What’s Going on With the CFPB?

If you've been paying attention this past year, you may have noticed that there has been a lot of news regarding the Consumer Financial Protection Bureau (CPFB). Former Director Chopra was left in charge for a surprising amount of time, two acting directors, pausing CFPB work, mass layoffs, court cases, one enforcement action, etc. Finally, just yesterday CFPB Acting Director Russell Vought said that he expects the CFPB to shut down within the next two to three months. So, what's happening and how did we get here?

In this blog we'll be going over the current status of the CFPB. However, before we begin, here is a rough timeline of some key events:

• February 1st: Director Chopra removed
• February 3rd: Treasury Secretary Scott Bessent appointed as Acting Director
• February 7th: OMB Director Russell Vought appointed as Acting Director
• Early February: Acting Director Vought halts most CFPB work​
• February 14th/March 28th: Temporary restraining orders against CFPB​
• April 16th: CFPB announces plan to lay off nearly 1,500 employees​
• April 18th/April 28th: Federal courts block layoff plan​
• July 4th: Reconciliation Bill signed, reducing CFPB budget from 12% to 6.5% of the Federal Reserve's expenses​
• August 15th: Appeals court rules that layoffs may move forward​
• September 5th: CFPB publishes Spring Regulatory Agenda
• September 10th: CFPB warns staff of potential layoffs due to the reduced budget
• October: CFPB announces job openings for two appellate attorneys
• October 15th: Director Vought says that CFPB may shut down in two to three months.

Where does the CFPB stand today?

As of today, the CFPB still exists. It is still able to withdraw funds from the Fed, albeit almost half of what it once had available to it. It is still involved in litigation and it is still involved in the rulemaking process. Its spring agenda was ambitious and contained:

• Nine rulemaking activities at the prerule stage​
• Ten rulemaking activities at the proposed rule stage​
• Five rulemaking activities at the final rule stage​.

So, there is some work being done. At the same time, the CFPB has lost hundreds of staff, many of whom preemptively left on their own. I haven't heard of a single credit union that has had an exam from the CFPB in 2025. Further, only one enforcement action has been filed since former Direct Chopra left. In comparison, between January 20, 2017 to October 15, 2017 during President Trump's first term, the CFPB filed 27 enforcement actions. This is clearly a large departure from the first administration.

Can the CFPB be shut down?

The CFPB was established by Congress in the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank). Without a similar act of Congress, the CFPB cannot be eliminated. That being said, it may not be against the law to effectively eliminate the CFPB by reducing its staff down to the bare minimum required by statute. Since August 15th, the CFPB has had the go ahead to enact sweeping layoffs. That has not occurred yet. It still may occur, especially considering Acting Director Vought's words yesterday.

What happens if the CFPB shuts down?

The first thing that should come to mind for credit unions if the CFPB shuts down, is that the laws and regulations that the CFPB oversees still exist. You cannot just ignore laws and regulations. While the CFPB may not act to enforce a law, the NCUA still has enforcement authority, states often have enforcement authority, and class action attorneys are always ready for a payday. Finally, credit unions should keep lookback periods and statutes of limitations in mind. It is possible that the CFPB may be revived in time if it is shut down. They can look at your past actions, determine that a violation occurred, and bring an action against your credit union.

All this being said, credit unions should continue on doing what they are doing. Nothing official has been said and the CFPB still exists and is still running. Rest assured, America's Credit Unions is monitoring the situation and will notify you of any actions that do occur.