OCC, FDIC, NCUA issue guidance on lending to unauthorized workers

US bank agencies issued joint guidance reminding institutions of credit risk management obligations when lending to individuals not legally authorized to work.

The guidance reinforces existing credit risk management expectations for loans to borrowers without US work authorization. Institutions should reassess documentation standards, repayment capacity assessment, and BSA/AML alignment while managing fair lending and reputational considerations.

Affects consumer lending policies, credit risk controls, and fair lending compliance across US banks and credit unions.

Joint interagency guidance signals heightened supervisory attention to a politically sensitive lending category.

“The OCC, FDIC, and NCUA issued guidance to remind supervised financial institutions of their existing obligations with respect to credit risk management when lending to individuals not legally authorized to work.”