On July 13, 2026, the OCC, FDIC, and NCUA issued interagency guidance on lending to individuals not legally authorized to work in the United States. The guidance tells institutions to apply existing credit risk management standards and account for elevated repayment and stability risks where appropriate.
What changed
The agencies formally addressed this borrower segment in supervisory guidance, calling for risk-sensitive underwriting, account management, classification, allowance analysis, and related controls while remaining consistent with consumer protection laws.
Compliance perspective
Lenders should review underwriting policy, exception management, servicing controls, and portfolio monitoring where products may reach this borrower population. Documentation standards and fair lending review should be calibrated before making process changes.
Key date
Effective date: July 13, 2026.
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