WASHINGTON – Following a series of anti-worker actions taken by the Trump Administration, Senator Ruben Gallego (D-AZ) and 44 members of both the House and Senate today sent a series of bicameral letters to the leaders of the Consumer Financial Protection Bureau (CFPB), U.S. Department of Labor (DOL), Federal Trade Commission (FTC), and National Labor Relations Board (NLRB) demanding answers about the administration’s rollback of protections from coercive employment agreements, including training repayment agreement provisions (TRAPs).
The bicameral letters mark the first time Congress has engaged in an oversight probe into the Trump Administration’s efforts to dismantle worker protections intended to address the growing use of coercive employer-driven debt agreements like TRAPs.
TRAPs have become increasingly prevalent across the United States, with serious consequences for workers. A 2024 study found that 1-in-12 workers in the U.S. are subject to a TRAP, with the percentage growing from 4.1 percent in 2014 to 8.7 percent in 2020. TRAPs are a type of “stay-or-pay” contract scheme that shifts the financial responsibility for training, equipment, and even alleged lost profits onto workers if a worker exits their job before a date set by the employer that can range from months to years. These contracts have been used to hold employees responsible for up to $75,000, and in some instances, exceeds the amount in which a worker was ever compensated.
In the letters, the lawmakers say that across the Trump Administration, “federal regulators and enforcement officials have retreated from a comprehensive, government-wide effort to protect workers from these predatory contracts.” For instance, the letters note that the announcement of a multistate settlement announced in July 2025 with HCA Healthcare disclosed for the first time that the investigation was conducted jointly with the CFPB during the Biden Administration; however, the CFPB was not part of the settlement announced earlier this year, raising concerns that the agency “may no longer be prioritizing its role in constraining employers’ use of debt to exploit workers.”
The letters also note that the DOL has been silent on TRAPs since the start of the Trump administration, after years of shining a spotlight on coercive training agreements; similarly, the Trump-led NLRB rescinded key guidance outlining how regional agency offices should approach such agreements. The FTC under Trump has also refused to defend a landmark and broadly popular rule banning noncompete agreements, which are contractual clauses that prevent workers from working for competitors of the employer. These anti-worker, anticompetitive practices can prevent Americans from getting better, higher-paying jobs.
The letters to the agency heads request answers to numerous questions related to protecting workers from anticompetitive coercive TRAPs, including: a) the number of investigations or lawsuits related to employer-driven debt or training-related repayment obligations that the CFPB has closed; b) the number of cases regarding stay-or-pay contracts, including TRAPs, that the DOL has withdrawn or settled; c) an explanation of how the FTC’s new approach to one-off enforcement actions will provide a meaningful substitute for the agency’s market-wide non-compete rule; and, d) an explanation of NLRB’s approach to handling complaints involving stay-or-pay contracts, such as TRAPs. The letters request a response from each agency by December 19, 2025.
The letters are endorsed by Protect Borrowers, National Nurses United (NNU), Consumer Federation of America, Towards Justice, National Employment Law Project (NELP), P Street, Open Markets Institute (OMI), Economic Security Project Action, American Federation of Teachers (AFT), American Economic Liberties Project, and Service Employees International Union (SEIU).
Read the letters HERE.
11/21/25