JON O. NEWMAN, Circuit Judge:
This appeal presents two issues concerning a civil penalty levied by the Board of Governors of the Federal Reserve System ("the Board"). The first is whether the Board is entitled to the ten percent surcharge on the penalty authorized by the Federal Debt Collection Procedures Act ("FDCP Act"), 28 U.S.C. §§ 3001-3308 (1994), in certain actions brought by the United States to recover debts. The second is whether the Board is entitled...
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