MEMORANDUM OPINION AND ORDER
SULLIVAN, District Judge.
INTRODUCTION
Plaintiffs, American Bankers Insurance Group, Inc., and two of its subsidiaries, American Bankers Insurance Company of Florida, and American Bankers Life Insurance Company of Florida, commenced this action against the Board of Governors of the Federal Reserve System ("the Board") to challenge a single provision of the Board's Regulation Z (12 C.F.R. Part 226), which...
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