After a series of celebrated accounting debacles, Congress enacted the Sarbanes-Oxley Act of 2002, which introduced tighter regulation of the accounting industry under a new Public Company Accounting Oversight Board (“Board”). The Board is composed of five members who are appointed by the SEC to serve staggered, five-year terms. The SEC can remove board members only for good cause. In turn, the president can remove the SEC commissioners only for good cause. In Humphrey’s Executor v. United States, 295 U.S. 602 (1935), the Supreme Court held that Congress has the power to create independent agencies headed by officers appointed by the president, but whom the president may remove only for good cause. Should Congress have the power to create an agency such as the Board whose members are protected by a “double-layer” of for-cause removal? Or does such a structure insulate board members from executive accountability and thereby subvert the president’s ability to ensure that the laws are faithfully executed?