"the bank will thoroughly evaluate the projected cash flows from the project and will have an independent appraiser appraise the property."

"they typically take information provided to the bank by the guarantor about his assets and make some estimate , based on the knowledge they have of what those assets might actually be worth within a range."

If you at the bank, then fail to recognize that he claimed the "tower penthouse was three times larger than it actually is. Like failing to reveal deed restrictions on Mar-a-Lago, that significantly reduce its market value." that this isn't a failure to do your due diligence and you wouldn't be fired for being so bad at your job? Would you feel the same if Hoodeac claimed his house was 10K sq ft instead of 2500 to come to his claimed valuation? That it's his fault, not your failure, that you accepted that rather than doing your job?

And even if we take your interpretation, that these poor little innocent banks couldn't possibly have known about these fraudulent representations, please tell us how you possibly get to justifying a $355M fine. You and everyone knows this will be drastically chopped down if not entirely struck down. But you don't care, the politicizing of our courts has done its job, and all you care about is that when that happens, well after the election, you'll be able to once again hope to utter those famous Harry Reid words "we won".