When Monogram Credit Card Bank of Georgia faced a consumer class-action suit last year, it turned to General Electric Capital Corp., its parent, to enlist the support of the Federal Deposit Insurance Corp.

Monogram then hired a former general counsel of the FDIC who drafted a policy letter incorporating what GE Cap was seeking. He had GE's attorneys check the letter, and directed a lower-level FDIC official to type the letter on the agency's letterhead. The letter then was presented to the federal court as FDIC policy, and the judge ruled in GE's favor.

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