Congressional Watchdog Examines CFPB Reorganization Efforts
The GAO has reported on the CFPB’s 2025 restructuring efforts, detailing workforce cuts, halted enforcement actions, funding reductions, and ongoing litigation that could shape the agency’s ability to fulfill its statutory mission
The U.S. Government Accountability Office (GAO) has released a detailed status report on the ongoing reorganization of the Consumer Financial Protection Bureau (CFPB), highlighting significant operational shifts, legal challenges, and uncertainties about the agency’s ability to carry out its statutory mission. The report, GAO‑26‑108448, was published at the request of congressional oversight committees.
The CFPB, created under the Dodd‑Frank Wall Street Reform and Consumer Protection Act, is charged with enforcing federal consumer financial laws, handling consumer complaints, promoting financial literacy, and monitoring financial markets for risks to consumers. However, since February 2025, CFPB leadership has undertaken a sweeping reorganization in response to executive directives aimed at reducing the bureau’s size and scope. These efforts have included issuing stop‑work orders, curtailing supervisory examinations, terminating enforcement cases, ending contracts, and reducing staff levels.
The GAO report details the status of these efforts through August 2025, presenting a chronology of actions and their context — including ongoing litigation and fluctuating court rulings that have directly affected CFPB’s ability to implement personnel and operational changes. Several workforce reductions and contract terminations are still subject to legal challenge, underscoring a broader conflict between agency leadership’s restructuring objectives and statutory obligations.
“We stand by the accuracy of the facts presented in our report, which are based on publicly available information including court dockets and Federal Register notices,” said Alicia Puente Cackley, director, financial markets and community investment for the GAO. “As consistently explained in our communications to CFPB leadership throughout this audit, we conducted this work within the scope of our authority in an independent and nonpartisan manner, and we take no position on the policies underlying CFPB leadership’s views about the agency’s past actions or the size of the agency. Our focus was on presenting the dates and events that took place at CFPB between February and August 2025.”
GAO’s review draws on a broad range of sources — including public filings, Federal Register notices, press releases, executive orders, and nonpublic CFPB documents — to assemble a factual timeline of events.
One pivotal legal development included an August 15, 2025 decision by the U.S. Court of Appeals for the D.C. Circuit, which vacated a lower court injunction that had barred CFPB from executing certain staffing actions and contract terminations. The appellate court, however, delayed the order’s effective date to give involved parties time to seek rehearing. Subsequent appellate decisions in late 2025 further complicated the litigation landscape, including a rehearing en banc that affected the procedural posture of personnel action disputes.
The report notes that CFPB declined to provide requested information or participate in briefings, citing ongoing litigation. GAO states it nonetheless stands behind the accuracy of the facts presented, which will form the basis for a forthcoming analysis of how these changes are affecting CFPB’s statutory responsibilities.
Notably, the report comes amid wider political and fiscal scrutiny of federal agencies’ budgets and missions. CFPB’s budget authority was amended in 2025 under congressional action that capped its funding at 6.5% of the Federal Reserve’s total operating expenses — a significant reduction from its previous allocation formula. Critics of CFPB have welcomed such constraints, while proponents of robust consumer financial oversight warn that diminished capacity could weaken protections for consumers and undermine markets.
GAO’s analysis does not evaluate the merits of CFPB’s policy choices but focuses strictly on documenting what actions have occurred, when, and under what legal or administrative circumstances. A future GAO report is expected to assess the effects of the reorganization on the bureau’s performance and mission execution.