Capitol Bank & Trust Co. v. 604 Columbus Avenue R6ealty Trust

USCA1 Opinion









July 1, 1992 UNITED STATES COURT OF APPEALS
FOR THE FIRST CIRCUIT

____________
No. 91-1976

IN RE: 604 COLUMBUS AVENUE REALTY TRUST,
Debtor,

_________

CAPITOL BANK & TRUST COMPANY,
Appellee,

v.

604 COLUMBUS AVENUE REALTY TRUST,
Appellant.

__________
No. 91-1977

IN RE: 604 COLUMBUS AVENUE REALTY TRUST,
Debtor,

_________

FEDERAL DEPOSIT INSURANCE CORPORATION,
AS RECEIVER/LIQUIDATING AGENT OF
CAPITOL BANK & TRUST COMPANY,
Appellant,

v.

604 COLUMBUS AVENUE REALTY TRUST, ET AL.,
Appellees.

____________


ERRATA SHEET


The opinion of this court issued on June 19, 1992, is

amended as follows:

On page 10, line 11 after block quote - add "and" after the

word "taxes."

On page 43, line 6 after block quote - "Court" should be

lower case.June 19, 1992

















____________________

No. 91-1976



IN RE: 604 COLUMBUS AVENUE REALTY TRUST,



Debtor,



__________



CAPITOL BANK & TRUST COMPANY,



Appellee,



v.



604 COLUMBUS AVENUE REALTY TRUST,



Appellant.



__________



No. 91-1977



IN RE: 604 COLUMBUS AVENUE REALTY TRUST,





















Debtor,



__________



FEDERAL DEPOSIT INSURANCE CORPORATION,

AS RECEIVER/LIQUIDATING AGENT OF

CAPITOL BANK & TRUST COMPANY,



Appellant,



v.



604 COLUMBUS AVENUE REALTY TRUST, ET AL.



Appellees.



____________________



APPEALS FROM THE UNITED STATES DISTRICT COURT



FOR THE DISTRICT OF MASSACHUSETTS



[Hon. A. David Mazzone, U.S. District Judge]
___________________



____________________



















Before



Torruella, Circuit Judge,
_____________

Weis* and Bownes, Senior Circuit Judges,
_____________________



____________________



Robert Owen Resnick with whom John F. Cullen, George J. Nader,
____________________ _______________ _______________

and Cullen & Resnick were on brief for 604 Columbus Avenue.
________________

Michael H. Krimminger with whom Richard J. Osterman, Jr., Ann S.
_____________________ _________________________ _______

Duross, and Richard N. Gottlieb were on brief for Federal Deposit
______ ____________________

Insurance Corporation.



____________________


____________________










































_____________________

*Of the Third Circuit, sitting by designation.



























































BOWNES, Senior Circuit Judge. This is a case involving
____________________

a failed loan transaction that well illustrates Polonius'

advice, "[n]either a borrower, nor a lender be."1 These

appeals require us to determine, inter alia, the
_____ ____

applicability of certain federal defenses available to the

Federal Deposit Insurance Corporation (FDIC) in its capacity

as receiver when it seeks to enforce against a bankrupt

borrower an obligation formerly held by a failed financial

institution.

PROCEDURAL PATH
PROCEDURAL PATH

This case arises from the default by the 604 Columbus

Avenue Realty Trust ("the Trust") on payment of a loan from

the Capitol Bank and Trust Company ("the Bank"). Following

the Trust's default, the Bank commenced mortgage foreclosure

proceedings on the properties securing its loan, among which

were the property owned by the Trust itself and properties of

the Trust's principal beneficiary, Millicent C. Young

("Young").2

To forestall the foreclosures by the Bank, both the

Trust and Young filed for protection under Chapter 11 of the



____________________

1. W. Shakespeare, Hamlet, act I, sc. iii at 75.

2. The Bank also had a mortgage on a property owned by the
Young Family Trust, of which Millicent Young was sole
beneficiary. The Young Family Trust was a named plaintiff in
the adversary proceeding in the bankruptcy and district
courts below. For purposes of convenience, we refer to Young
and the Young Family Trust collectively as "Young."

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Bankruptcy Code in the United States Bankruptcy Court for the

District of Massachusetts. In May 1988, the Trust, with

Young as co-plaintiff, initiated an adversary proceeding

against the Bank, its principal secured creditor. In

September 1990, the bankruptcy court awarded the plaintiffs

approximately $140,000 in damages on claims of fraud and

deceit, conversion, and breach of contract, plus interest and

attorney's fees. The bankruptcy court found that the Bank

improperly applied loan proceeds to payment of "soft costs"

incurred by the Trust financing fees, interest, taxes and

similar expenses. It also found that an officer of the Bank

extracted kickback payments from the loan proceeds in return

for his assistance in securing approval of the loan. Under

its power of equitable subordination pursuant to 11 U.S.C.

510(c), the bankruptcy court subordinated the Bank's secured

claim on the Trust's bankruptcy estate to the claims of the

Trust's other creditors by an amount equal to the damages,

plus interest and attorney's fees. It ordered the transfer

from the Bank to the Trust of a security interest in the

Trust's estate equivalent to the total of the damages,

interest and attorney's fees.

During the pendency of an appeal of this judgment to the

district court, the Bank was declared unsound by

Massachusetts banking officials. The FDIC was appointed





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receiver, and in February 1991 was substituted as defendant-

appellant in the district court.

In August 1991, the district court affirmed in

substantial part the bankruptcy court's rulings on the merits

of the Trust's claims and equitable subordination of part of

the Bank's secured claim. It ruled, however, that the FDIC

was entitled to raise the defenses available to it under the

doctrine of estoppel established in D'Oench, Duhme & Co. v.
________________________

FDIC, 315 U.S. 447 (1942), and 12 U.S.C. 1823(e). Invoking
____

the D'Oench doctrine, the district court vacated that part of
_______

the bankruptcy court's judgment that was premised on the

secret agreement by one of the Trust's principals to provide

kickbacks to a Bank officer.

Both the Trust and the FDIC appeal various aspects of

the judgments of both the bankruptcy and district courts. We

affirm the judgment of the bankruptcy court, as modified by

the district court.

BACKGROUND AND FACTS
BACKGROUND AND FACTS

Before stating the facts, we think it useful to review

the dual role of the FDIC in bank failures. Our recent

decision in Timberland Design, Inc. v. First Service Bank For
_________________________________________________

Savings, 932 F.2d 46, 48 (1st Cir. 1991), provides an
_______

excellent summary of the FDIC's different functions:

As receiver, the FDIC manages the assets of the
failed bank on behalf of the bank's creditors and
shareholders. In its corporate capacity, the FDIC
is responsible for insuring the failed bank's


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deposits. Although there are many options
available to the FDIC when a bank fails, these
options generally fall within two categories of
approaches, either liquidation or purchase and
assumption. The liquidation option is the easiest
method, but carries with it two major
disadvantages. First, the closing of the bank
weakens confidence in the banking system. Second,
there is often substantial delay in returning funds
to depositors.

The preferred option when a bank fails, therefore,
is the purchase and assumption option. Under this
arrangement, the FDIC, in its capacity as receiver,
sells the bank's healthy assets to the purchasing
bank in exchange for the purchasing bank's promise
to pay the failed bank's depositors. In addition,
as receiver, the FDIC sells the "bad" assets to
itself acting in its corporate capacity. With the
money it receives, the FDIC-receiver then pays the
purchasing bank enough money to make up the
difference between what it must pay out to the
failed bank's depositors, and what the purchasing
bank was willing to pay for the good assets that it
purchased. The FDIC acting in its corporate
capacity then tries to collect on the bad assets to
minimize the loss to the insurance fund.
Generally, the purchase and assumption must be
executed in great haste, often overnight.

Id. at 48 (citations omitted).
___

Turning to the case at hand, we first summarize the

extensive findings of fact of the bankruptcy court. See In
___ __

re 604 Columbus Avenue Realty Trust, 119 B.R. 350 (Bankr. D.
____________________________________

Mass. 1990) ("Bankruptcy Court Opinion"). The loan

transaction at issue in these appeals originated in the

efforts of Young and several business associates to purchase

two buildings located at 604-610 Columbus Avenue in Boston,

Massachusetts ("the Columbus Avenue properties"), and a

restaurant operated on the premises known as "Bob the Chef."



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Young was the owner of a contracting and construction

company. Among her business partners was Carl Benjamin

("Benjamin"), who served as her financial adviser.

In October 1985, Young and Benjamin learned of the

availability for purchase of the Columbus Avenue properties.

Young and Benjamin, along with two other partners, agreed to

enter into a business relationship through which they would

purchase the Columbus Avenue properties, renovate and resell

the properties as condominiums, resell the restaurant, and

share the profits from the condominium sales and sale of the

restaurant. In November 1985, Young and Benjamin offered the

owner of the Columbus Avenue properties $1.2 million for the

buildings and the restaurant.

Young's attorney, Steven Kunian ("Kunian"), suggested

that she and her partners seek financing for the purchase and

renovation of the Columbus Avenue properties from the Bank.

Kunian had represented the Bank from time to time on loan

transactions. In December 1985, Benjamin negotiated the

terms of a loan from the Bank on behalf of Young and the

other partners. The Bank was represented in these

negotiations by a loan officer, Arthur Gauthier, and a member

of the Bank's Board of Directors, Sidney Weiner ("Weiner").

Weiner also served on the Bank's Executive Committee, which

was responsible for the approval of loans. Although not a

salaried employee of the Bank, Weiner was paid director's and



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consultant's fees, and was regarded by Gauthier and other

bank employees as having primary authority for negotiation of

the loan to Young and her partners.

Loans larger than $25,000 required the approval of the

Bank's Executive Committee. Gauthier presented the proposal

for the loan for the Columbus Avenue properties three times

before the Executive Committee approved it on January 15,

1986. Final approval by the Executive Committee was achieved

when Young agreed to pledge her residence as additional

collateral for the loan. Weiner was one of the Executive

Committee members who voted to approve the loan.

Some time before the Executive Committee voted to

approve the loan, Weiner told Benjamin that the loan would

only be approved on the condition that Benjamin agree to pay

Weiner personally for his assistance in securing the Bank's

approval of the loan. In exchange for this kickback, Weiner

helped the loan proposal reach the Executive Committee, voted

to approve the loan, and influenced other Committee members

to vote in favor of the loan. There was no evidence that

other members of the Executive Committee were aware of

Weiner's kickback arrangement with Benjamin when they voted

to approve the loan. The bankruptcy court found that $26,300

was paid to Weiner.

Attorney Kunian represented both the Bank and the

borrowers at the closing on the loan on February 27, 1986.



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Kunian suggested that Young and her associates hold the

Columbus Avenue properties through a realty trust. At the

closing the 604 Columbus Avenue Realty Trust was created,

with Young as its trustee. Young was given 62.5% of the

beneficial interest in the trust, while each of her three

partners, including Benjamin, was made a 12.5% beneficiary.

To secure the loan from the Bank, Young executed on behalf of

the Trust a "Commercial Real Estate Promissory Note," a "Loan

and Security Agreement" ("L&SA"), an "Addendum to Loan &

Security Agreement ("L&SA Addendum"), and a "Construction

Loan Agreement" (referred to collectively as the "First Loan

Agreement"). The Bank, in turn, agreed to lend the Trust

$1,500,000.

The Bank used a standard-form L&SA, which contained the

following provisions:

SECTION 6. BANK'S RIGHT TO SET-OFF

6.01 The Borrower agrees that any deposits or
other sums at any time credited by or due from the
Bank to the Borrower, or any obligor or guarantor
of any liabilities of the Borrower in possession of
the Bank, may at all times be held and treated as
collateral for any liabilities of the Borrower or
any such obligor or guarantor to the Bank. The
Bank may apply or set-off such deposits or other
sums against said liabilities at any time.

. . . .

SECTION 8. EXPENSES:

8.01 The Borrower shall pay or reimburse the Bank
on demand for all out-of-pocket expenses of every
nature which the Bank may incur in connection with
this Agreement and the preparation thereof, the


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making of any loan provided for therein, or the
collection of the Borrower's indebtedness under
this Agreement . . . . [T]he Bank, if it chooses,
may debit such expenses to the Borrower's Loan
Account or charge any of the Borrower's funds on
deposit with the Bank.

The parties also executed an Addendum to this L&SA,

which established the following schedule for the Bank's

advancement of the proceeds of the loan to the Trust:

$1,200,000 at the closing to pay for the Trust's acquisition

of the Columbus Avenue properties and the restaurant; a

further $200,000 for construction-related expenditures at the

Columbus Avenue properties, but only upon itemized

requisitions approved by the Trust, its architect, and the

bank; and $100,000 for the "soft costs" incurred with respect

to the loan. "Soft costs" covered the various non-

construction costs of the renovation effort, and included

closing fees, interest, taxes, and insurance. To secure its

promissory note, the Trust gave the Bank, inter alia, a
_____ ____

mortgage on the Columbus Avenue properties and a conditional

assignment of rents from the properties in favor of the bank.

Young, in her individual capacity, also gave the Bank

mortgages on her residence and two other properties owned or

held on her behalf.

At the closing, the Bank disbursed approximately

$1,250,000, of which nearly $1,200,000 was paid to the owners

of the Columbus Avenue properties, and the remaining amount

was paid to the Bank itself for the costs of the loan. The


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Bank also created a checking account through which it was to

disburse the remaining amounts of the loan. A signature card

was created for the account bearing the names of Young,

Benjamin, and another partner of the Trust. Those listed on

the signature card had access to loan proceeds upon their

disbursement by the Bank. Young was apparently not aware

that Benjamin's signature was on the card.

The bankruptcy court found that the Trust's ability to

repay the loan on the Columbus Avenue properties hinged on

several assumptions that Young and her partners understood or

reasonably should have understood at the closing. One of

these assumptions was that $100,000 for soft costs

anticipated in First Loan Agreement would not cover those

costs completely and would have to be supplemented by funds

of Young and her partners. Another assumption was that the

Trust could generate the funds necessary to complete the

condominium project by selling the restaurant.

The Bank advanced the remainder of the proceeds of the

loan approximately $250,000 within forty-seven days of

the closing, in three large payment. Weiner personally

directed Gauthier to pay these advances into the Trust's

account, but did so without the approval of Young and in

violation of the procedures specified in the First Loan

agreement. The bankruptcy court found that the Bank paid

itself a total of $102,305.54 out of loan proceeds to cover



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soft costs, thereby exceeding by $2,305.54 the amount of soft

costs contemplated in the First Loan Agreement. The sum of

$26,300 was withdrawn by Benjamin from the loan account

without Young's knowledge or authorization, which was then

used to make kickback payments to Weiner. Sometime

thereafter, Young learned of Benjamin's conduct, and

attempted unsuccessfully to expel him from the Trust and to

get him to give up his beneficial interest in it.

