The U.S. Court of Appeals for the D.C. Circuit has agreed to rehear a case brought by the National Treasury Employees Union (NTEU) challenging a plan by Consumer Financial Protection Bureau (CFPB) Acting Director Russell Vought to carry out large-scale layoffs at the agency.
As part of its decision, the court issued a stay on the proposed layoffs while it reviews the case. The action vacates an earlier ruling that would have allowed the CFPB to eliminate up to 90% of its workforce, according to reporting from Bloomberg Law.
In the now-vacated decision, Judges Gregory Katsas and Neomi Rao had concluded that the lower court lacked jurisdiction to hear claims related to employee job losses. The judges also found that the plaintiffs failed to challenge a final agency action under the Administrative Procedure Act. The NTEU and its co-plaintiffs sought review by the full D.C. Circuit panel in September 2025.
Oral arguments before the full appeals panel are scheduled for Feb. 24, 2026.
Leadership Developments at the CFPB
Separately, the Trump administration has nominated a senior budget official to serve as the CFPB’s permanent director, a move that would allow Vought to remain as acting director until at least mid-June 2026.
In November 2025, Stuart Levenbach, a senior official at the White House Office of Management and Budget, was nominated to lead the bureau. The nomination is expected to give CFPB leadership additional time to advance its policy priorities while the confirmation process moves forward.
Levenbach’s nomination has been referred to the Senate Committee on Banking, Housing, and Urban Affairs, where it will typically undergo a hearing and committee review before proceeding to a full Senate vote.
Regulatory Authority and Funding Questions
While leadership changes remain pending, existing CFPB regulations continue to remain in effect. State attorneys general retain enforcement authority over many consumer financial protection laws, and several federal statutes allow for private rights of action, meaning compliance obligations remain unchanged regardless of shifts in federal enforcement posture.
In November 2025, the U.S. Assistant Attorney General issued a legal opinion concluding that the CFPB’s funding structure—specifically its authority to draw funds from the Federal Reserve—is unlawful. The opinion was submitted to the U.S. District Court for the District of Columbia in the ongoing case involving the NTEU and the CFPB’s acting director.
According to the court filing, the administration anticipates that the CFPB will continue operating, at a minimum, through Dec. 31, 2025, while funding and legal challenges are addressed.
Author: Jennifer Evancic
Jennifer.Evancic@ResourceManagement.com
Jennifer Evancic is a third-party auditor valued by creditors and large organizations for her knowledge in call monitoring within the collections industry. With meticulous attention to detail and a firm grasp of regulatory requirements, she ensures compliance with clients’ criteria and state and federal regulations.
Jennifer audits collections calls, ensuring they meet client-specific criteria and comply with regulations, providing valuable insights and maintaining industry standards.
Beyond her auditing responsibilities, Jennifer takes the lead in organizing and facilitating monthly call calibrations. These sessions serve as a collaborative forum where clients and their vendors come together to discuss call monitoring results and address any findings or areas for improvement. Jennifer’s guidance fosters open communication and ensures alignment between clients and vendors, driving continuous improvement in collections practices.
Jennifer stays up-to-date with compliance and industry best practices by participating regularly in peer meetings, regulatory updates and industry webinars. This keeps her informed about emerging issues and ensures she remains a knowledgeable leader in collections compliance.
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