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202.622.1419
Hotline: 877.SIG.2009
SIGTARP@treasury.gov
www.SIGTARP.gov

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SIGTARP: Quarterly Report to Congress | July 25, 2012

SIGTARP

Q3
2012

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SIGTARP

Office of the Special Inspector General
for the Troubled Asset Relief Program

Advancing Economic Stability Through Transparency, Coordinated Oversight, and Robust Enforcement

Quarterly Report to Congress
July 25, 2012

MISSION
SIGTARP’s Mission is to advance economic stability by promoting the
efficiency and effectiveness of TARP management, through transparency,
through coordinated oversight, and through robust enforcement against
those, whether inside or outside of Government, who waste, steal, or abuse
TARP funds.

STATUTORY AUTHORITY
SIGTARP was established by Section 121 of the Emergency Economic
Stabilization Act of 2008 (“EESA”) and amended by the Special Inspector
General for the Troubled Asset Relief Program Act of 2009 (“SIGTARP Act”).
Under EESA and the SIGTARP Act, the Special Inspector General has the
duty, among other things, to conduct, supervise, and coordinate audits and
investigations of any actions taken under the Troubled Asset Relief Program
(“TARP”) or as deemed appropriate by the Special Inspector General. In
carrying out those duties, SIGTARP has the authority set forth in Section 6 of
the Inspector General Act of 1978, including the power to issue subpoenas.

Office of the Special Inspector General
for the Troubled Asset Relief Program
General Telephone: 202.622.1419
Hotline: 877.SIG.2009
SIGTARP@treasury.gov
www.SIGTARP.gov

Contents
Executive Summary
Oversight Activities of SIGTARP
SIGTARP Recommendations on the Operation of TARP
Report Organization

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Section 1

The Office of the Special Inspector General for the
Troubled Asset Relief Program
SIGTARP Creation and Statutory Authority
SIGTARP Oversight Activities Since the April 2012 Quarterly Report
The SIGTARP Organization

Section 2

TARP Overview
TARP Funds Update
Financial Overview of TARP
Housing Support Programs
Financial Institution Support Programs
Asset Support Programs
Automotive Industry Support Programs

Section 3

AIG Remains in TARP as the Largest TARP Investment
Introduction
Rise and Fall of AIG Prior to TARP
Changes at AIG After the Government Bailout
AIG’s Current Businesses
AIG’s Changing Regulatory Environment

Section 4

TARP Operations and Administration
TARP Administrative and Program Expenditures
Current Contractors and Financial Agents

Section 5

SIGTARP Recommendations
Recommendations from SIGTARP’s Audit of the Hardest Hit Fund
Recommendations from SIGTARP’s Audit of the Net Present Value
Test’s Impact on the Home Affordable Modification Program
Update on Recommendation Regarding Hardest Hit Fund
Information Security
Endnotes

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Appendices
A.
Glossary
B.
Acronyms and Abbreviations
C.
Reporting Requirements
D.
Transaction Detail
E.
Cross-Reference of Report to the Inspector General Act of 1978
F.
Public Announcements of Audits
G.
Key Oversight Reports and Testimony
H.
Correspondence
I.
Organizational Chart

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Executive Summary

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special inspector general I troubled asset relief program

quarterly report to congress I July 25, 2012

Last quarter, SIGTARP reported that TARP’s legacies include white-collar crime
that SIGTARP is uncovering and stopping. This quarter, SIGTARP agents,
along with our law enforcement partners, arrested the CEO of TARP applicant
the Bank of the Commonwealth (“BOC”) of Norfolk, Virginia, and four other
bank executives for their alleged role in a massive fraud that contributed to the
bank’s 2011 collapse and the financial crisis.i The Federal Reserve Board Office
of Inspector General (“FRB OIG”) found that the bank’s regulator identified
fundamental weaknesses with the bank as early as 2000. However, the regulator
did not take advantage of multiple opportunities to “take stronger supervisory
action by implementing more aggressive enforcement actions.” Bank failures
have profound effects, including taxpayer losses for failed TARP banks;ii losses
to the FDIC’s fund that insures customer deposits; and losses to communities
that suffer from decreased access to lending for homes, small businesses, and
education. Bank failures fueled by fraud erode public confidence in the financial
system — confidence already down because of public perception of risky banking
practices, soaring executive compensation, and recent scandals. BOC’s failure and
the criminal charges provide lessons to be learned for the future. Banks should not
wait for the Government to catch fraud. Banks must better regulate risky practices,
strengthen internal controls, and eliminate opportunities to conceal losses. Banking
regulators must be vigilant in their examinations and enforcement to discover
risky practices and potential fraud that could threaten the safety and soundness of
banks. This is particularly true at the more than 300 banks left in TARP in which
taxpayers are investors. Only then will confidence in our nation’s banking system
and a sense of accountability be restored.

