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ARTICLE · 29 DECEMBER 2025

D.C. Circuit To Reconsider Injunction Barring CFPB Reductions In Force

Holland & Knight
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The U.S. Court of Appeals for the District of Columbia Circuit granted a petition for rehearing en banc filed by the National Treasury Employees Union (NTEU) and agreed to reconsider a three-judge panel's decision...

United StatesLitigation, Mediation & Arbitration
Eamonn Moran
Eamonn Moran
Ashley Feighery
Ashley Feighery
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The U.S. Court of Appeals for the District of Columbia Circuit granted a petition for rehearing en banc filed by the National Treasury Employees Union (NTEU) and agreed to reconsider a three-judge panel's decision lifting an injunction that sought to block the Trump Administration from pursuing extensive reductions in force (RIFs) at the CFPB. The per curiam order, entered on Dec. 17, 2025, is the latest development in what has been a tumultuous review of the CFPB's ability to effectively dismantle the agency via RIFs and decisions to decline additional funding. This announcement presumably also sets the stage for a review of the Trump Administration's current stance that the CFPB is unable to request additional funds from the Federal Reserve while there are no "combined earnings of the Federal Reserve System."

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