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Volume 25 - Number 14

July 7, 2014

Cordray’s Recess Appointment Likely Invalid, Issue Now Moot

President Barack Obamaís original recess appointment of Richard Cordray as director of the CFPB was likely unconstitutional, according to the rationale the U.S. Supreme Court used late last month to unanimously declare the presidentís nominees to the National Labor Relations Board out of bounds. Late last month, in NLRB v. Noel Canning, the SCOTUS ruled that the presidentís Jan. 4, 2012, recess appointments to the National Labor Relations Board were invalid. Alan Kaplinsky, a practice leader with the Ballard Spahr law firm, explained the legal question in dispute this way: ďThe NLRB recess appointments were made on January 4, the day after a new session of Congress had begun with a pro forma January 3 session and two days before ...

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With originations expected to drop in 2018, will your shop turn to non-QM/non-prime mortgage products as a way to bolster volumes?

Yes, definitely. We’re planning a launch.


No. It’s still difficult compliance/regulatory-wise.


Maybe. It’s under consideration.


Not now. But things could change as 2018 progresses.