Bank Failures
Bank failures skyrocketed following the onset of the financial crisis, from zero to
five failures a year between 1995 and 2007, to an average of 107 per year from
2008 through 2011. According to FDIC, 2010 was the high-water mark for bank
failures post-crisis, with 157 bank failures. The pace of bank failures has slowed
since the 2010 peak, but continues at an elevated rate, with 38 bank failures so far
this year.
While the crisis in real estate markets undoubtedly factored into the spike in
bank failures, internal problems such as poor corporate governance, weak risk management, and weak internal controls were contributing factors as well. The Federal
Reserve Bank of Philadelphia stated in a 2009 article, “People often presume that
the challenging economy and sluggish housing market were the key drivers behind
these failures, particularly since many tended to be geographically clustered in
distressed regions. While the external economic environment certainly was influential, it was rarely a standalone factor in a bank’s demise. The root causes of problems
are often traced to inherent risk exposures or management weaknesses that become

i

	In November 2008, Bank of the Commonwealth applied for $28 million in TARP funds, but was asked by its banking regulator to
withdraw its application.
	As of June 30, 2012, 17 TARP banks have failed.

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more pronounced under stressful conditions and ultimately impair an institution’s
ability to weather adverse conditions.” This is borne out in SIGTARP’s criminal
investigations of failed TARP applicant and recipient banks.

SIGTARP’s Criminal Investigations
SIGTARP has found in some of its criminal investigations that the financial
crisis was a crossroads for many bank executives, particularly those at regional or
community banks, whose business models focused predominantly on real estate
loans. Thousands of bank executives faced bank losses during the financial crisis
without turning to fraud. Those bank executives told the truth about losses and
non-performing loans and adequately reserved for future losses or wrote off losses.
Others turned to crime. For some bankers committing fraud, the sudden availability
of TARP funds was seen as a way to play the float in concealing past due loans as
bankers waited for a market upturn. These bankers viewed the financial crisis as an
opportunity to extend their fraud by exploiting our nation’s vulnerability.
The financial crisis also unveiled fraud that had been ongoing for years, as
shrinking capital and increasing delinquent loans left bankers with nowhere to
hide. For example, the criminal charges against five BOC executives and seven coconspirators highlight a massive bank fraud at the highest levels of management,
fueled by greed that included an unsuccessful attempt to use TARP funds.iii BOC
was the eighth largest bank failure in 2011, with an FDIC-estimated loss of $268
million. The indictment alleges that for years the bankers fraudulently masked
the bank’s condition out of fear that the bank’s declining health would negatively
impact investor and customer confidence. According to the charges, many of the
bank’s loans were funded and administered without regard to industry standards or
the bank’s own internal controls.
FRB OIG reported on the causes of the bank’s failure, including corporate
governance weaknesses, insufficient risk management practices, and pervasive
internal control weaknesses that when combined with deteriorating real estate
markets led to rapid asset quality deterioration. The bank failed to acknowledge
the extent of its problem loans and adequately reserve for losses. FRB OIG
reported that the bank’s supervisor, FRB Richmond, identified the bank’s
fundamental weaknesses in 2000, but did not take early and decisive action to
resolve those weaknesses. The regulator identified broad authority in the hands
of CEO Edward Woodard, an ineffective board that had not monitored risks, and
a weak internal audit function. FRB OIG reported that the failure to implement
appropriate risk management and internal controls created the opportunity for
the bank to engage in unsafe and unsound practices designed to mask the bank’s
true financial condition. In FRB OIG’s opinion, more forceful supervisory action
through enforcement actions or downgrades could have mitigated losses.

	Federal indictments are only charges and not evidence of guilt. A defendant is presumed to be innocent until and unless proven guilty.

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quarterly report to congress I July 25, 2012

These findings, along with allegations in the criminal charges resulting from
SIGTARP’s investigation, provide an opportunity for banks and their regulators
to take advantage of lessons learned. This is particularly true for banks in which
taxpayers still hold a TARP investment. Banks should not wait for the Government
to catch these schemes. Banks should engage in strong corporate governance and
internal controls to expose risky practices that could threaten the bank’s health.
Banking regulators have an opportunity to strengthen their examination
processes, including educating their examiners on identifying indicators of fraud
schemes in the BOC case and other SIGTARP cases that could impact the safety
and soundness of a bank. These schemes, as described below, are not isolated to
the few examples cited in this summary.

Common Fraud Schemes to Mask a Bank’s Financial
Conditioniv
Extend and Pretend Schemes
SIGTARP has uncovered “extend and pretend” schemes, by which bank insiders
create the illusion that a past-due loan is current. Methods include extending the
due date of a payment, changing loan terms, and creating new loans that bankers
know will be used not for the stated purpose, but instead to generate proceeds to
bring delinquent loans current. The bankers do not expect any payments to be
made on the new loans and eventually write off losses on the new loans. In these
schemes, bankers falsify the books and records to avoid reporting past-due loans
and to increase the amount of new loans.
BOC allegedly engaged in an “extend and pretend” scheme. CEO Edward
Woodard, his son bank officer Troy Brandon Woodard, and executive vice presidents Simon Hounslow and Stephen Fields were charged with overdrawing deposit
accounts to make loan payments, extending new loans or additional principal on
existing loans to cover payment shortfalls, changing the terms of loan agreements
to make loans appear current, and using funds from related entities to make loan
payments. According to the criminal charges, the bank funded new loans without
current borrower financial statements, without adequate collateral, and without
current appraisals for collateral. BOC loan officer Jeremy Churchill pled guilty to
submitting false information for new loans to developer Dwight Etheridge (also
charged), who allegedly used the proceeds to pay down his existing delinquent loan.
Another SIGTARP investigation demonstrating an “extend and pretend”
scheme involved failed, TARP-approved, First Community Bank in Hammond,
Louisiana. There, former CEO Reginald Harper and developer Troy Fouquet pled
guilty to fraud in which they knowingly hid Fouquet’s delinquent loans through a
number of methods to extend and pretend. This fraud impacted the bank’s $3.3
million TARP application, which the bank withdrew after Treasury approval.

