The CFPB filed a notice in NTEU v. Vought informing the court of the OLC's determination. According to the CFPB, the OLC concluded that the Federal Reserve System currently lacks any "combined earnings" from which the Bureau may draw funding, as required by the Dodd-Frank Act.
Under Dodd-Frank, the CFPB is authorized to request funding from the Federal Reserve rather than through congressional appropriations.
Despite the funding restriction, the CFPB said it "anticipates having sufficient funds to continue operations until at least December 31, 2025."
OLC opinions are binding upon Executive Branch agencies including the Bureau, according to the CFPB.