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Premier Insights

New Interagency Guidance on Lending to Non-Work Authorized Individuals: Implications for Banks and Credit Unions

July 23, 2026

The banking industry is adapting to evolving regulatory expectations around credit risk, customer due diligence, and compliance. Two key developments in May and July 2026 demand close attention: President Trump’s Executive Order 14406, “Restoring Integrity to America’s Financial System” (issued May 19, 2026), and the subsequent Interagency Guidance on Lending to Individuals Not Legally Authorized to Work in the United States, released by the FDIC, OCC, and NCUA on July 13, 2026.

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