CFPB’s OIG Investigating Current Workforce And Contracting Developments Plus Interpretations Adopted And Enforcement Actions Taken Under Then Director Chopra

The CFPB’s Office of Inspector General is still investigating the agency’s workforce and contracting moves to see what impact it has had on agency actions.

“We are reviewing the CFPB’s workforce and contracting actions to determine their high-level effects on mission-related activities and support functions,” the OIG said, in an update of its activities. “We are not assessing whether these actions complied with applicable laws, regulations, policies, or procedures because they are the subject of ongoing litigation.”

The office of Inspector General Michael E. Horowitz did not provide additional details of that probe.

The IG’s office had reported the investigation last summer in a letter to Senator Andy Kim, D-N.J.

The IG’s office, which also covers the Federal Reserve Board, reported last summer that it was investigating the bureau’s workforce reductions and its canceled contracts, according to a letter to Senator Kim, from then-Acting FRS/CFPB IG Fred Gibson.

Gibson said he already was investigating the workforce reductions at the bureau in response to a letter from Senator Gary Peters, D-Mich. and 15 other Senators. Responding to a call from Kim and Senator Elizabeth Warren, D-Mass., Gibson now has expanded his work to include contracts that have been canceled by the Trump Administration.

In February, the GAO issued a report that mainly detailed timelines of various actions at the CFPB related to the reorganization and downsizing of the agency. As noted by the GAO, the actual analysis of the effect of the actions will be set forth in a future report.

Separately, the OIG is investigating developments that occurred under the tenure of former Biden Administration Director Rohit Chopra.

“We are assessing whether the CFPB, under former Director Rohit Chopra, adhered to relevant processes and procedures in its decisions to broaden its definition of ‘unfair, deceptive, or abusive acts or practices’ and its definition of ‘credit,’ under the Truth in Lending Act,” the OIG said.

The CFPB had directed its examiners to apply the Consumer Financial Protection Act’s unfairness standard to conduct considered to be discriminatory whether or not it is covered by the Equal Credit Opportunity Act, such as in connection with denying access to a checking account. (After losing in District Court, the CFPB revised its exam manual to delete those directions. An appeal to the Fifth Circuit was dismissed, following the change in Administrations.)

While the OIG did not identify the interpretations of “credit” under the Truth in Lending Act that will be reviewed, they seem likely to include the interpretive rule on Buy Now Pay Later transactions, the proposed interpretive rule on Earned Wage Access transactions, the advisory opinion on Contract for Deed transactions, and the rule on PACE transactions. Although the rule on PACE transactions went into effect on March 1, 2026, under Acting Director Russell Vought, the CFPB withdrew the BNPL rule, the proposed EWA rule, and the Contract for Deed advisory opinion.

“We will also inquire whether the CFPB has available information that will enable us to assess the time and costs associated with the enforcement actions issued during then Director Chopra’s tenure in comparison to those issued during the tenure of prior directors,” the OIG said.

A probe into those developments had been requested by members of Congress, according to the OIG, which did not identify those members.