	The discussion of charges that follows is based on Federal indictments. Federal indictments are only charges and not evidence of guilt.
A defendant is presumed to be innocent until and unless proven guilty. SIGTARP has noted where the defendant pled guilty.

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Fraudulent Construction Draws
Banks may fund fraudulent draws on construction loans for work not completed
and use the proceeds to make it appear that delinquent loans are current. BOC
CEO Woodard is charged with funding eight fraudulent construction draws to
developer Dwight Etheridge, who was also charged, and who allegedly used the
proceeds to pay down his past-due BOC loans. BOC loan officer Churchill and
Etheridge’s vice president Recardo Lewis pled guilty to this scheme. BOC vice
president Stephen Fields is charged with funding fraudulent construction draws to
customers Menden and George Hranowskyj (who both pled guilty), without Fields
verifying that work was completed.v
Bank-Financed Sales of Bank-Owned Property or Troubled Loans
BOC CEO Woodard and three other bank executives are charged with funneling
bank-owned property (such as property the bank took over in foreclosure) to certain
borrowers who were delinquent on loans, to the detriment of the bank. It is alleged
that in exchange for preferential treatment on delinquent loans and no-questionsasked new loans, Menden (who pled guilty) used “straw purchasers” who were
Menden’s employees to buy bank-owned property. It is alleged that these “sales”
allowed the bank to take the properties off the bank’s books. The bank allegedly
concealed that it funded these purchases.
As a result of another SIGTARP investigation, Jerry Williams, CEO and chairman of TARP applicant Orion Bank of Naples, Florida, Thomas Hebble, executive
vice president, and Angel Guerzon, senior vice president, were sentenced to prison
for concealing that the bank financed the sale of notes secured by non-performing
mortgages. This fraudulently took the loans off the bank’s books.
Roundtrip Transactions Creating the Illusion of Capital Infusions
In these schemes a bank’s books fraudulently reflect that an investor infused capital
into the bank by buying stock. The capital infusion is not genuine because the
buyer actually used the bank’s own money to purchase the stock. The three Orion
Bank executives and bank borrower Francesco Mileto were sentenced to prison for
concealing the bank’s financing of the sale of Orion stock to Mileto’s associates.
Their fraud created the illusion of a $15 million capital infusion into the bank.
Delay and Pray Schemes
In a typical “delay and pray” scheme, bankers with knowledge of facts relating to
the likelihood of loans not being repaid delay recognizing those facts in their bank’s
books. This scheme, as with all the schemes above, typically involves falsification
of the bank’s books and records, and fraudulently concealing the status of loans
from regulators to make it appear that loans are current or that they are likely to
be repaid.

	In some instances bank insiders personally benefit from the fraud. BOC CEO Edward Woodard and his bank officer son Troy Brandon
Woodard were charged with having the bank fund fraudulent draws for construction on a bank branch when the true costs were for
renovating the son’s residence.

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quarterly report to congress I July 25, 2012

As a result of an ongoing SIGTARP investigation, Ebrahim Shabudin, executive vice president, and Thomas Yu, senior vice president, of TARP recipient United
Commercial Bank (“UCB”) of San Francisco, California, were charged with hiding
the bank’s true financial condition from investors, depositors, regulators, Treasury,
and the bank’s auditor. According to the indictment, the objective of the fraud
scheme was to conceal, delay, and avoid publicly reporting the bank’s number of
impaired loans and the bank’s true loan loss. The indictment charged that the
defendants used a variety of fraudulent accounting maneuvers and techniques
to conceal that they falsified the bank’s books and records. It is alleged that they
delayed downgrading the risk ratings of certain loans and falsified the bank’s books
and records, falsely describing or omitting information necessary to describe the
likelihood that certain loans would be repaid and the value of the collateral and
repossessed assets. UCB was the first TARP bank to fail. Taxpayers will suffer a
complete loss on the $298 million TARP investment. The FDIC estimates that
deposit insurance fund losses will be $2.5 billion.

Preventing Fraud and Bringing Accountability
Banks and their regulators have an opportunity to implement lessons learned
from the schemes SIGTARP uncovered in the Bank of the Commonwealth and
other cases. They can proactively detect and prevent fraudulent practices before
a bank fails and bring accountability where fraud is found. As was evident in the
BOC case, these schemes can impact the safety and soundness of the bank and
may ultimately contribute to the bank’s failure. Bank examiners should therefore
be on the alert to detect these and other schemes SIGTARP has uncovered and
be vigilant in enforcement. Banks should not wait for Government action. Banks
themselves must embrace the importance of self-regulation through effective
corporate governance, risk management, and a “checks and balances” system
of controls. Bank executives should expound these principles by virtue of their
leadership and fiduciary duties. Banks and bank regulators should report fraud
to law enforcement. Banks and their regulators must demonstrate strong will,
capability, and commitment to detecting and preventing bank failures and fraud.
In doing so, they can reassure American taxpayers of accountability and increase
market confidence in our banking system. SIGTARP is committed to uncovering
fraud related to TARP and bringing justice and accountability to the American
taxpayers. Confidence and public trust in banks and banking regulators are
fundamental to ensuring stability in our financial system.

