A bank account in today’s economy is no longer simply a place to keep money. It is essential for receiving wages, paying rent and bills, making online transactions, building savings, managing a business, and, ultimately, participating fully in the financial system.
For immigrants, access to this system has not always been easy. The lack of a Social Security Number (SSN), different forms of identification, a limited or nonexistent U.S. credit history, language barriers, and limited familiarity with the U.S. banking system have created significant obstacles for years. In 2025–2026, another factor was added to this picture: the tightening of U.S. immigration policy became increasingly intertwined with financial-system risk management. To understand the changes now taking place, however, it is important to distinguish between two separate issues from the outset: opening a bank account and obtaining credit are not the same thing.
Different Requirements for Opening an Account and Obtaining Credit
As of August 2026, there is no general federal rule in the United States that prohibits a noncitizen or a person without an SSN from opening a bank account solely for that reason. The Consumer Financial Protection Bureau (CFPB) explicitly states that a Social Security Number is not always required to obtain an account at a bank or credit union.[1] Banks are required to verify a customer’s identity, but depending on the policies of the particular financial institution, other identifying information and documents may be accepted. CFPB consumer materials, for example, identify an ITIN and foreign government-issued identification documents as possible forms of identification. At the same time, the specific documents accepted depend on the policies of the individual bank or credit union.[1]
Obtaining credit is a different process. When issuing a loan, credit card, or other credit product, a financial institution does more than verify a person’s identity, it evaluates income, credit history, existing obligations, repayment capacity, and other circumstances that affect the borrower’s ability to repay the debt. The policy changes introduced in 2026 have had a particularly clear impact on this second area.
What an ITIN Means and What Rights It Provides
The Individual Taxpayer Identification Number (ITIN) is often misunderstood. It is a tax identification number issued by the IRS to individuals who need a taxpayer identification number for federal tax purposes but are not eligible to obtain an SSN. Its purpose is clearly limited: an ITIN does not change a person’s immigration status and does not grant authorization to work in the United States. The IRS states this explicitly.[2]
At the same time, an ITIN is a practically important tool for interacting with the financial system. CFPB consumer materials identify an ITIN as one of the identification numbers that may be used in the process of opening a bank account. For customers arriving from abroad, some financial institutions may also accept a foreign passport or consular identification, although requirements vary among banks.[1] It is therefore important to distinguish among immigration status, tax identification, and access to banking services. One does not automatically determine another.
In 2026, Immigration and Financial Policy Became More Closely Intertwined
A significant change occurred on May 19, 2026, when President Donald Trump signed Executive Order 14406, Restoring Integrity to America’s Financial System.[3] The order links the security of the financial system to risks that, in the administration’s assessment, may arise when financial services and credit are provided to individuals who are not legally authorized to work in the United States. The Executive Order directed several federal agencies to review relevant rules and practices. Two areas emerged as particularly significant: the detection of financial crime and suspicious transactions, and the assessment of credit risk.
The order also directly addresses ITINs and calls for an assessment of financial institutions’ customer-identification and due-diligence approaches in circumstances where an ITIN or other identification is used to access financial services.[3] An important clarification is necessary, however: Executive Order 14406 does not prohibit the use of ITINs, eliminate the ability to open a bank account using an ITIN, or require the automatic closure of such accounts. Its primary focus is strengthening risk-based oversight.
FinCEN’s Advisory: An ITIN Is Not, by Itself, a “Red Flag”
Following the Executive Order, on June 5, 2026, the Financial Crimes Enforcement Network (FinCEN), together with the FDIC, OCC, and NCUA and in coordination with the IRS, issued the Joint Advisory on Non-Work Authorized Populations and Their Employers and Risks to the Integrity of the U.S. Financial System.[4] The advisory calls on financial institutions to pay closer attention to potential fraud, identity theft, payroll activity associated with unauthorized employment, tax violations, and other suspicious financial activity. The document identifies specific red flags that, when considered alongside other circumstances, may warrant closer scrutiny. These may include inconsistencies between information provided by a customer and the actual use of an account, unusual payroll or business activity, structured cash transactions, and transactions that are atypical for the customer’s profile.[4]
ITINs also appear in this context. An important distinction, however, is that possessing an ITIN or using a foreign passport does not, by itself, mean that a customer is engaged in unlawful financial activity. FinCEN’s risk-based approach requires financial institutions to assess the totality of the circumstances rather than draw an automatic conclusion based on a single identification document.[4]
For this reason, the common assertion that “banks have started monitoring immigrants with ITINs” overlooks the broader regulatory context. A more accurate description is that federal policy in 2026 calls on financial institutions to assess more carefully whether identification information, employment, sources of income, and transaction activity are consistent with one another, particularly when other indicators of risk are also present.
