Three federal bank regulators told lenders on July 13 to treat the possibility that a borrower could be deported as a repayment risk to be measured and managed. The Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation and the National Credit Union Association said in joint guidance that banks should account for the chance that people "not able to repay a loan because of deportation" pose "overall risk to the financial system," and should "identify, measure, monitor, and control these risks through safe and sound underwriting practices that assess a borrower's willingness and capacity to repay" [1].

AP's Fatima Hussein and Ken Sweet report the guidance does not order banks to close accounts; instead it hands lenders a supervisory rationale to tighten credit, part of a nine-month push "designed to strongly encourage banks to remove them as customers while not expressly mandating that the banks do so" [1]. It builds on a May executive order directing regulators to scrutinize customer citizenship and a FinCEN advisory flagging identity and payroll-tax fraud [1].

That is where the framings split. Administration-aligned accounts cast the move as routine safety-and-soundness risk control; immigrant-rights voices read it as exclusion by proxy. AP notes there is "limited data" on how many unauthorized immigrants hold accounts or loans [1] — which means the guidance is an instrument, not a measured portfolio loss. What actually decides who loses access is downstream: bank rejection rates, loan pricing and whether institutions quietly close accounts rather than defend borderline files.

-- Theo Kaplan, New York