OPEN LETTER TO ADAM MARTINEZ, RUSS VOUGHT, AND MARK PAOLETTA

Adam Martinez
Chief Operating Officer and Acting Chief Human Capital Officer
Consumer Financial Protection Bureau
1700 G Street NW
Washington, DC 20552

Mr. Martinez:

We seek your immediate assistance in providing adequate staffing to serve the pressing needs of separated employees. We ask that you immediately request approval from the Acting Director and/or Chief Legal Officer to assign appropriate staff levels and to instruct them to deliver critical, required documents and separation packages to terminated employees. We take comfort that, to your knowledge, “Since the February 3 email” from the Office of the Acting Director, you “have never had a work request be denied.” (Martinez Decl., Doc. 31-1, para. 22, D.D.C. Case No. 1:25-cv-00381 (Feb. 24, 2025).)

On February 11, 2025 at approximately 9:00p.m. Eastern, you removed virtually every probationary employee from their roles at the Bureau. On February 13, 2025, you removed virtually every term employee from their roles as well. All told, you terminated more than 130 Bureau employees, or 12% of the bargaining unit. Yet it has come to our attention that only one employee has been authorized to prepare and deliver separation packets to these 130+ terminated workers.

Unsurprisingly, two weeks later, most of the terminated employees still have not received their separation package documents, including these documents needed ASAP to file for unemployment insurance and to obtain health insurance coverage:

• SF-8 Unemployment Compensation for Federal Employees form
• SF-50 Notification of Personnel Action memorializing the termination
• SF2809 Health Benefits Election Form

We are asking that you:

• immediately authorize additional staff to prepare separation packets;
• deliver SF-8 forms to every terminated CFPB employee, immediately;
• deliver updated SF-50s to every terminated employee electronically, immediately;
• deliver SF2809 forms to every terminated CFPB employee, immediately, along with details on how the employee can look up the TCC premium corresponding to their specific plan, and how to shop for competing coverage on the health insurance marketplace;
• deliver all separation packets electronically to all the separated employees; and
• accomplish all of the above no later than 4:00p.m. Eastern, March 5, 2025.

Until then, the separated employees have urgent needs, including medical expenses for preplanned specialist procedures and surgeries, monthly lifesaving prescriptions that must be filled, and in several cases a newborn arriving in just a few weeks. As you are certainly aware, the employees’ applications for unemployment insurance will not be deemed complete, and they will receive no unemployment benefits, until they receive and submit the SF-8 and SF-50 forms referenced above. Additionally, they will have to pay out-of-pocket for all medical and pharmaceutical expenses unless and until they can obtain health coverage, and urgently need information about TCC to compare it to any other plan the employees may be able to select to choose one that is right for their families. These pressing human needs cannot wait any longer at the current pace that CFPB is processing this paperwork.

We further suggest that you take this opportunity to reflect on the staff, procedures, and good order you will need to put in place to the extent that even one more person will be involuntarily separated from the Bureau. Procedures must be put in place to ensure that staff continue to receive pay until the point that the SF-8, SF-50, and SF2809 necessary for post-employment life are fully prepared, certified, and delivered to future affected employees. In fact, there are already standard operating procedures in our Collective Bargaining Agreement, such as those for Reductions in Force (RIFs), that provide a lawful method for conducting mass terminations while allowing CFPB adequate time and resources to prepare these documents before carrying out separations.

Respectfully submitted by the undersigned,

cc:
Russell T. Vought, Acting Director of the CFPB and Director of OMB
Mark Paoletta, Chief Legal Officer of the CFPB and General Counsel of OMB