N/A — Industry-wide guidance

As reported in Ballard Spahr's Mortgage Banking Update dated July 23, 2026, the FDIC, OCC, and NCUA issued joint guidance reminding financial institutions of their safety and soundness obligations when extending credit to individuals not legally authorized to work in the United States. The guidance addresses lending practices and compliance expectations for banks in this context. While not a direct enforcement action, this interagency guidance is relevant to BaaS and bank-fintech partnerships where fintech platforms may originate loans on behalf of sponsor banks, and underwriting and compliance standards must be maintained across partner relationships.

Verified from source: Federal Banking Agencies issued joint guidance on lending to individuals not legally authorized to work in the United States, as reported in Ballard Spahr's Mortgage Banking Update dated July 23, 2026.