Even though the U.S. Senate has confirmed Richard Cordray as Director of the Consumer Financial Protection Bureau (CFPB), there is still a chance that some of Mr. Cordray's actions prior to his confirmation could be considered invalid because of his status as a recess appointee.

Ballard Spahr consumer financial services attorney Alan S. Kaplinsky said Mr. Cordray could avoid such legal issues by ratifying all the actions he took as director prior to his confirmation. Mr. Kaplinsky said that financial industry officials had been worried that if Mr. Cordray's actions were thrown out, the harsher versions of regulations mandated by the Dodd-Frank Act would go into place without the CFPB's rules.

"The provisions in Dodd-Frank that would apply in the absence of regulations would have been horrendous," Mr. Kaplinsky said.

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