Opponents of the Consumer Financial Protection Bureau have introduced legislation that could prevent the CFPB from enforcing or implementing regulations without a constitutionally confirmed director in place.

The move in Congress was prompted by an appellate court decision that invalidated President Obama’s recess appointments to the National Labor Relations Board. A similar case is pending against the President’s recess appointment of CFPB Director Richard Cordray.

But because the CFPB was created under the Dodd-Frank Act, it’s unknown how much a court ruling invalidating Mr. Cordray’s appointment would affect its ability to implement any regulatory and other decisions he made on new mortgage and financial services rules.

“We are still researching what the impact of a ruling would be on these final (mortgage) regulations,” said Alan S. Kaplinsky, leader of Ballard Spahr’s Consumer Financial Services Group. “I think some of them may be valid even under an acting director, and some of them may not be valid.”