CFPB Issues Statement on Considering Immigration Status as Part of Ability-to-Repay Analysis

CFPB, Fincen Guidance Casts A Pall Over ITIN Lending » NCRC

June 18, 2026, American Banker, CFPB, Fincen Guidance Casts A Pall Over ITIN Lending Manan Shah, policy advisor at the National Community Reinvestment Coalition, said that the advisories are a pretext for “excluding hard-working immigrants from accessing credit.” “Banks already have to follow strict identification and compliance measures,” he said. “Collecting data on immigration status will only worsen their administrative burden. Banks should …

CFPB Issues Statement on Considering Immigration Status as Part of Ability-to-Repay Analysis

The CFPB issued a statement addressing how analysis of a borrower’s ability to repay a mortgage loan may be affected if the borrower’s immigration status makes them non-work eligible or subject to deportation. TILA regulations require that lenders make a reasonable and good faith determination as part of the origination process that the borrower will have a reasonable ability to repay their loan.  This can include consideration of the borrower’s…