On January 27, the Government Accountability Office (GAO) released a report, Consumer Financial Protection Bureau: Status of Reorganization Efforts (GAO‑26‑108448), that offers a detailed snapshot of the Consumer Financial Protection Bureau’s (CFPB or Bureau) ongoing downsizing and restructuring. This is the first of two GAO reports that focus on the CFPB’s reorganization and its ability to fulfill its statutory functions going forward.

Between February and August 2025, CFPB leadership pursued significant reductions in staff, contracts, supervision, and enforcement activity while Congress moved to cut the Bureau’s funding cap. The report, requested by senior Democratic members of the Senate Banking Committee and House Financial Services Committee, describes these actions and previews a future GAO report on how they affect CFPB’s ability to carry out its statutory mandate.


A Smaller CFPB by Design

The Dodd‑Frank Act of 2010 created the CFPB to consolidate federal consumer financial protection authorities primarily under one federal agency, supervise covered institutions, and monitor markets for risks to consumers. According to the CFPB’s chief legal officer, in response to President Trump’s executive orders directing agencies to become smaller and more efficient, Bureau leadership has been reassessing how to carry out those duties “as a smaller, more efficient operation.”

Beginning in early 2025, the Bureau issued stop‑work orders, closed supervisory examinations, terminated employees and contractors, and shifted its enforcement posture. Many of these steps quickly became the subject of litigation. Courts across multiple circuits considered challenges to terminations and other downsizing actions, and those cases remain an important backdrop for the CFPB’s reorganization.

At the same time, Congress acted directly on CFPB’s finances. On July 4, 2025, President Trump signed the reconciliation bill (commonly known as the One Big Beautiful Bill Act), which reduced CFPB’s statutory funding cap from 12% to 6.5% of the Federal Reserve’s 2009 operating expenses (adjusted for labor costs). That change effectively halves the maximum amount CFPB can draw from the Federal Reserve to fund its operations.

Against this backdrop, GAO was asked to describe how stop‑work orders, workforce reductions, contract terminations, and related actions have affected CFPB’s ability to perform its statutory functions. The January 2026 report is the first installment; GAO expects to analyze the actual impact on CFPB’s performance in a subsequent report.


Highlights from the GAO Report

GAO’s report is descriptive, not evaluative. It focuses on what the CFPB has done and how through a series of charts, facts, data and timelines, rather than whether those choices represent sound policy. To compile the report, GAO relied on court dockets, Federal Register notices, statutes, executive orders, Office of Personnel Management and Office of Management and Budget memoranda, and certain internal CFPB documents. GAO notes that it repeatedly sought meetings, data, and documents from the CFPB regarding workforce changes, contracts, supervision, and enforcement. However, the CFPB declined to meet and did not provide any substantive responses, citing ongoing litigation, despite multiple extensions and opportunities to comment on draft materials provided by the GAO.

One key element is a table describing the CFPB’s planned reductions in force (RIFs) as of April 17, 2025. The figures show substantial planned RIFs across core divisions, including Supervision, Enforcement, Research/Monitoring/Regulations, and Consumer Response/Education, as well as reductions in the Legal Division and other offices. Some divisions would retain only a fraction of then‑onboard staff. GAO cautions that these numbers reflect plans and remain subject to litigation, but they underscore the intended staggering scale of the transformation.

April 17 Planned Reductions in Force (RIF)

Staff Onboard Division / Office (as of PP6 2025)Staff Released (RIF)Staff
Retained		% RIF
Supervision Division4874375090%
Operations Division3232933091%
Enforcement Division2481985080%
Research, Monitoring, and Regulations Division2302082290%
Consumer Response Education Division1491292087%
Legal Division87602769%
Directors Office8681594%
External Affairs4139295%
Office of the Directors Financial Analysts29290100%
Centralized Services550100%
Office of the Ombudsman4*3*175%
Total1689*1482*20788%

Source: National Treasury Employees Union v. Vought. Paoletta Decl. ECF No. 109 1 GAO-26-108448
Note: This table is based on the numbers presented in the chief legal officers declaration, which included a spreadsheet showing planned retention and release of staff by division and office. Some numbers from the declaration do not match those in the spreadsheet. Specifically, the numbers marked with asterisks are one employee more in the spreadsheet than the declaration. For example. the total number of staff onboard is 1690 in the spreadsheet and 1689 in the declaration.

GAO also documents that CFPB has closed or curtailed supervisory examinations, terminated or sought to terminate certain contracts, and moved to dismiss or resolve some enforcement actions and petitions to enforce civil investigative demands, while seeking to vacate or terminate a number of existing consent orders. On the policy side, the Bureau has withdrawn or rescinded multiple guidance documents, interpretive rules, policy statements, advisory opinions, and other guidance, as well as several proposed rules and certain rules of agency organization adopted in the prior administration. In at least one case, the CFPB has told a court that a final rule exceeded the agency’s authority and has requested a stay of litigation while it pursues a new rulemaking.

CFPB’s written response to the draft report, reproduced as an enclosure, sharply criticizes GAO’s work as inaccurate, biased, and incomplete, and asserts that ongoing litigation constrained the Bureau’s ability to provide information. GAO, in turn, states that it acted under its statutory audit authority, that litigation does not negate CFPB’s obligation to provide information, and that its report is grounded in publicly verifiable sources. GAO expressly disclaims any position on the policy merits of CFPB leadership’s views or on the appropriate size of the agency.


Implications and Next Steps

The GAO report confirms that CFPB is undergoing a deliberate and significant downsizing and restructuring effort but does not yet suggest that the Bureau has stepped away from its statutory mandate. Dodd‑Frank’s underlying consumer protection authorities remain unchanged. Instead, the report points to a CFPB with fewer resources, aggressive efforts to reshape its workforce and docket, and heightened legal and political scrutiny of how those efforts are carried out.

In the near term, this likely means that the Bureau will continue to exercise its powers, but with sharper choices about where to deploy staff and litigation resources. A smaller, reorganized CFPB may concentrate on particular products, practices, or institutions that align with current leadership’s priorities, while de-emphasizing other areas.

The statutory funding cut under the One Big Beautiful Bill Act is a durable constraint. Regardless of how litigation over personnel and organizational changes is resolved, a lower ceiling on CFPB’s independent funding stream will shape the Bureau’s capacity over time and may influence decisions about staffing, supervision, and enforcement portfolios. Congress’s willingness to legislate directly on CFPB’s funding also suggests that broader structural changes to the Bureau could be revisited.

GAO has signaled that this report is only the first step. Its next phase will examine the effects of the reorganization on CFPB’s ability to fulfill its statutory functions. That analysis could feed directly into congressional oversight, future legislation, and further debate over the size, scope, and role of the CFPB.