When the six-month term of the First Loan Agreement

expired in August 1986, the Trust could not repay the loan.

It therefore negotiated a second six-month loan to refinance

the first (the "Second Loan Agreement"). On September 12,

1986, the Trust signed a promissory note to the Bank for

$1,750,000, which was secured by the same mortgages and

guarantees as the First Loan Agreement. Young, on behalf of

the Trust, executed a new L&SA that contained provisions

identical to those in the L&SA accompanying the previous

loan. In addition, the Addendum to the L&SA in the Second

Loan Agreement provided, inter alia, the following scheme for
_____ ____

disbursement:

The Bank shall advance the loan proceeds
approximately as follows: a. $1,500,000.00 at
closing for acquisition of real estate and personal
property[;] b. $190,000.00 for construction costs
. . . [;] c. $60,000.00 for soft costs incurred
with respect to the loan.

At the closing of the Second Loan Agreement, $1,580,151.11 in

loan proceeds were disbursed to pay the $1,524,516.11 balance


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remaining on the First Loan agreement and $55,635 in

origination and attorney's fees for the new loan.

Four months later, in January 1987, the Trust sold the

property at 610 Columbus Avenue for $692,400 and paid the

Bank this amount in order to reduce the outstanding principal

balance of the Second Loan Agreement. In March 1987,

however, when the Second Loan Agreement came due, the Trust

was unable to repay it. The Bank therefore entered into an

"Agreement to Extend Mortgage and Note" with the Trust, in

exchange for an extension fee.

The bankruptcy court found that during the term of the

Second Loan Agreement and its extension, the Bank withdrew

from the loan proceeds $169,406.12 for various soft costs,

including closing fees, interest, charges for the loan

extension, taxes, and attorney's fees. This amount exceeded

the "approximately" $60,000 in soft costs originally provided

for in the second L&SA Addendum by $109,406.12.

The Second Loan Agreement, as extended, came due on June

10, 1987. The Trust was unable to make payment. In

September 1987, the Bank began foreclosure of the various

mortgages it held as security for the loan. The bankruptcy

court found that the reasons for the Trust's default

included, inter alia: the inability of the Trust to sell the
_____ ____

restaurant, and the attendant loss of cash needed to finance

the condominium renovations originally planned; the further



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deprivation of cash needed for the project as a result of the

kickback payments; and the Bank's overapplication of

$109,406.12 in proceeds from the second loan to payment of

soft costs. The bankruptcy court also concluded that it was

the Trust's failure to sell the restaurant, rather than the

Bank's overapplication of loan proceeds for soft costs and

the kickback payments, that was by far the single most

important reason for the failure of the project.

DECISIONS OF THE BANKRUPTCY AND DISTRICT COURTS
DECISIONS OF THE BANKRUPTCY AND DISTRICT COURTS

In bankruptcy court, the Trust and Young alleged that

the Bank entered into and administered the loans for the

improper purpose of extracting a kickback from loan proceeds.

They also alleged that the Bank improperly applied proceeds

from the two loans to the payment of soft costs. The

plaintiffs alleged fraud and deceit, conversion, and breach

of contract by the Bank. They also argued that the Bank's

inequitable conduct warranted the subordination of the Bank's

secured claim in the Trust's bankruptcy estate to those of

all of the Trust's other creditors. In addition, the Trust

and Young requested an order invalidating entirely the Bank's

mortgages on their properties.

The bankruptcy court conducted a seven-day trial. It

awarded the Trust $138,011.66 in damages. Of this amount,

$26,300 was assessed as damages for the kickback payments

made to Weiner by Benjamin. The kickback damages were based



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on claims of conversion, breach of contract and fraud under

Massachusetts law. The remaining $111,711.66 in damages

represented the total amount of soft costs that the

bankruptcy court found to have been improperly removed from

the loan proceeds by the Bank in violation of the limits set

by the two loan agreements i.e., $2,305.54 on the First

Loan Agreement and $109,406.12 on the Second Loan Agreement.

This award was premised on claims of conversion and breach of

contract. The bankruptcy court also ordered that the

$138,011.66 damages award be supplemented by an award of

reasonable attorney's fees, which it found were warranted as

an element of the conversion damages under Massachusetts law,

and also of post-judgment interest at the contract rate

specified in the loan agreements.

Invoking its powers of equitable subordination pursuant

to 11 U.S.C. 510(c), the court entered an order

subordinating the Bank's secured claim to the claims of

priority and general unsecured claimants in an amount equal

to the full amount of the damages, interest and attorney's

fees. It further directed that the Bank transfer to the

Trust's estate a portion of its security interest in an

amount equal to the total damages. The bankruptcy court

refused, however, to issue an order entirely invalidating the

mortgages held by the Bank.





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While the Bank's appeal of the bankruptcy court's

judgment was pending, the FDIC was appointed receiver and

liquidating agent of the Bank, and substituted for the Bank

as defendant-appellant. The FDIC continued the Bank's appeal

of the bankruptcy court's judgment as to the conversion,

breach of contract, and fraud claims, as well as its

challenge to the bankruptcy court's equitable subordination

of its secured interest in an amount equal to the total

damages. In addition, the FDIC raised two special federal

defenses as to each aspect of the damages claims. The FDIC

argued that the D'Oench doctrine or its statutory
_______

counterpart, 12 U.S.C. 1823(e) precluded the bankruptcy

court's award of damages on the kickback arrangement, insofar

as this claim was based on a secret agreement between Weiner

and Benjamin. The FDIC also argued that the special holder

in due course status accorded it under federal common law

entirely barred the Trust's claims for damages and equitable

subordination against it in its receivership capacity.

The Trust and Young, on the other hand, challenged the

applicability of the federal defenses urged by the FDIC, as

well as the FDIC's right to raise these defenses for the

first time on appeal. They also contested the bankruptcy

court's refusal to grant them an order invalidating entirely

the Bank's mortgages on their properties.





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In August 1991, the district court affirmed the

bankruptcy court's rulings on the merits of the plaintiffs'

conversion and breach of contract claims with respect to the

Bank's improper application of loan proceeds for payment of

soft costs. Although the district court found that the FDIC

was entitled to raise its federal defenses for the first time

on appeal, it rejected the FDIC's argument that the federal

common law holder in due course doctrine barred the Trust's

claims against it in its capacity as the Bank's receiver.

The district court also affirmed the equitable subordination

of the FDIC's secured claim on the Trust's estate in an

amount equal to the damages on the soft costs claims, i.e.,

$111,711.66, plus post-judgment interest. It reversed,

however, the bankruptcy court's inclusion of attorney's fees

as part of the overall amount of the FDIC's claim subject to

equitable subordination.

The district court vacated the bankruptcy court's award

of $26,300 of damages based on the kickback arrangement

between Benjamin and Weiner. Finding that the FDIC was

entitled to raise the D'Oench doctrine for the first time on
_______

appeal, the court held that the kickback arrangement was a

secret agreement squarely within the coverage of the

doctrine. It therefore reduced the equitable subordination

against the FDIC by an amount equal to the kickback damages.

Because it found that the fraud claims based on the kickback



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arrangement could not stand against the FDIC, the court

rejected the Trust and Young's arguments that it declare the

loan agreements and the mortgages on the plaintiffs'

properties void as illegal contracts in contravention of

public policy.











































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THE ISSUES ON APPEAL AND STANDARD OF REVIEW
THE ISSUES ON APPEAL AND STANDARD OF REVIEW

In their appeals to this court,3 both the FDIC and the

Trust press substantially the same arguments made in their

appeals of the bankruptcy court's judgment to the district

court.4 The FDIC argues that because it was the receiver of

an insolvent bank, federal common law barred the plaintiffs'

claims of conversion, breach of contract, and fraud, as well

as the equitable subordination of the FDIC's secured interest

in the Trust's estate. The FDIC maintains that any damages

against it in its receivership capacity based on the soft

costs claims were barred by the federal common law holder in

due course doctrine, and that the equitable subordination

against it in an amount equal to those damages is contrary to

federal common law. The FDIC also attacks the rulings of the

bankruptcy court, affirmed by the district court, that the

Bank misappropriated soft costs monies, as well as the

equitable subordination of its secured claim to reflect the

damages caused by the Bank's misappropriation. It further

challenges the district court's affirmance of an award of





____________________

3. Following the district court's judgment, both the FDIC
and the Trust docketed separate appeals with this court. The
FDIC's appeal is No. 91-1977; the Trust's is No. 91-1976.

4. Young is not a party to the Trust's appeal. Neither the
Trust nor Young has challenged the district court's
affirmance of the bankruptcy court's refusal to void the
mortgages on their properties.

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post-judgment interest on the $111,711.66 in damages on the

soft costs claims.

The Trust, on the other hand, argues that the district

court erred by applying the D'Oench doctrine for the first
_______

time on appeal. The Trust insists that the D'Oench doctrine
_______

does not bar its recovery on its claims relating to the

kickback scheme. The Trust also maintains that the district

court erred when it held that the bankruptcy court

incorrectly included attorney's fees as part of the overall

amount of the FDIC's security interest subject to equitable

subordination in favor of the Trust and other creditors.

In an appeal from a district court's review of a

bankruptcy court's decision, we "independently review[] the

bankruptcy court's decision, applying the clearly erroneous

standard to findings of fact and de novo review to

conclusions of law." In re G.S.F. Corp., 938 F.2d 1467, 1474
__________________

(1st Cir. 1991). See also In re Navigation Technology Corp.,
________ _________________________________

880 F.2d 1491, 1493 (1st Cir. 1989) (bankruptcy court's

determinations of law subject to de novo review); Briden v.
_________

Foley, 776 F.2d 379, 381 (1st Cir. 1985) (clearly erroneous
_____

standard of review applied to bankruptcy court's factual

findings).









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DISCUSSION
DISCUSSION

I. DISTRICT COURT REVIEW OF THE FDIC'S FEDERAL DEFENSES FOR
THE FIRST TIME ON APPEAL

Before considering the Trust's state law claims

underlying its damages award against the Bank, we first

address the FDIC's arguments that two special defenses

established under federal law the federal common law holder

in due course and D'Oench doctrines barred all of the
_______

plaintiffs' claims and resulting equitable subordination

against it as the Bank's receiver. In order to address the

merits of these federal defenses, we must, as a threshold

matter, determine whether the FDIC was entitled to raise them

for the first time in the district court in its appeal of the

bankruptcy court's judgment.

The district court based its decision to permit the FDIC

to assert its federal defenses exclusively on the Financial

Institutions Reform, Recovery and Enforcement Act of 1989

("FIRREA"), Pub. L. No. 101-73, 103 Stat. 183 (1989)

(codified at 12 U.S.C. 1811-1833e), which provides in

pertinent part:

(13) Additional rights and duties

(A) Prior final adjudication

The Corporation shall abide by any final
unappealable judgment of any court of
competent jurisdiction which was rendered
before the appointment of the Corporation as
conservator or receiver.




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(B) Rights and Remedies of conservator or
receiver

In the event of any appealable judgment,
the Corporation as conservator or receiver
shall

(i) have all the rights and remedies
available to the insured depository
institution (before the appointment of
such conservator or receiver) and the
Corporation in its corporate capacity,
including removal to Federal court and
all appellate rights; and

(ii) not be required to post any bond in
order to pursue such remedies.

12 U.S.C.A. 1821(d)(13)(A)-(B). The district court found

that the bankruptcy court's judgment in favor of the Trust

was "appealable" within the meaning of 1821(d)(13)(B). It

reasoned that the federal defenses against the Trust's claim

asserted by the FDIC in its receivership capacity were among

"the rights and remedies available to . . . the [FDIC] in its

corporate capacity." The district court concluded that the

"rights and remedies" granted the FDIC in its receivership

capacity included the right to raise its federal defenses for

the first time on appeal. The district court based this

analysis on its reading of FIRREA's text and legislative

history.5


____________________

5. As evidence of Congress' special solicitude for the
preservation of the rights of the FDIC in its receivership
capacity, the district court emphasized FIRREA's provision of
an automatic stay in any litigation to which the FDIC becomes
a party. See 12 U.S.C. 1821(d)(12). It also highlighted
___
language in FIRREA's legislative history explaining the need
for the automatic stay: "The appointment of a conservator or

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The district court acknowledged that this interpretation

of 1821(d)(13)(B) conflicted with that of the Fifth and

Eleventh Circuits, both of which have rejected this

interpretation of FIRREA. In Olney Savings & Loan
________________________

Association v. Trinity Banc Savings Association, 885 F.2d 266
_______________________________________________

(5th Cir. 1989), the Fifth Circuit ruled that

1821(d)(13)(B) did not in any way modify the substantive

rights of the FSLIC in its receivership capacity, but merely

assured the FSLIC standing to pursue all appeals previously

available to it only in its corporate capacity. Accordingly,

it held that FIRREA did not entitle the FSLIC to raise the

D'Oench doctrine for the first time on appeal. Id. at 275.
_______ ___

In Baumann v. Savers Federal Savings & Loan Assoc., 934 F.2d
_______________________________________________

1506 (11th Cir. 1991), cert. denied, ___ U.S. ___, 1992 U.S.
____________

LEXIS 2709, 60 U.S.L.W. 3780 (1992), the Eleventh Circuit

followed Olney, and rejected the argument of the Resolution
_____

Trust Corporation ("RTC") that 1821(d)(13)(B) entitled it

to raise the D'Oench doctrine. Id. at 1511. In Baumann, the
_______ ___ _______

Eleventh Circuit expressly rejected the interpretation of


____________________

receiver can often change the character of the litigation;
the stay gives the FDIC a chance to analyze pending matters
and decide how best to proceed." H.R. Rep. No. 54(I), 101st
Cong., 1st Sess. 331 (1989), reprinted in 1989 U.S.C.C.A.N.
_____________
86, 127. The district court further relied on two decisions
of the Texas Court of Appeals holding that 1821(d)(13)(B)
permits the FDIC to raise the D'Oench doctrine for the first
_______
time on appeal. See FDIC/Manager Fund v. Larsen, 793 S.W.2d
___ ___________________________
37 (Tex. Ct. App.), writ granted, 34 Tex. Sup. Ct. J. 91
____________
(1990); FSLIC v. T.F. Stone-Liberty Land Assocs., 787 S.W.2d
_________________________________________
475 (Tex. Ct. App. 1990).

-26-















1821(d)(13)(B) advanced by the district court in this case.

The Baumann court concluded that to read the statute
_______

otherwise would be to grant a federal receiver new

substantive rights, because neither FIRREA nor previously

existing statutes granted the RTC in its corporate capacity

the power to raise arguments for the first time on appeal.