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Oversight Activities of SIGTARP
SIGTARP actively strives to fulfill its audit and investigative functions. Since its
inception, SIGTARP has issued 19 published reports on audits and evaluations
as of June 30, 2012. Two audit reports have been published since the end of last
quarter: “Factors Affecting Implementation of the Hardest Hit Fund Program”
and “The Net Present Value Test’s Impact on the Home Affordable Modification
Program.” Section 1 of this report, “The Office of the Special Inspector General for
the Troubled Asset Relief Program,” discusses these two recently released reports.
SIGTARP is a white-collar law enforcement agency. As of July 12, 2012,
SIGTARP had more than 150 ongoing criminal and civil investigations, many in
partnership with other law enforcement agencies in order to leverage resources
throughout the Government. SIGTARP takes its law enforcement mandate seriously,
working hard to deliver the accountability the American people demand and deserve.
SIGTARP’s investigations have delivered substantial results, including:
• criminal charges against 91 individuals, including 64 senior officers (CEOs,
owners, founders, or senior executives) of their organizations
• criminal convictions of 67 defendants, of whom 28 have been sentenced to
prison (others are awaiting sentencing)
• civil cases against 51 individuals (including 37 senior officers) and 26 entities
(in some instances an individual will face both criminal and civil charges)
• orders of restitution and forfeiture and civil judgments entered for more than $4
billion. This includes restitution orders entered for $3.7 billion, forfeiture orders
entered for $126.9 million, and civil judgments and other orders entered for
$281.9 million. Although the ultimate recovery of these amounts is not known,
SIGTARP has already assisted in the recovery of $160.8 million
• savings of $553 million in TARP funds that SIGTARP prevented from going to
the now-failed Colonial Bank
Although much of SIGTARP’s investigative activity remains confidential, over
the past quarter there have been significant public developments in several of
SIGTARP’s investigations. See Section 1 of this report, “The Office of the Special
Inspector General for the Troubled Asset Relief Program,” for a description of
recent developments, including those involving Bank of the Commonwealth,
Colonial BancGroup, Inc./Taylor, Bean & Whitaker; FirstCity Bank, Orion Bank,
First Community Bank, and others.

quarterly report to congress I July 25, 2012

SIGTARP Recommendations on the
Operation of TARP
One of SIGTARP’s oversight responsibilities is to provide recommendations
to Treasury and the banking regulators related to TARP to facilitate effective
oversight and transparency and to prevent fraud, waste, and abuse. SIGTARP
has made 105 recommendations. Section 5 of this report, “SIGTARP
Recommendations,” provides updates on existing recommendations and
summarizes the implementation of previous recommendations.
This quarter, Section 5 includes discussions of SIGTARP’s recommendations
to Treasury included in its audit report “Factors Affecting Implementation of the
Hardest Hit Fund Program,” released April 12, 2012, and in its audit report “The
Net Present Value Test’s Impact on the Home Affordable Modification Program,”
released June 18, 2012. Section 5 also provides an update on an earlier SIGTARP
recommendation regarding information security in the Hardest Hit Fund program.

Report Organization
The report is organized as follows:
• Section 1 discusses the activities of SIGTARP.
• Section 2 details how Treasury has spent TARP funds so far and contains an
explanation or update of each program.
• Section 3 discusses American International Group, Inc. (“AIG”), which remains
in TARP as the largest TARP investment.
• Section 4 describes the operations and administration of the Office of Financial
Stability, the office within Treasury that manages TARP.
• Section 5 discusses SIGTARP’s recommendations with respect to TARP.
The report also includes numerous appendices containing, among other things,
figures and tables detailing all TARP investments through June 30, 2012, except
where otherwise noted.

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Sect io n 1

The Office of the Special
Inspector General for the
Troubled Asset Relief Program

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quarterly report to congress I July 25, 2012

SIGTARP Creation and Statutory Authority

The Office of the Special Inspector General for the Troubled Asset Relief Program
(“SIGTARP”) was created by Section 121 of the Emergency Economic Stabilization Act of 2008 (“EESA”) and amended by the Special Inspector General for the
Troubled Asset Relief Program Act of 2009 (“SIGTARP Act”). Under EESA and the
SIGTARP Act, SIGTARP has the responsibility, among other things, to conduct,
supervise, and coordinate audits and investigations of the purchase, management,
and sale of assets under the Troubled Asset Relief Program (“TARP”) or as deemed
appropriate by the Special Inspector General. SIGTARP is required to report quarterly to Congress to describe SIGTARP’s activities and to provide certain information about TARP over that preceding quarter. EESA gives SIGTARP the authorities
listed in Section 6 of the Inspector General Act of 1978, including the power to
obtain documents and other information from Federal agencies and to subpoena
reports, documents, and other information from persons or entities outside the
Government.
Under the authorizing provisions of EESA, SIGTARP is to carry out its duties
until the Government has sold or transferred all assets and terminated all insurance
contracts acquired under TARP. In other words, SIGTARP will remain “on watch”
as long as TARP assets remain outstanding.

