Regulatory Alerts2026-07-13 | FIL-36-2026Added · 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 enforceability, and potential concentration risks arising from employment instability or immigration enforcement changes. The guidance directs lenders to consider income stability, verify documentation, and review portfolio exposure to sectors disproportionately affected by workforce disruptions. This reminder aligns with concurrent Consumer Financial Protection Bureau statements regarding ability-to-repay determinations under the Truth in Lending Act and Equal Credit Opportunity Act.