FDIC and the Fed

"If the [Fed] were a commercial lender, it would be a candidate for a receivership, based on its capital ratios. ... Although the Fed's role as a central bank is much different from the role of a private-sector operation, the drastic changes in the size and shape of its balance sheet worry even some long-time Fed officials. Its consolidated assets have swelled to $2.2 trillion from $915 billion in about 11 months, and contain at least a half-dozen items that weren't there before. ... 'If the Fed had been [a savings-and-loan] ballooning its balance sheet so fast, the supervisors would have been all over it,' says Ed Kane, a Boston College finance professor. Yet others see a willy-nilly series of moves that didn't weed out insolvent banks. Boston College's Kane blames Treasury Secretary Henry Paulson for frightening Congress into parting with $700 billion. ... 'The Fed has violated two principal tenets of central banking,' says Lee Hoskins, former president of the Cleveland Fed: 'First, don't lend to insolvent institutions, and second, don't lend on anything but the most pristine collateral'--and at a penalty rate", Jack Willoughby at Barron's, 24 November 2008.

Yes.