Colum.L.Rev. at 290-92. 13 . We do not mean to say that the result in FAIC Securities was incorrect. The court’s finding that the brokers satisfied article III standing requirements was sufficient to establish the broker’s standing. Since the brokers were challenging the regulations as ultra vires the FDIA and the NHA, they were not required to establish that the interest they asserted fell within the zones of interests of those statutes. The zone of interests requirement thus was either inapposite or satisfied. See infra note 14. Nor was there any independent need for the brokers to establish third party standing since the legal right they asserted — the right not to be injured by unauthorized agency action — was their own. See Air Reduction Co. v. Hickel, 420 F.2d 592 (D.C.Cir.1969) (<HOLDING>); cf. Schnapper v. Foley, 667 F.2d 102
holding that helium producers had standing to enjoin the secretary of the interior from enforcing regulation requiring government contractors to purchase their helium needs from the secretary  a regulation claimed and held to be in excess of statutory authority holding a search of a probationers home pursuant to a wisconsin probation regulation was permissible under a special needs theory but not addressing whether the probationer had consented to the search under the regulation recognizing that the regulation was drafted pursuant to direct statutory authority holding that the challenge to a university regulation was moot because the regulation had been substantially amended holding that where a regulation could not fairly be read to have spoken at all on an issue an agencys proposed interpretation of the regulation as it pertained to that issue was not a reasonable interpretation of the regulation