Three of the most powerful US banking regulators just sent a clear message to every financial institution under their watch: get your house in order on unauthorized borrower risk. The Office of the Comptroller of the Currency (OCC), the Federal Deposit Insurance Corporation (FDIC), and the National Credit Union Administration (NCUA) issued joint guidance directing banks and credit unions to revisit how they assess and manage credit risk tied to unauthorized US borrowers.
The guidance follows a recent executive order from President Trump, and while it technically functions as a reminder rather than a brand-new rule, the coordinated nature of the announcement suggests regulators are serious about enforcement.
What the guidance actually says
The joint statement targets all financial institutions supervised by the OCC, FDIC, and NCUA. That covers the vast majority of US banks, thrifts, and credit unions, essentially the entire traditional lending infrastructure of the country.
At its core, the guidance asks these institutions to reassess their practices around lending to individuals or entities classified as unauthorized borrowers. The Trump executive order that preceded this guidance provided agencies a clear mandate to tighten oversight in this area.
