Last week, in U.S. ex rel. Advocates for Basic Legal Equality, Inc. v. U.S. Bank , the Sixth Circuit affirmed the dismissal of a False Claims Act suit against U.S. Bank because the conduct alleged by the qui tam relator had previously been publicly disclosed in a consent order with the Office of the Comptroller of the Currency and in an interagency report by the Federal Reserve, OCC, and Office of Thrift Supervision.