Project 2025 Trade Chapter Ignores Consumer Finance — But the Current CFPB Dismantling Is Underway
Project 2025's trade chapter focuses on tariffs and WTO reform, not consumer protection. Yet the agenda it helped shape is already executing CFPB freeze, open-banking rescission, and junk-fee repeal — actions that transfer billions from consumers to banks.
The Project 2025 trade chapter touts 'humility' in trade policy and warns against mission creep. While the chapter focuses on tariffs and the WTO, it does not call for dismantling the Consumer Financial Protection Bureau. Yet that dismantling is being executed now: the CFPB was ordered to halt enforcement and stop accepting new complaints on February 10, 2025; Acting Director Russell Vought proposed rescinding the Open Banking Rule (which would have given you control over your own financial data) on May 15, 2025, without public notice or comment; and Republicans in Congress used the Congressional Review Act to repeal the CFPB's credit-card late-fee cap in April 2025 — a rule that had been saving consumers an estimated $10 billion annually.
These actions are not in Project 2025's trade chapter, but they align with the broader deregulatory agenda that Project 2025 advocates elsewhere. The chapter warns against favoring one sector over another, yet the CFPB freeze and rule rescissions favor the financial sector over the families that get hit with junk fees, can't switch banks because their data is locked in, and now have nowhere to file a complaint when they are cheated. The Vought rescission of the Open Banking Rule, the junk-fee repeal, and the operational freeze are all already executed or in motion. They are not hypothetical proposals — they are being carried out right now, with billions of dollars in consumer losses as the consequence.
The humanitarian alternative
Congress should: (1) immediately restore CFPB funding and staffing, (2) reinstate the Open Banking Rule to ensure consumer data portability, (3) reissue and defend the junk fee rule limiting credit card late fees, and (4) reopen the consumer complaint database. The SEC should also require climate-risk disclosure to protect investors from systemic climate exposure.
Original source — excerpted
project2025 Project 2025 ch. 27: Financial Regulatory Agencies (pp 828-830)"— 795 — Trade against trade cheaters who dump products below cost into American markets or unfairly subsidize their exports. In fact, much of the cheating that does take place in the global trading arena can be addressed through such antidumping (AD) and countervailing duty (CVD) cases. Within the West Wing itself, it is equally critical that the National Security Adviser, the Chairman of the Council of Economic Advisers (CEA), and the Director of the National Economic Council (NEC) all be aligned on trade policy. During the Trump Administration, with the notable exception of the President’s third National Security Adviser, Robert O’Brien, and third CEA Chairman, Tyler Goodspeed, this regrettably was not the case. Finally, and perhaps surprisingly, the Secretary of Defense plays a key role in trade policy, at least when it comes to advancing Section 232 cases. Under Section 232 of the Trade Expansion Act of 1962,40 the President has the authority, through tariffs or other means, to reduce imports from other countries “if the President determines that such reduction or elimination would threaten to impair the national security.” As a practical matter, the Secretary of…"