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Seventh Circuit Upholds FDIC’s Use of In-House Enforcement Proceedings After “Close and Challenging” Constitutional Analysis

calendar_today August 14, 2026 person Scott A. Coleman, Beau Hurtig and Alan S. Kaplinsky domain ballard-spahr

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.

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