President Trump on Monday issued an Executive Order that prohibits most federal agencies from issuing proposed rules until an administration-appointed agency head reviews the regulation.

The President also imposed a hiring freeze at most federal agencies through another Executive Order.

The Executive Orders do not expressly exclude independent agencies, such as the CFPB. However, any Trump-appointed independent agency head would be likely to follow them.

The order governing rules requires agencies to withdraw any rules that have been sent to the Federal Register but have not been published in order to allow Trump-appointed agency heads to review them.

It is unclear when a Trump-appointed CFPB acting director will be in place. Trump almost certainly will fire CFPB Director Rohit Chopra since he has not tendered his resignation and administration officials dislike the aggressive regulatory regime adopted by the bureau since he has been the director. However, Trump did not take that action in his first day in office.

The Executive Order governing rules states that federal agencies should consider postponing, for a period of 60 days from January 20, i.e., until March 21, the effective date for any rules that have been published in the Federal Register or any rules that have been issued in any manner to allow administration officials to review any questions of fact, law and policy that might arise.

Federal officials imposing that 60-day delay should consider opening a comment period to allow interested parties to comment on issues of fact, law and policy, the order states. If more than 60 days are needed to review those comments, federal agencies may extend that period.

If the CFPB decides to follow the Executive Order, once an acting Director is in place, several agency rules could be affected.

For instance, the bureau last month issued a final rule prohibiting the listing of medical debt on credit reports, effective March 17.  The Executive Order would provide a few more days in which to review that rule.

Technically, the final rule that would limit the overdraft fees that large financial institutions may charge consumers appears to be outside of the scope of the Executive Order, even though it was published in the Federal Register on December 30, because it won’t take effect until October 1, 2025. However, in the spirit of the Executive Order, the CFPB may decide to review it in the same 60-day period as well, or simply to review it without regard to that 60-day period, and it and actions like it may be the subject of a future Executive Order directing review, to eliminate any uncertainty.

Similarly, the CFPB issued a final rule that extends certain Truth in Lending Act (TILA) requirements to Property Assessed Clean Energy (PACE) transactions. The effective date of that rule is March 26, 2026. The Economic Growth, Regulatory Relief, and Consumer Protection Act (Act), enacted in 2018, directs the CFPB to prescribe regulations that apply TILA ability-to-repay requirements to PACE transactions, and apply the TILA civil liability provisions to violations of the requirements. The CFPB final rule more broadly applies TILA requirements, with certain revisions and exemptions, to PACE transactions, so it may also be a candidate for review.

The CFPB also has proposed a rule banning companies from using contract clauses that the bureau said limit fundamental freedom, including those that waive a consumer’s legal rights and fine print that suppresses speech. Comments on that rule are due April 1, 2025.

On hiring, President Trump issued an Executive Order stating that no federal civilian position that was vacant at noon on January 20 may be filled and no new positions may be created. Administration officials also must, within 90 days, develop a plan to reduce the size of the federal government. Then, the hiring freeze would be lifted.