Id.
___

We think that the Olney and Baumann courts'
_____ _______

interpretation of 1821(d)(13)(B) is the proper one, and

hold that the district court erred when it read FIRREA as

allowing the FDIC in its receivership capacity to raise its

federal defenses for the first time on appeal. We agree with

the distinction drawn by Baumann: "the right at issue in this
_______

case is not the right of the [federal receiver] to argue [a

federal defense], which is unquestioned, but rather the right

of the [federal receiver] to raise an argument for the first

time on appeal." Id. at 1512. Section 1821(d)(13)(B) merely
___

accords the FDIC in its receivership capacity standing to

raise the same defenses available to the FDIC in its

corporate capacity. It does not establish that the FDIC as

receiver is entitled to raise its federal defenses for the

first time on appeal.

Although FIRREA does not grant the FDIC as receiver the

right to raise its special federal defenses to the Trust's

claims for the first time on appeal, we must also consider



-27-















whether there is any alternative basis on which the district

court could have permitted the FDIC to raise its federal

defenses. The FDIC argues that even if 1821(d)(13)(B) does

not grant it the right to raise its federal defenses, the

district court nonetheless had the discretion, in its

capacity as an appellate court, to address these defenses for

the first time on appeal.

The FDIC relies principally on Baumann for this
_______

argument. There, the Eleventh Circuit held that its

discretion as an appellate court permitted it to address the

federal receiver's D'Oench doctrine argument for the first
_______

time on appeal. Id. at 1513. The court stressed the fact
___

that the RTC had not had the opportunity to present its

argument in the trial court because it had not become a party

to the suit until after the entry of final judgment. Id. In
___

order to prevent the RTC from being "penalized for not

raising a defense it had no opportunity to present," the

Baumann court concluded that it would be appropriate to
_______

exercise its discretion to exempt the RTC in its receivership

capacity from its general rule precluding argument of issues

for the first time of appeal. Id. The Fifth Circuit has
___

also adopted Baumann's approach in similar circumstances in
_______

which the federal conservator or receiver becomes a party to

an appeal after the final judgment of the trial court. See
___

Resolution Trust Corp. v. McCrory, 951 F.2d 68, 71 (5th Cir.
__________________________________



-28-















1992) (citing Baumann and Union Fed. Bank v. Minyard, 919
_______ ____________________________

F.2d 335, 336 (5th Cir. 1990)).

It is the general rule in this circuit that arguments

not raised in the trial court cannot be raised for the first

time on appeal. See, e.g., Boston Celtics Ltd. Partnership
___ ____ ________________________________

v. Shaw, 908 F.2d 1041, 1045 (1st Cir. 1990); Brown v.
________ _________

Trustees of Boston Univ., 891 F.2d 337, 359 (1st Cir. 1989),
_________________________

cert. denied, ___ U.S. ___, 110 S. Ct. 3217 (1990). Like
____________

other circuit courts of appeals, however, we have recognized

that an appellate court has the discretion, in exceptional

circumstances, to reach issues not raised below. See United
___ ______

States v. La Guardia, 902 F.2d 1010, 1013 (1st Cir. 1990).
_____________________

In United States v. Krynicki, 689 F.2d 289, 291-92 (1st Cir.
_________________________

1982), we outlined the criteria for determining the

appropriate exercise of our discretion to hear new issues.

These criteria include, inter alia, whether the new issue is
_____ ____

purely legal, such that the record pertinent to the issue can

be developed no further; whether the party's claim appears

meritorious; whether reaching the issue would promote

judicial economy because the same issue is likely to be

presented in other cases; and whether declining to reach the

argument would result in a miscarriage of justice. Id.
___

The circumstances of this case were sufficiently

exceptional to have permitted the district court to consider

for the first time on appeal the merits of the federal



-29-















defenses raised by the FDIC in its receivership capacity.

The question of whether various federal defenses barred the

Trust's claims was purely legal and required no further

development of the factual record; the FDIC's federal

defenses were colorable, judged by the district court's

acceptance of the FDIC's D'Oench argument to bar damages on
_______

the kickback claims; judicial economy would have been

promoted by a ruling on the merits of the applicability of

the FDIC's federal defenses, given the increasing volume of

litigation involving federal receivers and/or conservators in

this circuit; and finally, it would have been unfair to

prevent the FDIC from raising its federal defenses when it

had no such opportunity to assert them before the bankruptcy

court. As Baumann and McCrory make clear, it is not uncommon
_______ _______

for a federal receiver or conservator to become a party to a

litigation after the final judgment of the trial court. To

prevent the FDIC from raising its federal defenses in such

circumstances would vitiate much of the purpose of allowing

these defenses in the first place.

II. THE D'OENCH DOCTRINE AS A BAR TO THE TRUST'S RECOVERY ON
_______
THE KICKBACK CLAIMS

We next review the question of whether the D'Oench
_______

doctrine, or its statutory counterpart, 12 U.S.C.








-30-















1823(e),6 bars the Trust's claims based on the kickback

scheme and any equitable subordination against the FDIC as

receiver.

In D'Oench, the Supreme Court held that in a suit
_______

brought by the FDIC to collect on a borrower's promissory

note, in which the FDIC was the successor in interest to the

original lender, the borrower was not entitled to rely on

agreements outside the documents contained in the lender

bank's records to defeat the FDIC's claim. 315 U.S. at 460-

61. The Supreme Court announced a federal common law

doctrine of equitable estoppel preventing the borrower from

using a "secret agreement" with the original lender as a



____________________

6. As amended by FIRREA, 1823(e) provides:
No agreement which tends to diminish or defeat the
interest of the Corporation in any asset acquired
by it under this section . . . , 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,
(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 committee, and
(4) has been, continuously, from the time of
its execution, an official record of the
depository institution.
We treat 1823(e) as the statutory codification of the
D'Oench doctrine. See Capizzi v. FDIC, 937 F.2d 8, 9 (1st
_______ ___ ________________
Cir. 1991); FDIC v. P.L.M. Int'l, Inc., 834 F.2d 248, 253
____________________________
(1st Cir. 1987).

-31-















defense to the FDIC's demand for payment. Id. D'Oench did
___ _______

not require that the borrower have the intent to defraud:

"The test is whether the note was designed to deceive

creditors or the public authority, or would tend to have that

effect. It would be sufficient in this type of case that the

maker lent himself to a scheme or arrangement whereby the

banking authority . . . was or was likely to be misled." Id.
___

at 460.

The contours of the D'Oench doctrine, which have
_______

expanded since the Court's original decision, are well-

established in this circuit. See Timberland Design, 932 F.2d
___ _________________

at 48-49; FDIC v. Caporale, 931 F.2d 1, 2 (1st Cir. 1991);
________________

FDIC v. P.L.M. Int'l, Inc., 834 F.2d 248, 252-53 (1st Cir.
___________________________

1987). Although the D'Oench decision involved the FDIC in
_______

its corporate capacity, "courts have consistently applied the

doctrine to those situations where the FDIC was acting in its

capacity as receiver." Timberland Design, 932 F.2d at 49
_________________

(citing cases). We have also adopted the position of the

great majority of the circuits that D'Oench "operates to bar
_______

affirmative claims as well as defenses which are premised

upon secret agreements." Id. In addition, D'Oench applies
___ _______

to claims involving secret agreements that sound either in

tort or in contract. Id. at 50 (citing Langley v. FDIC, 484
___ _______________

U.S. 86 (1987)). And finally, the fact that the FDIC may

have actual knowledge of the secret agreement is irrelevant:



-32-















"The proper focus under D'Oench is whether the agreement, at
_______

the time it was entered into, would tend to mislead the

public authority." Id.
___

Applying the principles enunciated in Timberland, the
__________

district court held that D'Oench estopped the Trust from
_______

raising against the FDIC its affirmative claims based on the

kickback scheme. It found that the record established that

the Trust, through its agent Benjamin, had "lent itself" to a

kickback scheme with the Bank. The district court concluded

that the unwritten agreement and subsequent kickback payments

between Weiner and Benjamin were a "secret agreement"

squarely within the coverage of D'Oench.
_______

The Trust contends that D'Oench should not have been
_______

applied for the district court for several reasons. It

argues that its tort claims of conversion and fraud stand on

a factual basis independent of the kickback arrangement, and

that these claims therefore cannot be barred by D'Oench. For
_______

similar reasons the Trust argues that its breach of contract

claim must also be upheld because the removal of $26,300 from

the loan proceeds was a breach of the express terms of the

written loan agreement, and not a breach of the unwritten

kickback arrangement. In the alternative, the Trust invokes

certain recognized exceptions to the D'Oench doctrine: it
_______

claims (1) that it is a non-negligent victim of "fraud in the

factum," and (2), that the district court should have found



-33-















that it was innocent of any intentional or negligent

deception because Benjamin was not acting as the Trust's

agent at the time he removed loan proceeds for the kickback

payments.

A. The Scope of the Kickback Agreement
___________________________________

We find little merit in the Trust's first argument,

which counsel appears in part to have abandoned during oral

argument.7 As we understand it, the Trust's contention is

that because its fraud and conversion claims are "not

premised upon" the kickback arrangement, D'Oench cannot
_______

apply. According to the Trust, "the kickback arrangement

merely explains why Capitol Bank chose to misappropriate the

[Trust's] assets, whereas the misappropriations themselves

are the basis of the [Trust's claims]." Brief for Appellant

604 Columbus Avenue Realty Trust at 27. The problem with the

Trust's position is that the bankruptcy court's findings in

respect to these claims, as well as its equitable



____________________

7. When pressed to explain why the D'Oench doctrine did not
_______
apply to all the Trust's claims relating to the secret
agreement between Benjamin and Weiner, counsel for the Trust
placed exclusive reliance on the argument that the Trust was
an innocent party that had not knowingly made itself a party
to the kickback arrangement with Weiner. Counsel stated that
"if the Trust had in fact entered into an oral agreement,
then you would be right; D'Oench would clearly apply. But
_______
the bankruptcy court did not find that fact. The bankruptcy
court found that Benjamin was liable to the Trust for the
twenty-six thousand dollars as well as the Bank. . . . [I]t
seems to me to be a very, very broad application of D'Oench
_______
where a borrower has not lent themselves [sic] in any fashion
to this agreement."

-34-















subordination of $26,300 in lieu of damages, were in fact

explicitly premised on the kickback arrangement. See
___

Bankruptcy Court Opinion, 119 B.R. at 371 (conversion); id.
___

at 374 (fraud); id. at 377 (equitable subordination). Nor
___

does the Trust elaborate as to how other facts, independent

of those relating to the kickback arrangement, provide an

alternative basis for the bankruptcy court's findings in its

favor.8 The Trust's tort claims fall squarely under

D'Oench: "D'Oench bars . . . affirmative claims . . . as long
_______ _______

as those claims arise out of an alleged secret arrangement."
___________________________________________

Timberland, 932 F.2d at 50 (emphasis added).
__________

The Trust next argues that D'Oench does not bar its
_______

breach of contract claim against the Bank for the $26,300

misappropriated from the Trust's account because this breach

was a violation of the written terms of the loan agreement.

It relies on Howell v. Continental Credit Corp., 655 F.2d 743
__________________________________

(7th Cir. 1981), which held that the FDIC cannot invoke

D'Oench "where the document the FDIC seeks to enforce is one
_______

. . . which facially manifests bilateral obligations and

serves as the basis of the [promisor's] defense." Id. at 746
___

(emphasis omitted). Seizing on the language of Howell, the
______


____________________

8. The Trust's attempts to distinguish Weiner's conduct from
the tortious conduct of the Bank are completely without
merit. The Trust prevailed on its tort claims against the
Bank in bankruptcy court on a respondeat superior theory, and
cannot now evade the precepts of D'Oench by intimating that
_______
these tort claims against the Bank had nothing to do with the
kickback arrangement masterminded by Weiner.

-35-















Trust advances much the same argument with respect to the

breach of contract claim as asserted in its challenge to

D'Oench's application to its tort claims, i.e., that the
_______

"bilateral obligations" of the loan agreement, and not the

secret kickback agreement, are the basis for its breach of

contract claim. Once again, the Trust's argument ignores the

opinion of the bankruptcy court, which expressly stated that

the $26,300 judgment for the Trust on the breach of contract

claim was founded on the kickback arrangement. See
___

Bankruptcy Court Opinion, 119 B.R. at 375.

The Trust's reliance on Howell is also misplaced. The
______

Trust's breach of contract claim required proof of the

existence of a secret kickback arrangement. Howell, on the
______

other hand, involved the FDIC's attempted enforcement of a

lease that expressly imposed bilateral obligations on both

the lessor and lessee. See Howell, 655 F.2d at 747. The
___ ______

Seventh Circuit ruled that the FDIC, as successor to the

lessor, could not assert D'Oench to bar the lessee's contract
_______

defenses. Id. In Howell, the lessee's contract defenses
___ ______

were not premised on any secret agreement, but were based on

the failure of the original lessor to fulfill the express

conditions of the lease. Id. The limited exception to the
___









-36-















D'Oench doctrine crafted by Howell does not apply to the
_______ ______

Trust's breach of contract claim.9

B. Fraud In The Factum
___________________

The Trust further claims that two other recognized

exceptions to the D'Oench doctrine apply to this case. The
_______

first exception is fraud in the factum. The Supreme Court's

decision in Langley v. FDIC, 484 U.S. 86 (1987), while
_________________

addressed to the issue of the FDIC's right to invoke

D'Oench's statutory counterpart, 12 U.S.C. 1823(e), is also
_______

applicable to analysis of fraud in the factum as a bar to the

application of D'Oench. In Langley, the Court distinguished
_______ _______

between the real defense of fraud in the factum, which

renders a loan agreement entirely void and takes the

agreement out of 1823(e), and a defense of fraud in the

inducement, which renders the loan agreement voidable but

does not preclude the FDIC's assertion of 1823(e).

Langley, 484 U.S. at 93-94. After reviewing the claim by the
_______

note makers that their participation in a land transaction

had been procured by misrepresentations as to the size and

character of the property involved, the Court concluded that



____________________

9. Since Howell, the Seventh Circuit has cautioned note
______
makers from the over-hasty invocation against the FDIC of the
exception to D'Oench contemplated by that decision: "Lesson
_______
Number One in the study of law is that general language in an
opinion must not be ripped from its context to make a rule
far broader than the factual circumstances which called forth
the language." FDIC v. O'Neil, 809 F.2d 350, 354 (7th Cir.
_______________
1987).

-37-















the note makers' argument was a claim of fraud in the

inducement. Accordingly, the Court found that the FDIC could

properly invoke 1823(e) to bar the assertion by the note

makers of their fraud defense. Id. at 94.
___

We think that the Langley Court's distinction for
_______

purposes of 1823(e) between fraud in the inducement and

fraud in the factum applies with equal force in the context

of D'Oench. We have characterized fraud in the factum as a
_______

real defense that may be asserted when the original lender

fraudulently procures the borrower's signature to an

instrument without that borrower's knowledge of its true

nature or contents. See FDIC v. Caporale, 931 F.2d 1, 2 n.1
___ _________________

(1st Cir. 1991) (noting that in the case of fraud in the

factum, "the instruments would be void rather than voidable,

leaving no title capable of transfer to the FDIC."). See
___

also E. Allan Farnsworth, Contracts 4.10 (1982) (describing
____ _________

fraud in the factum as arising in the rare situation in which

the defrauded party "neither knows nor has reason to know of

the character of the proposed agreement . . . .").

