July 17, 2026, JDSupra, Three Of The Federal Banking Agencies Issue Guidance On Credit Risks In Lending To Borrowers Without Work Authorization
The guidance is not without its critics. The National Community Reinvestment Coalition (“NCRC”) criticized the earlier CFPB statement and argued that credit decisions should turn on demonstrated repayment ability rather than hypothetical consequences associated with immigration status. It warned that the policy could exclude otherwise qualified borrowers from mainstream credit.
