Roughly 53% of the Consumer Financial Protection Bureau’s workforce, or 618 employees, would be cut under a plan the agency included in court documents Tuesday.

The CFPB asked the D.C. Circuit Court of Appeals to send the case back to the district court, with the hope that the revised workforce reduction plan would persuade the judge there to lift a preliminary injunction preventing cuts.

Additionally, the CFPB argued, the bureau can’t continue staffing at current levels because the One Big Beautiful Bill, passed last July, reduced the amount of funding the agency could request to 6.5% of the Federal Reserve’s operating expenses.

That amounts to $466.8 million in fiscal 2026, the CFPB said. But the bureau paid its employees $526.4 million in fiscal 2025, it added.

“It would be mathematically impossible to comply with the law without a workforce restructuring and reduction,” Geoffrey Gradler, the CFPB’s deputy director, wrote in a separate filing.

Under the plan, the CFPB’s supervision division, which conducts exams, would see the steepest cuts – 78% – as the agency would retain 77 of that unit’s 350 current employees.

The enforcement division, which investigates and takes legal action against financial institutions, would see a 63% workforce cut, to 50 employees from 137 under the plan.

The operations division, managing the bureau’s internal functions, would be cut by 48%, from 255 employees to 133.

The legal division would stand pat at 60 employees.

In a statement Thursday, Cat Farman, president of the National Treasury Employees Union 335, characterized the bureau’s outline as Acting Director Russ Vought’s “latest half-baked shutdown plan in his tiresome quest to destroy the CFPB via mass layoffs.”

The NTEU is the plaintiff in the CFPB’s yearlong court case. Farman noted that since President Donald Trump resumed office in January 2025, the CFPB’s headcount has shrunk to 1,166 from a peak of more than 1,700.

“Vought’s insistence that CFPB can meet its statutory obligations with only one-third of the staff is laughable, and an insult to the intelligence of the judges,” Farman said. “Everyone knows Vought doesn’t want CFPB to exist at all.”

In an October podcast appearance, Vought said of the CFPB, “We want to put it out – and we will be successful probably within the next two, three months.”

At the time, the CFPB was arguing that it could not request funds from the Fed, under its interpretation of the term “combined earnings” in the Dodd-Frank Act – and that it would run out of money in early 2026.

The district court, however, ruled that the CFPB must continue requesting money from the Fed. Vought this week requested $75.8 million to fund the CFPB’s fiscal third-quarter operations.

In its filing with the appeals court Tuesday, the CFPB said it expects a reduction in force would be necessary by the fourth quarter of 2026 without a revised staffing plan.

The revised plan, the bureau said, “makes clear that CFPB leadership will not close the agency absent the injunction, contrary to the central factual premise on which the injunction is based.”

Under the plan, the CFPB would be “sufficiently staffed to fulfill its statutory obligations,” the bureau said, and “plaintiffs would not be harmed.”

A court order, the CFPB argued, “would alleviate ongoing harm to the Executive Branch’s prerogative to right-size agency operations in line with an important Presidential policy.”

“Allowing CFPB to implement its downsizing plan now could also conserve judicial resources and help expedite resolution of this litigation,” the bureau asserted in its court filing.

Advocacy groups such as the National Consumer Law Center remained skeptical of the CFPB’s downsizing plan.

“This latest attempt to eliminate essential staff at the CFPB would reduce the bureau to an empty shell, unable to fulfill the functions the CFPB is statutorily required to engage in,” Chi Chi Wu, the NCLC’s director of consumer reporting and data advocacy, said in a statement Wednesday. “Cutting consumer protections during an affordability crisis, while people are holding record credit card and student loan debt and facing rising prices for gas, groceries, and utilities, is tone deaf and cruel.”

Among other cuts, the CFPB proposed cutting its consumer response education division by 29%, or 37 employees. Its external affairs division would be cut from 30 employees to five. The director’s office would have 15 employees, down from 62. The bureau’s regulations division, by comparison, would see a 12%, or 17-person reduction, according to the plan.