The Trust analogizes its situation to that of the

defendant in FDIC v. Turner, 869 F.2d 270 (6th Cir. 1989).
______________

There, the defendant signed a blank guaranty form to which

the name of the debtor and the amount of the guaranty were

later added. In addition, the name of the lending bank on

the original guaranty was subsequently obliterated with



-38-















correction fluid and substituted with that of another bank.

Id. at 272. When the FDIC sued to enforce this altered
___

version of the loan guaranty, the defendant raised the

defense of fraud in the factum. The Sixth Circuit agreed

that the defendant was defrauded as to the guaranty's

essential terms, and held that the FDIC was therefore

precluded from interposing D'Oench to bar the defense. Id.
_______ ___

at 275-76.

Review of these cases convinces us that the Trust's

claim was one of fraud in the inducement, and not of fraud in

the factum. The bankruptcy court found that the Bank, acting

under Weiner's supervision, falsely represented to the Trust

that the consideration for the first loan was limited to the

consideration itemized in the original agreement.10 The

Bank's misrepresentation did not go to the very character of

the proposed loan agreement, but only to its underlying

terms. Unlike the note maker in Turner, the Trust cannot
______

claim that when it executed the promissory note to the Bank,

it was "unaware of the nature of the documents [it] signed."

Caporale, 931 F.2d at 2, n.1. The Bank, through Weiner,
________


____________________

10. The bankruptcy court also found that the damages against
the Bank for both the Trust's tort and contract claims were
limited to the $26,300 in additional "consideration"
extracted from the proceeds of the First Loan Agreement. It
declined to declare the First Loan Agreement unenforceable
because of the illegal consideration, reasoning that to do so
would "penaliz[e] the Bank in the full amount of the loan, an
amount . . . grossly disproportionate to the amount
converted."

-39-















induced the Trust to execute the loan agreement by

misrepresenting the consideration involved. There was,

however, no fraud in the factum precluding application of

D'Oench because there is no evidence to suggest that the
_______

Trust did not fully understand the basic nature of the

obligation it assumed by entering the loan agreement. The

Bank's extraction of additional $26,300 in consideration from

the Trust did not fundamentally alter the nature of the

instruments themselves.

C. Innocence As A Defense to D'Oench
_________________________________

The second exception to D'Oench claimed by the Trust is
_______

that it was completely innocent of any intentional or

negligent deception. The Trust contends that it could not

have "lent [itself] to a scheme or arrangement" which misled

the FDIC because Benjamin negotiated and transferred the

kickback payments to Weiner without the knowledge of the

other beneficiaries of the Trust. The Trust maintains that

the district court improperly concluded that the record

established that the Trust involved itself in the kickback

scheme. Emphasizing that the bankruptcy court found that

both Benjamin and the Bank were liable on the conversion
____

count, the Trust claims that Benjamin could not have been

acting as its agent or for its benefit when he removed

$26,300 in loan proceeds from the Trust's accounts to make

kickback payments.



-40-















As authority for its claim of innocence as an exception

to D'Oench, the Trust cites a footnote to Vernon v.
_______ __________

Resolution Trust Corp., 907 F.2d 1101, 1106 n.4 (11th Cir.
_______________________

1990), which in turn relies on an earlier decision of the

Ninth Circuit, FDIC v. Meo, 505 F.2d 790 (9th Cir. 1974).
____________

Yet in Baumann, the Eleventh Circuit expressly rejected
_______

Vernon's suggestion of the continued viability of a "complete
______

innocence" exception: "it is clear that this exception is no

longer tenable because lack of bad faith, recklessness, or

even negligence is not a defense in D'Oench cases." 934 F.2d
_______

at 1516. See also FSLIC v. Gordy, 928 F.2d 1558, 1567 n.14
___ ____ ______________

(11th Cir. 1991) (observing that innocence doctrine of Meo,
___

in light of Supreme Court decision in Langley, "is based on
_______

an outdated understanding" of D'Oench). Baumann emphasized
_______ _______

that such an exception would be contrary to the broad purpose

of D'Oench to prevent a private party from enforcing against
_______

the federal authority "any obligation not specifically

memorialized in a written document such that the agency would

be aware of the obligation when conducting an examination of

the institution's records." Baumann, 934 F.2d at 1515.
_______

In Timberland, this court also stressed the basic
__________

purpose of D'Oench to protect a federal receiver even "where
_______

the only element of fault on the part of the borrower was his

or her failure to reduce the agreement to writing." 932 F.2d

at 49 (citation omitted). We agree with the Baumann court
_______



-41-















that the borrower's state of mind is irrelevant, because the

"proper focus under D'Oench is whether the agreement, at the
_______

time it was entered into, would tend to mislead the public

authority."

Id. at 50. Our earlier cases have never recognized the
___

"complete innocence" exception to D'Oench alluded to by the
_______

Trust, and we reject the invitation to adopt it now as the

law of this circuit.

Our conclusion that there is no "complete innocence"

exception to D'Oench is not entirely dispositive of the
_______

Trust's argument. As we understand it, the "innocence"

professed by the Trust is not the kind of paradigmatic

"complete innocence" formerly recognized as an exception to

D'Oench i.e., a borrower entering into an unrecorded side
_______

agreement innocent of any intentional or negligent deception.

Rather, the Trust's claim of "innocence" is really an

argument that the actions of Benjamin should not be

attributed to the Trust and that the Trust did not actually

lend itself to the kickback arrangement.

The factual record belies the assertion that Benjamin

did not act on behalf of the Trust. The bankruptcy court

found that it was Benjamin alone who negotiated the terms of

the First Loan Agreement on behalf of Young and her

associates. It was Benjamin who at the same time agreed to

the kickback arrangement that secured Weiner's assistance in



-42-















obtaining approval of the loan by the Executive Committee.

At the closing of the First Loan Agreement at which time

the Trust was formally created a signature card was

executed authorizing Benjamin to withdraw funds from the

Trust's loan proceeds account. The bankruptcy court further

found that Benjamin was also given authority to access the

Trust's funds in other accounts at the Bank, including one

for the restaurant and another for rental income from the

Columbus Avenue properties.

It seems clear that Benjamin acted with the ostensible

authority of the Trust and its principals throughout the

negotiation and execution of the First Loan Agreement. The

Trust, therefore, cannot disclaim all of Benjamin's actions

with respect to the kickback agreement. Indeed, the Trust is

willing to concede that "one could argue that Benjamin was

acting as an agent of the [Trust] when he entered into the

kickback scheme with Weiner." Brief for Appellant 604

Columbus Avenue Realty Trust at 32. In these circumstances,

the Trust "lent [itself] to a scheme or arrangement whereby

the banking authority . . . was or was likely to be misled."

D'Oench, 315 U.S. at 460.11
_______


____________________

11. Our ruling is consistent with the decision in FDIC v.
________
Kasal, 913 F.2d 487 (8th Cir. 1990), cert. denied, ___ U.S.
_____ _____ ______
___, 111 S. Ct. 1072 (1991). In its reply brief, the Trust
draws on language from a dissenting opinion in Kasal for the
_____
general proposition that "it is a perversion of justice to
hold the borrowers responsible for funds misappropriated by a
bank officer." Id. at 496 (Heaney, J., dissenting). In
___

-43-















Because we find that the district court correctly

applied the D'Oench doctrine to bar the Trust's claims and
_______

equitable subordination against the Bank based on the

kickback agreement, we do not reach the FDIC's arguments

under 1823(e).

III. THE FEDERAL HOLDER IN DUE COURSE DOCTRINE AS A BAR TO
THE TRUST'S CLAIMS AND EQUITABLE SUBORDINATION AGAINST THE
FDIC IN ITS RECEIVERSHIP CAPACITY

We turn next to the FDIC's principal argument on appeal:

that the district court erred when it held that the federal

common law holder in due course doctrine did not bar the

Trust's claims against the FDIC in its receivership capacity

and the equitable subordination of the FDIC's secured

interest in the Trust's bankruptcy estate. The FDIC

addresses this argument to the bankruptcy court's judgment

against the Bank for $111,711.66 on the Trust's conversion

and breach of contract claims for misapplication of loan

proceeds for payment of interest, taxes and other soft

costs.12 The FDIC has conceded in this case that D'Oench
_______

does not bar the Trust's claims based on breach of the soft


____________________

Kasal, the borrower was totally unaware of a misappropriation
_____
from his accounts by a bank officer. In this case, Benjamin,
a representative of the Trust, both negotiated and carried
out the misappropriations from the Trust's account.

12. The FDIC also argues that the federal holder in due
course doctrine bars the Trust's fraud claim arising from the
kickback agreement. Because we have already held that the
Trust's claims based on the kickback agreement were barred by
the D'Oench doctrine, we need not address this aspect of the
_______
FDIC's holder in due course argument.

-44-















costs provisions of the two loan agreements. Instead, the

FDIC insists that policy concerns similar to those underlying

the D'Oench doctrine militate in favor of expanding the
_______

federal holder in due course doctrine to the FDIC in its

receivership capacity when, as here, there has been no

purchase and assumption transaction by the FDIC in its

corporate capacity.

A. Origins of the Federal Holder in Due Course Doctrine
____________________________________________________

In order to evaluate the strength of the policy concerns

that the FDIC asserts as the basis for extending the federal

holder in due course doctrine to the FDIC in the

circumstances of this case, we first examine this doctrine as

it has emerged in cases involving purchase and assumption

transactions by the FDIC in its corporate capacity.

The germinative opinion in the development of the

federal holder in due course doctrine was Gunter v.
__________

Hutcheson, 674 F.2d 862 (11th Cir.), cert. denied, 459 U.S.
_________ ____________

826 (1982). In Gunter, the FDIC in its corporate capacity
______

acquired a promissory note after a purchase and assumption

transaction involving a failed Tennessee bank. The note

makers brought suit for rescission of the note held by the

FDIC on the basis of, inter alia, fraudulent
_____ ____

misrepresentation by the directors of the failed bank. Id.
___

at 866. The FDIC counterclaimed for payment of the note in

the district court, asserting that 1823(e) barred the note



-45-















makers' claims, and arguing in the alternative that federal

common law gave it a defense against claims of fraud of which

it lacked knowledge. Id. at 866-67.
___

Although the Gunter court rejected the application of
______

1823(e) to bar the note maker's fraud claims,13 it accepted

the FDIC's argument that a federal common law rule of non-

liability against these claims was necessary in order for the

FDIC to accomplish its statutory objectives. In reaching

this conclusion, the Gunter court applied the Supreme Court's
______

test for determining whether the implementation of a federal

program would be frustrated without the adoption of a uniform

federal rule. See United States v. Kimbell Foods, Inc., 440
___ ____________________________________

U.S. 715 (1979). Applying Kimbell Foods, the Gunter court
______________ ______

stressed the FDIC's duty to promote "the stability of and

confidence in the nation's banking system," id. at 870, and
___

the preferred status of the purchase and assumption

transaction as a means of accomplishing this duty because "it

avoids the specter of closed banks and the interruption of

daily banking services." Id.
___






____________________

13. The Gunter court found it necessary to reach the merits
______
of the FDIC's federal common law argument because it found
that the note maker's fraud defenses were not precluded by
1823(e). Gunter, 674 F.2d at 867. This analysis of
______
1823(e) as not barring a claim of fraud in the inducement was
subsequently disapproved by the Supreme Court in Langley.
_______
See Langley, 484 U.S. at 93-94.
___ _______

-46-















The court noted that speed was of the essence in a

purchase and assumption transaction because of the need to

preserve the going concern value of the bank:

[T]he FDIC must have some method to evaluate its
potential liability in a purchase and assumption
versus its potential liability from a liquidation.
Because of the time constraints involved, the only
method of evaluating potential loss open to the
FDIC is relying on the books and records of the
failed bank to estimate what assets would be
returned by a purchasing bank and to estimate which
of those assets ultimately would be collectible.

Id. After considering the impact of the federal rule on
___

settled commercial expectations ordinarily governed by state

law, the court concluded that protection of the FDIC from

unknown fraud claims "far outweighed" any potential damage to

these expectations. Id. at 872.
___

The court therefore announced a federal common law

holder in due course rule applicable to the FDIC in its

corporate capacity:

[A]s a matter of federal common law, the FDIC has a
complete defense to state and common law fraud
claims on a note acquired by the FDIC in the
execution of a purchase and assumption transaction,
for value, in good faith, and without actual
knowledge of the fraud at the time the FDIC entered
into the purchase and assumption agreement.

Id. at 873. Gunter thus expanded federal common law to bar
___ ______

fraud claims by the note makers that would not otherwise have

been barred by the D'Oench doctrine or 1823(e). See id. at
_______ ___ ___

872 & n.14 (noting that D'Oench doctrine and 1823(e) embody
_______

a "more limited" policy of protecting the FDIC).



-47-















This court has adopted the rule of Gunter. See Southern
______ ___ ________

Indus. Realty, Inc. v. Noe, 814 F.2d 1 (1st Cir. 1987) (per
__________________________

curiam). See also FDIC v. Bracero & Rivera, Inc., 895 F.2d
_________ _______________________________

824, 828-29 (1st Cir. 1990) (dicta acknowledging holder in

due course doctrine's availability to the FDIC in its

corporate capacity). Other circuit courts have expanded the

federal common law holder in due course doctrine to bar all

personal defenses against the FDIC, and have looked to state

law principles in order to distinguish between real and

personal defenses. See Campbell Leasing Inc. v. FDIC, 901
___ ______________________________

F.2d 1244, 1249 (5th Cir. 1990); FDIC v. Wood, 758 F.2d 156,
____________

161 (6th Cir.) (the FDIC "takes the note free of all defenses

that would not prevail against a holder in due course."),

cert. denied, 474 U.S. 944 (1985). See also FDIC v. Bank of
____________ ________ _______________

Boulder, 911 F.2d 1466, 1474-75 (10th Cir. 1990) (en banc)
_______

(adopting federal rule of transferability of letters of

credit protecting FDIC in its corporate capacity during

purchase and assumption), cert. denied, ___ U.S. ___, 111 S.
____________

Ct. 1103 (1991). In all of these cases, the underlying

rationale for a federal holder in due course rule has been

consistent with that articulated by Gunter: to promote
______

purchase and assumption transactions. See Wood, 758 F.2d at
___ ____

160-61 (federal holder in due course rule necessary because

"the essence of a purchase and assumption transaction is

speed"); Campbell Leasing, 901 F.2d at 1248-1249 (same
_________________



-48-















analysis); Bank of Boulder, 911 F.2d at 1474-75 (uniform rule
_______________

of transferability necessary because of time constraints of

purchase and assumption).

