Since taking office, the Trump administration has significantly curtailed the CFPB’s rulemaking and enforcement activity. Recently, Congress and federal courts have been grappling with what that means for CFPB employees and the rules the CFPB has enacted and enforces. On April 9, 2025, the United States House of Representatives voted to pass a joint resolution disapproving a CFPB rule that would make certain large payment companies subject to Regulations E and Z. The same day, the Court of Appeals for the D.C. Circuit heard oral arguments to resolve a TRO that would maintain the existence of the CFPB as it stood before the administration change. What does this mean for you and your clients? 

On January 24, 2025, the United States Supreme Court ordered expedited briefing to resolve the current circuit split over whether a federal court may certify a class action pursuant to Federal Rule of Civil Procedure 23(b)(3) when some members of the proposed class lack any Article III injury.

On March 27, 2025, citing priorities to reduce agency budget costs and eliminate redundancy among sub-agencies, the U.S. Department of Health and Human Services (HHS) announced that it would be undergoing a significant restructuring, including cutting 20,000 jobs largely from public health agencies.