How should the Supreme Court resolve, in its forthcoming Seila Law decision on the permissibility of single-headed independent agencies, the split between en banc decisions in the Fifth Circuit and D.C. Circuit? Although the Court will likely (and I argue, correctly) extend its 2010 Free Enterprise Fund ruling to find the single director of the CFPB an unconstitutional intrusion into the President’s ability to “take Care that the Laws be faithfully executed,” it is of critical importance to the administrative state whether the Justices rule broadly to obviate Humphrey’s Executor or approach the independent agency question more incrementally. I urge the incremental approach in this Article. By developing a formal model of how structural features alone or combination affect presidential power, I demonstrate how the multi-member bipartisan leadership of the traditional independent regulatory agency could be less likely to “go rogue” against the elected executive, in comparison to a solitary agency head protected from removal. Plural commissions and boards can thus be distinguished constitutionally and preserved (along with Humphrey’s Executor) even if the CFPB Director falls in Seila Law. I also explore the implications of the independent regulatory agency’s other structural problem within formalist separation-of-powers jurisprudence, in that it takes on quasi-legislative regulatory functions originally vested with the legislature, in addition to its insulation from presidential control. If it can be shown that these two features help mitigate one another through the creation of a semi-autonomous structure resembling a legislature or “reverse parliament,” they become, if hardly unproblematic, at least less problematic. Taken singly, resolution of the constitutional tensions and anomalies created by either legislative delegation or commission independence would likely be sub-optimal from both a constitutional and administrative viewpoint, even if a committed originalist might prefer a return to a federal government with neither feature as the best of all possible worlds. I conclude the bureaucratic structure of the independent, plural, and bipartisan regulatory commissions – especially if reformed by aligning the statutory terms of chairs with the presidential cycle – may be a constitutional second-best to an unrecoverable Madisonian allocation of authority.