“The convening of periodic pro forma sessions in which no business is to be conducted does not have the legal effect of interrupting an intrasession recess otherwise long enough to qualify as a ‘Recess of the Senate’ under the Recess Appointments Clause.  In this context, the President therefore has discretion to conclude that the Senate is unavailable to perform its advise-and-consent function and to exercise his power to make recess appointments.” … Continue Reading

The Internet is alive with the breaking news that President Obama has decided to make a “recess appointment” to name Richard Cordray as the Director of the CFPB.  Unless the appointment is successfully challenged, this move would open up a whole range of powers to the Bureau, including the power to regulate non-bank players and the authority to act under the “unfair, deceptive, or abusive” provisions in the Dodd-Frank Act.… Continue Reading