The Most Significant Change Is Emerging in Credit
Compared with bank accounts, the 2026 changes have had a much more direct impact on credit evaluation. On January 12, 2026, the CFPB and the U.S. Department of Justice withdrew their 2023 joint statement concerning noncitizen borrowers.[5] The 2023 statement had cautioned creditors that policies involving citizenship and immigration status could, under certain circumstances, conflict with the anti-discrimination requirements of the Equal Credit Opportunity Act (ECOA) and Regulation B.
The additional guidance was withdrawn in 2026. The CFPB and DOJ emphasized the existing provisions of Regulation B, which permit creditors, within certain limits, to consider an applicant’s immigration status or permanent resident status, as well as information necessary to evaluate the creditor’s rights and remedies regarding repayment.[5] This does not mean that discrimination based on national origin, race, or other characteristics protected under ECOA has become permissible. Those prohibitions remain in effect. What changed was the additional policy interpretation that the CFPB and DOJ had issued in 2023 regarding noncitizen borrowers.
The May Executive Order brought the credit issue further to the forefront. It directed the CFPB to consider how potential deportation and resulting loss of income could affect the ability to repay of a borrower who is not authorized to work in the United States. At the same time, the relevant federal financial regulators were directed to issue guidance on credit-risk management.[3]
Another important development in this process was the CFPB’s June 8, 2026 statement, Statement on Ability To Repay and Immigration Status. One month later, the OCC, FDIC, and NCUA relied on the same approach in their joint guidance when addressing how circumstances related to immigration status may affect the assessment of a borrower’s ability to repay.[6] On July 13, 2026, the OCC, FDIC, and NCUA issued joint guidance on lending to individuals who are not legally authorized to work in the United States.[7] According to the regulators, lending to such borrowers may involve elevated credit risk because their ability to generate income, continuity of employment, and financial stability may be more uncertain. Financial institutions are advised to incorporate these risks into underwriting, assessments of repayment capacity, account management, credit classification, and other risk-management processes.[7]
This is where the distinction between a bank account and credit becomes clearest: having an ITIN or successfully opening a bank account does not, by itself, mean that a customer will qualify on the same terms for a mortgage, auto loan, credit card, personal loan, or business loan.
Access to Financial Services in New York Is Already Uneven
This issue is particularly important for New York because unequal access to the banking system is not a new problem. According to the New York City Comptroller’s report Access to Banking & Credit in New York City, 7.6% of New York City households were unbanked in 2023, compared with 4.1% nationwide.[8]
The disparity is also apparent when viewed by citizenship status: 9.9% of noncitizens in New York City were unbanked, compared with 5.8% of citizens. The Comptroller’s report also notes that undocumented migrants can open accounts at some financial institutions using an ITIN, passport, or similar identification.[8] But formal eligibility does not always translate into meaningful access.
Documentation is a particularly significant barrier for Hispanic households: according to FDIC data cited in the report, 15.6% of unbanked Hispanic households identified the lack of personal identification required to open an account as the main reason they did not have one.[8] Account fees, minimum-balance requirements, language barriers, and distrust of financial institutions in some communities create additional obstacles.
When the Banking System Is Less Accessible, the Consequences Extend Beyond the Individual Consumer
The lack of a bank account may appear to be an individual financial problem, but its consequences are broader. Households outside the banking system often rely more heavily on check-cashing services and other alternative financial services, while the absence of a formal financial history can also make future access to credit more difficult.[8] This is particularly important for immigrant entrepreneurs. After registering a business, opening a business bank account is an important step toward separating personal and business finances and maintaining proper financial records. But an account is only the beginning of business growth. The next stage often requires working capital, a line of credit, equipment financing, or other forms of business credit.
If circumstances related to work authorization and income stability assume greater importance in credit-risk assessments, this second stage, access to financing, could become more difficult for some immigrants.
