New Guidance on Non-Work Authorized Borrowers

The Federal Deposit Insurance Corporation, the National Credit Union Administration, and the Office of the Comptroller of the Currency (“agencies”) have issued Interagency Guidance on lending to borrowers who are not authorized to work in the United States.

The guidance discusses how lending to non-work authorized borrowers increases credit risk, and how this risk should be managed by safe and sound underwriting practices. The guidance discusses the CFPB statement released last month and urges financial institutions to consider that document’s discussion of compliance obligations under TILA, Regulation Z, ECOA, and Regulation B.

More information is available here.