Villafane-Neriz v. Federal Deposit Insurance

                United States Court of Appeals
                    For the First Circuit
                                         

No. 93-1487

                   MIGUEL VILLAFANE-NERIZ,
            INSURANCE COMMISSIONER OF PUERTO RICO,

                    Plaintiff, Appellant,

                              v.

            FEDERAL DEPOSIT INSURANCE CORPORATION,

                     Defendant, Appellee.

                                         

         APPEAL FROM THE UNITED STATES DISTRICT COURT

               FOR THE DISTRICT OF PUERTO RICO

      [Hon. Juan M. Perez-Gimenez, U.S. District Judqe]
                                                      

                                         

                            Before

                     Breyer, Chief Judge,
                                        
              Boudin and Stahl, Circuit Judges.
                                              

                                         

Carlos  J. Morales-Bauza  with  whom Jesus  R.  Rabell-Mendez  and
                                                             
Rossello-Rentas & Rabell-Mendez were on brief for appellant.
                           
J.  Scott  Watson,  Senior  Attorney,  with  whom  Ann  S. DuRoss,
                                                                 
Assistant  General  Counsel,  and  Richard J.  Osterman,  Jr.,  Senior
                                                         
Counsel, were on brief for appellee.

                                        

                        April 4, 1994
                                        

          STAHL,  Circuit  Judge.   In this  appeal plaintiff
                                

seeks  the proceeds of a  certificate of deposit  issued by a

now-failed  bank.    Simultaneously  with  its  purchase, the

certificate  was assigned  to  a third  party, the  Insurance

Commissioner  of the  Commonwealth   of   Puerto   Rico ("the

Commissioner").   The Commissioner  brought suit  against the

FDIC  seeking to establish his  right to the  proceeds of the

certificate, and attempted to introduce  documents evidencing

both  the assignment and  the bank's  acknowledgment thereof.

The district court  applied 12  U.S.C.   1823(e)  to bar  the

assignee's  use of  the assignment  documents.   Finding both

section 1823(e)  and the  D'Oench1 doctrine inapplicable,  we
                                 

reverse.

                              I.
                                

           FACTUAL BACKGROUND AND PRIOR PROCEEDINGS
                                                   

          The facts of this case are  essentially undisputed.

In order to  do business  in the commonwealth,   Puerto  Rico

insurance  companies are  first  required by  law to  deposit

funds with the  Commissioner.   See 26  L.P.R.A.     801-809.
                                   

Moreover,  once these  funds are  deposited, Puerto  Rico law

provides that they  may not  be levied upon  by creditors  or

                    

1.  As  we pointed out in  McCullough v. FDIC,  987 F.2d 870,
                                             
874  (1st Cir.  1993), section  1823(e) is  "somewhat loosely
described as  the codification" of the  D'Oench doctrine, and
                                               
the parties' briefs in this case address both D'Oench and its
                                                     
"statutory partner," id.  at 874  n.6.  Seeing  no reason  to
                        
except   D'Oench  from   our   discussion,  we   address  the
                
application of both doctrines.

                             -2-
                              2

claimants  of the insurance company.  Id.   809 ("No judgment
                                         

creditor  or other claimant of an insurer shall levy upon any

deposit  held pursuant  to  this chapter,  or  upon any  part

thereof.").   On  July  20, 1983,  in  order to  satisfy  the

statutory   deposit   requirement,  Guaranty   Insurance  Co.

("Guaranty")  purchased a  six-month  certificate of  deposit

from the Girod Trust  Company ("Girod" or "the bank")  in the

principal amount of $50,000.  The certificate  of deposit had

a maturity date of January 17, 1984.  On the same day that it

purchased  the  certificate,  Guaranty,  through  one  of its

officers,  executed a separate document entitled a "Fiduciary

Assignment" in which it irrevocably assigned and conveyed its

interest in  the certificate of deposit  to the Commissioner.

Girod was not a party to the Fiduciary Assignment.

          Accompanying  both the  certificate of  deposit and

the Fiduciary Assignment was yet another document executed on

the  same date, July  20, 1983, entitled  "Requisition to the

Bank." This Requisition stated,  inter alia, that Girod would
                                           

not  release  the funds  represented  by  the certificate  of

deposit,  "whether the  principal value  or income  thereof,"

without  the   authorization  of  the  Commissioner.     More

specifically, the Requisition stated, "[W]e [Girod] agree and

promise  to dispose of  the certificate of  deposit  .   .  .

only  with  prior  authorization  from  the  Commissioner  of

Insurance of  Puerto Rico."   The  Requisition was signed  by

                             -3-
                              3

Allwin  Perez "in  his capacity  as manager  of the  San Juan

branch of Girod Trust Company."  His signature was notarized.

