meta_id 3320956

On July 13, 2026, the Office of the Comptroller of the Currency (OCC), the Federal Deposit Insurance Corporation (FDIC), and the National Credit Union Administration (NCUA) issued joint guidance to supervised financial institutions regarding credit risk management for borrowers not legally authorized to work in the United States. The agencies identified that lending to individuals without work authorization presents elevated credit risk due to greater uncertainty surrounding a borrower's ability to generate income, maintain employment, and remain financially stable. The guidance advises financial institutions to identify, measure, monitor, and control these risks through safe and sound underwriting practices that assess a borrower's willingness and capacity to repay according to the terms of the credit obligation. The agencies also directed financial institutions to consider the Consumer Financial Protection Bureau's (CFPB) June 8, 2026 "Statement on Ability To Repay and Immigration Status," which reminded creditors of their obligations under the Truth in Lending Act as implemented by Regulation Z and the Equal Credit Opportunity Act as implemented by Regulation B as they relate to non-work-authorized borrowers. The guidance applies to all supervised financial institutions, including banks, credit unions, and other lending entities regulated by the OCC, FDIC, or NCUA. The agencies issued this guidance in accordance with Executive Order 14406, "Restoring Integrity to America's Financial System," which addresses risks to the financial system posed by the extension of credit or financial services to the inadmissible and removable population. Financial institutions should review their current lending policies and underwriting procedures to ensure compliance with the agencies' supervisory expectations regarding credit risk assessment for non-work-authorized borrowers. The full guidance is available on the OCC website.