Federal Banking Agencies Issue Joint Guidance on Lending to Individuals Not Legally Authorized to Work in the United States

On July 13, 2026, the Federal Deposit Insurance Corporation (FDIC), Office of the Comptroller of the Currency (OCC), and National Credit Union Administration (NCUA) issued interagency guidance reminding the financial institutions they supervise of their existing safety and soundness obligations when extending credit to individuals who are not legally authorized to work in the United States. So far, no such guidance has issued from the Federal Reserve Board.... By: Ballard Spahr LLP