Federal bank regulators issue guidance directing lenders to account for immigration status as a credit risk factor.

On Monday, July 13, 2026, the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, and the National Credit Union Administration issued joint guidance directing banks and credit unions to treat borrowers without legal work authorization as potentially posing elevated credit risk. The guidance stems from a May 2026 executive order signed by President Trump requiring financial institutions to more closely scrutinize the immigration status of customers. Banks are instructed to identify, measure, monitor, and control these risks through underwriting practices that assess a borrower's capacity to repay, accounting for the possibility of deportation or loss of income.