of financial records in accordance with the procedures authorized by Title 26.” Title 26 is, of course, a reference to the Internal Revenue Code, and includes the summons provision at issue in this case, 26 U.S.C. § 7609. In response, plaintiff contends that the RFPA exception for disclosures “authorized by Title 26” does not apply here because defendants violated Title 26 when they faded to obtain the signature of an “approving officer.” Pl.’s Opp’n at 10-11. First, under the plain language of 12 U.S.C. § 3413(c), the RFPA does not apply to summonses issued pursuant to 26 U.S.C. § 7609 because, to state the obvious, they are summonses “in accordance with the procedures authorized by Title 26.” See Grant v. IRS, No. 06-CV-402-JMH, 2007 WL 2174731, at *4 (E.D.Ky. July 27, 2007) (<HOLDING>); Bell v. United States, 521 F.Supp.2d 456,
holding that the federal register notice requirements do not apply to federal criminal statutes holding that the notice requirements of section 101101 do not apply to employees because they are not governmental units holding a bank liable where a bank officer held checks that were intended to pay the irs for withheld taxes holding that the notice requirements of 38 usc  5103a do not apply to motions based on clear and unmistakable error holding that under the plain language of  3413c the rfpas notice requirements  simply do not apply to irs subpoenas referring to a summons issued to a bank under 26 usc  7609