The Consumer Financial Protection Bureau (CFPB) filed a notice informing the court in NTEU v. Vought that the Department of Justice’s Office of Legal Counsel (OLC) has determined that the Bureau may not legally request funds at this time from the Federal Reserve under Dodd-Frank.
OLC made this conclusion on the basis that the Federal Reserve System currently lacks any “combined earnings” from which the Bureau may draw funding, as required by Dodd-Frank. OLC opinions are binding upon Executive Branch agencies including the Bureau.
The Bureau anticipates having sufficient funds to continue operations until at least December 31, 2025.