Empty leather chair.
After Consumer Financial Protection Bureau Director Richard Cordray announced Wednesday that he would step down at the end of November, it sparked a flurry of speculation about who President Trump would pick to succeed the agency chief.

The White House said that it would announce an acting director and a permanent successor "at the appropriate time." It seems likely that it will want to at least install an interim head as soon as Cordray leaves. If not, David Silberman, the agency's acting No. 2, would take over, a prospect that the Trump administration would probably like to avoid.

That could lead to some interesting choices. Under the Federal Vacancies Act, it appears that an acting director must come from the ranks of those already confirmed by the Senate for a different position. That limits who the Trump administration could tap, though there's some leeway there for an appointee to pick his or her own designate to handle agency responsibilities.

The issue of a permanent director, meanwhile, is liable to be a hot topic going forward. The Trump administration has been slow to nominate banking regulators. It only recently got Randal Quarles confirmed to the Federal Reserve Board, and its second regulator, Joseph Otting, is set to be confirmed as early as Wednesday as comptroller of the currency. As a result, it could take some time before the White House settles on a CFPB nominee.

One thing is clear. Whomever is chosen, Democrats will be looking to grill them hard. Sen. Elizabeth Warren, D-Mass., warned Wednesday that the CFPB is "no place for another Trump-appointed industry hack." To be sure, Democrats can do little to stop the ultimate choice. Given recent Senate changes, the minority party can no longer filibuster nominees. Still, Democrats will likely scrutinize the choice.

Following is a guide to the top names being discussed:
Treasury Secretary Steven Mnuchin with wife, actress Louise Linton. Also with money, currency
Steven Mnuchin, U.S. Treasury secretary, right, and his wife Louise Linton hold a 2017 50 subject uncut sheet of $1 dollar notes bearing Mnuchin's name for a photograph at the U.S. Bureau of Engraving and Printing in Washington, D.C., U.S., on Wednesday, Nov. 15, 2017. A change in the Senate tax-overhaul plan that would expand a temporary income-tax break for partnerships, limited liability companies and other so-called "pass-through" businesses won the endorsement of a national small-business group today. Photographer: Andrew Harrer/Bloomberg
Andrew Harrer/Bloomberg

Interim director: Treasury Secretary Steven Mnuchin

This isn't as crazy as it sounds. Because Mnuchin has already been confirmed by the Senate, he can legally step in to run the CFPB on a temporary basis. He would not have to give up his duties as Treasury secretary (including, pictured above, putting his signature on new currency).

Indeed, it seems likely that if Mnuchin is chosen, he would likely appoint a Treasury official to act in his stead in the day-to-day operations of the CFPB. This would ensure the Trump administration has full control over what CFPB does — and doesn't do — until an independent director in nominated and confirmed.

Treasury officials likely to be considered for that role include Craig Phillips, a counselor to Mnuchin, and Jared Sawyer, a deputy assistant secretary of financial institutions policy at Treasury.
OMB Director Mick Mulvaney
Mick Mulvaney, director of the Office of Management and Budget (OMB), pauses while speaking during a White House press briefing in Washington, D.C., U.S., on Thursday, July 20, 2017. Mulvaney has called Trump's tax-cutting approach to the economy MAGAnomics, a spin on Trump's campaign slogan, "Make America Great Again" and has repeatedly attacked the Congressional Budget Office (CBO) for its estimates on the impact of Republicans' plans to repeal and replace Obamacare. Photographer: Andrew Harrer/Bloomberg
Andrew Harrer/Bloomberg

Interim director: Office of Management and Budget Director Mick Mulvaney

Similar to Mnuchin, Mulvaney would be there as a placeholder, likely designating OMB staff to handle the day-to-day operations of the CFPB.

But with so few Trump appointees who have been Senate confirmed, the ranks of potential acting directors isn't long.
David Silberman, acting deputy director of the CFPB.

Interim director: David Silberman

As the acting deputy director of CFPB, Silberman will get the job if the Trump administration doesn't act when Cordray leaves.

If that occurs, however, it doesn't seem likely to last long. Silberman will be seen as following in Cordray's footsteps. Since the administration has been clear that it wants to begin easing consumer protection regulations, effectively keeping the status quo wouldn't make sense.
Todd Zywicki, professor of law at George Mason University
Todd Zywicki, a professor of law at George Mason University, testifies to the House Oversight and Government Reform subcommittee on TARP and Financial Services about the administration’s auto bailouts and the Delphi pension decisions in Washington, D.C., U.S., on Tuesday, July 10, 2012. Photographer: Joshua Roberts/Bloomberg
Joshua Roberts/Bloomberg

Director: Todd Zywicki

Todd Zywicki, professor of law at George Mason University, has had his name talked about for months as a potential candidate to succeed Cordray, stretching back to when Trump took office.

It's not hard to see why. Zywicki has been an outspoken critic of the CFPB. He wrote a paper in 2012 asking if the agency was a "savior or menace." He concluded it was the latter.

"The CFPB is likely to raise the price and reduce access to credit, thereby harming the very consumers it was founded to protect," he wrote.

