Project 2025 Tracker / What’s done, what’s next

27. Financial Regulatory Agencies · Major

Order the immediate dissolution of the CFPB

Blocked

839 27. Financial Regulatory Agencies

“Provided the Supreme Court affirms the Fifth Circuit holding in Community Financial Services Association of America, the next conservative President should order the immediate dissolution of the agency—pull down its prior rules, regulations and guidance, return its staff to their prior agencies and its building to the General Services Administration.”

What has happened

  1. Blocked

    The en banc court denied the government's motion to modify the stay, held the appeal in abeyance while retaining jurisdiction, and remanded for the district court to decide in the first instance whether to modify, suspend or dissolve the injunction in light of a revised reduction-in-force plan. The injunction remains in force in the meantime. The Bureau is still standing and still issuing rules: it published a regulatory agenda on 2026-08-14 and a joint rescission notice on 2026-08-25.

  2. Blocked

    The D.C. Circuit granted rehearing en banc, vacated the panel's 2025-08-15 judgment, and put the preliminary injunction back in force — as partially stayed on 2025-04-11 and modified on 2025-04-28 — pending argument on 2026-02-24.

  3. Attempted

    A second lever: the Office of Legal Counsel opined, at the acting director's request, that the CFPB may not draw funds from the Federal Reserve while the Federal Reserve is operating at a loss, because "combined earnings" in 12 U.S.C. 5497(a)(1) means profits. The Bureau expected to exhaust its funds that quarter; OLC's answer was that the director must report to Congress and seek an appropriation rather than draw. Defunding by legal opinion is the dissolution ask pursued by other means.

  4. Attempted

    A D.C. Circuit panel vacated the preliminary injunction and remanded, holding the challenged conduct was not reviewable final agency action because it had not been formally recorded. The block was lifted and the dismantling could resume; Judge Pillard, dissenting, wrote that "the evidence that is before us is damning" and that many of the undisputed actions "cannot reasonably be understood as advancing any purpose other than the willful destruction of a congressionally created agency."

  5. Blocked

    Judge Amy Berman Jackson granted a preliminary injunction "that maintains the agency's existence until this case has been resolved on the merits, reinstating and preserving the agency's contracts, work force, data, and operational capacity." The court wrote that without it "the CFPB will be dissolved and dismantled completely in approximately thirty days." The D.C. Circuit administratively stayed the order on 2025-04-03, stayed it in part on 2025-04-11, then restored paragraph three on 2025-04-28 after the government proposed a reduction in force covering nearly 90 percent of the staff.

  6. Attempted

    The dissolution was ordered. After the President removed the CFPB's director on 2025-01-31 and named Russell Vought acting director on 2025-02-07, Vought told every employee on 2025-02-10 to "not perform any work tasks" without the chief legal officer's approval; the headquarters at 1700 G Street was closed and its lease canceled; contracts were canceled across five components and all but two in a sixth; 85 probationary and 130 term employees were terminated, including the Student Loan Ombudsman; and two reductions in force were planned that would have ended at least 80 percent of the remaining workforce. The district court, after a two-day evidentiary hearing, found "a concerted, expedited effort to shut the agency down" and that the defendants had "no intention of operating the CFPB at all." The findings are the Primary record of the February actions, which were never published in the Federal Register.

Research log

What was searched, and what didn’t count as evidence

Research notes

  • The Mandate makes this ask conditional — “Provided the Supreme Court affirms the Fifth Circuit holding in Community Financial Services Association of America.” The Court did the opposite: it reversed the Fifth Circuit and upheld the CFPB’s funding mechanism 7-2 in CFPB v. CFSA, 601 U.S. 416 (2024), before the tracking window opened. The dissolution was ordered anyway, so the Recommendation is tracked on what was done, not on whether the condition was met.
  • The February 2025 actions were never published in the Federal Register — which is precisely what the D.C. Circuit panel relied on when it vacated the injunction. The only Primary record of them is the litigation, so the court documents carry their own dates while the event is dated to the stop-work order of 2025-02-10.
  • The district court docket, NTEU v. Vought, No. 1:25-cv-00381 (D.D.C.), is at https://www.courtlistener.com/docket/69624423/national-treasury-employees-union-v-vought/ and is a lead only: CourtListener docket pages refuse unauthenticated reads. The appellate dockets are D.C. Cir. Nos. 25-5091 (consolidated with 25-5132) and, for a later appeal, 26-5220 (filed 2026-06-10).
  • Related cases found in the CourtListener bulk snapshot but not read: Rise Economy v. Vought (D.D.C. 1:25-cv-02374, terminated 2026-05-15; N.D. Cal. 5:25-cv-10481; 9th Cir. 26-3134), State of Illinois v. Vought (N.D. Ill. 1:26-cv-01566, filed 2026-02-11), State of New York v. Vought (2025-12-22), Fontanez v. Vought (D.D.C., 2025-12-27 and 2026-02-18) and Steele v. Vought (D.C. Cir. 26-5060). The clustering of state and employee suits from December 2025 tracks the funding cut-off that followed the OLC opinion; none of their documents were opened, so none is Evidence.
  • The rules the Mandate asks be pulled down are being pulled down separately: the Bureau rescinded or withdrew a long series of rules, interpretive rules and circulars through 2025 and 2026. Those are logged under the narrower rule-rescission Recommendations, not here; this item is about dissolving the agency.
Action
eliminate
Object
the CFPB’s rules, staff, and headquarters building
ID
2178