Law360 quotes Ryan M. Wilson in an article discussing The Royal Bank of Scotland’s (RBS) $4.9 billion settlement with the U.S. Department of Justice (DOJ)  to end claims that the bank defrauded investors by using low-quality loans behind its residential mortgage-backed securities. The settlement amount constitutes a civil penalty under the Financial Institutions Reform, Recovery and Enforcement Act. Wilson notes that the significance of the dollar amount speaks to the severity of RBS’s conduct and the amount of time required to reach a settlement. He also states that the size of the penalty could reflect the fact that RBS is one of the last major banks to strike a deal with the DOJ. (subscription required to access article)