collins brief today on the fhfa uncosnt structure: https://www.dropbox.com/s/urdvu3nqlow0eox/collins%203%3A20%3A17%20brief%20re%20separation%20of%20powers%20fhfa.pdf?dl=0
excellent brief imo
edit: especially part where collins argues there is no distinction between an official who serves unlawfully because of a violation of appointments clause (where unlawful officials prior acts are voided), and an official who serves unlawfully because of a violative removal clause. fhfa argues that at worst, court should simply amend statute going forward to make removable at will, leaving past decisions intact. collins i think does a great job of challenging this.
fhfa argues that while an officer who was improperly appointed never was in a lawful position to act, fhfa director was in a lawful position to act notwithstanding the removal issue, and is lawful until the removal issue is resolved.
collins argues that consistent with appointments clause caselaw, the NWS should be invalidated and reconsidered, if the director wishes, by a director who is removable at will.