On July 13, 2026, the Trump administration issued guidance through three federal bank regulators— the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, and the National Credit Union Administration— which suggests that banks should consider unauthorized immigrants as presenting an 'elevated credit risk.' This guidance does not introduce new regulations but reminds banks of their existing obligations to assess the creditworthiness of borrowers, particularly those without U.S. work authorization.
Jonathan Gould, the Comptroller of the Currency, emphasized that banks must know their customers, a requirement that predates this guidance.
Critics argue that this could deter not only unauthorized immigrants but also those with work authorization from using banking services, potentially increasing compliance costs for banks and pushing some financial activities outside the regulated banking system, which raises concerns about fraud.
The Urban Institute noted that while most mortgages require a Social Security number, some unauthorized immigrants can obtain loans using an Individual Tax Identification Number (ITIN), with only 5,000 to 6,000 ITIN mortgages issued in 2023 compared to 4.6 million total mortgage originations.
This regulatory push follows an executive order from President Trump aimed at tightening financial access for unauthorized immigrants, reinforcing a risk-based approach without mandating verification of immigration status for all customers