JUSTICE O'CONNOR delivered the opinion of the Court.
This case presents the question whether Congress granted the Federal Savings and Loan Insurance Corporation (FSLIC), as receiver, the exclusive authority to adjudicate the state law claims asserted against a failed savings and loan association. We hold that Congress did not grant FSLIC such power, and that the creditors of a failed savings and loan association are entitled to de novo consideration of their claims in court. We also hold that creditors are not required to exhaust FSLIC's current administrative claims procedure before filing suit, because the lack of a clear time limit on FSLIC's consideration of claims renders the administrative procedure inadequate.
I
From 1983 to 1986, Coit Independence Joint Venture (Coit), a real estate concern, borrowed money from FirstSouth, F.A. a federal savings and loan association. Subsequent disagreements led Coit to file suit against FirstSouth in October, 1986, in the 95th Judicial District Court of Dallas County, Texas. In its state court complaint, Coit alleged that it had received two loans of $20 million and $30 million to purchase two parcels of undeveloped land. Coit alleged that FirstSouth had required it to pay a "profit participation" interest in any profits derived from sale of the property as a condition of receiving the loans. Coit asserted that this "profit participation" fee was interest that, when added to the regular accrued interest rate, made the loans usurious under Texas law. Complaint 4-13, App. 17-22. Coit also alleged that FirstSouth orally agreed to allow Coit to draw down funds to improve the property purchased with the $30 million loan, and to carry the loan, by executing any necessary renewal notes, for at least five years unless the property was sold earlier. Coit charged that FirstSouth violated this agreement in August, 1986, by refusing to renew the notes and threatening to foreclose on the property.
Coit sought damages from FirstSouth for usury. Alternatively, Coit sought a declaratory judgment that FirstSouth was Coit's partner by virtue of its profitsharing interest in the joint venture, and that FirstSouth had breached its fiduciary duty and its implied duty of good faith and fair dealing. Complaint 11-16, App. 21-23. Coit also sought a declaration that any outstanding note was unenforceable.
On December 4, 1986, two months after Coit filed suit in state court, the Federal Home Loan Bank Board (Bank Board) determined that FirstSouth was insolvent, and appointed FSLIC as receiver. Substituting itself for FirstSouth in Coit's state suit, FSLIC removed the case to federal court. In February, 1987, the District Court dismissed the suit for lack of subject matter jurisdiction, relying on North Mississippi Savings & Loan Assn. v. Hudspeth, 756 F.2d 1096 (CA5 1985), cert. denied, 474 U.S. 1054 (1986).
In Hudspeth, the Court of Appeals for the Fifth Circuit held that FSLIC has exclusive jurisdiction to adjudicate claims against the assets of an insolvent savings and loan association placed in a FSLIC receivership, subject first to review by the Bank Board and then to judicial review under the Administrative Procedure Act. 756 F.2d at 1103. The Hudspeth court relied on two statutory provisions in reaching this conclusion. First, 12 U.S.C. § 1464(d)(6)(C) states that,
[e]xcept as otherwise provided in this subsection, no court may… except at the instance of the Board, restrain or affect the exercise of powers or functions of a conservator or receiver.
Second, 12 U.S.C. § 1729(d) provides that,
[i]n connection with the liquidation of insured institutions, [FSLIC] shall have power… to settle, compromise, or release claims in favor of or against the insured institutions, and to do all other things that may be necessary in connection therewith, subject only to the regulation of the Federal Home Loan Bank Board.
The Hudspeth court reasoned that Congress, by these provisions, intended that FSLIC should be able to act quickly in liquidating failed institutions and "not be interfered with by other judicial or regulatory authorities." 756 F.2d at 1101.
The Fifth Circuit rejected Hudspeth's argument that adjudication of claims against a debtor, as opposed to allocation of assets to satisfy those claims, is not a receivership function, and thus that judicial resolution of claims would not "restrain or affect" FSLIC's powers as receiver. The court reasoned that judicial "resolution of even the facial merits of claims… would delay the receivership function of distribution of assets," and that "such a delay is a restraint' within the scope of the statute." Id. at 1102. The court found further support for its reading of the statute in the Board's regulations giving FSLIC the power to disallow claims not "proved to its satisfaction," 12 CFR §§ 549.4, 569a.8 (1988), which the court took to mean the power to adjudicate claims. 756 F.2d at 1102, and n. 5.
