MEMORANDUM OPINION
KESSLER, District Judge.
Plaintiff, National Home Equity Mortgage Association ("NHEMA"), brings this action under the Administrative Procedure Act, 5 U.S.C. § 706. Plaintiff challenges amendments to 12 C.F.R. § 560.220, which the Office of Thrift Supervision ("OTS") adopted and published as a final rule on September 26, 2002 ("Amended Rule"). 67 Fed.Reg. 60542 (Sept. 26, 2002). Defendants are OTS and its Director, James...
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