CFPBGuidancemedium

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On Jun 22, 2026, the CFPB adopted new enforcement principles designed to replace standards used under the Biden Administration. The principles have four components: addressing actual consumer harm, due process, collaboration, and efficiency. The bureau will focus enforcement on real harm rather than theoretical or speculative injury and will root actions in clear statutory authority rather than novel interpretations.

Institutions that self-report violations and cooperate will not be punished for their candor. The CFPB applied the new approach in its handling of Bilt's credit card services transition to a new bank partner, engaging directly with the company rather than launching a protracted investigation. Bilt subsequently reached out to affected customers and offered to reimburse overdraft, late, and insufficient funds fees related to the transition.

The bureau also committed to avoiding duplicative enforcement where state or other federal regulators are better positioned to act.

Implications
  1. Establishes new CFPB posture that may reduce formal enforcement actions against cooperating BaaS participants
  2. Bank-fintech partnerships may benefit from self-reporting frameworks to avoid public consent orders
  3. Shift in enforcement philosophy could lead to less public transparency about fintech compliance failures
  4. Other regulators (OCC, FDIC, Fed) may or may not align with CFPB's collaborative approach
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