Signed May 19, 2026, the Restoring Integrity to America’s Financial System Executive Order directs Treasury, the Consumer Financial Protection Bureau (CFPB), and federal financial regulators, including the National Credit Union Administration (NCUA), to take a series of timed actions focused on two policy goals:
The EO creates no new rules by itself. All actionable changes will flow from formal advisory guidance and future rulemaking.
| Deadline | Required Action |
| 60 days
Jul 18 |
Treasury Advisory (Sec. 3a): Treasury must issue a formal advisory describing red flags and typologies for suspicious activity related to non-work-authorized populations, including payroll tax evasion, ITIN-based account opening, structuring, labor trafficking, and use of nominee/shell structures.
Credit unions should expect to receive this and incorporate flagged typologies into SAR monitoring programs, BSA policies, and staff training. |
| 60 days
Jul 18 |
NCUA credit risk guidance (Sec. 4b): NCUA, as a named federal functional financial regulator, must issue guidance on managing credit risks associated with the non-work-authorized population. This guidance will directly affect how credit unions approach loan underwriting and portfolio risk assessment. |
| 60 days
Jul 18 |
CFPB ability-to-repay clarification (Sec. 4a): The CFPB shall consider clarifying that deportation risk and associated wage loss may be factored into ability-to-repay analysis under Reg Z. Note: CFPB must only ‘consider’ this, it is not required to act. |
| 90 days
Aug 17 |
Proposed CDD rule changes (Sec. 3b): Treasury must propose BSA regulation changes to strengthen customer due diligence (CDD), including collection of beneficial ownership information and authority to obtain immigration status information where risk-based factors warrant it. This would flow to credit unions as covered financial institutions under BSA. |
| 180 days
Nov 15 |
CIP rule changes considered (Sec. 3c): Treasury and federal regulators shall consider changes to CIP requirements, including addressing risks posed by foreign consular identification cards. Any changes will require formal notice-and-comment rulemaking before taking effect. |
Actual operational impact will depend on the content of the Treasury Advisory and any future CIP rule. The EO itself changes nothing today. However, two near-term deliverables (The Treasury Advisory (July 18) and NCUA’s credit risk guidance (July 18)) will require attention.
California’s Credit Unions and Nevada’s Credit Unions are actively engaged with the NCUA, CFPB, Treasury, and credit union system stakeholders to ensure credit union perspectives are represented early in the implementation process. This engagement is focused on both the timing and nature of agency action, particularly the distinction between regulatory guidance and formal rulemaking.
In practice, this distinction is important for implementation planning. Agency-issued guidance can be issued more quickly and does not go through notice-and-comment, but it often shapes supervisory expectations and examination focus in real time. By contrast, rulemaking follows a formal process that includes public notice-and-comment, allowing the League and credit unions to directly influence the final regulatory outcome.
As Treasury and the federal regulators move through the EO’s 60-, 90-, and 180-day deliverables, California’s Credit Unions and Nevada’s Credit Unions are working to stay ahead of both tracks—engaging early on anticipated guidance while also preparing to participate fully in any resulting rulemaking process. This includes direct dialogue with regulators and Treasury staff to ensure operational realities for credit unions are understood before supervisory expectations are set.
For more information, email Lisa Quaranta.
Your League-member benefits include the Compliance Hotline — providing exclusive access to dedicated compliance experts:
Using the above phone number and email address, you can gain access to a knowledgeable team that’s ready to address all your credit union’s compliance inquiries — promptly and efficiently. With the Compliance Hotline, you can proactively respond to impromptu questions and issues by getting clarity and insight on technical topics that normally slow you down. We want to help you unlock the full potential of your League membership by leveraging the resources and support you need to navigate the complex world of compliance effortlessly. We’re ALWAYS just a phone call or email away!
Additionally, other League-member compliance resources include:
For more information, email Lisa Quaranta.
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