JUST IN: DOJ releases Office of Legal Counsel opinion by AAG Steven Engel, dated today, concluding POTUS can appoint acting director of CFPB under the Vacancies Reform Act. justice.gov/sites/default/… 
Here is @marty_lederman's cogent response (via thread) to the OLC opinion:
Engel and Lederman both basically agree that this comes down to a question of whether the Dodd-Frank language that the deputy director "shall" serve as acting director makes (or can make) that the sole basis for filling a vacancy — eliminating the VRA (which Trump is using).
Both of them point to the Senate Committee Report, so I uploaded it, highlighting the key portion here: documentcloud.org/documents/4310…
Anyway, there's certainly more to come on this, but I was reading up tonight once I got home — so I figured I might as well share what I have!
