October 23, 2013

In this article, Jenner & Block Partner Reid J. Schar and Associate Ramon Villalpando explore the potential scope of the Financial Institution Reform, Recovery, and Enforcement Act (FIRREA), a recently revived federal statute that was enacted in response to the savings and loan crisis of the 1980s and early 1990s.  The authors consider FIRREA’s potentially expansive reach and its possible use by the federal governmentto levy million-dollar civil penalties in historically private disputes between companies where an alleged fraud “affect[s] a federally insured financial institution.”  They examine recent legal developments regarding FIRREA for the benefit of in-house counsel.