Late last month, in Starr Int’l Co. v. Fed Reserve Bank of N.Y., the Second Circuit held that the Federal Reserve Bank of New York (“FRBNY”) could not be held liable for state law fiduciary duty claims when it was acting under its statutory mandate to rescue a corporate entity. In doing so, the court made clear that such protections would extend to the Federal Reserve Bank where it is alleged that, in some of the actions it took, FRBNY had exceeded its statutory authority.