Like the Fiduciary Assignment, the Requisition stated,  "This

requisition will be irrevocable."  The certificate of deposit

itself was given to, and remains with, the Commissioner.

          Less  than   three  months  after   purchasing  the

certificate of  deposit from Girod, Guaranty  executed a loan

agreement, unrelated to the certificate  of deposit, pursuant

to  which  it borrowed  $600,000 from  Girod.   The  loan was

evidenced by a  promissory note for  that amount, payable  to

Girod.   The note  was due  on April  26, 1984,  and Guaranty

began  making payments  according  to  the  loan  agreement's

schedule.

          On  January 17,  1984, the  certificate of  deposit

came due.  At the request of Guaranty, it was  "rolled over,"

i.e., extended for a term of  six additional months.  In  the

meantime, Guaranty had fallen behind on payments due to Girod

under the $600,000  loan agreement.   On July  16, 1984,  the

certificate of deposit came  due again.  This  time, however,

the certificate was not  "rolled over."  Rather, on  July 18,

1984,  two  days  after  the  certificate  had  matured,  the

proceeds were credited to Guaranty's  account.  Specifically,

$50,000 from the certificate of  deposit was  credited toward

Guaranty's outstanding  indebtedness under the  $600,000 loan

agreement.

                             -4-
                              4

          On August 16,  1984, Girod  was declared  insolvent

and the  FDIC was appointed receiver.   On December 19, 1984,

Guaranty  also  became  insolvent.    The  Commissioner   was

appointed  Guaranty's  receiver.   On  August  25, 1986,  the

Commissioner filed  a proof of  claim with the  FDIC, seeking

payment  on the  certificate of  deposit.   On May  22, 1991,

having  received no  payment on  the claim,  the Commissioner

filed a complaint against  the FDIC in the Superior  Court of

Puerto  Rico   seeking  to   recover  the  proceeds   of  the

certificate  of  deposit.   The  FDIC removed  the  action to

federal court pursuant to 12 U.S.C.   1819(b).

          The   parties   filed  cross-motions   for  summary

judgment.2 Without ruling on  the motions, the district court

asked the parties to  submit briefs on the application  of 12

U.S.C.   1823(e).3 Upon submission of the briefs,the district

                    

2.  The Commissioner argued, in  essence, that the offset was
improper  and that  he was  entitled to  the proceeds  of the
certificate of  deposit.  The  FDIC argued, inter  alia, that
                                                       
the Commissioner's claim was barred by laches.

3.  Section 1823(e) states:

          No agreement which  tends to diminish  or
          defeat the interest of the [FDIC] in  any
          asset  acquired by it  under this section
          or  section 1821 of this title, either as
          security for a loan  or by purchase or as
          receiver   of   any  insured   depository
          institution, shall be  valid against  the
          Corporation unless such agreement--

          1) is in writing,

                             -5-
                              5

court  held  that section  1823(e) barred  the Commissioner's

reliance    upon  either  the  Fiduciary  Assignment  or  the

Requisition (also referred to hereinafter as "the  assignment

documents").    In  essence,  the  court  reasoned  that  the

assignment documents constituted an "agreement which tends to

diminish or defeat the interest of" the  FDIC in an asset for

purposes of section 1823(e).   The district court went  on to

reason that, because the  assignment documents failed to meet

the requirements  set out in section 1823(e), e.g., they were

approved by neither  the bank's  board of  directors nor  its

loan committee, the Commissioner was barred from relying upon

them.  Therefore, the district court ordered summary judgment

in favor of the FDIC.4

                    

          2)  was    executed    by  the depository
          institution  and  any person  claiming an
          adverse  interest  thereunder,  including
          the  obligor, contemporaneously  with the
          acquisition   of   the   asset   by   the
          depository institution,

          3) was approved by the board of directors
          of the depository institution or its loan
          committee, which approval shall be
          reflected in the minutes of said board or
          committee, and

          4) has been, continuously, from the time
          of its execution, an official record of
          the depository institution.