Since Hudspeth was decided, FSLIC has successfully urged state and federal courts to dismiss a broad variety of claims for lack of subject matter jurisdiction. Those creditor claims have included contract and tort claims, see, e.g., Resna Associates, Ltd. v. Financial Equity Mortgage Corp., 673 F.Supp. 1371, 1372 (NJ 1987), alleged antitrust violations, Red Fox Industries, Inc. v. FSLIC, 832 F.2d 340 (CA5 1987), and even racketeering claims, Baer v. Abel, 637 F.Supp. 343, 347 (WD Wash.1986).
In the instant case, Coit appealed the District Court's dismissal of its case for lack of subject matter jurisdiction to the Fifth Circuit. That court acknowledged that, since Hudspeth was decided, two other courts had held that Congress did not intend FSLIC to enjoy exclusive jurisdiction over creditors' state law claims against savings and loan associations under FSLIC receivership. Morrison-Knudsen Co. v. CHG International, Inc., 811 F.2d 1209 (CA9 1987), cert. dism'd sub nom. FSLIC v. Stevenson Assocs., 488 U.S. 935 (1988); Glen Ridge I Condominiums, Ltd. v. FSLIC, 734 S.W.2d 374 (Tex.App.1986), writ of error denied, 750 S.W.2d 757 (Tex.1988), cert. pending, No. 88-659. However, the Fifth Circuit held that it was bound by Hudspeth, and affirmed the District Court's dismissal of Coit's suit. The court also concluded that Coit's constitutional challenges to exclusive FSLIC jurisdiction were not ripe for review. Coit Independence Joint Venture v. FirstSouth, F.A. 829 F.2d 563, 565 (CA5 1987).
On September 28, 1987, the deadline established by FSLIC for the filing of creditor claims against FirstSouth, Coit filed its proof of claim with FSLIC for approximately $113 million. Six months later, FSLIC notified Coit that its claim had been "retained for further review." There has been no further action on Coit's claim.
We granted certiorari to resolve the conflict in the lower courts over whether FSLIC has exclusive authority to adjudicate the validity of creditors' state law claims against failed savings and loan associations under a FSLIC receivership. 485 U.S. 933 (1988). We now reverse.
II
Resolution of this case requires us to interpret statutory provisions governing FSLIC and the Bank Board that were enacted over a span of 50 years. Moreover, those provisions are embedded in a complex statutory framework. Prior to the Great Depression of the 1930's, savings and loan associations were chartered and regulated by the States alone. However, in the face of heavy withdrawals from savings accounts, mortgage loan defaults, and limited funds for home mortgages during the depression, Congress passed the Federal Home Loan Bank Act, 47 Stat. 725, now codified, as amended, 12 U.S.C. § 1421 et seq. That Act provided for the creation of up to 12 federal home loan banks throughout the country whose function was to loan money to savings and loan associations and to certain other mortgage lenders. 47 Stat. 726, 12 U.S.C. § 1423. The Act also created the Federal Home Loan Bank Board to oversee the 12 home loan banks and to raise funds for them by selling bonds. 47 Stat. 736, 12 U.S.C. § 1437. See T. Marvell, The Federal Home Loan Bank Board 20 (1969).
One year later, Congress enacted the Home Owners' Loan Act of 1933 (HOLA), which empowered the Bank Board to organize, regulate, and charter federal savings and loan associations. 48 Stat. 128, as amended, 12 U.S.C. § 1461 et seq. The HOLA also gave the Bank Board the power to prescribe rules and regulations for the
reorganization, consolidation, merger, or liquidation of such associations, including the power to appoint a conservator or a receiver to take charge of the affairs of any such association.
HOLA, § 5(d), 48 Stat. 133, now codified, as amended, 12 U.S.C. § 1464(d)(11).
