On September 14, the Sixth Circuit affirmed the trial court's finding that a failed bank's parent did not make a capital maintenance commitment to the bank. After the parent filed for bankruptcy, the FDIC was appointed receiver for the bank. The FDIC then sought payment from the parent under the statute requiring a party seeking reorganization to fulfill commitments to maintain the capital of an insured depository institution. The Sixth Circuit held that the trial court correctly found that a previously agreed to cease-and-desist order requiring the parent's board to ensure the bank complies with its capital ratio is ambiguous because it can be read as establishing an oversight role or a capital maintenance commitment. The trial court could, therefore, conclude that the order did not include a capital maintenance commitment. FDIC v. AmTrust Financial Corp.