On October 22nd, the D.C. Circuit addressed the Office of Thrift Supervision's director indemnification rules. Shareholders of a savings and loan filed a securities lawsuit against the S&L and its directors and obtained a preliminary injunction in which they gained control of the S&L and ousted the directors. The now former directors sought indemnification from the S&L under OTS regulations. The Court held that the ex-directors were not entitled to indemnification under either OTS's mandatory or permissive indemnification rules. Bender v. Jordan.