A recent move by the Trump administration is aimed at making it harder for immigrant families to manage their money. On May 19, 2026, President Trump signed Executive Order 14406, Restoring Integrity to America’s Financial System, directing federal financial regulators to review banking and lending policies involving immigrants. Several federal agencies have now issued guidance implementing portions of the order, potentially imperiling immigrants’ access to financial services like opening a bank account or borrowing money.
Federal law does not give government agencies the power to stop people from opening bank accounts or applying for credit based on their immigration status. But the Trump administration has been aggressive in using any power it has to make immigrants feel unsafe and unwelcome in the United States.
This recent guidance could influence how some companies approach lending, account opening, and financial crime monitoring. If they have limited access to banks and companies that loan money, immigrant families could struggle to buy homes, start businesses, or keep their money (and themselves) safe.
Why Financial Inclusion Matters
Access to safe and affordable banking services is an important part of economic stability. Bank accounts allow people and families to receive wages, pay bills, and build credit. Access to lending unlocks the stability that comes from home ownership, investing in reliable transportation, and starting a business that can provide a source of income. For many immigrants, access to regular financial institutions means they don’t have to use companies like payday lenders or check-cashing services that charge high costs and have fewer protections. Unfortunately, research shows immigrants are already significantly less likely to have a bank account than U.S.-born households.
Current Law on Immigrants and Banking
There is no law that prevents immigrants of any status from opening bank accounts or applying for credit. Under the Bank Secrecy Act, existing regulations do require financial institutions to verify a customer’s identity when opening a new account, but they do not require banks to inquire about a customer’s immigration status. Banks may ask for a Social Security Number to open an account, but many also accept Individual Taxpayer Identification Numbers and other forms of identification to satisfy these requirements for immigrants without a Social Security Number.
What Have Agencies Said About Immigrants and Banking to Date?
Following the executive order, several federal agencies issued guidance signaling how the Trump administration would like financial institutions to approach lending money, preventing money laundering, and managing risk when immigrants apply for credit.
- The Consumer Financial Protection Bureau issued guidance reminding creditors that they may consider potential immigration-related employment interruptions when evaluating whether they can repay certain loans. For example, a lender could consider the likelihood that a borrower’s work authorization will expire, affecting future employment.
- The Department of the Treasury / Financial Crimes Enforcement Network issued a joint advisory, identifying the use of ITINs as one of the risk factors that financial institutions may consider when developing customer risk profiles and imposing increased monitoring for potential money laundering or fraud.
- The Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, and the National Credit Union Administration issued guidance encouraging banks to consider changes in federal immigration enforcement, employment verification practices, labor availability, and workforce disruptions as increasing the risk of lending in certain areas. In other words, banks are being encouraged to consider whether the administration’s mass deportation efforts could affect borrowers’ ability to repay loans.
What Immigrants Need to Know
Although recent government actions have raised questions, the most important thing immigrants should know is that current banking laws remain in place. Still the new guidance could lead to changes and additional scrutiny so here are important takeaways:
- Immigrants can continue to open bank accounts and access financial services. Banking laws and regulations do not prohibit financial institutions from accepting ITINs or require banks to close existing accounts held by ITIN users.
- Lending processes may become more complicated for some. The recent guidance may lead some financial institutions to request additional documentation or take a more cautious approach when evaluating certain loan applications or banking relationships.
- Lenders may deny loans for additional reasons. If a borrower has immigration-related employment interruptions, some lenders may decide to deny a loan if they think it could affect the person’s ability to repay.
What Comes Next for Immigrants’ Access to Banks and Lending?
The guidance issued so far represents only the first phase of implementing Executive Order 14406. Several of the executive order’s most significant directives have not yet been implemented, including:
- Changes to customer identification requirements when opening new accounts and other processes, particularly targeting the use of consular ID cards.
- Changes to risk monitoring expectations could require banks to collect or evaluate additional information about customers, including their immigration status.
For now, advocates should continue supporting immigrant communities in understanding their rights while closely monitoring future agency actions. Just as importantly, advocates should engage with financial institutions, making sure they know that the guidance issued to date does not mandate any particular action and does not require banks to restrict immigrants access to their services. In fact, as detailed in the National Consumer Law Center’s review of this executive order, banks could face discrimination claims if they do so.
Advocates can also document and uplift any harmful impacts of banks that chose to use this order to try and exclude immigrants from their services. It is important that the administration’s continued attempts to make immigrants feel unwelcome do not go unchallenged.
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