Denkler v. United States
In Denkler v. United States, 782 F.2d 1003 (Fed.Cir.1986), the Court concluded that the Board of Governors of the Federal Reserve System ("Fed") was a non-appropriated funds instrumentality" ("NAFI") because its enabling statute, 12 U.S.C. 243-44:
(1) Requires the Fed to finance its own activities by taxing the Federal Reserve Banks, rather than by requesting appropriated funds;
(2) Explicitly states that the funds that the Fed receives from the Banks are not construed to be government funds or appropriated moneys;
(3) Unlike most enabling statutes, does not authorize appropriations. Denkler, 782 F.2d at 1004-05.