Key Takeaways
New OCC, FDIC and NCUA guidance states that lending to individuals not authorized to work in the United States may present elevated credit risk and should be addressed through prudent underwriting.
The guidance follows recent Trump administration actions that signal a changed federal approach to evaluating credit applications from unauthorized workers.
Financial institutions should review underwriting practices, compliance protocols and customer-facing forms to address the new guidance while managing fair lending risk.
On July 13, the Office of the Comptroller of the Currency (OCC), the National Credit Union Administration (NCUA) and the Federal Deposit Insurance Corporation (FDIC) issued interagency guidance on lending to individuals who are not legally authorized to work in the United States. The new guidance advises that “lending to individuals who are not legally authorized to work in the United States may present elevated credit risk because a borrower’s ability… Read the complete article here...
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