id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
inlawrev-26849	Schafer, Sloan	A Case for the Extension of the De Facto Officer Doctrine	2022	24	.pdf	application/pdf	11246	789	63	The opinion sparked questions concerning the validity of the CFPB’s rules, regulations, and enforcement actions taken prior to Seila Law.2 Former CFPB Director Kathleen Kraninger attempted to ratify the CFPB’s actions.3 Similarly, former CFPB Director Richard Cordray was unconstitutionally appointed to the position in 2013, and he issued a ratification for all of his actions taken prior to his valid reappointment.4 However, Directors Kraninger and Cordray’s ratifications differed in one important aspect. Letter from Kathleen Kraninger, CFPB Director, to Nancy Pelosi, Speaker, U.S. House of Representatives, p. 1 (Sept. 17, 2019).	cache/inlawrev-26849.pdf	txt/inlawrev-26849.txt