SIGTARP Oversight Activities Since the
April 2012 Quarterly Report

SIGTARP continues to fulfill its oversight role on multiple parallel tracks:
investigating allegations of fraud, waste, and abuse related to TARP; conducting
oversight over various aspects of TARP and TARP-related programs and activities
through 19 published audits and evaluations, and 105 recommendations as of June
30, 2012; and promoting transparency in TARP and the Government’s response to
the financial crisis as it relates to TARP.

SIGTARP Investigations Activity
SIGTARP is a white-collar law enforcement agency. As of July 12, 2012, SIGTARP
had more than 150 ongoing criminal and civil investigations, many in partnership
with other law enforcement agencies in order to leverage resources throughout the
Government. SIGTARP takes its law enforcement mandate seriously, working hard
to deliver the accountability the American people demand and deserve. SIGTARP’s
investigations have delivered substantial results, including:
• criminal charges against 91 individuals, including 64 senior officers (CEOs,
owners, founders, or senior executives) of their organizations
• criminal convictions of 67 defendants, of whom 28 have been sentenced to
prison (others are awaiting sentencing)

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• civil cases against 51 individuals (including 37 senior officers) and 26 entities
(in some instances an individual will face both criminal and civil charges)
• orders of restitution and forfeiture and civil judgments entered for more than $4
billion. This includes restitution orders entered for $3.7 billion, forfeiture orders
entered for $126.9 million, and civil judgments and other orders entered for
$281.9 million. Although the ultimate recovery of these amounts is not known,
SIGTARP has already assisted in the recovery of $160.8 million
• savings of $553 million in TARP funds that SIGTARP prevented from going to
the now-failed Colonial Bank
SIGTARP investigates white-collar fraud related to TARP. These investigations include, for example, accounting fraud, securities fraud, insider trading, bank
fraud, mortgage fraud, mortgage modification fraud, false statements, obstruction
of justice, money laundering, and tax crimes. Although the majority of SIGTARP’s
investigative activity remains confidential, over the past quarter there have been
significant public developments in several SIGTARP investigations.

The Bank of the Commonwealth
SIGTARP agents, along with its law enforcement partners, arrested four former
executives of Bank of the Commonwealth (“BOC”), including CEO and chairman
of the board Edward Woodard, his son Troy Brandon Woodard, executive vice
presidents Simon Hounslow and Steven Fields, along with two bank customers,
Thomas Arney and Dwight Etheridge. On July 11, 2012, a Federal grand jury
sitting in the Eastern District of Virginia returned a 25-count indictment against
the six individuals for their alleged roles in a massive fraud scheme that contributed
to the failure of the bank. Each charge contained in the indictment carries a
maximum penalty of 30 years in prison, if convicted.
BOC was a community bank headquartered in Norfolk, Virginia, that failed in
September 2011. It was the eighth largest bank failure in the country that year,
and the largest bank failure in Virginia since 2008. Six other defendants have been
charged (five of whom pled guilty) in this case for a total of 12 defendants. The
FDIC estimates that BOC’s failure will cost the deposit insurance fund more than
$268 million.
SIGTARP has been investigating this case because in November 2008, BOC
sought $28 million in TARP funds. BOC’s Federal banking regulator asked the
bank to withdraw the TARP application.
The four senior bank officers were charged on July 11, 2012, with fraud
schemes to conceal past-due loans and remove foreclosed property from the bank’s
books. The indictment details how friends of the bank received sweetheart deals
in return for helping mask the bank’s true financial condition. The indictment also
details how bank insiders benefitted personally from various schemes.
According to the indictment, BOC more than doubled its assets from 2005 to
2009. This was largely through brokered deposits, a financial tool that allows investors to pool their money and receive higher rates of returns. Because of the high

quarterly report to congress I July 25, 2012

volatility of these deposits, an institution must remain well-capitalized to accept
and renew brokered deposits.
The indictment alleges that BOC funded and administered many loans during this period without following industry standards or the bank’s own internal
controls, and by 2008, the volume of the bank’s troubled loans and foreclosed real
estate soared. From 2008 to 2011, BOC executives (Edward Woodard, Hounslow
and Fields) allegedly utilized various methods to fraudulently mask the bank’s true
financial condition out of fear that the bank’s declining health would negatively
impact investor and customer confidence and affect the bank’s ability to accept and
renew brokered deposits.
To fraudulently hide BOC’s troubled assets, bank insiders allegedly overdrew
demand deposit accounts to make loan payments, extended new loans or additional
principal on existing loans to cover payment shortfalls, changed the terms of loan
agreements to make loans appear current, and used funds from related entities
(sometimes without authorization from the borrower) to make loan payments. In
addition, the BOC executives allegedly hid millions of dollars of non-performing
loans from the bank’s board of directors.
The BOC executives also allegedly provided preferential treatment to troubled
borrowers, including Arney, Etheridge, and others, to purchase bank-owned property. The borrowers were already having difficulty making payments on their existing
loans and the financing allowed the borrowers to convert these non-earning assets
into earning assets. In some instances, according to the indictment, these new
loans exceeded the purchase price of the property, which resulted in the borrowers
obtaining cash at closing that they used to make payments on their other loans at
the bank and for their own personal purposes. In addition, BOC executives caused
the bank to fund loans to troubled borrowers to purchase or attempt to purchase
properties owned by Edward Woodard and Troy Brandon Woodard.
Additionally, the indictment alleges that Edward Woodard and Hounslow
caused the bank to fund three loans totaling $11 million without approval of the
board of directors and falsely represented in bank records that the board had
approved the loans. BOC subsequently charged off $9 million of these loans
as a loss. In addition, Edward Woodard and Troy Brandon Woodard allegedly
caused BOC to pay fraudulent invoices purportedly for construction costs for a
bank branch when the true costs were incurred for renovations to Troy Brandon
Woodard’s personal residence.
Six other individuals have been charged (five of whom pled guilty) in this ongoing investigation:
• On April 12 and July 12, 2012, respectively, business partners Eric H. Menden
and George P. Hranowskyj pled guilty to engaging in a fraud scheme that
contributed to the failure of BOC. Menden and Hranowskyj admitted to
performing favors for BOC insiders by using the proceeds of loans provided
by BOC insiders to purchase BOC-owned properties and properties owned
by BOC insiders. Menden and Hranowskyj further admitted to submitting
construction draw requests to the bank for amounts owed to subcontractors

