Federal Banking Agencies Issue Guidance on Lending to Borrowers Without Work Authorization

Short summary

The OCC, FDIC, and NCUA issued interagency guidance on lending to borrowers without legal work authorization, citing elevated credit risk from potential employment interruptions or removal from the U.S. Institutions must assess repayment capacity, collateral recovery challenges, documentation adequacy, and portfolio concentrations tied to immigration enforcement exposure. The guidance references existing TILA, Regulation Z, ECOA, and Regulation B obligations and advises monitoring further supervisory developments.

• •OCC, FDIC, NCUA issued guidance on lending to borrowers without work authorization
• •Institutions must assess credit risk from employment instability and removal risk
• •Compliance with TILA, Reg Z, ECOA, and Reg B required; CFPB June 2026 statement referenced

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