In 1934, Congress established FSLIC to insure the accounts of all federal savings and loan associations and certain state-chartered associations. National Housing Act (NHA), § 402(a), 48 Stat. 1256, as amended, 12 U.S.C. § 1725(a). If an insured institution was in default, FSLIC was required by the NHA to either pay depositors the insured amount of their account or to transfer the insured account to an insured institution not in default. NHA, § 405(b), 48 Stat. 1259, as amended, 12 U.S.C. § 1728(b). If a federal savings and loan association was in default, FSLIC was to be appointed conservator or receiver, and was authorized
(1) to take over the assets of and operate such association, (2) to take such action as may be necessary to put it in sound and solvent condition, (3) to merge it with another insured institution, (4) to organize a new Federal savings and loan association to take over its assets, or (5) to proceed to liquidate its assets in an orderly manner, whichever shall appear to be to the best interests of the insured members of the association in default; and in any event [FSLIC] shall pay the insurance as provided in section 405 and all valid credit obligations of such association.
NHA, § 406(b), 48 Stat. 1260, now codified, as amended, 12 U.S.C. § 1729(b)(1). FSLIC could also accept appointment as receiver of a state-chartered insured institution, assuming the same powers and duties as those with respect to a federal institution. NHA, § 406(c), 48 Stat. 1260, as amended, 12 U.S.C. § 1729(c)(1)(A). In the event that FSLIC liquidated a failed savings and loan, the NHA provided:
[FSLIC] shall have power to carry on the business of and to collect all obligations to the insured institutions, to settle, compromise, or release claims in favor of or against the insured institutions, and to do all other things that may be necessary in connection therewith, subject only to the regulation of the court or other public authority having jurisdiction over the matter.
NHA, § 406(d), 48 Stat. 1260, now codified, as amended, 12 U.S.C. § 1729(d).
In the Housing Act of 1954, Congress amended both the NHA and the HOLA. The Housing Act amended § 5(d) of the HOLA by setting forth specific grounds for the Bank Board's appointment of a conservator or receiver for a federal savings and loan association, such as insolvency, violation of law or regulation, concealment of books or records, and unsound operation. Housing Act of 1954, § 503, 68 Stat. 635-636, as amended, 12 U.S.C. § 1464(d)(6)(A). The Housing Act required formal administrative hearings, subject to judicial review under the Administrative Procedure Act, before a conservator or receiver could be appointed. § 503, 68 Stat. 636.
The first major amendments to the 1934 NHA were made in the Financial Institutions Supervisory Act of 1966 (FISA), Pub.L. 89-695, 80 Stat. 1028, 1036, now codified, as amended, 12 U.S.C. §§ 1464, 1730 (1982 and Supp. IV). This Act gave the Bank Board a more flexible array of enforcement powers, short of placing thrifts in receivership or terminating their insurance, to prevent insured institutions from violating laws or regulations or engaging in unsafe and unsound practices. The FISA also gave the Bank Board authority, with respect to federal savings and loan associations, to appoint a conservator or receiver ex parte and without notice if certain grounds existed, including insolvency, substantial dissipation of assets due to violations of law or unsafe or unsound practices, willful violation of a cease-and-desist order, or concealment of books, papers, records, or assets. FISA, 80 Stat. 1032-1033, 12 U.S.C. § 1464(d)(6)(A).
If the Bank Board appointed a conservator or receiver, the savings and loan association could, within 30 days, bring an action in United States district court "for an order requiring the Board to remove such conservator or receiver." Ibid. It is in this context that the following language, relied on by the Fifth Circuit in Hudspeth, first appeared:
Except as otherwise provided in this subsection, no court may take any action for or toward the removal of any conservator or receiver, or, except at the instance of the Board, restrain or affect the exercise of powers or functions of a conservator or receiver.
FISA, 80 Stat. 1033, 12 U.S.C. § 1464(d)(6)(C). The FISA also added greater scope to the Bank Board's power to make rules and regulations, including rules and regulations governing the liquidation of failed savings and loan associations and the conduct of receiverships. FISA, 80 Stat. 1035, 12 U.S.C. § 1464(d)(11).
