On March 31, the CFPB moved the U.S. Court of Appeals for the D.C. Circuit to modify its stay pending appeal to allow the Bureau to immediately implement a new reduction-in-force (RIF) plan that would more than halve its staff from 1,174 employees to 556. As previously covered by InfoBytes, the D.C. Circuit granted en banc review and held oral argument on February 24 in a case brought by the union representing CFPB employees and other organizations to challenge the Bureau’s earlier plans to significantly reduce agency staff levels. In its motion, the CFPB requested, in the alternative to the modification of the existing stay pending appeal, a limited 45-day remand to the district court to reconsider the preliminary injunction (covered by InfoBytes here) in light of the new plan, the enactment of the One Big Beautiful Bill Act, and the Supreme Court’s decision in Trump v. CASA, Inc. The CFPB further asked the court to hold the appeal in abeyance while the district court reconsiders the injunction.

The revised RIF plan proposes cuts across every division, including reducing the Enforcement Division from 137 employees to 50 and the Supervision Division from 350 to 77. The Bureau stated that the plan supersedes any prior plans and demonstrates that the Bureau’s leadership does not intend to shut down the agency — the central factual premise underlying the district court’s March 28, 2025, injunction. The CFPB argued that a workforce reduction is now legally unavoidable, citing the One Big Beautiful Bill Act, signed July 4, 2025, which cut the Bureau’s annual funding cap by nearly half, limiting fiscal year 2026 transfers to $466.8 million — well below the $677.5 million the CFPB said it needed to comply with the injunction. The Bureau warned that at current staffing levels, its cash reserves would run out by the fourth quarter of calendar year 2026.