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that were inflated or for work that was not completed. Menden and Hranowskyj
admitted knowing the loan proceeds obtained from these draw requests
were to be used solely for renovating the property but instead they used the
proceeds for their own personal purposes. At the time the bank failed, Menden
and Hranowskyj owed the bank approximately $41 million and the total loss
attributed to the loans outlined in court was over $13 million. Menden and
Hranowskyj also pled guilty to a separate six year tax fraud scheme that cost
state and Federal Government over $12 million and investors more than $8
million. At sentencing on September 26, 2012, Menden faces a maximum
of 15 years in Federal prison and possible restitution of up to $49 million.
Hranowskyj, scheduled to be sentenced on October 15, 2012, faces a maximum
of 25 years in Federal prison.
• On May 9, 2012, Jeremy C. Churchill, a BOC vice president and commercial
loan officer, pled guilty to conspiracy to commit bank fraud. According to
court documents, Churchill admitted that, under the direction of a BOC coconspirator, Churchill submitted loan requests to the bank to provide more than
$1 million to Tivest Development and Construction LLC (“Tivest”) and Genesis
Staffing, Inc. (“Genesis”), companies owned by Etheridge, who was having
difficulty keeping current on $8 million in loans he guaranteed at the bank.
BOC approved these loan requests based on false representations by Churchill
and a BOC co-conspirator that the funds would be used to pay pre-development
costs for an office tower project and operational costs at Genesis. To the
contrary, Etheridge allegedly used the proceeds to make payments on other
loans at the bank. BOC subsequently fully charged off these $1 million in loans
as a loss. Churchill also admitted to requesting that BOC provide a $4.1 million
loan to Tivest to be used to purchase an incomplete condominium project from
the owners who were delinquent on their loan at the bank. BOC would have
suffered a substantial loss had it foreclosed on this property. Churchill admitted
that he and a bank co-conspirator used approximately half the loan proceeds
to pay down the underlying loan on the property. Churchill faces a maximum
penalty of five years in prison when he is sentenced on August 24, 2012.
• On May 15, 2012, Recardo Lewis, a former vice president at Tivest, pled guilty
to conspiracy to commit bank fraud. Lewis, allegedly at the direction of
Etheridge, submitted eight draw requests to the bank on construction
loans that fraudulently inflated the amounts owed to contractors and included
costs for work that was not completed. Etheridge allegedly used the funds
from these draws to make interest payments on other loans at the bank, to
operate other businesses, and for other personal purposes. BOC subsequently
charged off approximately $1.3 million of this $4.1 million loan as a loss.
Lewis faces a maximum penalty of five years in prison when he is sentenced
on September 19, 2012.
• On September 15, 2011, Natallia Green, a former employee of Menden
and Hranowskyj, pled guilty to making a false statement to BOC in a loan
application. According to court documents, on August 12, 2010, Green
submitted an application to the bank requesting a home loan in the amount of

quarterly report to congress I July 25, 2012

$108,000 to purchase a piece of property owned by the bank. Green admitted
that she knowingly lied in her application by falsely stating that she had $29,000
in cash in banks and admitted that she provided an altered bank statement to
support her false assertion. On January 25, 2012, Green was sentenced to five
years’ probation, and was ordered to pay $106,519 in restitution.
• On August 10, 2011, Maria Pukhova, a former employee of Menden and
Hranowskyj, was charged with making a false statement on a loan application to
BOC. The information alleges that, on April 30, 2010, Pukhova defrauded the
bank by making false representations on a loan application.
This ongoing investigation is being conducted by SIGTARP, the United States
Attorney’s Office for the Eastern District of Virginia, the Federal Bureau of
Investigation (“FBI”), the Internal Revenue Service Criminal Investigation (“IRSCI”), and the Federal Deposit Insurance Corporation Office of Inspector General
(“FDIC OIG”).

