Regulators not taking their foot off the pedal

While the government efficiency crusade is slashing federal oversight and trimming bureaucracy, regulatory enforcement looks like it remains strong — but timing is key.

The Department of Government Efficiency’s (DOGE) influence on federal financial regulators has coincided with what appears to be a higher than usual intensity of enforcement action.

Since February, more than 75,000 federal employees have exited under voluntary separation programs. The SEC has already acknowledged a 16% workforce reduction in early 2025.

Yet enforcement — particularly at the SEC — is not slowing down. In fact it’s picking up. According to the SEC’s H1 2025 enforcement results, the Commission filed 314 total enforcement actions — more than doubling its output compared to the same six-month period the year prior. These include 201 standalone actions, representing a roughly 120% year-over-year increase.

After a record-breaking first quarter with 200 total enforcement actions, acting Director of the Division of Enforcement Sanjay Wadhwa said, “As these impressive figures reflect, the Division has not taken its foot off the pedal in the new fiscal year. On the contrary, the hard work of the dedicated staff … has resulted in the busiest start to a fiscal year that I have witnessed in my 20-plus years at the Commission.”

However, taking a closer look at the timing illustrates a more nuanced picture. With 200 enforcement actions in Q1, that leaves only 114 in Q2 — a roughly 40% drop quarter-over-quarter.

This slow-down is highly unusual. The last time the SEC has seen a downturn in enforcement actions was back in 2021, when they completed 107 enforcement actions in the first quarter, followed by a 92-action second quarter, representing a much smaller 14% decrease.

Historically, the SEC tends to ramp up activity as the fiscal year progresses, reaching its peak at the end of the year. That this year’s Q1 was so unusually high — followed by a sharp drop — raises the question of whether early enforcement could have been front-loaded in anticipation of political headwinds and shifts to other agency priorities, including policy change.

DOGE’s cost-cutting measures may also be playing a role in this recalibration. While the SEC has so far maintained a high output, institutional stress appears to be mounting. The departure of nearly 500 staff members in late March — nearly 10% of the agency workforce — will likely continue to have some effect on its ability to conduct and complete regulatory actions in this fiscal year.

CFPB in DOGE cross hairs

The Consumer Financial Protection Bureau (CFPB) appears to be next in DOGE’s line of fire. According to DOGE’s own “Agency Deregulation Leaderboard,” the CFPB led all agencies in budget cuts, shedding over $14 billion in April — nearly as much as the next four departments combined.

One of the DOGE’s most significant regulatory rollbacks to date came in April with the repeal of the CFPB’s Credit Card Penalty Fees rule. Originally enacted on May 14, 2024, the rule capped late fees that credit card issuers could charge consumers. According to DOGE’s estimates, repealing the rule is expected to generate up to $9.5 billion in federal savings — the second largest single cut reported on its leaderboard to date.

While the DOGE’s website lists more than $170 billion in estimated savings — figures that have been met with widespread skepticism — the department’s actions are unmistakably constraining the CFPB’s ability to carry out its regulatory mandate.

Earlier this month, the CFPB announced the withdrawal of 67 regulatory guidance documents, including interpretive rules, policy statements, and advisory opinions issued since its inception in 2011.

“The Bureau is reducing its enforcement activities in light of President Trump’s directives to deregulate and streamline bureaucracy,” the Bureau explained in its statement on May 12, and “… is reducing its own enforcement to only those areas statutorily required.”

The new acting CFPB Director Russel Vought has also dismissed over half of the Bureau’s pending enforcement actions — totalling 21 dismissed cases out of a total 38. 19 of the dismissed cases were brought by the former CFPB Director Rohit Chopra who was appointed by former President Joe Biden.

The most recent addition to the CFPB’s list of dismissed Biden-era enforcement action occurred on May 27, when the Bureau dropped its remaining claims against Snap Finance, a lease-to-own fintech company.

The original lawsuit, filed in 2023, alleged that Snap’s financing practices violated consumer protection laws applicable to credit products.

However, in August 2024, a federal judge dismissed most of the Bureau’s claims, ruling that lease-to-own agreements do not constitute credit under the Consumer Financial Protection Act. Rather than proceeding with the remaining limited claims, the CFPB has now abandoned the case in its entirety.