The CFPB published a “Notice of Ratification” in today’s Federal Register in which Director Cordray ratifies the actions he took prior to his confirmation by the Senate as CFPB Director.  In the notice, he states “I believe that the actions I took during the period I was serving as a recess appointee were legally authorized and entirely proper.  To avoid any possible uncertainty, however, I hereby affirm and ratify any and all actions I took during that period.”