Regulatory Alerts2026-07-13
Added · Updated
Interagency Guidance on Lending to Individuals Not Legally Authorized to Work in the United States
The OCC, FDIC, and NCUA remind supervised financial institutions of their existing obligations to manage credit risk when lending to borrowers not legally authorized to work in the United States. Institutions must apply safe and sound underwriting practices to assess repayment capacity, collateral recovery, and concentration risks associated with potential employment instability or immigration enforcement actions. The guidance aligns with CFPB statements confirming that creditors may consider immigration status and work authorization when determining ability to repay under the Truth in Lending Act and Equal Credit Opportunity Act.
Topics
Share