P submitted an application to D for a certificate authorizing them to organize a new bank. D denied the application with a brief letter, which stated in part: 'We have concluded that the factors in support of the establishment of a new National Bank in this area are not favorable.' No formal hearings were required. P did not request a formal hearing but asked for reconsideration. D granted the request and a supplemental field examination was conducted. D again denied the application in a letter that stated: 'We were unable to reach a favorable conclusion as to the need factor.' P brought suit in District Court. The court granted summary judgment against P, holding that de novo review was not warranted in the circumstances and finding that 'although D may have erred, there is a substantial basis for his determination, and . . . it was neither capricious nor arbitrary.' The court of appeals held that D's ruling was 'unacceptable' because 'its basis' was not stated with sufficient clarity to permit judicial review. It remanded the case 'for a trial de novo before the District Court' because D twice inadequately and inarticulately resolved P's presentation. D appealed.