4.  The  district  court also  summarily  concluded  that the
assignment  of the  certificate of  deposit "was  not validly
consented to by  [Girod],   represented by Mr.  Perez."   The
proceedings below  reflect only that  Girod may  have had  an
internal   procedure  which   required  that   two  qualified
employees,  rather than  a single  employee, sign  agreements

                             -6-
                              6

                             II.
                                

                          DISCUSSION
                                    

          The sole issue before us is whether section 1823(e)

bars   the  Commissioner   from  relying  on   the  Fiduciary

Assignment and  the Requisition  in making his  claim against

the FDIC.  We hold that the Commissioner is not so barred.

A.  Standard of Review
                      

          Where, as here, the essential  facts are undisputed

and the sole issue on appeal involves a pure question of law,

our  review is de novo.  See,  e.g., FDIC v. Keating, 12 F.3d
                                                    

314, 316 (lst Cir. 1993).

B.  Bank Assets and Bank Liabilities
                                    

          We  begin with  crucial,  if  rudimentary,  banking

terminology.  As  one commentator recently noted,  "It may be

helpful  to recall  that  banks and  thrifts have  a somewhat

counterintuitive perspective on  the accounting of  deposits,

which  appear   on  their  balance   sheets  as  liabilities.
                                                            

                    

which bound Girod.   We agree with the Commissioner  that the
bank's   own   internal   procedures   are   not  necessarily
dispositive on the  issue of  whether the bank  was bound  by
Perez's signature.  See, e.g., 10 Am. Jur. 2d Banks 99 (1963)
                                                   
("[W]hen  a bank opens its doors for business with the public
and  places officers in charge,  persons dealing with them in
good  faith and without any  notice of any  want of authority
will be protected where  an act is performed in  the apparent
scope  of the  officer's  authority, whether  the officer  is
actually clothed with such authority or not.").  The FDIC has
offered no argumentation or authority to the contrary, either
below or on appeal.   Thus, we conclude that the record  does
not  support a  conclusion  as  a  matter  of  law  that  the
assignment was invalid.

                             -7-
                              7

Meanwhile, loans from banks appear on their balance sheets as

assets."   David G. Oedell, Private  Interbank Discipline, 16
                                                         

Harv.  J.L. &  Pub.  Pol'y 327,  384  n.206 (1993)  (emphasis

added). In other words, bank deposits, including certificates

of  deposit such as  the one at  issue here, see  12 U.S.C.  
                                                

1811(1)  (defining  a deposit  as,  inter  alia, "the  unpaid
                                               

balance of money or its equivalent received or held by a bank

. . .  which is  evidenced by its  certificate of  deposit"),

represent obligations on the part of a bank to repay funds to

depositors.  As such, they are reflected on a bank's books as

liabilities.   Loans  made to  bank  customers, on  the other

hand, represent obligations on the part of borrowers to repay

sums certain  to the  bank, and  as such are  reflected on  a

bank's books as assets.

          Obviously, the books  of failed banks contain  both

assets and  liabilities.  The FDIC  fulfills vastly different

functions  as  to the  two sides  of  a failed  bank's ledger

sheet.

C.  The Role of the FDIC in Bank Failures and the Purpose of
                                                            
D'Oench and Section 1823(e)
                           

          The  role  of the  FDIC  in bank  failures  is well

established.    Its  "basic  mission is  to  protect  insured

depositors," FDIC  v. La Rambla Shopping Ctr., Inc., 791 F.2d
                                                   

215,  218 (lst Cir. 1986),  which it does  by "undertaking an

obligation  to pay  depositors when  an insured  bank fails."

FDIC v. Nichols, 885 F.2d 633, 636 (9th Cir. 1989).  In other
               

                             -8-
                              8

words, satisfying a failed bank's liabilities, especially its

deposits, is a primary goal of the FDIC.

          A  failed bank's  assets,  on the  other hand,  are

either liquidated or  transferred to a  solvent bank.5   See,
                                                            

e.g., FDIC v. P.L.M. Int'l, Inc., 834 F.2d 248, 254 (lst Cir.
                                

