Recent reporting from the ABA Banking Journal and the American Banker describes a rapidly evolving restructuring of the Consumer Financial Protection Bureau (CFPB or Bureau) under the Trump administration, with significant implications for the agency’s future role and for regulated entities.

Lease on Headquarters in D.C. Terminated

According to documents obtained by Reuters through a Freedom of Information Act request, the Office of the Comptroller of the Currency (OCC) terminated the CFPB’s lease for its Washington, D.C., headquarters in February 2026, approximately six years early, and transferred the property to the General Services Administration at no cost. This move aligns with public statements by President Trump and Office of Management and Budget Director/Acting CFPB Director Russell Vought, both of whom have expressed a desire to substantially shrink or even close the Bureau, which was created by Congress in 2010 under the Dodd-Frank Act after the 2008 financial crisis.

The lease termination does not itself dissolve the CFPB, but it is a concrete step that reduces the Bureau’s physical footprint and underscores the administration’s broader effort to limit the Bureau’s size and visibility.

Proposed Deep Workforce Cuts Remain Under Court Review

The American Banker reports that the administration is simultaneously pursuing aggressive workforce reductions. In filings with the U.S. Court of Appeals for the D.C. Circuit, government lawyers have proposed a reduction in force (RIF) that would cut the CFPB’s staff by more than half — from roughly 1,100 employees to about 550. When President Trump’s second term began, the Bureau reportedly had more than 1,750 employees.

The National Treasury Employees Union has challenged the RIF plan, and a court‑ordered stay currently prevents the CFPB from implementing large‑scale terminations. The administration has withdrawn an earlier proposal that could have eliminated up to 90% of staff and is now seeking approval of a narrower cut.

CFPB Hiring Litigation Attorneys While Cutting Enforcement Activities

At the same time it is planning to shrink overall staffing, the CFPB is selectively hiring. As reported in the American Banker, the Bureau recently posted a job announcement for an attorney‑advisor in its Office of Litigation. The position is focused on defending the CFPB in “a wide range of legal disputes, including defensive litigation relating to the CFPB’s rulemaking activities.”

American Banker reports that enforcement attorneys have been offered the opportunity to transfer into the litigation unit, even as the enforcement division faces some of the largest proposed cuts under the RIF. The litigation positions are non‑union posts and come with heightened background‑check and ongoing vetting requirements.

According to experts cited by the American Banker, the Bureau appears to be repositioning itself for increased Administrative Procedure Act challenges to its rulemakings, particularly as it rewrites or scales back rules issued under the Biden administration, including those involving open banking, small‑business lending data collection, medical debt, nonbank registries, and overdraft fees.

Our Take

Taken together, the developments suggest a strategic pivot. The physical downsizing of the headquarters, the sharp proposed reduction in staff, and the targeted hiring of litigators all point toward a CFPB with a narrower footprint, less emphasis on front‑line enforcement, and greater focus on defending its rules and restructuring decisions in court. We will continue to watch Bureau developments closely and report on them in due course.