Exec Order: Immigrant Interactions & Financial Institutions

The White House recently issued an Executive Order on Restoring Integrity to America’s Financial System, directing the U.S. Treasury Department, National Credit Union Administration (NCUA), and other federal agencies to review and address issues involving undocumented immigrants’ interactions with financial institutions.

The order contemplates additional guidance and rulemaking over the next six months. Federal agencies have already begun issuing related guidance:

• June 5, 2026 — FinCEN/NCUA/FDIC/OCC Joint Advisory: Federal regulators issued an advisory identifying red flags associated with suspicious activity involving the unlawful employment of non-work-authorized individuals. While focused primarily on employer and labor-broker misconduct, the advisory notes that ITIN usage may be considered as one factor in a broader risk-based customer due diligence review. The advisory does not create new legal requirements or mandate account closures.
• June 8, 2026 — CFPB Ability-to-Repay Statement:The CFPB issued a statement reminding creditors that information relating to a borrower’s ability to maintain employment income may be relevant to ability-to-repay determinations under Regulation Z. The statement does not create new legal obligations.

Additional federal guidance and proposed rulemaking are expected in the coming months, including potential changes affecting BSA/AML compliance, customer due diligence requirements, and customer identification procedures.

To assist credit unions, California’s Credit Unions and Nevada’s Credit Unions have developed the following compliance resources and frontline staff talking points.

California:

• California FinCEN Joint Advisory Compliance Bulletin.
• California CFPB Statement Compliance Bulletin.
• Frontline Talking Points.

For additional context, review the statement issued by California’s Credit Unions.

Nevada:

• Nevada FinCEN Joint Advisory Compliance Bulletin.
• Nevada CFPB Statement Compliance Bulletin.
• Frontline Talking Points.

For additional context, review the statement issued by Nevada’s Credit Unions.

For More Information

Access the ‘Compliance Hotline’

Your League-member benefits include the Compliance Hotline — providing exclusive access to dedicated compliance experts:

• 844-731-6072
• CANV@viclarityus.com

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:

• ViClarity
• CU PolicyPro
• ComplySight
• InfoSight
• CU Store
• Record Retention Guide
• GRC Technology Solutions

For more information, email Lisa Quaranta.

Powered by ViClarity, a California’s Credit Unions and Nevada’s Credit Unions company.