One System, Two Parallel Directions
Two seemingly contradictory trends have emerged in financial policy over the past two years. On the one hand, regulators have sought to adapt account-opening and customer-identification processes to modern technology. On June 27, 2025, the OCC, FDIC, and NCUA, with FinCEN’s concurrence, issued an exemption order allowing banks, under certain conditions, to obtain a customer’s Taxpayer Identification Number from a reliable third-party source rather than directly from the customer.[9] This does not eliminate Customer Identification Program requirements: banks must still maintain risk-based procedures and must be able to form a reasonable belief that they know the customer’s true identity.[9]
On the other hand, 2026 policy places greater emphasis on how a customer’s identification relates to employment, sources of income, transactions, and credit risk.
These two directions are not necessarily in conflict. One simplifies how identification is obtained, while the other strengthens the assessment of what risks may be associated with a particular financial relationship.
What Is Actually Changing for Immigrants?
As of August 2026, the most accurate summary is this: the door to the U.S. banking system has not automatically closed to immigrants. The CFPB continues to state explicitly that a Social Security Number is not always required to obtain an account at a bank or credit union.[1] The ITIN remains a valid tax identification number, while appropriate documents issued by foreign governments may be used depending on the requirements of the particular financial institution.
What has changed is the risk-assessment environment. Federal policy in 2026 calls for financial institutions to pay closer attention to customer identification, sources of income, employment, transaction patterns, and particularly in the credit context, income stability and repayment capacity.[3][4][7]
The implications of these changes are especially significant for New York. In a city where immigrants constitute an important part of both the labor market and the small-business sector, access to the financial system is not simply a matter of individual convenience. It is connected to business financing, homeownership, savings, credit history, and economic mobility.
Financial Security and Financial Inclusion Should Not Be Mutually Exclusive
Banks have legal obligations related to customer identification and the detection and reporting of money laundering and other unlawful financial activity. At the same time, an effective financial system must avoid automatically equating genuine financial risk with a customer’s immigration or demographic profile alone.
The practical impact of the new 2026 policies will depend on precisely this balance. If the system can accurately identify genuine risks while preserving access to lawful financial activity, security and financial inclusion can reinforce one another.
That will be the central test of the new policy: whether the U.S. financial system can protect its integrity while continuing to provide access to the people who participate in its economic life.
Sources
[1] Consumer Financial Protection Bureau (CFPB) — Bank Accounts and Services, updated June 16, 2026. The CFPB explicitly states that a Social Security Number is not always required to obtain an account at a bank or credit union.
https://www.consumerfinance.gov/consumer-tools/bank-accounts/
[2] Internal Revenue Service (IRS) — Individual Taxpayer Identification Number (ITIN). The IRS explains that an ITIN is used for federal tax purposes, does not change a person’s immigration status, and does not provide authorization to work in the United States.
https://www.irs.gov/individuals/individual-taxpayer-identification-number
[3] The White House — Executive Order 14406, Restoring Integrity to America’s Financial System, May 19, 2026.
[4] Financial Crimes Enforcement Network (FinCEN) — Joint Advisory on Non-Work Authorized Populations and Their Employers and Risks to the Integrity of the U.S. Financial System, FIN-2026-A002, June 5, 2026.
https://www.fincen.gov/resources/advisories/fincen-advisory-fin-2026-a002
[5] Consumer Financial Protection Bureau / U.S. Department of Justice — Withdraw Joint Statement on Fair Lending and Credit Opportunities for Noncitizen Borrowers, January 12, 2026.
[6] Consumer Financial Protection Bureau — Statement on Ability To Repay and Immigration Status, June 8, 2026, as referenced in the subsequent federal interagency lending guidance.
[7] Office of the Comptroller of the Currency (OCC), Federal Deposit Insurance Corporation (FDIC), National Credit Union Administration (NCUA) — Interagency Guidance on Lending to Individuals Not Legally Authorized to Work in the United States, July 13, 2026.
https://www.occ.treas.gov/news-issuances/bulletins/2026/bulletin-2026-31.html
[8] Office of the New York City Comptroller — Access to Banking & Credit in New York City, 2025.
https://comptroller.nyc.gov/reports/access-to-banking-credit-in-new-york-city/
[9] OCC, FDIC, NCUA, with FinCEN concurrence — Customer Identification Program Taxpayer Identification Number Collection Requirement Exemption Order, June 27, 2025.