CFPB Funding and Staffing Remain in Place Pending Court Review 

The Consumer Financial Protection Bureau will continue operating through the second quarter of fiscal year 2026 following a Jan. 9, 2026, federal court order in NTEU v. Vought. In response to the ruling, the bureau submitted a request to the Federal Reserve for the funding necessary to carry out its statutory responsibilities. 

The U.S. District Court for the District of Columbia addressed the administration’s decision not to submit a quarterly funding request for the bureau. The court ruled that compliance with an existing injunction requires the CFPB to affirmatively request the funding it is authorized to receive under federal law in order to maintain operations. 

In a written determination, Vought stated that although he disagreed with the court’s interpretation regarding the Federal Reserve’s earnings, he determined that $145 million was required to fund the bureau’s operations for the second quarter of fiscal year 2026, consistent with the court’s order. 

The ruling confirms that the CFPB must continue operating as a congressionally established agency while litigation remains ongoing. As a result, the bureau is required to maintain its staffing levels, contracts, and core functions until further court action. 

Additional developments occurred in December 2025, when the U.S. Court of Appeals for the D.C. Circuit vacated an August 2025 decision that had allowed the implementation of a reduction in force affecting approximately 90% of the bureau’s workforce. That action reinstated a preliminary injunction preventing the proposed layoffs scheduled for early 2026. 

The D.C. Circuit’s decision to rehear NTEU v. Vought en banc places the case before the full court, replaces the earlier panel ruling, and preserves the injunction that blocks the planned staff reductions. Oral arguments are scheduled for February 2026. 

On Dec. 30, 2025, U.S. District Judge Amy Berman Jackson issued a clarification of the injunction requiring that the bureau’s funding remain at existing levels until the appellate court hearing. The court rejected claims that a funding lapse was imminent, stating that the circumstances cited by the defendants did not support that conclusion. 

The administration has asserted that the Federal Reserve’s financial performance limited its ability to fund the bureau. The court noted, however, that the Federal Reserve has provided funding to the CFPB since 2011 without regard to profitability. Public reporting also indicated that the Federal Reserve returned to profitability in early December 2025. 

The case centers on whether the executive branch may limit a congressionally created agency’s operations by restricting staffing and funding. The Office of Legal Counsel has taken the position that the bureau must seek funding through congressional appropriations rather than through its existing funding structure. 

As the litigation continues, the regulatory obligations applicable to the accounts receivable management industry remain unchanged. Federal and state consumer protection laws continue to apply, and the expectations for compliance management systems are not affected by the ongoing court proceedings.