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Inclusiv & NLCUP Joint Statement on Executive Order: Restoring Integrity to America’s Financial System

On May 19, President Trump issued Executive Order: Restoring Integrity to America’s Financial System, which directs the Secretary of the Treasury, in consultation with federal prudential banking regulators, including the National Credit Union Administration, to consider changes to the Bank Secrecy Act’s implementing regulations. The proposed regulatory changes would exclude immigrants from the mainstream financial system, restricting access to credit for people with Individual Taxpayer Identification Numbers (ITINs) as well as imposing limitations on the use of consular identification cards.

Inclusiv and NLCUP are deeply opposed to the financial exclusion this Executive Order is likely to drive. If implemented as proposed, it would cause a surge in the number of unbanked people including immigrants with work authorization who may feel unwelcome at mainstream financial institutions as a result. And we will likely see increasing property crime as people carrying their paychecks in cash become attractive robbery targets. All this to exclude from our financial system people who want nothing more than to achieve the American Dream and build a better life for themselves and their families. As our movement faces the challenges this Executive Order creates together, Inclusiv and NLCUP remain focused on working with community development credit unions to strengthen their local economies and effectively and responsibly serve their members.

When people can save securely and fully participate in the economy regardless of immigration status, society is stronger and more stable as a result. The economy functions best when finances flow through regulated financial institutions like banks and credit unions because they are subject to well-established safeguards and regulatory oversight. In contrast, pushing more people and money flows outside of regulated financial systems creates gaps in visibility and greater risk of fraud and abuse, as well as increasing property crime.

In addition to driving exclusion from the banking system and reducing the ability of federal regulators to safeguard our financial system, the Executive Order, if the recommended regulations are enacted, could create a nearly insurmountable operations and compliance burden for financial institutions in tracking the immigration and work authorization status of their members. This burden will be felt most acutely by small credit unions and will likely lead to closures and fewer affordable financial services in the communities that need credit unions the most.

This Executive Order is not binding law, but the proposal and directives are certainly concerning. We’ll be monitoring subsequent developments and providing updates to members and partners as more information becomes available.