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

BY: Consumer Finance Team
State Capital building

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.

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