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Guidance for Credit Unions on Handling ICE Presence

A number of credit unions are seeking assistance in navigating situations involving the potential onsite presence of U.S. Immigration and Customs Enforcement (ICE) officials.

This includes whether ICE can be restricted if those officials attempt to enter the credit union’s premises, including branch locations and attendant parking lots.

Additionally, it includes whether and under what circumstances a credit union can share the financial records of members who possess an Individual Taxpayer Identification Number (ITIN) as their method to confirm personal identity obtained through the Customer Identification Program (CIP) process.

Analysis of Incoming Questions

Click here for an analysis of these questions from America’s Credit Unions and to learn more about:

  • Entry of ICE officials upon credit union premises.
  • Credit union sharing information regarding members with an ITIN.

ICE Resources

Additional resources related to ICE and questions regarding the protection of financial assets and financial preparedness in the face of deportation can be found here:

Considerations for Financial Preparedness

This CNBC article provides a high-level summary and links to additional resources.

Keeping You Updated

The California Credit Union League, Nevada’s Credit Unions, and America’s Credit Unions will continue to update this resource as more questions arise.

The information provided in this primer should not be construed as providing legal services, legal advice, or in any way establishing an attorney-client relationship. Credit unions should consult with a qualified legal professional to obtain advice tailored to the institution’s specific circumstances. This resource is intended only to be a summary of available information at the time of publication and is not all inclusive.

Given the rapidly changing regulatory environment, the information provided herein may not be reflective of the most current developments even at the time of publication.

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