The Colonial BancGroup, Inc./Taylor, Bean & Whitaker
On June 15, 2012, Delton de Armas, the former chief financial officer of Taylor,
Bean & Whitaker (“TBW”), was sentenced by the U.S. District Court for the
Eastern District of Virginia to five years in prison. De Armas previously pled guilty
to conspiracy to commit bank and wire fraud and making false statements for his
role in a $2.9 billion fraud scheme that led to the failures of TBW and Colonial
Bank (“Colonial”). As previously reported, Lee Bentley Farkas, the former chairman
of TBW, was convicted at trial in 2011 of 14 counts of conspiracy, and bank,
securities, and wire fraud, and sentenced to 30 years imprisonment. On June 20,
2012, the U.S. Court of Appeals for the Fourth Circuit upheld Farkas’ conviction.
Colonial Bank was initially approved to receive $553 million in TARP funding that
SIGTARP prevented from going to the bank.
De Armas admitted that he and others engaged in a scheme to defraud financial institutions that had invested in TBW’s wholly-owned lending facility, Ocala
Funding (“Ocala”). Shortly after Ocala was established, de Armas learned that inadequate assets were backing its loans. This collateral deficit increased to more than
$700 million by June 2008. De Armas knew that a subordinate sent false collateral
reports to Ocala investors that misrepresented the collateral deficit. De Armas
acknowledged that he and former TBW chief executive officer Paul Allen also
provided false explanations to investors and regulators about the deficit in Ocala’s
collateral. De Armas further admitted that he directed a subordinate to inflate an
accounts receivable balance on the books of TBW, which inflated TBW’s financial
statements. De Armas admitted knowing that these false financial statements were
provided to the Government National Mortgage Association (“Ginnie Mae”) and
the Federal Home Loan Mortgage Corporation (“Freddie Mac”) for their determination to renew TBW’s authority to sell and service securities guaranteed by Ginnie
Mae and Freddie Mac. De Armas also admitted to reviewing and editing a letter
sent by Allen to Ginnie Mae that contained false statements regarding the reason
for TBW’s delay in providing audited financial statements to Ginnie Mae.

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Six additional defendants pled guilty and were sentenced to prison in 2011
for their roles in the fraud scheme. Allen was sentenced to 40 months in prison;
Catherine Kissick, the former senior vice president of Colonial Bank, was sentenced to eight years in prison; Desiree Brown, the former treasurer of TBW, was
sentenced to six years in prison; Raymond Bowman, the former president of TBW,
was sentenced to 30 months in prison; Sean Ragland, a former senior financial
analyst at TBW, was sentenced to three months in prison; and Teresa Kelly, the
former operations supervisor in Colonial Bank’s Mortgage Warehouse Lending
Division, was sentenced to three months in prison.
This case was investigated by SIGTARP, the FBI, FDIC OIG, the Department
of Housing and Urban Development Office of Inspector General (“HUD OIG”),
the Federal Housing Finance Agency Office of Inspector General (“FHFA OIG”),
the Securities and Exchange Commission (“SEC”), and IRS-CI, and was prosecuted by the U.S. Department of Justice Criminal Division’s Fraud Section and the
U.S. Attorney’s Office for the Eastern District of Virginia.

FirstCity Bank
On June 26, 2012, Clayton A. Coe, the former vice president and senior
commercial loan officer at FirstCity Bank (“FirstCity”), pled guilty in U.S.
District Court for the Northern District of Georgia to bank fraud and to making
a false statement on his tax return. Coe faces a maximum sentence of 33 years
in prison and a fine of up to $1.1 million at his sentencing on September 18,
2012. In February 2009, FirstCity unsuccessfully sought $6.1 million in Federal
Government assistance through TARP. FirstCity failed and was seized by Federal
and state authorities on March 20, 2009.
According to court documents, as senior commercial loan officer, Coe was
primarily responsible for recommending to FirstCity’s loan committee whether to
approve commercial loans to real estate developers. Coe admitted to defrauding
FirstCity by causing FirstCity’s loan committee to approve an $800,000 loan to a
borrower in connection with a real estate development transaction that provided a
personal financial benefit to Coe. Coe concealed from FirstCity’s loan committee
that the borrower used the loan proceeds to purchase land lots from a company
owned by Coe and his wife and that the Coes had purchased these lots from the
true owner at a lower sales price on the same day the loan to the borrower closed.
Coe also admitted to failing to report to the Internal Revenue Service $476,000
in commissions he earned for loans he originated as FirstCity’s senior commercial
loan officer.
As previously reported, on October 21, 2011, Mark A. Conner, the former
president, chief executive officer, and chairman of FirstCity, pled guilty to conspiracy to commit bank fraud and perjury. Conner is scheduled to be sentenced on
August 9, 2012, and faces a maximum of 12 years in Federal prison, a lifetime ban
from the banking industry, a requirement to forfeit $7 million, and an order to pay
significant restitution to the FDIC and victim banks. Robert E. Maloney, FirstCity’s
former in-house counsel, has also been charged with conspiracy to commit bank
fraud, making false entries in the records of an FDIC-insured financial institution,

quarterly report to congress I July 25, 2012

and conspiracy to commit money laundering. A trial date has not been set for
Maloney.
The case is being investigated by SIGTARP, the United States Attorney’s Office
for the Northern District of Georgia, the FBI, IRS-CI, and FDIC OIG.

