The head of the CFPB, Richard Cordray, was initially appointed by a recess appointment which has generated speculation as to its validity and resulted in certain court actions.  Mr. Cordray’s appointment was subsequently confirmed by the senate in July 2013.  Mr. Cordray has recently sought to dispel doubts about his recess appointment actions by ratifying all such actions by this document published in the Federal Register.

The document states: “I believe that the actions I took during the period I was serving as a recess appointee were legally authorized and entirely proper. To avoid any possible uncertainty, however, I hereby affirm and ratify any and all actions I took during that period.”