1987).   Needless to say,  not all borrowers  (i.e., obligors

with  regard  to  the   bank's  assets)  happily  meet  their
                                      

obligations toward a failed bank, and many  attempt to assert

claims and defenses against the FDIC aimed at relieving those

obligations.   The doctrines  enunciated in D'Oench,  Duhme &
                                                             

Co.   v.  FDIC,  315  U.S.  447  (1942),  and  its  statutory
              

counterpart, 12 U.S.C.   1823(e),  greatly limit the types of

claims  and defenses  that borrowers  may assert  against the

FDIC.   In essence, such  claims and defenses  are limited to

those that  are based on  documentation in the  failed bank's

records.  Moreover, these  doctrines governing the claims and

defenses of borrowers are designed to enable the FDIC to meet
                     

more  effectively its  obligations to  pay depositors.   See,
                                                            

                    

5.  Admittedly,  the FDIC  often, as  it did  here, transfers
obligations on both sides of a failed bank's ledger sheets to
                   
a  solvent bank.   In   such   situations,  the solvent  bank
"purchases"  certain  of  the  failed  bank's    assets,  and
simultaneously "assumes"  that bank's liabilities,  i.e., its
deposits.    Such  a  transaction  is  known  commonly  as  a
"purchase and assumption" transaction.  See, e.g., Timberland
                                                             
Design Inc. v. First  Serv. Bank for Savs.,  932 F.2d 46,  48
                                          
(lst Cir. 1991); La Rambla, 791 F.2d at 218.  Depositors then
                          
maintain their insured deposits, while borrowers  continue to
meet their obligations, allowing banking business to continue
with some regularity.

                             -9-
                              9

e.g.,  Timberland Design  Inc. v. First Serv. Bank for Savs.,
                                                            

932  F.2d  46, 48  (lst  Cir.  1991)  ("`[T]he D'Oench  Duhme
                                                             

doctrine  .  .  .  favors the  interests  of  depositors  and
                                                        

creditors  of a  failed bank,  who cannot  protect themselves

from secret agreements, over  the interests of borrowers, who
                                                        

can.'") (emphasis supplied) (quoting Bell & Murphy & Assocs.,
                                                             

Inc. v. Interfirst Bank Gateway, N.A., 894 F.2d 750, 754 (5th
                                     

Cir.), cert. denied, 498 U.S. 895 (1990)).
                   

D.   The Assignment Documents:   Agreements Affecting  a Bank
                                                             
Deposit
       

          Turning to the transaction here, it is evident that

at  the time the certificate of deposit was purchased and the

Fiduciary Assignment and the Requisition were  executed, they

were agreements  having an effect  on one of  Girod's insured

deposits,6 rather than one  of its assets.   The significance

of  this distinction is made  clearer if we  examine, step by

step, the banking transactions at issue.

                    

6.  As to the existence  of an insured deposit in  this case,
we cannot say, given  the state of the record  below, whether
or to what  extent we would be  willing to follow  the Eighth
Circuit's  holding in In re Collins Sec. Corp., 998 F.2d 551,
                                              
554-55 (8th Cir. 1993) (holding that the  FDIC  is not liable
in its corporate  capacity because no account  existed at the
time  of   the  bank's   failure  due  to   a  non-fraudulent
pre-failure  bank error).  We merely point out to the parties
that similar  issues may arise on remand, along with possible
jurisdictional  issues. See  La  Rambla, 791  F.2d at  220-21
                                       
(finding  no   jurisdictional   basis  under   12  U.S.C.    
1819(b)(2)(D)  or (E)  for counterclaim  against FDIC  in its
capacity as receiver).

                             -10-
                              10

          It   is  undisputed  that  Guaranty  purchased  and

assigned  the  certificate  of  deposit  on  July  20,  1983.

Suppose that Girod had failed  the following day, i.e., after

the purchase  and assignment  of the certificate  of deposit,

but before Guaranty  borrowed any  funds from Girod.   If  at

that point the Commissioner sought  payment from the FDIC, we

think  it  indisputable  that  neither  D'Oench  nor  section
                                               

1823(e) would be implicated at all.

          Section 1823(e)  would be inapplicable  because, by

its  terms, that  section  applies only  to agreements  which

"tend to diminish  or defeat the interest of the  FDIC in any

asset acquired by  it."   Prior to Guaranty's  taking of  its
                               

$600,000 loan,  Guaranty's certificate of deposit  was merely

an insured deposit, unrelated  to any particular Girod asset.

Given that  the Commissioner's claim would  diminish no Girod

asset,  and  would merely  amount to  a  claim on  an insured

deposit, section 1823(e) would have no application.

