MEMORANDUM OPINION AND ORDER
JOYCE HENS GREEN, District Judge.
Plaintiffs American Insurance Association (AIA) and Alliance of American Insurers (AAI or Alliance), national trade associations representing companies engaged in property and casualty insurance, brought suit against the Office of the Comptroller of the Currency, the Acting Comptroller, and the United States ("Comptroller"), challenging a decision by the Comptroller allowing Citibank, N.A. (...
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