Executive Order on Financial Regulation Issued

Posted by John Trull on May 20, 2026

President Trump has issued an Executive Order titled “Restoring Integrity to America’s Financial System.” The Order directs several federal financial regulatory agencies to review and consider revisions to existing regulations, guidance, and supervisory expectations related to customer identification, Bank Secrecy Act (BSA) compliance, underwriting, and lending risk management.

This Executive Order does not require a universal or banking industry-wide collection of citizenship information on existing or new accounts as was initially discussed by the Administration and reported by press outlets earlier in the year.

Specific directives in the Executive Order include:

• Treasury issuing an advisory to financial institutions identifying potential red flags and suspicious activity patterns related to payroll tax evasion, concealment of ownership, structuring, labor trafficking, and other unlawful activity
• Treasury and federal financial regulators considering changes to BSA and customer due diligence regulations, including possible revisions to Customer Identification Program (CIP) requirements
• The CFPB considering whether ability-to-repay standards should explicitly account for potential deportation or loss of wages when evaluating repayment ability
• Federal financial regulators issuing guidance related to managing credit risks associated with lending and financial services provided to individuals without work authorization

At this stage, the Executive Order itself does not directly change existing regulations, underwriting rules, or compliance obligations. Most provisions direct agencies to evaluate, propose, or issue future guidance or rulemakings. As a result, there will not be immediate required operational changes for credit unions until agencies provide additional direction.

That said, depending on how agencies implement the Order, future impacts could include changes to CIP and beneficial ownership procedures, additional Bank Secrecy Act/Anti-Money Laundering due diligence, and revised examiner focus areas related to identification and underwriting practices.

While GoWest continues to review the Order and evaluate potential implications for credit unions, including any operational, compliance, examination, or lending impacts, we would appreciate feedback from credit unions on:

• Whether you anticipate reviewing or modifying any policies or procedures as a result of this Order
• Any concerns regarding operational, compliance, or lending impacts
• Any questions you would like GoWest to raise with regulators as implementation moves forward

We will continue monitoring agency responses, guidance, and any proposed rulemakings associated with the Executive Order and will provide additional updates as more information becomes available. We will be working with America’s Credit Unions and the League System to strategize response actions as the agency review process begins.

Posted in Advocacy on the Move, Regulatory Advocacy.