Subsequent statutes have extended the Bank Board's power to appoint FSLIC as receiver of insolvent state-chartered thrifts. See Bank Protection Act of 1968, Pub.L. 90-389, § 6, 82 Stat. 295-296, as amended, 12 U.S.C. §§ 1729(c)(2), 1729(c)(3); Garn-St. Germain Depository Institutions Act of 1982, Pub.L. 97-320, § 122(d), 96 Stat. 1482, 12 U.S.C. § 1729(c)(1)(B); Competitive Equality Banking Act of 1987, Pub.L. 100-86, § 509(a), 101 Stat. 635, note following 12 U.S.C. § 1464 (1982 ed., Supp. V).
Once FSLIC is appointed receiver of an insolvent savings and loan association, FSLIC steps into the shoes of the association and takes control of its assets. If FSLIC liquidates the association, it must promptly reimburse insured depositors out of its insurance fund. 12 U.S.C. § 1728(b). If FSLIC is not satisfied regarding the validity of a depositor's claim, "it may require the final determination of a court of competent jurisdiction before paying such claim." Ibid. FSLIC then satisfies the claims of uninsured creditors to the extent that the association's assets permit it to do so. Because FSLIC is subrogated to the rights of the insured depositors whom it has reimbursed, FSLIC is normally the single largest claimant against the assets of a failed savings and loan association, and generally recoups a substantial portion of its insurance payouts from those assets. See Morrison-Knudsen Co., 811 F.2d at 1215-1216; Note, 10 W.New Eng.L.Rev. 227, 229-230 (1988).
III
Coit argues that Hudspeth incorrectly held that Congress granted FSLIC adjudicatory power over creditors' claims against failed savings and loan associations under FSLIC receivership, subject only to limited judicial review in the courts under the Administrative Procedure Act, 5 U.S.C. § 551 et seq. Although FSLIC argued below, invoking Hudspeth, that the District Court lacked subject matter jurisdiction over Coit's claims, the Solicitor General does not endorse that position. See Brief for Respondent 16, 17, 20, and n. 13, 39-40. Respondent concedes both that "the power conferred by HOLA and the NHA should not be characterized as a power of adjudication,'" id. at 17, and that the District Court had subject matter jurisdiction over Coit's claim. [ Footnote 1 ] Id. at 16-17, 39. Respondent also acknowledged at oral argument that a creditor suing in court is entitled to a " de novo determination" of its claim. Tr. of Oral Arg. 36. We agree. The statutes governing FSLIC and the Bank Board do not grant FSLIC adjudicatory power over creditors' claims against insolvent savings and loan associations under FSLIC receivership, nor do they divest the courts of jurisdiction to consider those claims de novo.
A
Congress granted FSLIC various powers in its capacity as receiver, but they do not include the power to adjudicate creditors' claims. Section 406 of the NHA conferred upon FSLIC the traditional powers of a receiver "to settle, compromise, or release claims in favor of or against the insured institutio[n]," 12 U.S.C. § 1729(d), and to "pay all valid credit obligations of the association," § 1729(b)(1)(B). Those essential functions of FSLIC as receiver have not changed since the enactment of the NHA in 1934. The plain language of §§ 1729(b) and 1729(d) cannot be read to confer upon FSLIC the power to adjudicate disputes with the force of law. The power to "settle, compromise, or release" claims both is distinguishable from the power to adjudicate and is, to some extent, inconsistent with it. As the Ninth Circuit reasoned in Morrison-Knudsen Co., 811 F.2d at 1219:
Settlement and compromise strongly suggest the presence of the power of the other party to take the dispute to court. Settlement and compromise are to avoid that result. A body with the power to say 'yes' or 'no' with the force of law has much less need to settle or to compromise.
