The BFS, as enhanced by the FIRREA
(9) and the Crime Control Act of
, broader in scope than the False Claims Act, has wide application since it incorporates a variety of banking law and invokes huge, civil monetary penalties that can be ruinous to institutions.
The [Justice] Department's tortured legal analysis has turned FIRREA
on its head," argued the House panel.
, the Financial Institutions Reform, Recovery and Enforcement Act, allows the Justice Department to sue over fraud affecting a federally insured financial institution.
Thus, the issue of the continuing vitality of the common law doctrine in light of the revision of [section] 1823(e) by FIRREA
was not discussed in any of these opinions.
LaCroix, who is also a partner in the Beachwood, Ohio-based management liability broker OakBridge Insurance Services, said he's not sure FIRREA
automatically applies to credit unions like it does banks.
While not required to do so by FIRREA
, OCC and the Federal Reserve had taken some steps to support minority banks.
For residential tract development, FIRREA
also states that the appraisal must reflect appropriate deductions and discounts for holding costs, marketing costs, and entrepreneurial profit.
In 1992, the FDIC issued an interpretation of FIRREA
arguing that SAIF deposit insurance assessments on thrift deposits by banks, or those in thrifts that converted to state-chartered commercial or savings banks (which account for roughly 38 percent of all thrift deposits), could not be used to pay interest on the FICO bonds.
Member banks are required to provide technical assistance to applicants under Section 721 of FIRREA
It shows the importance of different institutions in the mortgage market in 1968, as the New Deal system was starting to unravel: in 1980, when policymakers were forced to recognize that the S&Ls could no longer function as portfolio lenders in an inflationary world; in 1989, when FIRREA
was passed to address the losses of the S&Ls and the insolvency of the FSLIC; and in 1992, the latest year for which information is available.
The bank decided to make the loan, but FIRREA
required a $3,500 appraisal.