Alston & Bird Consumer Finance Blog

Archives for November 10, 2020

Could President Biden Appoint an Acting CFPB Director Under the FVRA? Not if He Fires Director Kraninger First

State Capital building

In a November 10 client advisory, our Financial Services & Products Group explores the case law and academic research surrounding the implications of a President removing a Senate-confirmed department head before the end of their term.

  • Would an acting director’s actions be lawful?
  • What does Dodd–Frank say?
  • More importantly, what does the Federal Vacancies Reform Act say?

You can read the client alert here.