BFA’s Religious Exemption
BFA operated in a manner similar to a bank in many respects. Its investment products were similar to those sold by financial institution. Its trust department, which was fully authorized by the federal government to serve as a passive trustee of IRAs, was similar to a trust department at a bank. BFA also made real estate loans in a manner similar to a bank. Because of its bank like operations and products, BFA faced several risk factors that affect banks and other savings institutions, such as interest rate risk and liquidity risk.