Quote: "Calabria said that conservatorship is essentially administrative bankruptcy, with him as the administrative bankruptcy judge. Therefore FnF being in conservatorship is the same as being in bankruptcy"
As I read the Collins Plaintiff brief, one of the central points of their argument is that FHFA cannot be BOTH conservator and receiver at the same time. According to HERA, the agency must formally notify congress if it takes on the role of Receiver. Therefore, to take actions as a receiver (liquidation) while only claiming the title of Conservator is a violation of APA.