The Consumer Financial Protection Bureau is facing an unprecedented financial crisis—and the consequences could reshape the future of consumer financial protection. On December 10, 2025, Acting CFPB Director Russ Vought informed the U.S. District Court for the District of Columbia that the Bureau will run out of money by year-end unless Congress provides a direct appropriation. (Because of dwindling funds, it has recently been reported that the CFPB will be transferring to DOJ the representation of the CFPB in all lawsuits in which it is a party.)

This development comes amid ongoing litigation over an injunction issued by Judge Amy Berman Jackson, which currently restricts the CFPB from reducing its workforce or taking other steps toward winding down operations. Although a D.C. Circuit panel vacated that injunction, its mandate remains stayed pending a petition for rehearing en banc—leaving the injunction in place for now.

Complicating matters further, the Department of Justice’s Office of Legal Counsel has recently concluded that the CFPB cannot legally draw additional funds from the Federal Reserve while the Fed is operating at a loss, and that doing so would violate the Anti-Deficiency Act. The CFPB now intends to seek funding directly from Congress, though approval is far from assured.

With major rulemakings—including those under Sections 1033 and 1071, as well as a new ECOA proposal—hanging in the balance, the stakes for industry, regulators, and consumers could not be higher.

Join us on December 15, 2025, at 12:00 PM ET for a 90-minute webinar analyzing the legal, operational, and policy implications of the CFPB’s funding crisis.

Our expert panel will discuss:

• The validity of the CFPB’s and OLC’s interpretations of the Dodd-Frank funding provisions
• Whether the Bureau waived its funding-deficiency arguments through delay or inconsistent conduct
• The status of CFPB actions taken while the Fed was operating at a loss
• The impact on current and future rulemakings if funding lapses
• Operational consequences for financial institutions and other regulators
• Potential judicial or legislative solutions—including whether this crisis could push Congress to bring the CFPB under the normal appropriations process

This program is essential for financial institutions, in-house counsel, compliance officers, and policymakers seeking clarity in a rapidly evolving situation with far-reaching implications. Click the link below to register.

CLE Credit

Approved for 1.5 CLE credits in CA, NV, NY & PA; 1.8 NJ. Uniform Certificates of Attendance will be provided.

Moderator: Alan S. Kaplinsky

Panelists: Alex J. Pollock, Hal S. Scott, Richard J. Andreano Jr., John L. Culhane Jr., and Joseph J. Schuster