Bank casts “some doubt” on Atlantic Financial, although it remarked that Central Bank did not involve theories of vicarious liability, like agency. Dinco v. Dylex Ltd., 111 F.3d 964, 968 (1st Cir.1997). Many courts have held that Central Bank does not bar a principal’s liability for its agents’ misstatements. Some circuits have espoused the contrary view. See Dinco, 111 F.3d at 968 (“The phrase ‘vicarious liability5 is something of a trap where used promiscuously to embrace markedly different theories of third-party liability, such as agency, partnership, and civil conspiracy. Central Bank involved none of those concepts, but rather rejected ‘aiding and abetting’ liability under section 10(b).... ”); Suez Equity Investors, L.P. v. Toronto-Dominion Bank, 250 F.3d 87, 101 (2d Cir.2001) (<HOLDING>); AT & T Co. v. Win-back & Conserve Program,
holding that the principal is liable for an agents acts committed within the scope of the agents employment holding that corporation will be liable under false claims act if agent acts with apparent authority even if corporation received no benefit from agents fraud recognizing that agents of a corporation may be held criminally responsible for crimes committed in the name of the corporation holding that central bank did not shield business entities from being held liable for misstatements of their agents since a corporation can only act through its employees and agents  an allegation that a particular agent may have doctored or conveyed the report will not immunize the principals from liability for a knowing deception holding that parties who knowingly receive benefits from agents efforts cannot later deny their liability to him as principals