Prior research indicates that subjective cognitive decline (SCD) affects approximately one-third of older adults with Chronic Obstructive Pulmonary Disease (COPD). However, there is limited population-based research on risk factors associated with SCD-related functional limitations within this vulnerable subgroup. A secondary data analysis of 2019 Behavioral Risk Factor Surveillance System data was conducted to address this gap, focusing on Americans ≥45 years old with COPD (N = 107,204). Several sociodemographic and health-related factors were independently associated with SCD-related functional limitations. Retired and unemployed individuals were significantly more likely to require assistance with day-to-day activities due to memory loss or confusion compared to employed individuals (AOR = 3.0, 95% CI: 1.2–8.0; AOR = 5.8, 95% CI: 3.01–1.5, respectively). Additionally, unemployed individuals were over five times more likely to report confusion or memory loss affecting social activities (AOR = 5.7, 95% CI: 2.9–11.0). Disparities were also observed among different racial groups, with Black/African Americans (AOR = 4.9, 95% CI: 2.3–10.4) and Hispanics (AOR = 2.4, 95% CI: 1.2–4.7) more likely than White and non-Hispanic people, respectively, to give up daily chores due to SCD. Our findings underscore the need for culturally sensitive interventions to address functional limitations faced by retired, unemployed, and minority adults with COPD and SCD.