His nomination would be praised by Republicans in part because he agrees with criticisms that the agency's structure leaves it unaccountable. He has endorsed replacing the single director with a five-person board, among other changes.

He would likely be fiercely opposed by Senate Democrats, but without enough votes to stop him, that would not be a major impediment.
Mark Calabria, chief economist for Vice President Mike Pence
Mark Calabria, director of financial regulation studies with the Cato Institute, speaks during a Senate Banking Committee hearing in Washington, D.C., U.S., on Wednesday, Sept. 14, 2011. The hearing was entitled Ònew ideas for refinancing and restructuring mortgage loans.Ó Photographer: Andrew Harrer/Bloomberg *** Local Caption *** Mark Calabria
Andrew Harrer/Bloomberg

Director: Mark Calabria

Calabria, the chief economist for Vice President Mike Pence, is well known in financial policy circles.

Before joining the administration earlier this year, Calabria ran the financial services policy arm of the Cato Institute. Before that, he was a top aide to the Senate Banking Committee under former chairman Richard Shelby, R-Ala. Calabria was in the trenches for Republicans during the Dodd-Frank Act debates and has been an outspoken advocate for housing finance reform.

Though he would likely draw opposition from Democrats, Calabria would come to the job with an in-depth knowledge of recent banking policy.
Rep. Jeb Hensarling, a Republican from Texas and chairman of the House Financial Services Committee, listens during a House Financial Services Subcommittee hearing in Washington.

Director: Rep. Jeb Hensarling, R-Tex.

House Financial Services Committee Chairman Jeb Hensarling seems like an outside choice for the next CFPB director.

For one, the agency job will be vacant next month, while Hensarling is not due to retire from Congress until the end of next year. It seems unlikely that Hensarling would give up the chairmanship of the House banking panel when he still has time to enact new legislation.

Still, his name has been discussed, given his outspoken views on the CFPB. Hensarling has attempted to effectively gut the agency as part of his Financial Choice Act regulatory relief bill, a move that would not endear him to CFPB employees if he were picked as director. Yet Republicans would be assured that the bureau would be reined in.
Keith Noreika, acting Comptroller of the Currency (left), and Richard Cordray, director of the Consumer Financial Protection Bureau.
Keith Noreika, acting Comptroller of the Currency, speaks during a Senate Banking Committee hearing in Washington, D.C., U.S., on Thursday, June 22, 2017. Top U.S. banking regulators are sprinting to ease the Volcker Rule, stress tests and other constraints on Wall Street after the Trump administration issued a long list of proposals last week for rolling back post-crisis financial rules. Photographer: Andrew Harrer/Bloomberg
Andrew Harrer/Bloomberg

Director: Keith Noreika

It's difficult to know if Keith Noreika, the outgoing acting comptroller of the currency, is a true contender for the CFPB job — or whether it's just an effort to stick a fork in Cordray's eye on his way out. Cordray and Noreika have openly feuded for months about the CFPB's rule to ban mandatory arbitration clauses.

It led to accusations and counter-accusations about whether the CFPB rule would hurt consumers. Ultimately, the Senate rejected the rule, which led Noreika to take a victory lap of sorts.

If he is nominated, Democrats would surely fight a Noreika appointment as hard as possible. Democrats have come to loathe Noreika, even though he's only been in office for a little more than six months, and would view him as hostile to the CFPB's work.
Former Texas Representative Randy Neugebauer.
Representative Randy Neugebauer, a Republican from Texas, chairs a hearing of the Investigations and Oversight subcommittee of the House Financial Services Committee in Washington, D.C., U.S., on Wednesday, July 27, 2011. Standard & Poor's President Deven Sharma said at the hearing that credit-rating firms, which have weighed in on the debate over the U.S. debt ceiling, should be free from political pressure when they assess sovereign debt. Photographer: Jay Mallin/Bloomberg *** Local Caption *** Randy Neugebauer
Jay Mallin/Bloomberg

Director: Former Rep. Randy Neugebauer, R-Tex.

Unlike many on this list, Neugebauer was already interviewed for the CFPB job. The White House said early this year it had talked to the Texas Republican about replacing Cordray.

At the time it was seen as proof that the administration was considering ousting Cordray — a fight it ultimately decided against.
Scott Garrett, president of the Export-Import Bank nominee for President Trump, speaks during a Senate Banking, Housing, and Urban Affairs Committee confirmation hearing in Washington.

Director: Former Rep. Scott Garrett, R-N.J.

What makes Garrett's name interesting is that he's already been tapped for a post in the Trump administration.

But the former congressman has had a tough time during his confirmation process for head of the Ex-Im Bank. Just last week, he had to disavow his own prior statements about the need for the institution.

That could lead the White House to conclude Garrett might fit easier someplace else. As a former top member of the Financial Services Committee, Garrett has sharply criticized the CFPB in the past. Like Hensarling and Neugebauer, he would be likely to push for substantial changes at the agency.
hill-french-rep.jpg

Director: Rep. French Hill, R-Ark.

Another House Financial Services Committee member, Hill would likely take a similar approach as Hensarling and other conservatives to reining in the CFPB.

Unlike the others, however, Hill has a banking background. He previously served as CEO of Delta Trust and Banking Corp. in Little Rock.
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