          Nor would  the D'Oench doctrine, in  the absence of
                                

section 1823(e), apply in such a situation.  At its broadest,

the D'Oench  doctrine disallows claims and  defenses based on
           

schemes or arrangements "whereby banking authorities would be

misled."   FDIC v. Caporale, 931  F.2d 1, 2 (lst  Cir. 1991).
                           

Prior  to  the  $600,000  loan to  Guaranty,  the  assignment

presented no  such threat.   Bank examiners  would have  been

fully aware  of the  bank's liability  on the certificate  of

                             -11-
                              11

deposit, and the Commissioner's claim merely would present an

issue as  to who was entitled to payment.  Moreover, the FDIC

does not argue  that the loan to Guaranty, in  and of itself,

altered the validity of the assignment.

          In  sum,  prior  to  the bank's  crediting  of  the
                         

proceeds  of the  certificate  of  deposit toward  Guaranty's

outstanding indebtedness, this case  involved an insured bank

deposit,   rather  than  a   bank  asset.     It  is  equally

indisputable  that  prior   to  that  crediting  transaction,

neither section 1823(e) nor D'Oench would have applied to bar
                                   

the  Commissioner's reliance upon the Fiduciary Assignment or

the Requisition in establishing his  right to the proceeds of

the certificate of  deposit.   Rather, the FDIC,  as it  does

with other  deposits, would have  paid the proceeds  from the

certificate  of  deposit   to  the  Commissioner7  upon   his

establishing  his right to those proceeds.  Cf. In re Collins
                                                             

Sec. Corp., 998 F.2d  551, 553 (8th Cir. 1993)  (stating that
          

FSLIC, as  receiver for failed bank,  allowed unsecured claim

by assignee of certificate of deposit  which had been wrongly

paid out to assignor).

                    

7.  Absent the crediting of the certificate of deposit toward
Guaranty's indebtedness,  the  Commissioner would  have  been
entitled to its proceeds either in his capacity as  assignee,
or in his capacity as Guaranty's receiver.  The FDIC does not
object to the  capacity in which the  Commissioner now brings
this appeal,  and we  therefore assume, without  prejudice to
the district court's ability to determine otherwise, that the
Commissioner seeks recovery in his proper capacity.

                             -12-
                              12

E.  Reverse  Alchemy:   Do Girod's  Pre-failure Actions  Turn
                                                             

Gold
    
into Lead
         

          With  breathtaking  legerdemain,  the FDIC  assumes

that,  upon   Girod's  crediting  of  the   proceeds  of  the

certificate  of deposit toward  Guaranty's $600,000 debt, the

Fiduciary Assignment  and  the Requisition  were  transformed

into agreements which  tend to diminish the  interests of the

FDIC in an asset for purposes of section 1823(e).  We decline
                

to adopt such a rule for three related reasons.

          First, assuming that  the Commissioner's version of

facts is correct,   Girod's crediting  of the certificate  of

deposit toward  Guaranty's  $600,000 loan  and the  resulting

"relationship"  between the  certificate  of deposit  and the

loan,  cannot  be   characterized  as  anything   other  than

ineffective.     At  the  time  that   Girod  "credited"  the

certificate   of   deposit   toward  Guaranty's   outstanding

indebtedness,  the certificate  of deposit  had already  been

validly assigned  to the Commissioner.  Moreover,  as   noted

above,  Puerto   Rico  law  specifically  prohibits creditors

of  insurance  companies  from  levying  upon  the  statutory

deposit  at  issue here.   In  other  words, given  the valid

assignment,   as    well   as   the    additional   statutory

protection it  is afforded, the certificate  of deposit could

never  rightfully   become  security  for  Girod's   loan  to

Guaranty. If the  certificate could  never rightfully  secure

                             -13-
                              13

Guaranty's loan in the  first instance, we see  no principled

way  of  now  holding  that it  is  nonetheless  sufficiently

related  to that loan so as to "diminish" the FDIC's interest

in the loan for purposes of section 1823(e).

          Second, if the bank's  actions in this case somehow

"magically"  transformed  agreements  about  a  deposit  into

agreements  which  diminish the  FDIC's  interest  in a  bank

asset, then all agreements about deposits, even those whereby

a deposit is created, could potentially be subject to section

1823(e).   In other  words, any  time  a bank,  prior to  its

failure, improperly  closed a  passbook  savings account  and

credited the proceeds therein toward outstanding indebtedness

from an  entirely unrelated  account, the depositor  would be

without  remedy, inasmuch  as passbook  savings accounts  are

rarely,  if ever, created with the approval of bank boards of

directors  or  bank   loan  committees.    See  12  U.S.C.   
                                              

1823(e)(3).   We have no  doubt that Congress  could not have

intended such a result.

