A recent New York court decision has cleared the way for lenders to seek recovery against non-recourse carve-out, or “bad boy,” guarantors during a pending mortgage foreclosure action if a borrower files for bankruptcy. In so doing, the court answered a question that, surprisingly, was thus far apparently unanswered in a reported decision in New York: whether New York’s “one action rule” under RPAPL § 1301 bars a lender from obtaining a money judgment against a “bad boy” guarantor for the debt if a mortgage borrower files for bankruptcy while a foreclosure action is underway.

On Thursday, Ireland's Finance Minister Brian Lenihan released a "Minister's Statement on Banking" announcing new commitments to troubled Irish banks. The statement began: "It is an urgent and immediate priority to reinforce international market confidence in our ability and commitment to restore our banking system to health and to secure the long-term sustainability of our fiscal position." Toward that end, Mr. Lenihan announced increased commitments to banks and building societies.

On Friday, the Illinois Department of Financial and Professional Regulation, Division of Banking closed Ravenswood Bank, headquartered in Chicago, Illinois, and appointed the FDIC as receiver for the bank.

On Friday, the Office of Thrift Supervision closed Olde Cypress Community Bank, headquartered in Clewiston, Florida, and appointed the FDIC as receiver for the bank.

On Friday, the Executive Commission of the Bank of Spain appointed the Fund for Orderly Bank Restructuring (FROB) as interim administrator of Roman Catholic Church-controlled savings bank Caja de Ahorros y Monte de Piedad de Córdoba (CajaSur).

Yesterday, the Office of the Commissioner of Financial Institutions of the Commonwealth of Puerto Rico closed Eurobank, headquartered in San Juan, Puerto Rico, and the FDIC was appointed receiver.

On Friday, the Georgia Department of Banking and Finance closed Bank of Hiawassee, headquartered in Hiawassee, Georgia, and the FDIC was named receiver.  As receiver, the FDIC entered into a purchase and assumption agreement wi

On Friday, the Office of the Comptroller of the Currency closed The La Coste National Bank , headquartered in La Coste, Texas, and the FDIC was named receiver.

Yesterday, the FDIC announced that it had entered into a purchase and assumption agreement to assume the assets and deposits of the recently created Independent Bankers’ Bank Bridge Bank (IBBBB). IBBBB was created by the FDIC on December 18, 2009, to take over the operations of The Independent Bankers’ Bank, headquartered in Springfield, Illinois.

This evening, the OTS closed Century Bank, FSB, headquartered in Sarasota, Florida, and the Florida Office of Financial Regulation closed Orion Bank, headquarte