The CFPB Is Dead, Long Live The CFPB

In the two weeks since our last update on what is happening with the Consumer Financial Protection Bureau ("CFPB"), the Trump administration has continued to take actions that make it seem as though they are intending to wind down the agency.

In statements filed in the case brought against the administration by the National Treasury Employees Union ("NTEU") to attempt to stop the shutdown of the agency, one CFPB employee reported that they heard one Senior Executive of the DOGE team working on evaluating the CFPB say that it will become a "room at Treasury, White House, or Federal Reserve with five men and a phone in it." Accordingly, the CFPB's headquarters building is in the process of having its lease ended and the name of the agency has been removed. Importantly, the vast majority of CFPB employees have not been working during their administrative leave, because the Chief Legal Officer of the CFPB must approve any and all work being done and has approved