Similarly, the directive that FSLIC as receiver "shall pay all valid credit obligations of the association" cannot be read to confer upon FSLIC the power to adjudicate claims against an insolvent savings and loan association subject only to review under the Administrative Procedure Act. This provision simply empowers FSLIC, much like an ordinary insurance company, to pay those claims proved to its satisfaction. It does not give FSLIC the power to adjudicate claims with the force of law; nor does it preclude claimants from resorting to the courts for a determination of the validity of their claims.
Moreover, §§ 1729(b) and 1729(d) do not exist in isolation, but are embedded within a complex statutory framework. Stafford v. Briggs, 444 U. S. 527, 444 U. S. 535 (1980) (" [I]t is well settled that, in interpreting a statute, the court will not look merely to a particular clause in which general words may be used, but will take in connection with it the whole statute'") (quoting Brown v. Duchesne, 19 How. 183, 60 U. S. 194 (1857)). The statutory framework in which § 1729 appears indicates clearly that, when Congress meant to confer adjudicatory authority on FSLIC, it did so explicitly, and set forth the relevant procedures in considerable detail. For example, in its role as supervisor of ongoing thrift institutions, FSLIC, together with the Bank Board, is empowered to adjudicate violations of federal law, to issue cease-and-desist orders, to remove officers and directors, and to impose civil sanctions. See 12 U.S.C. §§ 1464(d), 1730. The statutory provisions that confer this authority set forth with precision the agency procedures to be followed and the remedies available, with explicit reference to judicial review under the Administrative Procedure Act. See 12 U.S.C. §§ 1464(d)(7)(A), 1730(j)(2). It is thus reasonable to infer that, if Congress intended to confer adjudicatory authority upon FSLIC in its receivership capacity, it would have enacted similar provisions governing procedural and substantive rights and providing for judicial review.
The Hudspeth decision rested primarily on 12 U.S.C. § 1464(d)(6)(C). That provision, introduced in 1966 as § 101 of the FISA, 80 Stat. 1033, states that,
[e]xcept as otherwise provided in this subsection, no court may take any action for or toward the removal of any conservator or receiver, or, except at the instance of the Board, restrain or affect the exercise of powers or functions of a conservator or receiver.
(Emphasis added.) The Hudspeth court reasoned that judicial "resolution of even the facial merits of claims… would delay the receivership function of distribution of assets," and that "such a delay is a restraint' within the scope of the statute." 756 F.2d at 1102. We disagree.
First, this language does not add adjudication of creditor claims to FSLIC's receivership powers; it simply prohibits courts from restraining or affecting FSLIC's exercise of those receivership "powers and functions" that have been granted by other statutory sources. As discussed above, none of the statutes governing FSLIC and the Bank Board confers upon FSLIC the power to adjudicate claims against an insolvent savings and loan over which FSLIC has been appointed receiver.
Second, when the statutory context in which the provision appears is examined, it is clear that it does not have the meaning that Hudspeth attributed to it. Section 1464(d)(6)(A) sets forth the specific grounds for appointment of a receiver by the Bank Board, and expressly authorizes associations placed in receivership to bring suit within 30 days in United States district court to challenge the receiver's appointment. Following the provision for a court challenge to remove the receiver comes the statutory language prohibiting courts, "[e]xcept as otherwise provided in this subsection," from taking any action to remove the receiver or to "restrain or affect" the exercise of the receiver's "powers or functions." When read in its statutory context, this provision prohibits untimely challenges to the receiver's appointment or collateral attacks attempting to restrain the receiver from carrying out its basic functions. It does not divest state and federal courts of subject matter jurisdiction to determine the validity of claims against institutions under a FSLIC receivership. See Note, 10 W.New Eng.L.Rev. at 257-260; Baxter, Life in the Administrative Track: Administrative Adjudication of Claims Against Savings Institution Receiverships, 1988 Duke L.J. 422, 484-485.
