Agencies Issue Guidance on Lending to Individuals Not Legally Authorized to Work in the United States — 2026-07-13

The Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, and the National Credit Union Administration (collectively, the agencies) today issued guidance to remind supervised financial institutions of existing supervisory expectations with respect to credit risk management, particularly as it relates to borrowers who are not legally authorized to work in the United States. As the guidance discusses, lending to individuals who are not legally authorized to work in the United States may present elevated credit risk because a borrower’s ability to generate income, maintain employment, and remain financially stable may be subject to greater uncertainty. Among other things, 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.