ARNOLD, Circuit Judge.
The principal question presented in this case is whether there is an implied federal right of action for damages for violations of certain provisions of the Flood Disaster Protection Act of 1973 and the National Flood Insurance Act (NFIA), 42 U.S.C. §§ 4012a(b), 4104a (1976). The District Court held that there is such a right of action and granted plaintiffs' motion for summary judgment. Hofbauer v. Northwestern Nat'l Bank of Rochester...
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