That the "restrain or affect" language should not be read to preclude de novo court adjudication of the validity of creditors' claims against savings and loans in receivership is reinforced by the fact that, at the time of the statute's enactment, it was well established at common law that suits establishing the existence or amount of a claim against an insolvent debtor did not interfere with or restrain the receiver's possession of the insolvent's assets or its exclusive control over the distribution of assets to satisfy claims. Morris v. Jones, 329 U.S. 545, 329 U. S. 549 (1947); Riehle v. Margolies, 279 U. S. 218, 279 U. S. 224 (1929). As this Court discussed in Morris:
No one can obtain part of the assets or enforce a right to specific property in the possession of the liquidation court except upon application to it. But proof and allowance of claims are matters distinct from distribution…. 'The latter function, which is spoken of as the liquidation of a claim, is strictly a proceeding in personam. ' The establishment of the existence and amount of a claim against the debtor in no way disturbs the possession of the liquidation court, in no way affects title to the property, and does not necessarily involve a determination of what priority the claim should have.
329 U.S. at 329 U. S. 549 (citations omitted). Moreover, suits to establish the validity and amount of a claim against an insolvent national bank under a statutory receivership were not seen as interfering with the powers or functions of the receiver. See Bank of Bethel v. Pahquioque Bank, 14 Wall. 383, 81 U. S. 401 -402 (1872).
Looking to the practical effects of court adjudication on the receivership process, the Hudspeth court erroneously assumed that such adjudication would "restrain" FSLIC's exercise of its receivership powers by delaying its prompt liquidation of failed savings and loans. As this Court held in Riehle v. Margolies, a receiver's distribution of assets need not be postponed pending the resolution of disputed claims in other courts:
The power to fix the time for distribution may include the power… to decline to postpone distribution awaiting disposition of litigation in another court over a contested claim.
279 U.S. at 279 U. S. 224. See also 3 R. Clark, Law and Practice of Receivers § 649(c) (3d ed.1959). Indeed, the Bank Board's own regulations provide for interim distributions. See 12 CFR § 549.4(d) (1988) (allowing creditor claims to be paid by the receiver "from time to time, to the extent funds are available, in such manner and amounts as the Board may direct").
Finally, even if court adjudication of creditor claims delayed the distribution of assets, and thereby constituted a "restraint" on FSLIC's receivership functions, Hudspeth provides no explanation for why the delay resulting from judicial review of FSLIC's administrative claims procedure would constitute any less of a "restraint." In sum, judicial resolution of Coit's state law claims against FSLIC as receiver for FirstSouth simply would not "restrain or affect" FSLIC's exercise of its receivership functions within the meaning of § 1464(d)(6)(C).
C
Several provisions of the NHA indicate that Congress clearly envisaged that the courts would have jurisdiction over suits by creditors against FSLIC as receiver. When it established FSLIC in 1934, Congress provided that FSLIC could "sue and be sued, complain and defend, in any court of law or equity, State or Federal." NHA, § 402(c)(4), 48 Stat. 1256, now codified, as amended, 12 U.S.C. § 1725(c)(4). Moreover, in the Housing Act of 1954, Congress amended the NHA to establish a statute of limitations for actions against FSLIC to enforce deposit insurance claims, which were the most common type of claim in any thrift liquidation at the time. Housing Act of 1954, § 501(2), 68 Stat. 633, 12 U.S.C. § 1728(c). Most significantly, in 1966, in the very statute that contained the "restrain or affect" language of 12 U.S.C. § 1464(d)(6)(C), Congress provided an explicit grant of subject matter jurisdiction to the courts that clearly envisaged suits by creditors against FSLIC as receiver:
Notwithstanding any other provision of law,… (B) any civil action, suit, or proceeding to which [FSLIC] shall be a party shall be deemed to arise under the laws of the United States, and the United States district courts shall have original jurisdiction thereof, without regard to the amount in controversy; and (C) [FSLIC] may, without bond or security, remove any such action, suit, or proceeding from a State court to the United States district court… : Provided, That any action, suit, or proceeding to which [FSLIC] is a party in its capacity as conservator, receiver, or other legal custodian of an insured State-chartered institution and which involves only the rights or obligations of investors, creditors, stockholders, and such institution under State law shall not be deemed to arise under the laws of the United States.
