Opinion for the Court filed by Chief Judge EDWARDS.
HARRY T. EDWARDS, Chief Judge:
Petitioners are three directors of Charter Federal Savings & Loan Association ("Charter"). In 1988, Charter applied to the Federal Home Loan Bank Board ("Bank Board") — the predecessor agency of the Office of Thrift Supervision ("OTS") — for permission to convert from "mutual" ownership to "stock" ownership. The Bank Board denied Charter's application, finding...
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