As we have previously reported, the litigation over the attempted shutdown of the Consumer Financial Protection Bureau (CFPB or Bureau) has continued to move quickly through the courts. By way of background, the D.C. district court had granted a preliminary injunction requiring the CFPB to reverse its shutdown efforts, reinstate its workforce, and continue performing its statutory duties, finding that Acting Director Russell Vought’s actions were inconsistent with the Bureau’s statutory obligations under Title X of the Dodd-Frank Act. In our August 2025 post, we covered the D.C. Circuit panel’s decision vacating that preliminary injunction, holding that most of the National Treasury Employees Union’s (NTEU) claims belonged in the Civil Service Reform Act regime and that the remaining claims did not target reviewable final agency action. In our December 2025 post, we reported on the full court’s decision to grant rehearing en banc, vacate the panel’s judgment, and set an expedited briefing schedule. With the panel decision vacated, the en banc court took up the case with the partial stay continuing to govern the parties’ conduct in the interim.