How would the CFPB fare under Heritage’s Project 2025?

The Heritage Foundation has created what it describes as “the conservative movement’s unified effort to be ready for the next conservative Administration to govern” in a document titled Mandate for Leadership: The Conservative Promise, with a subheading of Project 2025; Presidential Transition Project. As far as I know, no presidential candidate has adopted it. It was written before the Supreme Court’s decision in CFSA. Here’s some of what it says about the CFPB (footnotes omitted):

Congress should abolish the CFPB and reverse Dodd–Frank Section 1061, thus returning the consumer protection function of the CFPB to banking regulators and the Federal Trade Commission. Provided the Supreme Court affirms the Fifth Circuit holding in Community Financial Services Association of America, the next conservative President should order the immediate dissolution of the agency—pull down its prior rules, regulations and guidance, return its staff to their prior agencies and its building to the General Services Administration.

Until this can be accomplished, however, Congress should

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Require that no CFPB funds are spent on enforcement actions that are not based on a rulemaking that complies with the Administrative Procedure Act.

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At least they want to keep the FTC.

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