The Congressional Research Service recently reviewed the D.C. Circuit’s January 2013 decision in Noel Canning v. National Labor Relations Board, and came to the conclusion that nearly all of the CFPB’s rulemakings could be validated by the Treasury Secretary, should President Obama’s recess appointment of Richard Cordray as bureau director be similarly declared unconstitutional. If Director Cordray’s appointment was not valid, the only CFPB rules the Secretary could not ratify are its “larger participant” rules for...