The Department of Government Efficiency (DOGE) is planning to fire the “vast majority” of employees at the Consumer Financial Protection Bureau (CFPB), agency employees — some using pseudonyms for fear of retaliation — told a federal court in sworn declarations.

Seven current and five former CFPB employees submitted the declarations as part of the National Treasury Employees Union case against Office of Management and Budget director Russell Vought, who’s currently serving as the acting director of the CFPB. The union is seeking to halt the already in-progress dismantling of the financial services watchdog, which fields thousands of consumer complaints each week about financial products, and as of 2023, had returned $17.5 billion to consumers over 12 years through things like monetary compensation and canceled debts. Earlier this month, The Verge reported that roughly 20 technologists at the agency were suddenly fired on a weeknight, amid a broader swath of layoffs. The court has temporarily barred the CFPB from making further cuts.

Four of the seven current employees declined to provide their names publicly but offered to identify themselves to the court under seal. In the declarations, provided under penalty of perjury, the employees described a hasty firing process orchestrated by DOGE, with cursory thought as to who would handle consumer protection issues and CFPB data once the agency was gutted. The stop-work order at the agency has prevented staffers from even conducting necessary work “to maintain the security and stability of the CFPB’s computer systems,” according to one of the declarations.

One current employee, using the pseudonym Alex Doe, says that, around February 13th, their team “was directed to assist with terminating the vast majority of CFPB employees as quickly as possible.” Alex Doe described a three-phase approach: first, firing probationary employees who are newer to the agency; second, firing “approximately 1,200 additional employees, by eliminating whole offices, divisions, and units”; and third, terminating most of the remaining employees within 60-90 days, “leaving a Bureau that could not actually perform any functions, or no Bureau at all.”

The CFPB is responsible for ensuring that companies offering financial services are not misleading consumers or skirting the law. Consumers could submit complaints to the agency about credit cards and loans, and the agency could also initiate enforcement actions and rulemakings, like the one it previously finalized to monitor large digital payment providers as it does banks.

The speed of the recent layoffs necessitated “bypassing several ordinary procedures, safeguards, and rules,” according to Alex Doe, who says that the timeline of the terminations was specifically dictated by DOGE employee Jordan Wick. Only a court order that temporarily prevented further firings stopped the remaining terminations from going through on Valentine’s Day, they add. The CFPB and White House did not immediately respond to requests for comment.

In a meeting after the court order, CFPB chief operating officer Adam Martinez told staff that “he did not yet know what agency would perform a similar role for the CFPB or whether the Bureau itself would technically continue to exist with a small staff to perform those functions,” according to Alex Doe.

A second current employee, using the pseudonym Blake Doe, disputes Martinez’s declaration to the court that consumers who would have been served by the CFPB’s now-eliminated Student Loan Ombudsman could just turn to the agency’s general Ombudsman office. “That is not possible, however, because the employees of the general Ombudsman Office have been ordered not to perform any work,” writes Blake Doe. Contrary to Martinez’s declaration, Blake Doe says they’ve seen evidence that the CFPB was in communication with the Federal Reserve about how to return money there or to the Treasury.

Other declarations raise issues about DOGE staffers’ privacy and security training to handle CFPB systems and concerns about where agency data — which could include HR and reasonable accommodation records — might end up.

A CFPB contracting officer going by the name of Charlie Doe says that contract termination notices they saw did not include the usual data preservation notices to ensure CFPB data is not lost. Between February 11th and 14th, the agency issued termination notices for over a hundred contracts, Charlie Doe says, including ones that maintain the consumer complaint database and ensure it’s scrubbed of personally identifiable information, ignoring feedback from employees about which contracts were necessary to keep to follow the law.

“The hasty termination of almost all of the Bureau’s contracts resulted in systems and services being turned off before CFPB or contract personnel returned CFPB data,” a fourth employee, Drew Doe, writes. “Because not all systems have off-line backups, some of the CFPB’s data may have been deleted. Among other things, this data may include CFPB Human Resource records, Reasonable Accommodation records, Ombudsman records, and Equal Employment Opportunity records. The data may not be recoverable and as of February 25th, CFPB is trying to now figure out which systems and services have records.”

Some of the seemingly hasty work is apparently deliberate. CFPB director of digital services Adam Scott submitted an email exchange he was copied on to the court, in which the agency’s chief information officer, Christopher Chilbert, told an employee that it was his understanding that the CFPB’s deleted homepage was a decision made by Vought, “and it was not an error made by the members of the DOGE team.”

Drew Doe claims that DOGE staffers “were given full privileged access to CFPB systems and data, without following the process that the CFPB ordinarily requires to do so,” including signing documents about the governance of CFPB systems and data. In meetings over the past couple of weeks, they add, senior executives told agency staff “that the CFPB would exist in name only.”