B. Application Of The Federal Holder in Due Course
___________________________________________________
Doctrine To The FDIC As Receiver
________________________________

The FDIC argues that the federal holder in due course

rule should be available to it in its capacity as the Bank's

receiver. The FDIC insists that in order for it to decide

whether a purchase and assumption or a liquidation is the

least costly approach to disposing of the assets of a failed

bank, it must be able to make that decision based on absolute

reliance on the bank's records, unimpeded by personal

defenses. The FDIC also asserts that if the federal holder

in due course doctrine is limited exclusively to purchase and

assumption transactions, it will be unable to employ a

variety of newly-developed "hybrid" transactions for the

resolution of bank failures that include elements drawn from

both a liquidation and a purchase and assumption.

Accordingly, the FDIC urges that we hold that the federal

holder in due course doctrine applies to the FDIC in its

receivership capacity, regardless of whether a purchase and

assumption transaction is consummated.

To support its argument, the FDIC relies on several

cases in which the FDIC in its receivership capacity was

allowed to invoke the federal holder in due course doctrine

to bar the makers of promissory notes from asserting their


-49-















personal defenses. But these cases involved notes acquired

by the FDIC as receiver after a purchase and assumption
_____

transaction.14 For example, in Campbell Leasing, the FDIC
________________

was appointed receiver of a failed Texas bank and arranged

for a purchase and assumption transaction with a federally-

established bridge bank, NCNB. 901 F.2d at 1247. During the

purchase and assumption, NCNB acquired a promissory note that

had previously been the subject of a lawsuit by the note

maker against the failed bank. As receiver of the failed

bank, the FDIC, along with NCNB, moved for summary judgment

on the note maker's claims and on a counterclaim for

enforcement of the note, arguing that the D'Oench and federal
_______

holder in due course doctrines barred all the note maker's


____________________

14. The cases cited by the FDIC either involved the
application of the federal holder in due course doctrine to
assets acquired by the FDIC as receiver following a purchase
and assumption transaction, or were not directly decided
under the holder in due course rule. See FDIC v. McCullough,
___ __________________
911 F.2d 593 (11th Cir. 1990), cert. denied, ___ U.S. ___,
____________
111 S. Ct. 2235 (1991); In re CTS Truss, Inc. v. FDIC, 868
_______________________________
F.2d 146 (5th Cir. 1989); Firstsouth, F.A. v. Aqua Constr.
__________________________________
Inc., 858 F.2d 441 (8th Cir. 1988). In McCullough, the court
____ __________
observed that both the FDIC and FSLIC as receiver are
"clothed under federal common law with the same defenses that
would be accorded a holder in due course under state law."
911 F.2d at 603. Yet in McCullough, the note on which the
__________
federal receiver was seeking to recover had earlier been
acquired by the failed savings institution in a purchase and
assumption transaction. Id. at 596. CTS Truss involved the
___ _________
enforcement by the FDIC as receiver of an asset acquired by
it in its corporate capacity, 868 F.2d at 147, and was
decided under 1823(e) rather than the federal holder in due
course doctrine. Id. at 150. As for Firstsouth, the federal
___ __________
common law rule at issue was the D'Oench doctrine, and not
_______
the more expansive holder in due course doctrine recognized
by Gunter. Firstsouth, 858 F.2d at 443.
______ __________

-50-















claims and affirmative defenses. Id. The district court
___

granted summary judgment for the FDIC and NCNB, and the Fifth

Circuit affirmed the judgment on appeal. The court observed

that it could find

no logical reason to limit federal holder in due
course protection to the FDIC in its corporate
capacity, to the exclusion of its receivership
function. In its corporate capacity, the FDIC is
obligated to protect the depositors of a failed
bank, while the FDIC as receiver must also protect
the bank's creditors and shareholders. In both
cases, the holder in due course doctrine enables
the FDIC to efficiently fulfill its role, thus
minimizing the harm to depositors, creditors, and
shareholders. . . . We conclude that the FDIC
enjoys holder in due course status as a matter of
federal common law whether it is acting in its
corporate or receivership capacity.

Id. at 1249 (citations omitted).
___

The FDIC argues that because the protections of the

federal holder in due course doctrine have been available to

it in its receivership capacity in cases like Campbell
________

Leasing, the logical next step is to apply the doctrine to
_______

the FDIC in its receivership capacity regardless of whether a

purchase and assumption transaction has occurred. According

to the FDIC, this extension of the federal holder in due

course rule is necessary to enable it to decide properly

whether a liquidation or purchase and assumption is the least

costly means of dealing with the failed bank.

In its briefs in this appeal, however, the FDIC has

neglected to mention the one decision that has directly

addressed this argument. In FDIC v. Laguarta, 939 F.2d 1231
________________


-51-















(5th Cir. 1991), the FDIC argued that it was entitled to

invoke the federal holder in due course doctrine to bar any

defenses against enforcement of a promissory note acquired by

it directly in its capacity as receiver. Id. at 1233-35.
___

After observing that the FDIC's federal holder in due course

argument had been raised in a "belated supplemental brief,"

the Fifth Circuit dismissed it peremptorily in a footnote:

Here the FDIC sues only in its capacity as receiver
for the institution which made the loan and is
payee in the note sued on, and the FDIC does not
assert, nor does the record establish, that the
loan or note has ever been transferred or was ever
part of a purchase and assumption transaction. To
the extent that it precludes defenses beyond those
precluded by D'Oench, Duhme, the federal holder in
______________
due course doctrine is inapplicable to such a
situation. Gunter . . . . See Campbell Leasing .
______ ___ ________________
. . . Indeed, a major policy goal underlying the
federal common-law holder in due course doctrine is
to facilitate purchase and assumption transactions
of failed financial institutions in lieu of
liquidations. Campbell Leasing; Gunter.
________________ ______

Id. at 1239 n.19 (citations partly omitted).
___

We likewise reject the FDIC's attempt to expand the

federal holder in due course doctrine far beyond its original

purpose of promoting purchase and assumption transactions

that preserve the going concern value of the bank. None of

the policy considerations that originally prompted the

adoption of a federal holder in due course rule are present

when, as in this case, the FDIC as receiver is seeking only

to enforce an obligation in a liquidation. A liquidation

does not further the federal policy of "bringing to



-52-















depositors sound, effective, and uninterrupted operation of

the [nation's] banking system with resulting safety and

liquidity of bank deposits." Campbell, 901 F.2d at 1248
________

(quoting S. Rep. No. 1269, 81st Cong., 2d Sess., reprinted in
____________

1950 U.S.C.C.A.N. 3765, 3765-66). Likewise, there is no need

for speedy evaluation of the assets of a failed institution,

and therefore little justification for adoption of a broad

federal rule that would displace settled commercial

expectations controlled by state law. Cf. Gunter, 674 F.2d
___ ______

at 872 (applying the Kimbell Foods test for adoption of
______________

federal common law rule). Furthermore, the FDIC does not

rely as heavily on the books and records of the failed bank

to estimate its total loss in a liquidation as it must in a

purchase and assumption.15


____________________

15. This distinction between the cost estimate of a
liquidation versus that in a purchase and assumption
transaction was noted in Gunter:
______
The maximum liability of the FDIC in a liquidation
is fixed by the $100,000-per-depositor insurance
limitation. In a purchase and assumption
transaction, however, the FDIC agrees to repurchase
any unacceptable assets from the purchasing bank
and cannot rely on the statutory limitation of its
liability. Hence to make the [cost test currently
codified at 18 U.S.C. 1823(c)(4)(A)], the FDIC
must have some method of estimating its potential
liability under a purchase and assumption to
compare it to the maximum liability in a
liquidation.
Gunter, 674 F.2d at 870 n.10. This analysis belies the
______
FDIC's assertion that if the federal holder in due course
doctrine were limited solely to assets sold through a
purchase and assumption, the federal receiver could not
reliably estimate the cost of a liquidation as compared to
that of a purchase and assumption.

-53-















However desirable it may be for the FDIC in its

receivership capacity to be able to bar counterclaims or

affirmative defenses by the maker of a promissory note not

already eliminated by D'Oench and 1823(e), such a broad
_______

principle of federal common law cannot find its justification

in the federal holder in due course doctrine currently

applied by the courts. The district court's well-reasoned

analysis of the FDIC's federal holder in due course argument

aptly summarizes some of its deficiencies:

The holder in due course doctrine normally allows
innocent purchasers of negotiable instruments to
rely on such instruments when they are acquired for
value. The FDIC is granted this status so it can
quickly scan a bank's balance sheet to negotiate
its sale. Thus, the FDIC is not held up to an
obligation to scrutinize the assets of a failed
bank before it agrees to execute a purchase and
assumption. . . .

The exigencies of a purchase and assumption
transaction also differentiate the holder in due
course doctrine from D'Oench. D'Oench is concerned
_______ _______
with the integrity of a bank's records the FDIC
can only be charged for claims apparent from a
search of the bank's files. The holder in due
course doctrine, on the other hand, relieves the
FDIC even from claims apparent on the face of the
Bank's records. . . . The reach of the federal
holder in due course doctrine being much wider than
even the extraordinary remedy of D'Oench, the
_______
circumstances in which it is applied should be
correspondingly limited.

The FDIC nonetheless insists that the unavailability of

the federal holder in due course rule in the absence of a

purchase and assumption would "immeasurably delay and

complicate the resolution of receiverships" and create



-54-















"delays and difficulties [that] could greatly impair the

FDIC's ability to complete its statutory mission." In the

same breath, however, the FDIC complains that the existing

federal rule is problematic because it "substantively alters

the receiver's evaluation of the alternative transactions in

favor" of purchase and assumptions. The FDIC cannot have it

both ways. The federal holder in due course doctrine was

fashioned precisely for the purpose of expediting the

purchase and assumption transaction. See Gunter, 674 F.2d at
___ ______

869-71. It was never intended as a panacea intended to

relieve the FDIC of all the "difficulties" arising from state

law defenses and counterclaims during the liquidation of

assets. We decline to address the FDIC's argument that a

decision not to extend the federal holder in due course rule

will impair its ability to conduct certain new "hybrid"

transactions i.e., transactions that involve elements of

both a liquidation and a purchase and assumption because

this case does not involve such a "hybrid."

We therefore hold that the FDIC was not entitled to

invoke the federal common law holder in due course doctrine

to bar the Trust's claims of breach of contract and

conversion as to the soft costs damages.16



____________________

16. Because the FDIC is not entitled to holder in due course
status under the federal common law rule, we need not decide
whether the Trust's soft costs claims would be barred by
Massachusetts holder in due course law.

-55-















IV. FEDERAL COMMON LAW AS A BAR TO EQUITABLE SUBORDINATION
OF THE FDIC'S SECURED CLAIM AGAINST THE TRUST

The FDIC next argues that to allow equitable

subordination of part of its secured claim would be contrary

to federal common law. The FDIC asserts that the

availability of the equitable subordination remedy against it

would frustrate federal policies intended to assist it in

fulfilling its statutory duty to recover the maximum amount

from bankrupt borrowers during the liquidation of assets of

failed banks. The FDIC also insists that to allow equitable

subordination against it would be inappropriate where the

misconduct leading to the equitable subordination was that of

the Bank and its officers, and not of the innocent federal

receiver.

Section 510(c) of the Bankruptcy Code specifically

authorizes a bankruptcy court to apply "principles of

equitable subordination."17 The judicially-developed case

law of equitable subordination is of long standing. See 3 L.
___

King, Collier on Bankruptcy 510.01 (15th ed. 1992)
_______________________


____________________

17. 11 U.S.C. 510(c) provides:
Notwithstanding subsections (a) and (b) of this section,
after notice and a hearing, the court may
(1) under principles of equitable
subordination, subordinate for purposes of
distribution all or part of an allowed claim
to all or part of another allowed claim or all
or part of an allowed interest to all or part
of another allowed interest; or
(2) order that any lien securing such a
subordinated claim be transferred to the
estate.

-56-















("Collier"). The doctrine permits a bankruptcy court to

rearrange the priorities of creditors' interests, and to

place all or part of the wrongdoer's claim in an inferior

status. The generally-recognized test for equitable

subordination, adopted by this court, is set forth in In re
_____

Mobile Steel Co., 563 F.2d 692, 703 (5th Cir. 1977):
________________

(i) The claimant must have engaged in some type of
inequitable conduct.

(ii) The misconduct must have resulted in injury
to the creditors of the bankrupt or conferred an
unfair advantage on the claimant.

(iii) Equitable subordination of the claim must
not be inconsistent with the provisions of the
Bankruptcy Act.

Id. at 699-700 (citations omitted). See also In re Giorgio,
___ ___ ____ _____________

862 F.2d 933, 938-39 (1st Cir. 1988) (applying Mobile Steel
_____________

test); 3 Collier at 510.05[2]. Before reaching the issue

of whether this test was properly applied by the bankruptcy

court, we first determine whether equitable subordination

against a federal receiver should be prohibited as a matter

of federal common law.

Only one decision in the federal courts of appeals has

directly addressed the issue of equitable subordination

against the FDIC. See In re CTS Truss, Inc., 868 F.2d 146
___ ______________________

(1989), withdraw'g, 859 F.2d 357 (5th Cir. 1988). In CTS
__________ ___

Truss, the FDIC in its corporate capacity filed a proof of
_____

claim in bankruptcy court on certain notes and security

documents made by the debtor. The debtor objected to the


-57-















proof of claim, arguing that the FDIC's claim should be

equitably subordinated to the claims of all the other

creditors because the failed bank had engaged in wrongful

conduct against the debtor prior to the FDIC's intervention

as receiver. Id. at 147. The bankruptcy and district courts
___

held that the FDIC's claims could not be subordinated because

the "FDIC was a transferee innocent of any misconduct against

CTS." Id.
___

The Fifth Circuit affirmed the bankruptcy court's

decision, but on different grounds, holding that equitable

subordination against the FDIC would have been improper for

two distinct reasons. First, the court found that "[e]ven if

the Bank's actions could be imputed to the FDIC, we do not

believe that the unusual remedy of equitable subordination is

appropriate to the facts alleged by the [debtor]." Id. at
___

148. Applying the Mobile Steel test, the court held that the
____________

debtor had failed to allege facts that demonstrated that the

bank's conduct towards it would have justified the equitable

subordination of a claim on the debtor's assets subsequently

acquired by the FDIC. Id. at 148-49. The court disregarded
___

the issue of the FDIC's "innocence" in assuming the assets of

the failed bank, focussing instead on whether the failed

bank's actions fit "within any of the classic patterns of







-58-















conduct that have led the courts to fashion the extraordinary

remedy of equitable subordination." Id. at 148.18
___

The other ground for the Fifth Circuit's holding in CTS
___

Truss was the availability to the FDIC of 1823(e) and,
_____

implicitly, the D'Oench doctrine to bar the debtor's
_______

claims. Id. at 149-50 & n.8. The court thought it "likely"
___

that the debtor had deliberately decided against raising its

defenses to its indebtedness premised on the bank's conduct

because it realized that the FDIC would be shielded from

these claims. Id. at 149. It found that 1823(e)
___

"squarely" covered the debtor's claims against the Bank, and

that the debtor would therefore have been unable to raise

these claims against the FDIC. Id. at 150. The court
___

concluded that "[e]ven if principles of equitable

subordination otherwise permitted the imputation of wrongful

conduct to a transferee such as the FDIC, we would be

constrained to hold that [ 1823(e)] forbids that result."

