What is the test for maintaining a claim against an insolvent national bank in receivership?

It is central to the plan that a claim against an insolvent national bank in receivership cannot be maintained unless the liability of the bank accrued and became unconditionally fixed on or before the declaration of insolvency. To state it another way, such a claim must be due and owing at the time of the insolvency, 12 U.S.C. 194 & 1821(d), otherwise it does not constitute a claim against a receiver regardless of what other rights the obligee may have. This rule was reaffirmed in Kennedy v. Boston-Continental Nat'l Bank, 84 F.2d 592, 597 (1st Cir. 1936), cert. dismissed, 300 U.S. 684, 57 S.Ct. 667, 81 L.Ed. 887 (1937), where in referring to a lease claim against an insolvent national bank the court said: