In January 2012, President Obama bypassed the Senate and announced three “recess appointments” to the National Labor Relations Board, a majority of the five-person Board. The president had taken similar action in March 2010, when he placed two members on the Board by recess appointment. Since those appointments, the NLRB has repeatedly reversed or watered down decades-old Board decisional law, nearly always ruling “against” employers in doing so, and has taken steps to impose a number of new regulations on employers.