2026 Enforcement Trends – CFPB and FTC Targeting Predatory Lenders

According to legal analysis from Winnow Law, federal enforcement in the lending industry is accelerating in Q2 2026 .

What Are the Top Enforcement Priorities? 

• UDAAP (Unfair, Deceptive, or Abusive Acts or Practices) – Lenders using deceptive marketing or hidden fees are being targeted
• Fair lending and redlining investigations – Discrimination in lending is under scrutiny
• Servicing compliance failures – Problems with how loans are managed after origination
• "Junk fee" enforcement – Hidden fees that surprise borrowers
• AI-driven credit decision transparency – Lenders using algorithms must be able to explain how they make decisions

Why Is This Happening?

Regulators are shifting from issuing guidance to pursuing enforcement. Supervisory examinations are becoming more data-driven, and agencies are increasing scrutiny of internal controls, third-party risk management, consumer disclosures, and algorithmic underwriting systems .

Which Agencies Are Involved?

• Consumer Financial Protection Bureau (CFPB) – Leading on UDAAP, fair lending, servicing compliance, junk fees, and AI transparency 
• Federal Trade Commission (FTC) – Focusing on data security, consumer privacy, marketing compliance, fraud prevention, and cybersecurity failures 
• Securities and Exchange Commission (SEC) – For publicly traded lenders, focusing on cybersecurity governance disclosures, risk management transparency, and internal control failures 

What This Means for Borrowers:

If you have been harmed by a lender's deceptive practices, regulators are actively looking for cases like yours. The enforcement environment is more favorable to borrowers now than it has been in years.

What You Can Learn:

Document everything. If a lender uses deceptive practices, your complaint could be part of a larger enforcement action.

Step-by-Step Action:

Step 1: If you believe a lender has engaged in unfair or deceptive practices, file a complaint with the CFPB at consumerfinance.gov/complaint.

Step 2: Keep detailed records. Enforcement actions rely on evidence. Screenshots, emails, call logs, and loan documents are all valuable.

Step 3: Be aware that regulators are particularly interested in AI-driven lending decisions. If an algorithm denied you credit or charged you higher rates, ask for an explanation. Under enforcement trends, lenders must be able to provide one .