D

D'Oench, Duhme bars parties from 'rely[ing] on an oral agreement between [a failed bank and its customer] as the basis for defenses or claims against the FDIC.' Lemaire v. FDIC, 20 F.3d 654, 657 (5th Cir. 1994). Enacted in 1950, not long after the Supreme Court decided D'Oench, Duhme, section 1823(e) codifies that common law ruling. Bowen v. FDIC, 915 F.2d 1013, 1015 n.3 (5th Cir. 1990). The statute provides that any 'agreement which tends to diminish or defeat the interest of the [FDIC] in any asset acquired by it under this section' shall not 'be valid against the [FDIC] unless such ...