On July 22, 2019, the U.S. Court of Appeals for the Eleventh Circuit dealt another blow to bank directors, upholding the award of damages to the FDIC in the case FDIC v. Loudermilk, which involved the former directors of Buckhead Community Bank. The case was perhaps best known for defining Georgia’s business judgment rule, at least until the Georgia General Assembly reacted by defining the standard of liability for directors and officers in a manner more consistent with prior expectations.