          Third,  neither  the Fiduciary  Assignment  nor the

Requisition  constitutes  an  "agreement"  for   purposes  of

section 1823(e).  Cf.  Bateman v. FDIC, 970 F.2d  924, 927-29
                                      

(lst Cir.  1992) (holding  that bank's consent  to mechanics'

lien was not an "agreement" for purposes of section 1823(e)).

The  bank's  "acceptance"  of  the assignment  here  did  not

involve bargaining, consideration,  an exchange of  promises,

                             -14-
                              14

or  many  other   ordinary  accoutrements   of  a   classical

contractual "agreement."   See Langley v. FDIC, 484  U.S. 86,
                                              

91 (1987) (defining "agreement" as used in section 1823(e) in

terms of  traditional  contract  principles).    Rather,  the

bank's "acceptance"  of the  assignment in this  case appears

very similar  to the mortgagee's "consent"  to the imposition

of  a mechanic's lien in  Bateman.  "Consent"  in Bateman was
                                                         

required  by state law  to give the  mechanic's lien priority

over the mortgagee's lien.  Bateman, 970 F.2d  at 927-29.  We
                                   

held there that the  mortgagee's "consent" did not  amount to

an "agreement" for purposes  of section 1823(e).  Id.   Here,
                                                     

the state  law mechanism  whereby the certificate  of deposit

was  created,  assigned  to  the  Commissioner,  and  further

protected from levying  by creditors is similar  to the state

mechanic's  lien system in Bateman.   Thus, for quite similar
                                  

practical and conceptual reasons, we reach a similar result.

          As a  final argument urging a  contrary result, the

FDIC  relies heavily on language  on the reverse  side of the

certificate of deposit itself, which states that the proceeds

of the certificate may be applied against the named obligee's

outstanding indebtedness.  The rationale behind this argument

appears to be that this language warned the Commissioner that

Girod  had a  right,  upon maturity  of  the certificate,  to

credit  the   certificate  of  deposit   against  outstanding

indebtedness  on  a  bank   asset,  and  that  therefore  the

                             -15-
                              15

Commissioner, though still  an obligee of  the bank,   should
                                      

have sought written board approval of the assignment, much as

a D'Oench-wary obligor would.  Again, we disagree.
         

          First, the  certificate  of  deposit  was,  by  its

terms,  assignable.8   Second,  the  FDIC's  argument  places

depositors  and  their  assignees  essentially  in  the  same

position  as borrowers,  requiring  that  they guard  against

purely  contingent  (and  in  this  case,  contractually  and

statutorily  forbidden) bookkeeping maneuvers  on the part of

the failed bank.   Moreover, in this case, such  an expansive

reading of  the dual  doctrines would penalize   rather  than

reward, a  depositor who, unlike most  other depositors, took

steps  to preserve and memorialize his rights.  We decline to

adopt such a novel and onerous reading of the relevant law.

          We reemphasize  that this case does  not involve an

effort  by a borrower who,  having promised his bank deposits

as  security  for  a  loan, later  attempts  to  destroy that

security  by asserting an oral promise by the bank to release

that security notwithstanding  the prior written  commitment.

Here, the borrower did not promise the certificate of deposit

as  security for its loan  and, indeed, did  not even own the

                    

8.  Language  on  the  reverse  side of  the  certificate  of
deposit stated:
          The  assignment of this  Certificate to a
          third  party will not be considered valid
          until said transaction has  been notified
          to, and accepted by the bank.

                             -16-
                              16

certificate of deposit at the time it borrowed the money from

the bank, for  it had previously assigned the  certificate of

deposit to the Commissioner.   Moreover, the borrower in this

case, namely Guaranty, is  not claiming any rights at  all to

the  funds at  issue.   Rather, the  sole issue before  us is

whether section  1823(e)   applies to bar  the Commissioner's

claims,  and we conclude that it does not.

                             III.
                                 

                          CONCLUSION
                                    

          For  the  foregoing  reasons,  the  order  of   the

district court entering summary judgment in favor of the FDIC

based upon the application of 12 U.S.C.   1823(e) is

          Reversed  and  remanded  for   further  proceedings
                                                             

consistent with this opinion.
                             

                             -17-
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