Id.
___

The Fifth Circuit's decision in CTS Truss establishes
_________

several principles that are useful to consideration of the


____________________

18. The court also noted that to the extent the debtor's
claims of fraud and breach of an oral promise were
"allegations [that] would justify disallowance or an offset
against the Bank's secured claim, they would prevent the
assertion of a claim of equitable subordination." Id. at 149
___
(citing Mobile Steel for the proposition that "claims should
____________
be subordinated only to the extent necessary to offset the
harm done by the inequitable conduct").


-59-















FDIC's argument in this case. CTS Truss stands for the
__________

proposition that equitable subordination against the FDIC is

barred when the claims on which the request for subordination

is premised cannot be asserted against the FDIC because of

federal law. On the other hand, CTS Truss does not entirely
_________

preclude the possibility of equitable subordination of an

interest acquired by the FDIC because of the conduct of the

failed bank. The Fifth Circuit declined to adopt the

reasoning of the bankruptcy court below that the FDIC could

not be equitably subordinated because it was "a transferee

innocent of any misconduct" against the debtor. Id. at 147.
___

Instead, the court focussed on the issue of whether the

conduct of the FDIC's predecessor in interest fit the

"classic pattern[]" necessary for equitable subordination

under the test in Mobile Steel. Because it found that the
____________

bank's conduct in relation to the debtor in CTS Truss did not
_________

fit that pattern, the Fifth Circuit never directly reached

the issue of whether it would be appropriate to impute the

actions of the bank to the FDIC for purposes of equitable

subordination.

In this case, the FDIC asks that we adopt a rule of

federal common law preventing the equitable subordination of

the secured claim of a federal receiver as a result of

misconduct by a failed bank. We reject this approach because

we think that the analysis of the Fifth Circuit in CTS Truss
_________



-60-















demonstrates that such a broad rule of federal common law is

unnecessary to protect a federal receiver.

As evidence of a federal policy to protect the value of

assets acquired by the FDIC in its receivership capacity, the

FDIC cites the developing federal common law embodied in the

D'Oench and federal holder in due course doctrines. As an
_______

additional example of Congressional intent to protect it, the

FDIC also points to the recent amendments in FIRREA extending

the coverage of 1823(e) to the FDIC as receiver.19

Drawing on these examples, the FDIC urges that the adoption

of a federal rule barring equitable subordination is a

logical extension of this policy to protect it in its

receivership capacity. Otherwise, the FDIC warns, the

"absence of a federal rule barring equitable subordination of

the receiver's claims against bankrupt borrowers will

materially and adversely restrict the receiver's ability to

resolve bank receiverships at the lowest cost to the public."

Brief for Appellant FDIC As Receiver for Capitol Bank and

Trust Company at 32.





____________________

19. FIRREA amended 1823(e) by extending its coverage to "any
asset . . . acquired by [the FDIC] . . . either as security
for a loan or by purchase or as receiver of any insured
________________________________
depository institution . . . ." (Emphasis added). Before
______________________
FIRREA, 1823(e) applied only to the FDIC in its corporate
capacity, and it was only through decisions applying the
D'Oench doctrine that the FDIC as receiver was protected from
_______
unrecorded agreements. See Timberland, 932 F.2d at 49.
___ __________

-61-















The problem with this argument, as CTS Truss
__________

demonstrates, is that the adoption of a federal common law

rule precluding equitable subordination would be superfluous

in those cases in which the debtor's claims against the

receiver were already barred under D'Oench, 1823(e), or, if
_______

the asset was acquired by the receiver after a purchase and

assumption, the federal holder in due course doctrine. Only

if the debtor's request for equitable subordination were

based on claims not already barred by the FDIC's federal

defenses would a federal common law rule preventing equitable

subordination be necessary to protect the value of assets

acquired by the FDIC in its receivership capacity. The

FDIC's suggestion that the absence of such a common law rule

would "undercut the policy underlying the well-established

federal common law D'Oench Duhme and federal holder in due
_____________

course doctrines" is plainly hyperbole. A rule precluding

equitable subordination against the FDIC would in fact work a

significant expansion of the protections already afforded it

in its receivership capacity under D'Oench and 1823(e).
_______

Claims or defenses that a borrower might otherwise properly

assert against the federal receiver would be rendered

meaningless if the borrower entered bankruptcy because

equitable subordination would be unavailable even if the

borrower prevailed on these claims or defenses.





-62-















The FDIC maintains that such a result would be

consistent with the policy of enhancing the federal

receiver's ability to resolve bank failures at the lowest

cost to the public. Yet if the maximization of the FDIC's

recovery on the assets of a failed bank was the sole

objective of federal statutory and common law in this area,

then all claims or defenses against the FDIC's recovery on
___

assets would by now have been barred by federal statutes or

common law. As our discussion of D'Oench, 1823(e) and the
_______

federal holder in due course doctrine makes clear, while it

is certainly true that federal law affords the FDIC broad

protection against the claims and defenses of borrowers, that

protection has never amounted to total immunity. Cf. FDIC v.
___ _______

Jenkins, 888 F.2d 1537, 1546 (11th Cir. 1989) ("Of course, it
_______

would be convenient to the FDIC to have an arsenal of

priorities, presumptions and defenses to maximize recovery to

the insurance fund, but this does not require that courts

must grant all of these tools to the FDIC in its effort to

maximize deposit insurance fund recovery."). Nor are we

convinced that the absence of a federal rule preventing

equitable subordination would impair the operation of the

FDIC as receiver to the same extent that, for example, the

absence of a federal holder in due course doctrine would

impair the FDIC's ability to conduct purchase and assumption

transactions. Cf. Gunter, 674 F.2d at 870 (principal
___ ______



-63-















justification for federal common law rule was that its

absence would "make the FDIC's task of executing its

statutory mandate . . . nearly impossible"). Maximization of

the FDIC's recovery alone has never been an adequate

justification for the adoption of a rule of federal common

law.

The FDIC also argues that equitable subordination would

never be appropriate when it was only the wrongful conduct of

the failed bank and its officers, and not of the innocent

federal receiver, that provided the bankruptcy court with the

basis for subordination.20 This argument raises the issue

left undecided by CTS Truss: whether it would be appropriate
_________

to impute the misconduct of officials of a failed bank to the

federal receiver for purposes of equitable subordination.

While the question is a close one, we think that any

inequity that would result from imputing bank officials'

misconduct to the federal receiver would be outweighed by

adoption of a federal common law rule that would entirely

prevent the debtor/borrower or its creditors from benefitting

from the remedy of equitable subordination. The FDIC would



____________________

20. The FDIC relies for this argument, inter alia, on the
___________
reasoning of the lower courts' decisions in CTS Truss that
_________
there would be "no basis for equitably adjusting the
distribution of the bankrupt's assets because the claimant
________
never engaged in misconduct." Brief for Appellant FDIC at 34
(citing district court decision in CTS Truss). As we have
_________
noted, the Fifth Circuit expressly declined to ground its
decision on this rationale.

-64-















not necessarily be the only "innocent" creditor affected by

the adoption of such a rule. Many of the debtor/borrower's

other "innocent" creditors would be deprived of any

possibility of recovery from the estate in bankruptcy if

equitable subordination was barred against the federal

receiver. The FDIC should also be subjected to the

constraints of equity.

CTS Truss prevents equitable subordination against a
_________

federal receiver based on claims or defenses of the

debtor/borrower that are barred by the FDIC's established

federal statutory and common law protections. The FDIC has

not identified any additional policy considerations, beyond

those already supporting its preexisting federal protections

against borrowers' claims, that would favor the adoption of a

new federal common law rule giving the federal receiver even

greater protection in the event of the borrower's

bankruptcy.21 Accordingly, we find that there is no basis



____________________

21. The FDIC maintains that in this case the statutory
limitation on its liability as a receiver justifies the
denial of equitable subordination. See 12 U.S.C.
___
1821(i)(2). This fact-specific argument is not pertinent to
our consideration of whether it is necessary to adopt a rule
of federal common law barring equitable subordination against
the federal receiver. We also note that we doubt that the
diminution of the secured claim of the federal receiver
resulting from equitable subordination would be a "liability"
against the FDIC within the meaning of this provision. Texas
_____
American Bancshares, Inc. v. Clarke, 954 F.2d 329 (5th Cir.
____________________________________
1992), a case involving the priority of payments by the FDIC
to creditors of a failed bank after a purchase and
assumption, is not material to the issue before us.

-65-















for totally exempting the FDIC in its receivership capacity

from the remedy of equitable subordination permitted under

the Bankruptcy Code.

We hold that equitable subordination may be sought

against a federal receiver as long as this claim survives the

test imposed by CTS Truss. The claim of equitable
__________

subordination is valid only if, (1) the claims or defenses on

which the borrower's claim for subordination is premised are

not already barred by the FDIC's recognized protections under

federal law, and, (2) if the misconduct alleged in these

claims or defenses against the receiver's predecessor in

interest falls within "any of the classic patterns of conduct

that have led courts to fashion the extraordinary remedy of

equitable subordination." CTS Truss, 868 F.2d at 148.
_________

V. THE BANKRUPTCY COURT'S JUDGMENT ON THE MERITS OF THE
TRUST'S SOFT COSTS CLAIMS

The district court correctly determined that the federal

holder in due course doctrine did not bar the Trust's

conversion and breach of contract claims stemming from the

misapplication of loan proceeds to soft costs payments.

Having decided that equitable subordination is not barred as

a matter of federal common law against a federal receiver, we

must now consider the FDIC's challenge on the merits to the

bankruptcy court's rulings in favor of the Trust on the






-66-















breach of contract, conversion and equitable subordination

claims relating to the soft costs overages.22

A. Breach of Contract and Conversion
_________________________________

The FDIC challenges the district court's affirmance of

the ruling of the bankruptcy court that the Bank breached the

loan agreements by removing from the loan proceeds amounts

that exceeded the agreed-upon limits for soft costs by

$111,711.66. It contends that the provisions of the

standard-form L&SA used for each loan agreement required the

Trust to pay all expenses incurred by the Bank, and

authorized the Bank to withdraw from any of the Trust's

account any monies necessary to repay those expenditures.

The FDIC places particular emphasis on sections 6.01 and 8.01

of the L&SA, which provide, inter alia, that "the Borrower
_____ ____

agrees that any deposits or other sums . . . may at all times

be held and treated as collateral for any liabilities of the

Borrower . . . ."; that "the Borrower shall pay or reimburse

the Bank on demand for all out-of-pocket expenses of every

nature . . . ."; and that "the Bank, if it chooses, may debit







____________________

22. The merits of the Trust's claims arising from the
kickback arrangement are not at issue because the district
court properly applied D'Oench to vacate that part of the
_______
bankruptcy's court's judgment and equitable subordination
award in favor of the Trust that was premised on the kickback
claims.

-67-















such expenses to the Borrower's Loan Account or charge any of

the Borrower's funds on deposit with the Bank."23

The FDIC argues that both the district and bankruptcy

court concluded erroneously that the allocations of soft

costs provided in the addendum to the L&SA in each loan

agreement prohibited the Bank from removing from the Trust's

loan account additional amounts necessary to cover soft costs

expenses once the original estimates were exceeded. It

contends that both the Bank and the Trust knew that the soft

costs allowances in both loan agreements $100,000 in the

First Loan Agreement and "approximately" $60,000 in the

Second Loan Agreement would be inadequate to pay all the

soft costs expenses. According to the FDIC, by withdrawing

payments for soft costs in excess of these amounts, the Bank

was within its rights under the express terms of both L&SAs.

More importantly, the FDIC argues, the Bank never intended to

relinquish its rights under the L&SAs to complete recovery of

unpaid expenses by limiting itself to the soft costs

allowances included in the addenda to the L&SAs.

Following the lead of the parties and both courts below,

we treat Massachusetts law as controlling in this case. This

circuit has recognized that when interpreting contracts under

Massachusetts law, "[i]n the search for plain meaning, a



____________________

23. The FDIC also relies on several similar provisions of
the construction loan agreements.

-68-















court should consider 'every phrase and clause . . . [in

light of] all the other phraseology contained in the

instrument, which must be considered as a workable and

harmonious means for carrying out and effectuating the intent

of the parties.'" Boston Edison Co. v. FERC, 856 F.2d 361
__________________________

(1st Cir. 1988) (quoting J.A. Sullivan Corp. v. Commonwealth,
___________________________________

494 N.E.2d 374, 378 (Mass. 1986)). The principles of

interpretation applied by the Massachusetts courts conform to

those of the leading commentators. Specific terms are given

greater weight than general language. See Lembo v. Waters,
___ ________________

294 N.E.2d 566, 569 (Mass. App. Ct. 1973) ("'If the apparent

inconsistency is between a clause that is general and broadly

inclusive in character and one that is more limited and

specific in its coverage, the latter should generally be held

to operate as a modification and pro tanto nullification of

the former.'") (quoting 3 A. Corbin, Contracts 547, at 176
_________

(1960)). Separately negotiated or added terms are given

greater weight than standardized terms or other terms not

specifically negotiated. See Carrigg v. Cordeiro, 530 N.E.2d
___ ___________________

809, 813 (Mass. App. Ct. 1988) ("If . . . there is conflict

and inconsistency between a printed provision and one that

was inserted by the parties especially for the contract that

they are then making, the latter should prevail over the

former.") (citations omitted).





-69-















Applying these principles to the Bank's conduct in this

case, we conclude that the courts below were correct in

holding that the Bank breached both loan agreements by

withdrawing from the Trust's accounts payments for soft costs

that exceeded the agreed-upon allocations. Although the

provisions of the standard form L&SA used in both loan

agreements gave the Bank broad authority to recover its out-

of-pocket expenses, each L&SA was supplemented by an addendum

prepared by the parties that specifically limited the amount

of loan proceeds recoverable by the Bank as soft costs. The

L&SA Addendum to the First Loan Agreement provided that only

$100,000 of the loan proceeds were to be applied to soft

costs and the remaining $200,000 in proceeds would be used

for construction funding. The Bank's withdrawals of soft

costs exceeded that $100,000 allocation by $2,305.54. The

L&SA Addendum to the Second Loan Agreement provided that the

Bank would "advance the loan proceeds approximately as

follows: . . . $60,000 for soft costs incurred with respect

to the loan." The Bank's withdrawals of soft costs exceeded

this "approximate" allocation by $109,406.12.

