Ballard Spahr--Alan S. Kaplinsky, Michael Gordon & John L. Culhane, Jr.
In a unanimous decision, a three-judge panel of the U.S. Court of Appeals for the Fifth Circuit ruled that the funding mechanism for the CFPB violates the U.S. Constitution’s Appropriations Clause and the separation of powers principles on which it is based that will have a huge impact on CFPB issued rules, guidance, and existing enforcement orders.