A nonpartisan congressional watchdog has documented one of the most sweeping administrative transformations in the Consumer Financial Protection Bureau's 15-year history. A Government Accountability Office audit covering events from February through August 2025 found that the CFPB issued stop-work orders, planned to reduce its workforce by approximately 88 percent, dismissed at least 17 active enforcement cases, rescinded 70 guidance documents and proposed rules, and closed its Washington headquarters — all while declining to provide documents and data the GAO requested under its statutory audit authority.
What the GAO Found
The audit report, designated GAO-26-108448 and published on February 10, 2026, was commissioned by four members of Congress: Sen. Elizabeth Warren, Sen. Andy Kim, Rep. Bill Foster, and Reps. Maxine Waters and Al Green. The GAO is the legislative branch's independent investigative arm, and its reports represent the official public accountability record of federal agency actions.
The audit examined the period from February 2025 through August 2025, during which the CFPB underwent rapid structural changes. The GAO relied primarily on publicly available information — court dockets, Federal Register notices, press releases, executive orders, and Office of Personnel Management memoranda — because the CFPB declined to cooperate with the audit directly. The GAO also noted the limitations this non-cooperation imposed on its ability to independently verify specific figures, including the final employee headcount. For more on the regulatory rollback landscape, see GTP's Regulatory Watch coverage.
The Workforce Numbers
The CFPB employed approximately 1,700 people at the start of the review period. According to GAO-26-108448, bureau leadership planned to reduce the workforce by approximately 88 percent — retaining as few as 207 employees, a figure the CFPB itself cited in court filings as the minimum necessary to perform "duties required by law."
The planned reductions were unevenly distributed across divisions. The supervision division — responsible for monitoring financial institutions' ongoing compliance with consumer protection statutes — faced reductions of approximately 90 percent of staff. The enforcement division faced cuts of approximately 80 percent.
Many terminations were issued during the review period, but became "caught up in litigation," as the GAO described it. Because the CFPB declined to provide the GAO with final headcount data, the exact number of employees actually terminated or retained as of the audit's cutoff could not be independently verified. The bureau's physical footprint also contracted: the GAO documented that the CFPB closed its Washington, D.C. headquarters and terminated all regional office leases during the review period.
Enforcement Actions: What Was Dropped
As of January 30, 2025, the CFPB had 34 active enforcement cases — legal actions against financial institutions and individuals for alleged violations of consumer protection law. According to GAO-26-108448, during the review period the bureau dismissed 16 of those cases with prejudice and one without prejudice, closing 17 of the 34 active matters.
The CFPB also "moved to vacate or terminate a number of existing consent orders," the GAO found. Consent orders are legally binding agreements between the bureau and regulated entities following prior enforcement actions; vacating them ends obligations that had previously been imposed. The bureau additionally closed or curtailed supervisory examinations — the routine compliance monitoring process by which the CFPB oversees financial institutions. The specific number of examinations halted was not disclosed to the GAO.
"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."
— U.S. Government Accountability Office, GAO-26-108448, February 2026
70 Rules and Guidance Documents Rescinded
In addition to enforcement and workforce changes, the GAO documented that the CFPB rescinded or withdrew 70 guidance documents and proposed rules during the February–August 2025 review period. Guidance documents are non-binding interpretive materials that define how the bureau understands regulated entities' compliance obligations under existing statutes. Their withdrawal does not change the underlying law but signals a significant reduction in the bureau's stated enforcement priorities and interpretive positions. For context on CFPB rulemaking activity, see the CFPB's Federal Register page, which reflects official rulemaking history.
How the CFPB Is Funded — And Why That Matters
Unlike most federal agencies, the CFPB is not funded through annual congressional appropriations. Under Section 1017 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010, the bureau draws funding directly from Federal Reserve System earnings, up to a statutory cap adjusted for employment cost growth. For fiscal year 2024, that cap was $785 million, according to the Congressional Research Service report R48295. The Federal Reserve's 2024 Annual Report confirms the CFPB's operational funding flows through the Federal Reserve System, with the CFPB's Inspector General share totaling $18.6 million for that year.
This funding structure means Congress cannot defund the CFPB through the annual appropriations process, though it retains the ability to amend the Dodd-Frank formula. The bureau's 2025 restructuring was executed through internal administrative actions — not through budget cuts imposed by Congress — making the GAO's documentation of those actions the primary official public accountability record available to the public and policymakers. This is relevant context for understanding the Federal Reserve's role in the broader regulatory environment.
The Audit Dispute
The CFPB's response to the GAO's findings was pointed. The bureau characterized the report as "inaccurate, biased, and incomplete," according to language the GAO reproduced in the report's official comments section. CFPB leadership also described the audit as having been "initiated at the behest of hyper-partisan Democrat Members."
The GAO did not yield. It invoked 31 U.S.C. § 716(a)(1), its statutory authority to obtain information required for audits, and stated that the existence of litigation "does not limit our authority to obtain information required for our audits." The agency's formal response: "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."
Both positions are reproduced in the published report. The GAO's mandate comes directly from Congress; its audit authority is independent of executive branch consent.
All primary data in this article is drawn from GAO-26-108448, "Consumer Financial Protection Bureau: Status of Reorganization Efforts," published February 10, 2026. The GAO is the nonpartisan, independent legislative branch agency that serves as Congress's official auditor. The report covers CFPB actions from February through August 2025, based on publicly available information including court dockets, Federal Register notices, and OPM/OMB memoranda. CFPB funding cap data is from Congressional Research Service report R48295, cited via Congress.gov. Federal Reserve operational budget data is from the Federal Reserve 2024 Annual Report, System Budgets section. The GAO noted it could not independently verify certain figures because the CFPB declined to provide requested documentation.
Ongoing Litigation
The employee terminations and certain CFPB administrative actions during the review period became the subject of federal litigation in multiple circuits. The Ninth Circuit denied a government motion to stay a district court order that had enjoined the CFPB from carrying out certain workforce actions. As of the report's publication in February 2026, the GAO noted that litigation was ongoing and the legal status of the employee terminations remained unresolved.
The GAO's report acknowledges the litigation context but maintains its audit findings are based on documented, publicly available facts. The legal proceedings represent a separate track from the administrative record documented in GAO-26-108448.