We reject the FDIC's arguments that the soft cost limits

were merely estimates. The loan agreements clearly

contemplated that while a portion of the loan proceeds would

be used for the soft costs, the balance of the proceeds were

to be applied by the Trust to the costs of the construction



-70-















project that was the objective of the entire transaction. A

finding that the Bank breached these provisions does not, as

the FDIC maintains, necessarily conflict with the bankruptcy

court's determination that both parties understood that the

$100,000 soft costs allocation in the First Loan Agreement

would have to be supplemented by payments from the Trust's

funds.

The FDIC correctly points out that when the Trust failed

to cover the entirety of soft costs expenses incurred by the

Bank, the Bank had the authority to recover these expenses

from any of the Trust's accounts under the general provisions

of the L&SAs used in each loan. Yet the means by which the

Bank chose to exercise that authority that is, by

immediately recovering all its excess expenses directly from

the loan proceeds otherwise earmarked for construction

costs countermanded the specifically-agreed upon allocation

of loan proceeds between soft costs and construction costs.

As the district court correctly noted, while the general

provisions of the L&SAs and the construction loan agreements

gave the Bank discretion to apply the Trust's payments on the
________

loan as it saw fit, these provisions did not "give the Bank

the untrammelled right to advance and apply loan proceeds

willy-nilly." We therefore affirm the bankruptcy court's

judgment for an amount equivalent to the total of the excess

withdrawals made by the Bank towards soft costs payments for



-71-















both loans i.e., $2,305.54 for the First Loan Agreement and

$109,406.12 for the Second, for a total of $111,711.66.

The FDIC also challenges the finding of the courts below

that the Bank was also liable for conversion of the extra

$111,711.66 removed from the loan proceeds for soft costs.

Conversion consists of the wrongful exercise of dominion or

control over the personal property of another. See 14A D.
___

Simpson & H. Alperin, Massachusetts Practice: Summary of the
______________________________________

Law 1771 (1974). In order to recover for conversion,
___

plaintiffs must show that at the time of the alleged

conversion they had either actual possession or the right to

immediate possession or control of the property in question.

Id. See also Mechanics Nat'l Bank of Worcester v. Killeen,
___ ___ ____ _____________________________________________

384 N.E.2d 1231, 1240 (Mass. 1979).

The FDIC argues that the Bank's withdrawal of excess

soft costs payments did not constitute conversion because the

Trust never had an immediate right to possession or control

over the loan proceeds. It contends that the Trust failed to

satisfy the conditions of the loan agreement that required

the Trust, inter alia, to provide itemized requisitions of
_____ ____

its construction expenses prior to the Bank's disbursement of

any proceeds. Because of its failure to satisfy these

conditions precedent, the FDIC reasons, the Trust never

acquired a right to control or possession of any loan

proceeds disbursed for construction purposes. Thus, the FDIC



-72-















concludes, when the Bank disbursed loan proceeds for payment

of construction costs and then applied these payments to soft

costs payments, the Bank could not have converted those

funds.

The problem with the FDIC's reasoning is that it

misstates the factual circumstances of this case that explain

why the Bank chose to disburse loan proceeds for
___

construction. The FDIC ignores the finding by the bankruptcy

court that Bank officers, under Weiner's orders, deliberately

violated the conditions precedent of the First Loan Agreement

in order to expedite the advancement of loan proceeds. See
___

Bankruptcy Court Opinion, 119 B.R. at 360-61. The bankruptcy

court also found that portions of those proceeds were then

removed by Benjamin to make kickback payments to Weiner. As

for the Second Loan Agreement, the bankruptcy court found

that the conditions precedent for construction fund

disbursement were in fact complied with by the Trust. Id. at
___

367. The record demonstrates that the Bank advanced monies

to the Trust's loan account after the completion of

construction work, only to apply these loan proceeds to the

payments of soft costs.

We reject the FDIC's argument that the Trust had no

right to possess and control the proceeds of both loan

agreements once they were deposited to the Trust's account.

There is no basis in the record for the claim that violations



-73-















by the Trust of the conditions precedent entitled the Bank to

disburse funds for construction costs, begin to charge the

Trust interest, and at the same time withdraw portions of

these proceeds for soft costs payments. Both courts below

correctly concluded that the Bank, by withdrawing amounts for

soft costs beyond the agreed-upon limits of both loan

agreements, thereby converted funds belonging to the Trust.

B. Equitable Subordination
_______________________

Because we have determined that the district court

correctly found that the Trust's soft costs claims were not

barred against the FDIC by federal law, we focus on the

second element of the CTS Truss analysis: whether the
__________

misconduct of the Bank fit "within any of the classic

patterns of conduct that have led the courts to fashion the

extraordinary remedy of equitable subordination." CTS Truss,
_________

868 F.2d at 148.24

The FDIC argues that even if the district court properly

upheld the Trust's breach of contract and conversion claims,

equitable subordination was nonetheless erroneous because the

Trust failed to establish two of the elements of the Mobile
______

Steel test: that the Bank's overapplication of loan proceeds
_____

to soft costs was misconduct sufficient to support an award

of equitable subordination, or that this misconduct resulted


____________________

24. We disregard the FDIC's arguments that it is an
"innocent" receiver, having rejected this line of reasoning
in Part IV, supra.
_____

-74-















in injury to the Trust's other creditors. See Giorgio, 862
___ _______

F.2d at 938-39; Mobile Steel, 563 F.2d at 692. It also
____________

claims that to permit equitable subordination of its secured

claim would result in a double recovery by the Trust.

Although the remedy of equitable subordination has been

applied relatively infrequently, it is usually directed

towards misconduct arising in three situations: when a

fiduciary of the debtor misuses his position to the

disadvantage of other creditors; when a third party dominates

or controls the debtor to the disadvantage of others; or when

a third party defrauds the other creditors. Id. at 148-49
___

(citing 3 Collier at 510.05). See also A. DeNatale and P.
___ ____

Abram, The Doctrine of Equitable Subordination as Applied to
______________________________________________________

Nonmanagement Creditors, 40 Bus. Law. 417, 430-45 (1985)
________________________

("DeNatale & Abram"). This court has summarized briefly the

purpose of the remedy:

The case law does not suggest that the doctrine of
equitable subordination gives the bankruptcy court
a general license to weigh the moral quality of
_______
each debt or to compare creditors in terms of moral
worth; rather it indicates that the bankruptcy
court may equitably subordinate those debts, the
creation of which was inequitable vis-a-vis other
_______________
creditors. It permits a bankruptcy court to take
_________
account of misconduct of one creditor towards
another, just as that court often can take account
of a creditor's misconduct towards the debtor when
______
considering whether to allow, or to disallow, a
claim.

Thus, most cases involving "equitable
subordination" also involve corporate insiders or
fiduciaries who have obtained unfair advantages
over other creditors through, for example, fraud.


-75-















Where a bankruptcy court has subordinated the debt
of a creditor who was not an insider, it has done
so on the ground that that conduct was egregious
and severely unfair in relation to other creditors.

Giorgio, 862 F.2d at 939 (citations omitted and emphasis in
_______

original).

Whether the creditor is an insider or fiduciary of the

debtor is fundamentally important to the level of scrutiny

that courts apply to allegations of misconduct against a

creditor. See In re Fabricators, Inc., 926 F.2d 1458, 1465
___ ________________________

(5th Cir. 1991). See also DeNatale & Abram at 424 ("The
___ ____

creditor's duty of fair dealing is increased in the precise

degree that the creditor has power and control over the

debtor's affairs."). Claims arising from dealings between a

debtor and an insider are rigorously scrutinized by the

courts. Fabricators, 926 F.2d at 1465. On the other hand,
___________

if the claimant is not an insider, "then evidence of more

egregious misconduct such as fraud, spoliation or

overreaching is necessary." Id. (citing In re N&D
___ ____________

Properties, Inc., 799 F.2d 726 (11th Cir. 1986)). See also
________________ ___ ____

In re Friedman, 126 B.R. 63, 71-72 (Bankr. 9th Cir. 1991)
______________

(same principle).

Rather than decide the question of whether the Bank was

a fiduciary or insider of the Trust, the bankruptcy court

based its decision to award equitable subordination on its

finding that the Bank's conduct was "illegal, egregious and

severely unfair to other creditors" within the meaning of


-76-















Giorgio. Bankruptcy Court Opinion, 119 B.R. at 377. The
_______

bankruptcy court's equitable subordination of the Bank was

grounded on the Trust's claims of fraud, breach of contract

and conversion claims relating to the kickback scheme and its
___

claims of breach of contract and conversion premised on the

soft costs overages. The court specifically cited the Bank's

"fraud and illegality," which the bankruptcy court found

"together constitute one of the three general categories of

misconduct recognized by the courts as warranting equitable

subordination." Id.
___

The district court upheld the equitable subordination

against the FDIC's challenge on appeal, but at the same time

vacated that portion of the original judgment that was based

on the kickback claims, which it properly determined were

barred by D'Oench. Accordingly, the district court removed
_______

from the judgment of equitable subordination the $26,300 in

damages attributable to the kickback scheme. The district

court otherwise affirmed in its entirety the bankruptcy

court's determination that the Bank's misconduct justified

equitable subordination with respect to the soft costs

claims.

The FDIC argues that the Bank's misconduct in relation

to the breach of contract and conversion claims was

insufficient to support equitable subordination. This

argument raises an issue that was not fully addressed by the



-77-















district court when it reviewed the Trust's equitable

subordination claim against the FDIC as the successor to the

Bank: whether the bar under D'Oench to the Trust's kickback
_______

claims, and in particular its fraud claim, affected the

validity of the bankruptcy court's original judgment of

equitable subordination.

The bankruptcy court specifically premised the equitable

subordination on the Bank's "fraud and illegality," and the

Trust has never argued in this case that the Bank was an

insider or fiduciary of the Trust. Nor has the Trust ever

asserted that the Bank dominated or controlled its

affairs.25 Accordingly, the issue is whether equitable

subordination can be based solely on the Bank's misconduct in

relation to the excess withdrawals of soft costs.

Courts have struggled to define precisely the misconduct

necessary to support equitable subordination against a

creditor who is not an insider. Fraud or misrepresentation


____________________

25. We add that such allegations, if made in this case,
would not have been sufficient to satisfy the rigorous
standard necessary to prove control or domination of the
Trust's affairs by the Bank. See, e.g., In re Burner, 109
___ ____ _____________
B.R. 216, 228 (Bankr. W.D. Texas 1989) ("A non-insider
creditor will be held to a fiduciary standard only where his
ability to control the debtor is so overwhelming that there
has been a merger of identities."); In re Beverages Int'l
______________________
Ltd., 50 B.R. 273, 282 (Bankr. D. Mass. 1985) ("[m]ore than
____
mere pressure or influence on a debtor must be shown"). We
also note that "[a]s a general rule lenders are not
fiduciaries when it comes to collection on their claims." In
__
re Kelton Motors, Inc., 121 B.R. 166, 191 (Bankr. D. Vt.
________________________
1990) (citing In re W.T. Grant Co., 699 F.2d 599, 609 (2d
_____________________
Cir.), cert. denied, 464 U.S. 822 (1983)).
____________

-78-















are the most frequent justifications for equitable

subordination of the non-insider.26 They are not, however,

required:

Something less than actual fraud . . . will
suffice. The fixing of the lower limit is the
elusive boundary which cannot be clearly defined.
Although the courts have used general terms such as
injustice or unfairness to fix this lower limit,
the minimum level of offending conduct appears to
be conduct that shocks the conscience of the court.
. . .

DeNatale & Abram at 423-24. Types of misconduct sufficient

to warrant equitable subordination against non-insiders have

included instances of "[v]ery substantial misconduct

involving moral turpitude or some breach or some

misrepresentation where other creditors were deceived to

their damage . . . or gross misconduct amounting to

overreaching . . . ." In re Mayo, 112 B.R. 607, 650 (Bankr.
__________

D. Vt. 1990) (citations omitted). For the most part, courts








____________________

26. See, e.g., In re Bowman Hardware & Elec. Co., 67 F.2d
___ ____ ___________________________________
792, 795 (7th Cir. 1933) (where creditor participated with
debtor in scheme to misrepresent debtor's financial state,
creditor's claim subordinated to that of other creditor
injured by that misrepresentation); In re Osborne, 42 B.R.
_____________
988, 1000 (W.D. Wis. 1984) (equitable subordination
appropriate against lender based on its misrepresentations to
another creditor about that creditor's prospects for
payment); In re Slefco, 107 B.R. 628, 644 (Bankr. D. Minn.
____________
1989) (equitable subordination of bank's claim predicated on
bank's misrepresentation of amounts it intended to loan
debtor).

-79-















have been reluctant to find the requisite level of misconduct

in arms-length dealings between borrowers and lenders.27

In Kham & Nate's Shoes No. 2, Inc. v. First Bank of
_____________________________________________________

Whiting, 908 F.2d 1351 (7th Cir. 1990), the Seventh Circuit
_______

reversed the equitable subordination of a bank's priority

claim to a borrower's estate. Id. at 1356-1359. The
___

bankruptcy court had justified the equitable subordination on

the basis of, inter alia, the hardship caused to the
_____ ____

borrower/debtor by the bank's suspension of a new line of

credit.28 Finding that the bank was not an insider or

fiduciary of the borrower, and that the suspension of the

borrower's line of credit was permitted under the loan

contract, the Seventh Circuit rejected the reasoning of the

bankruptcy court. Id. at 1356-58. During the course of its
___

opinion, the court stated:


____________________

27. See In re Pacific Express, Inc., 69 B.R. 112, 117-18
___ _____________________________
(Bankr. 9th Cir. 1986) (creditors' loan agreement with
debtor, which effectively shifted risk of loss to other
creditors, was not "the type of overreaching, fraud or other
conduct which would justify subordination of a non-insider's
claim"); In re Dry Wall Supply, Inc., 111 B.R. 933, 937-39
____________________________
(D. Colo. 1990) (rejecting equitable subordination based on
allegations that creditor knew that loan transaction would
render borrower insolvent); In re Pinetree Partners, Ltd., 87
_____________________________
B.R. 481, 490 (Bankr. N.D. Ohio 1988) (lender's refusal to
provide additional credit and threatened foreclosure of
debtor's mortgage not sufficiently egregious to warrant
equitable subordination).

28. The other basis for the district court's equitable
subordination was its finding that the bank had induced the
borrower's suppliers to draw on letters of credit issued
prior to the bank's provision of the new line of credit. Id.
___
at 1354.

