JOHN R. GIBSON, Circuit Judge.
The issue in this case is whether the Board of Governors of the Federal Reserve System was subject to the procedural requirements of the Right to Financial Privacy Act, 12 U.S.C. §§ 3401-3422 (1982), when it reviewed financial records of Stephen Adams, Alfred T. Burke and Merritt Gates maintained by American National Bank of St. Paul, Minnesota, on three occasions in 1982 and 1983. These records related to loans made by American...
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