Regulators Signal Heightened Scrutiny of Lending to Non-Work Authorized Borrowers

The federal banking regulators issued new interagency guidance directing supervised financial institutions to take a closer look at credit risk when lending to individuals who are not legally authorized to work in the U.S. The guidance, issued jointly by the Office of the Comptroller of the Currency (OCC), Federal Deposit Insurance Corporation (FDIC), and National Credit Union Administration (NCUA), follows a May 2026 Executive Order (discussed here) aimed at addressing perceived risks to the... By: Troutman Pepper Locke