Article

Factual Summary: Bank, a wholly-owned subsidiary of Holding Company, issued credit cards and purchased credit card receivables as part of its banking operations. Concerned about Bank's ability to pay for receivables if credit cards were terminated, Bank Regulator required that Holding Company obtain an LC payable to Bank in the event that the credit cards were terminated. Accordingly, Holding Company/Applicant caused an LC to be issued payable to Bank/Beneficiary.

Subsequently, Bank/Beneficiary drew US$14 million under the LC. Citing concerns of future fraud or violation of the terms of the LC, Applicant sought injunction prohibiting Bank Regulator or its assigns from requesting or ordering draws on the LC.

The Court granted Bank Regulator's Motion to Dismiss for Lack of Subject Matter Jurisdiction pursuant to 12 U.S.C. §1818(I)(1)(#18), the Financial Institutions Supervisory Act of 1966 (FISA).


Legal Analysis:

1. Bank Solvency; Bank Regulation; Safety and Soundness; Financial Institutions Supervisory Act of 1966 (FISA): Bank Regulator contended that the court "lack[ed] subject matter jurisdiction to compel [Bank Regulator] to act in a particular manner regarding its enforcement of the Consent order and its supervision of [Bank/Beneficiary]," according to the Financial Institutions Supervisory Act of 1966 (FISA). The act denies U.S. district courts "'jurisdiction to affect by injunction or otherwise the issuance or enforcement of any notice or order under any such section, or to review, modify, suspend, terminate, or set aside any such notice or order.'" The court agreed that it did not have jurisdiction over Bank Regulator or its supervision of Bank/ Beneficiary, and accordingly dismissed the complaint.

[JEB/fkd]

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