On May 21st, the D.C. Circuit affirmed the district court's order denying a motion to intervene. Senior note-holders of Washington Mutual ("WaMu"), a failed bank, sought to intervene in litigation between, among others, Deutsche Bank and the FDIC concerning mortgage-backed securities issued by WaMu. The D.C. Circuit held that Circuit law requires the note-holders to establish standing, which they failed to do. Although the note-holders have an economic interest in WaMu's receivership assets, those interests do not face imminent threatened invasion. The note-holders' fear that the FDIC may enter into an unfavorable settlement is pure conjecture. Deutsche Bank National Trust Co. v. FDIC.