Three federal bank regulators issued joint guidance Monday warning that lending to borrowers not authorized to work in the United States poses a credit risk banks must manage, AP reported [1]. The Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, and the National Credit Union Administration told institutions to "identify, measure, monitor, and control these risks through safe and sound underwriting practices that assess a borrower's willingness and capacity to repay," citing the prospect that a borrower "may not be able to repay a loan because of deportation" [1].
The guidance carries out a Trump executive order signed in May that directs banks to scrutinize the citizenship of their customers. It is one of several measures the administration has taken to push people living in the country illegally out of the banking system. DACA recipients and immigrants with Temporary Protected Status fall within its reach.
One fact sits under the whole exercise: no one knows the size of the problem. There is, AP reports, "limited data on how many people in the U.S. illegally have bank accounts and have loans through the banks" [1]. The regulators name a systemic risk without a count of the borrowers who supposedly create it, or a loss record showing they default more.
Supporters treat the danger as self-evident and opponents call it invented; AP prices the guidance instead against what it fails to quantify. The number that would settle the argument -- exposure, delinquency, portfolio share -- is exactly the number the guidance does not supply.
-- PRIYA SHARMA, Delhi