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