may be imposed by bank regulatory agencies under other provisions of this bill.”). The report goes on to suggest that three separate penalties "for thé same violation” are possible — (1) criminal fines, (2) civil penalties under Section 1833a, and (3) civil penalties under Section 1818(i). Id. 138 . See Serpico, 320 F.3d at 694 (recognizing deterrence as principal thrust of FIRREA enhanced criminal/civil provisions); Ghavami, 2012 WL 2878126 at *5 (same). 139 . Cf. United States v. Menendez, No. 11 Civ. 6313(MMM), 2013 WL 828926, *6 (C.D.Cal. Mar. 6, 2013) (setting forth factors court would use to assess Section 1833a penalty, which included inter alia defendant’s “financial condition and ability to pay’’); Advance Pharmaceutical, Inc. v. United States, 391 F.3d 377, 399 (2d Cir.2004) (<HOLDING>); 12 U.S.C. § 1818(i)(2)(G)(i) (permitting
holding that defendants ability to pay may be considered in assessing penalty under controlled substances act holding that conduct designated as a felony under state law but as only a misdemeanor under the controlled substances act does not qualify as an aggravated felony holding that the legislature intended for multiple punishments when a defendant makes a single act of possessing different types of controlled substances holding  1227a2bi limits the meaning of controlled substance for removal purposes to the substances controlled under  802 holding that under section 172550 two prior violations of the controlled substances act occurring in the same incident should be treated as one offense and noting that if multiple prior convictions are obtained for violations of the controlled substance act unrelated to one another and not arising out of a single incident there is no prohibition against counting each conviction separately for sentencing purposes