MEMORANDUM OPINION AND ORDER
JOYCE HENS GREEN, District Judge.
Plaintiff American Insurance Association (AIA) brings this action challenging a ruling by defendant Comptroller of the Currency that would allow Citibank, a national bank subsidiary of a registered bank holding company, to offer a type of municipal bond insurance in the form of standby letters of credit. AIA, joined by amici the National Association of Life Underwriters and the National...
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