On April 22, 2013, Los Angeles-based federal judge Mariana Pfaelzer tossed on timeliness grounds a suit filed by the FDIC, as receiver, against JPMorgan Chase & Co.,  Bank of America Corp., Citigroup Inc. and Deutsche Bank AG.  The suit alleged misrepresentations concerning the credit quality of mortgages backing several RMBS certificates sold to Strategic Capital Bank.  The court concluded that the '33 Act's one-year statute of limitations expired before the FDIC was named receiver, and that the "FDIC does not have the power to revive these expired claims.”