Opinion for the Court filed by Circuit Judge GINSBURG.
Opinion concurring in part and concurring in the judgment filed by Circuit Judge ROGERS.
GINSBURG, Circuit Judge:
Robert D. Rapaport was the majority shareholder of a savings and loan association that failed. Thereafter the Office of Thrift Supervision, as successor to the Federal Savings and Loan Insurance Corporation, ordered him to pay approximately $1.5 million pursuant to his agreement personally...
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