On January 9, CFPB Acting Director Russel Vought submitted a $145 million funding request to Federal Reserve Board Chair Jerome Powell for the CFPB’s second quarter of fiscal year 2026. The notice states the submission was made in accordance with a court order directing the CFPB to continue to following the funding processes set out in the Consumer Financial Protection Act, which requires quarterly transfers in an amount the Director determines is reasonably necessary from the Federal Reserve System’s “combined earnings” (previously discussed here).

In the attached letter, Vought stated he disagrees with the court’s interpretation of “combined earnings,” but, pursuant to the order, determined that $145 million is reasonably necessary for the CFPB to carry out its statutory authorities during the quarter. 

Putting It Into Practice: The request signals that the CFPB is proceeding on the assumption that it will continue operating under its existing statutory funding framework while the dispute plays out. At the same time, the Acting Director’s stated disagreement with the court’s interpretation underscores that the legal uncertainty has not been resolved and could still affect longer-term planning, particularly if future requests, appeals, or compliance disputes alter the Bureau’s access to funds. Companies should treat this development as a signal to remain engaged with CFPB processes while staying alert to potential shifts later in the year.