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The director may determine the merits of the appeal, or at the election of the financial institution, refer the appeal to an administrative law judge appointed by the FFIEC to conduct a hearing. In any hearing, neither the director nor the administrative law judge could defer to the opinions of the examiner or agency.
the Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDIC), the Office of the Comptroller of the Currency (OCC), or the National Credit Union Administration (NCUA)) are not included in the Working Group, especially given the allegations of an ‘Operation Choke Point 2.0.,’
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