In a closely watched decision with potentially significant implications for federal banking enforcement, the U.S. Court of Appeals for the Seventh Circuit has upheld the Federal Deposit Insurance Corporation’s authority to adjudicate certain enforcement actions through its own administrative process rather than in federal court. In Bonan v.
Seventh Circuit Upholds FDIC’s Use of In-House Enforcement Proceedings After “Close and Challenging” Constitutional Analysis
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August 14, 2026
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Scott A. Coleman, Beau Hurtig and Alan S. Kaplinsky
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