-80-















[W]e are not willing to embrace a rule that
requires participants in commercial transactions
not only to keep their contracts but also do
"more" just how much more resting in the
discretion of a bankruptcy judge assessing the
situation years later. . . . Unless pacts are
enforced according to their terms, the institution
of contract, with all the advantages private
negotiation and agreement brings, is jeopardized.

"Inequitable conduct" in commercial life means
breach plus some advantage-taking, such as the star
____
who agrees to act in a motion picture and then,
after $20 million has been spent, sulks in his
dressing room until the contract has been
renegotiated. Firms that have negotiated contracts
are entitled to enforce them to the letter, even to
the great discomfort of their trading partners,
without being mulcted for lack of "good faith."

Id. at 1356-57 (citations omitted). The Seventh Circuit also
___

rebutted the debtor's arguments that equitable subordination

could be based on a breach of contract arising from the

bank's failure to provide it telephonic as well as written

notice of the suspension of the line of credit, noting that

"[e]quitable subordination . . . is not a device to magnify

the damages available for inconsequential breaches of

contract." Id. at 1359.
___

Applying the somewhat amorphous case law standards for

equitable subordination to the facts of this case, we find

that the Bank's excess withdrawals of soft costs was conduct

sufficiently egregious to justify equitable subordination.

The Bank's actions could fairly be characterized as "gross

misconduct amounting to overreaching." Mayo, 112 B.R. at
____

650. Unlike the insubstantial breach of contract alleged in



-81-















Kham & Nate's Shoes, the Bank's withdrawal of over $100,000
___________________

in excess of the agreed-upon soft costs limits was a

substantial breach of the loan agreements. Moreover, the

fact that the Bank advanced and withdrew loan proceeds

arbitrarily, and at the same time caused interest to run on

misappropriated proceeds, in our view rises to the level of

"advantage-taking" within the meaning of Kham & Nate's Shoes.
___________________

As the bankruptcy court also found, the conversion of

the soft costs monies handicapped the renovation effort and

resulted in the Bank's recovering for its own benefit funds

that the Trust had bargained with the Bank to set aside for

construction creditors. Bankruptcy Court Opinion, 119 B.R.

at 377. While the Bank was entitled to enforce the loan

agreements without regard to the hardship imposed on the

Trust, Kham & Nate's Shoes, 908 F.2d at 1357, those loan
____________________

agreements did not authorize the Bank to seek reimbursement

for unpaid soft costs from the Trust's construction funds.

In this case, the hardship imposed on the Trust and its

construction creditors flowed from the Bank's improper and

unauthorized administration of the loans, and could therefore

properly have been considered an element of the equitable

subordination inquiry. We conclude that the Bank's

misconduct in relation to the soft costs claims was

sufficient evidence of misconduct on which to predicate the

equitable subordination of the FDIC's secured claim.



-82-















The FDIC nonetheless argues that equitable subordination

would be not appropriate under the second prong of Mobile
______

Steel because the Bank's misconduct did not result in injury
_____

to the Trust's other creditors. The FDIC bases this argument

on the bankruptcy court's determination that the

misappropriation of loan proceeds by the Bank was not the

principal cause of the failure of the Trust's construction

project and failure to repay the loan. The FDIC maintains

that the bankruptcy would have resulted even if the

misapplication of loan proceeds had not occurred, and that

any harm to the Trust's other creditors thus cannot be

attributed to the Bank's conduct.

The FDIC's argument boils down to the assertion that

equitable subordination is inappropriate unless the

misconduct at issue is a major cause of the debtor's

bankruptcy. This argument is without support in the case

law. The second prong of Mobile Steel establishes only that
____________

equitable subordination is appropriate when the misconduct

results in actual harm to the debtor or the other creditors,

"or conferred an unfair advantage on the claimant":

In examining the effect of the conduct on
creditors, the court should consider the effect on
the then-known creditors, as well as future
creditors. In this analysis, the question to be
answered is whether or not the offending conduct
had an impact on the bankruptcy results, that is,
the bottom line, in the proceeding before the
court. . . . This would encompass all the effects
of fraud and inequitable conduct that would have an



-83-















impact upon [other creditors' legal or equitable
rights in the bankruptcy results]. . . .

In demonstrating the harm, the objecting party
usually need not identify specifically each
particular creditor who was harmed and quantify the
injury suffered by each. If the misconduct results
in harm to the entire creditor body, the objecting
party need demonstrate only that the misconduct
harmed the creditor body in some general, albeit
concrete, manner.

DeNatale & Abram at 426 (footnotes omitted). The bankruptcy

court found, inter alia, that the Bank's misconduct damaged
_____ ____

other creditors by depleting the Trust's assets and,

consequently, its bankruptcy estate, and by substantially

handicapping the renovation effort, on which many creditors

ultimately had to rely for compensation. Bankruptcy Court

Opinion, 119 B.R. at 377. We find that this depletion of the

funds available for construction, and its attendant impact on

the success of the Trust's renovation efforts, was a

sufficiently concrete harm to the Trust's other creditors to

warrant equitable subordination of the Bank. Cf. In re
___ ______

Beverages Int'l Ltd., 50 B.R. 273, 283 (Bankr. D. Mass. 1985)
____________________

("the misconduct may result in harm to the entire creditor

body, [or] a particular class of creditors") (citing DeNatale

& Abram).

There is no merit to the FDIC's argument that the Bank's

conduct did not reduce the money present in the bankruptcy

estate available to the other creditors. The FDIC points out

that the Bank's overages of soft costs payments merely



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reduced the overall amounts due the Bank (and FDIC) as the

Trust's principal secured creditor. It reasons that there

could be no harm to the Trust's other creditors because the

FDIC's secured claim exceeds the value of the Trust's assets.

Such an argument ignores the very nature of the equitable

subordination remedy, whose precise purpose is to permit

recovery by other creditors with lower priority claims

because of misconduct of a particular creditor whose claim

would otherwise enjoy priority.

We also reject the FDIC's assertion that equitable

subordination of its secured claim would grant the Trust a

windfall double recovery. It is clear that it is the Trust's

unsecured creditors who will benefit from the partial

subordination of the FDIC's claim, not the Trust. The FDIC's

contention that damages are an adequate remedy at law is

equally spurious. The FDIC asserts that its secured claim

far exceeds the value of the Trust's estate or its

properties. Payment of damages by the FDIC on the soft costs

claim, rather than equitable subordination of an equivalent

amount, would simply increase the value of the estate that

the FDIC would recover. Without equitable subordination, the

FDIC would recoup from the Trust's estate any damages

attributable to the Bank's misconduct. Equitable

subordination is necessary in order to permit recovery by the





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Trust's other creditors to reflect the injury caused by the

Bank's misappropriation of loan proceeds for soft costs.

Accordingly, we affirm the equitable subordination of

the FDIC's secured claim, as reduced by the district court to

an amount equivalent to the damages attributable to the

excess soft costs monies withdrawn by the Bank.

VI. INTEREST

The FDIC next attacks the inclusion of interest on the

soft costs overages as part of the total amount of its

secured claim subject to equitable subordination. It

contends that the district court's affirmance of the

bankruptcy's court award of post-judgment interest "at the

contract rate from the dates on which they were

misappropriated" was contrary to law. The FDIC argues that:

(1) federal law forbids a post-judgment award of interest to

the extent that it provides for interest after appointment of

a receiver; and (2) the district court erred by setting post-

judgment interest at the rate found in the Loan Agreements.

Because the FDIC did not raise its first argument in the

district court below, we will not consider it. The district

court's opinion makes no mention of the federal law bar to

post-judgment interest claimed by the FDIC. The Trust

asserts in its brief that the issue was never raised in the

district court, and the FDIC has not refuted this contention

in its reply brief. There is also nothing in the record



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before us that indicates that the issue was raised below.

We, therefore, deem the argument waived. See Boston Celtics,
___ ______________

908 F.2d at 1045.

The FDIC relies for its second argument on section 6C of

chapter 231 of the General Laws of Massachusetts, which

provides in pertinent part:

In all actions based on contractual obligations,
upon a verdict, finding or order for judgment for
pecuniary damages, interest shall be added by the
clerk of the court to the amount of damages, at the
contract rate, if established, or at the rate of
twelve per cent per annum from the date of the
breach or demand.

Mass. Gen. Laws Ann. ch. 231, 6C. The FDIC argues that

this statute requires a twelve percent rate of interest on a

judgment on a contract unless the contract obligated the

judgment debtor in this case the Bank to pay interest at

a different rate. The FDIC contends that because the Loan

Agreements imposed no obligation on the Bank to pay any

interest to the Trust, Massachusetts' default judgment

interest rate of twelve percent must be applied.

To our knowledge, the Massachusetts Supreme Judicial

Court has never addressed the issue of whether rates of

interest in a promissory note should be treated as the

"contract rate" for purpose of post-judgment interest against

the lender. See Mechanics Nat'l Bank, 384 N.E.2d at 1240
___ _____________________

n.14 (declining to address issue). After review of the

bankruptcy court's interpretation of section 6C, we are



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persuaded that the court correctly decided to apply interest

at the contract rate specified in the loan agreements:

The contract rate is appropriate here . . . because
the Bank charged interest at the contract rate for
the misappropriated proceeds. Some of the interest
charged has been paid, and the remainder is part of
the Bank's secured claim[]. . . .

Bankruptcy Court Opinion, 119 B.R at 371 n.17. Application

of the contract rate of interest was necessary in order to

assure that the equitable subordination award fully reflected

the damages to the Trust resulting from the Bank's excess

withdrawal of soft costs. We affirm the district court's

rejection of the FDIC's challenge on this issue.

VII. ATTORNEY'S FEES

The district court affirmed equitable subordination

against the FDIC's secured claim in an amount equivalent to

the damages incurred by the Trust from the soft costs

overages plus interest. It reversed, however, the bankruptcy

court's determination that Massachusetts law permitted

attorney's fees as an element of the damages for conversion.

The district court held:

The Bankruptcy Code permits equitable subordination
of "all or part of an allowed claim to all or part
of another allowed claim." 11 U.S.C. 510(c)(1).
As I have previously held that it was improper to
award attorney's fees as an element of conversion
damages, the attorney's fees can no longer be
considered part of appellees' allowed claim against
the estate. Thus, the plain language of the
statute precludes the subordination of the Bank's
claim to the fee award.




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While the district court rejected subordination of attorney's

fees on the grounds identified by the bankruptcy court, it

also observed in a footnote that "[a]ttorney's fees [could] .

. . still be allowed, of course, as an administrative

expense, see 11 U.S.C. 503(b)(3), accorded the priority
___

specified in the Bankruptcy Code."

The Trust challenges the district court's reversal of

the bankruptcy court's inclusion of attorney's fees in the

equitable subordination. The Trust does not, however,

contest the district court's interpretation of Massachusetts

conversion law. Rather, the Trust or more precisely, the

Trust's attorneys argue that attorney's fees are a valid

administrative expense claim against the bankruptcy estate

within the meaning of 11 U.S.C. 330(a)(1) and

503(b)(2).29 The Trust's attorneys contend that because



____________________

29. Section 503(b) of the Bankruptcy Code governs the
allowance of administrative expenses. Among the
administrative expenses permitted, after notice and a
hearing, are claims for "compensation and reimbursement
awarded under section 330(a) of this title." 11 U.S.C.
503(b)(2). Section 330(a) provides in pertinent part:
(a) After notice to any parties in interest and to
the United States trustee and a hearing . . . the
court may award to a trustee, to an examiner, to a
professional person employed under section 327 or
1103 of this title, or to the debtor's attorney
(1) reasonable compensation for actual,
necessary services rendered by such trustee,
examiner, professional person, or attorney,
. . . based on the nature, the extent, and the
value of such services, the time spent on such
services, and the cost of comparable services
other than in a case under this title . . . .

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their fees are in fact a valid "claim" under these

provisions, the bankruptcy court's decision to include

attorney's fees in the equitable subordination against the

Bank was proper. See 11 U.S.C. 510(c)(1) (bankruptcy court
___

may, "under principles of equitable subordination,

subordinate for purposes of distribution all or part of an

allowed claim to all or part of another allowed claim . . .

.").

This argument puts the cart before the horse. Although

both the bankruptcy and district courts acknowledged, in

dicta, that a request by the Trust for attorney's fees might
_____

be an allowable administrative expense under the Bankruptcy

Code, neither court expressly made such a determination. In

fact, the Trust's attorneys acknowledge in their reply brief

that they have not, as yet, asked the bankruptcy court to

award them attorney's fees as an administrative expense

claim. See Reply Brief for Appellant 604 Columbus Avenue
___

Realty Trust at 2-3. Any such award of attorney's fees as an

administrative expense under sections 330(a)(1) and 503(b)(2)

would require notice and a hearing. See 11 U.S.C. 330(a)
___

and 503(b).





____________________

11 U.S.C. 330(a). Administrative expenses allowable under
503(b), which include expenses under 330(a), are given
first priority of payment under the Bankruptcy Code. See 11
___
U.S.C. 507(a)(1).

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In these circumstances, we need not address the argument

that the bankruptcy court should properly have subordinated

the Bank's secured claim to an administrative expense claim

of the Trust's attorneys. Such a claim had neither been made

nor allowed by the bankruptcy court at the time of its

equitable subordination of the Bank. We, therefore, affirm

the district court's reversal of the bankruptcy court's

inclusion of attorney's fees in the equitable subordination

against the Bank, insofar as that decision reversed the award

of attorney's fees as an element of the conversion

damages.30

CONCLUSION
CONCLUSION

To summarize, we find that:

(1) the FDIC was entitled to raise its defenses under

federal law for the first time on appeal in the district

court;

(2) the D'Oench doctrine barred the Trust's claims for
_______

fraud, conversion, and breach of contract arising from

the kickback scheme;

(3) the federal holder in due course doctrine did not

apply to the FDIC in its receivership capacity in the

absence of a purchase and assumption transaction, and




____________________

30. We express no opinion on the merits of the Trust's claim
that its attorney's fees are administrative expenses within
the meaning of sections 330(a)(1) and 503(b)(2).

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therefore did not bar the Trust's claims for conversion

and breach of contract based on the soft costs overages;

(4) federal common law did not preclude equitable

subordination against the FDIC in its receivership

capacity;

(5) the bankruptcy and district courts properly found

for the Trust on its breach of contract and conversion

claims based on the soft costs overages;

(6) equitable subordination of the FDIC's secured claim

in an amount equivalent to the soft costs damages was

proper;

(7) the bankruptcy court properly included as part of

the overall amount of the FDIC's claim subject to

equitable subordination an award of post-judgment

interest on the soft costs damages at the contract rate;

and

(8) attorney's fees were not an element of conversion

damages, and could not properly have been included in

the amount equitably subordinated.

AFFIRMED.
________













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