FISA, 80 Stat. 1042, 12 U.S.C. § 1730(k)(1) (emphasis added). The proviso clause sets out the types of suits Congress expected FSLIC to defend against in state courts, including suits by creditors against FSLIC as receiver for state-chartered savings and loan associations. Moreover, there is no indication that Congress intended to treat state-chartered and federally chartered associations differently in this respect. See, e.g., 12 U.S.C. § 1729(c)(1)(A) (granting FSLIC the "same powers and duties" as receiver for defaulted state institutions as it has with respect to federal savings and loan associations). In sum, we conclude that Congress clearly envisaged that the courts would have subject matter jurisdiction over creditor suits against FSLIC.
Because we conclude that FSLIC has not been granted adjudicatory authority by Congress, and that Coit is entitled to de novo consideration of its state law claims in court, we need not reach Coit's claim that adjudication by FSLIC subject only to judicial review under the Administrative Procedure Act would violate Article III of the Constitution under Northern Pipeline Construction Co. v. Marathon Pipe Line Co., 458 U. S. 50 (1982). Similarly, we need not reach Coit's due process and Seventh Amendment challenges to adjudication by FSLIC of its state law claims. We note, however, that the usury and breach of fiduciary duty claims raised by Coit, like the contract disputes in Morrison-Knudsen Co., 811 F.2d at 1221, involve "private rights" which are at the "core" of "matters normally reserved to Article III courts." Commodity Futures Trading Comm'n v. Schor, 478 U. S. 833, 478 U. S. 853 (1986); Northern Pipeline, supra, at 458 U. S. 69 -72. The court below adopted an interpretation of the statutes governing FSLIC and the Bank Board that raises serious constitutional difficulties. In our view, those statutes can and should be read to avoid these difficulties. Schor, supra, at 478 U. S. 841 ; Crowell v. Benson, 285 U. S. 22, 285 U. S. 62 (1932).
IV
Although FSLIC argued below that the District Court lacked subject matter jurisdiction over Coit's state law claims, respondent now defends the Fifth Circuit's judgment on the narrower ground that
the Bank Board and FSLIC plainly do have power to require claimants first to present their claims to FSLIC, and exhaust the administrative process leading to allowance, settlement, or disallowance
before suing on the claims in court. Brief for Respondent 20, and n. 13. Coit does not challenge the Bank Board's authority to establish a voluntary claims procedure. Coit contends, however, that the statutory provisions relied on by FSLIC do not demonstrate a congressional intent to require exhaustion of administrative remedies by claimants before they can file suit in court. Reply Brief for Petitioner 3.
A
Our past cases have recognized that exhaustion of administrative remedies is required where Congress imposes an exhaustion requirement by statute. Weinberger v. Salfi, 422 U. S. 749, 422 U. S. 766 (1975); Myers v. Bethlehem Shipbuilding Corp., 303 U. S. 41, 303 U. S. 50 -51 (1938). Where a statutory requirement of exhaustion is not explicit,
courts are guided by congressional intent in determining whether application of the doctrine would be consistent with the statutory scheme.
Patsy v. Florida Board of Regents, 457 U. S. 496, 457 U. S. 502, n. 4 (1982). Moreover, "a court should not defer the exercise of jurisdiction under a federal statute unless it is consistent with that intent." Id. at 457 U. S. 501 -502.
Congress gave the Bank Board a broad statutory mandate to reorganize or liquidate an insolvent federal savings and loan, using FSLIC as receiver for that purpose. 12 U.S.C. § 1464(d)(6). As we have discussed above, Congress also expressly granted FSLIC as receiver the responsibility to "pay all valid credit obligations of the association," § 1729(b)(1)(B), to "liquidate its assets in an orderly manner," § 1729(b)(1)(A)(v), and to "settle, compromise, or release claims in favor of or against the insured institutions, and to do all other things that may be necessary in connection therewith," § 1729(d). Moreover, Congress gave the Bank Board the broad
power to make rules and regulations for the reorganization, consolidation, liquidation, and dissolution of associations,… and for the conduct of conservatorships and receiverships.
§ 1464(d)(11).
Over 45 years ago, the Bank