Looking Ahead to 2026
We expect financial institutions will continue to navigate a fractured regulatory landscape. As the Consumer Financial Protection Bureau (CFPB) continues retreating from regulation, institutions must track divergent state disclosure and fee-regulation regimes while facing closer scrutiny from the Office of the Comptroller of the Currency (OCC) and Federal Reserve. We also expect continued litigation and policy debate over financial institutions’ fraud risk models and fee disclosures.
Key Trends From 2025
Goodwin tracked 12 enforcement actions in the cards, payments, and consumer banking space in 2025, three shy of the 2024 total. Regulators collected more than $372 million in civil money penalties through actions brought by the CFPB, the Federal Trade Commission (FTC), the Federal Deposit Insurance Corporation (FDIC), the U.S. Department of Justice (DOJ), and various state attorneys general and regulators.