Orion Bank
On June 12, 2012, Jerry J. Williams, former president, chief executive officer, and
board chairman of Orion Bank (“Orion Bank”) and its holding company, Orion
Bancorp, Inc., was sentenced by the U.S. District Court for the Middle District
of Florida to 72 months in Federal prison. As previously reported, in February
2012, Williams pled guilty to conspiracy to commit bank fraud and making false
statements to Federal regulators arising from his participation in a bank fraud
scheme involving Orion Bank. In October 2008, Orion Bancorp unsuccessfully
sought $64 million in TARP funds. As part of the sentence, the court ordered
Williams to pay $5.76 million in restitution to victims and ordered an additional
hearing to determine restitution to be paid by Williams to FDIC.
Williams admitted that, after Orion Bank failed to raise capital as instructed by
Federal banking regulators, he conspired with two other Orion Bank executives,
Thomas Hebble (former executive vice president), Angel Guerzon (former senior
vice president), and a former Orion Bank borrower, Francesco Mileto, to mislead
state and Federal regulators into believing that Orion Bank was financially healthier
than it truly was. The conspirators committed their scheme in part by restructuring
distressed assets of Orion Bank to fraudulently create the illusion that certain of
the bank’s non-performing loans were performing loans. The conspirators furthered
their scheme by secretly financing the sale of Orion Bancorp stock to Mileto,
which created the false impression to regulators of a legitimate capital infusion that
considerably improved the bank’s capital position. Williams admitted to providing
regulators with false documents and statements about Orion Bank’s capital position
and amount of capital raised.
As previously reported, Hebble, Guerzon, and Mileto pled guilty to their participation in the fraud and received prison sentences of 30 months, 24 months, and
65 months, respectively. Hebble and Guerzon were also each ordered to pay $33.5
million in restitution to FDIC and Mileto was ordered to pay $65.2 million in
restitution to FDIC ($33.5 million of which is to be paid jointly and severally with
Guerzon and Hebble). The court also ordered forfeiture of $2 million as to Mileto.
Florida’s Office of Financial Regulation closed Orion Bank on November 13,
2009, and appointed FDIC as receiver. FDIC estimates that Orion Bank’s failure
will cost the deposit insurance fund more than $600 million.
The case is being investigated by SIGTARP, the U.S. Attorney’s Office for the
Middle District of Florida, the FBI, IRS-CI, the Federal Reserve Board Office of
Inspector General (“FRB OIG”), and FDIC OIG.

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First Community Bank
On April 26, 2012, Reginald R. Harper pled guilty in the U.S. District Court for
the Eastern District of Louisiana to conspiracy to commit bank fraud. Harper’s
co-conspirator, Troy A. Fouquet, previously pled guilty on March 15, 2012. The
charges against Harper and Fouquet arose from their orchestration of a fraudulent
scheme to conceal delinquent, non-performing loans at First Community Bank of
Hammond, Louisiana (“First Community Bank”) by creating new “sham” loans.
Harper was the former president, chief executive officer, and loan officer of First
Community Bank. Fouquet was a Louisiana real estate developer.
Harper arranged for First Community Bank to provide more than $2 million
in loans to Fouquet in 2004 to purchase land and build houses on the land.
However, they were unable to identify a sufficient number of qualified buyers for
the houses. In response, Harper and Fouquet devised various cover-up schemes
to avoid reporting the delinquent loans made by Harper to Fouquet. For example,
they used “nominee” loans and “straw” borrowers to apply for new loans from First
Community Bank, which Harper authorized, and then used the proceeds to pay off
the original loans made to Fouquet. Harper and Fouquet’s misconduct caused First
Community Bank to suffer severe financial losses.
As a result of Harper’s and Fouquet’s fraudulent activities, First Community
Bank submitted a false “call report” (a report meant to disclose the bank’s true
financial condition) to its regulator, which later affected the bank’s application for
TARP funds. First Community Bank ultimately withdrew its TARP application,
despite being approved to receive $3.3 million in TARP funds.
At sentencing, Fouquet and Harper each face a maximum of five years in
Federal prison and a fine. Harper and Fouquet are scheduled to be sentenced on
October 25, 2012.
The case is being investigated by SIGTARP, the U.S. Attorney’s Office for the
Eastern District of Louisiana, and the FBI.
John Farahi and David Tamman (New Point Financial Services, Inc.)
On June 4, 2012, John Farahi pled guilty in the U.S. District Court for the Central
District of California to charges of mail fraud, loan fraud, selling unregistered
securities, and conspiracy to obstruct justice, all relating to his ownership and
operation of an investment firm known as New Point Financial Services, Inc.
(“New Point”). Farahi is scheduled to be sentenced on January 14, 2013. He faces
a maximum penalty of 75 years in Federal prison, a fine of up to $1.75 million, and
possible restitution of approximately $7 million.
Farahi was the former co-owner and president of New Point. Farahi admitted
that, from 2005 until 2009, he operated a Ponzi scheme through New Point in
which he convinced potential investors to invest their money with him by falsely
assuring them their money would be invested in safe investments. Farahi also told
investors that New Point would invest in the corporate bonds of companies backed
by TARP and other Government programs and that the investors risked losing their
money only if the U.S. government failed. