Indigenous Advance Ministries Founder Steve Happ. “We have five employees in Uganda, and they had to wait an extra week for a paycheck. That may not sound like much in the West, but in Uganda, that can mean a week without eating a full meal. At the end of the day, our purpose is to serve people in need in Uganda. No bank should hinder efforts to help widows, orphans, and the impoverished.”

Alliance Defending Freedom is an alliance-building, non-profit legal organization committed to protecting religious freedom, free speech, parental rights, and the sanctity of life.

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Jeremy Tedesco
Jeremy Tedesco
Senior Counsel, Senior Vice President of Corporate Engagement
Jeremy Tedesco serves as senior counsel and senior vice president of communications for Alliance Defending Freedom.
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Michael Ross
Michael Ross
Legal Counsel
Michael Ross serves as legal counsel for the Center for Academic Freedom with Alliance Defending Freedom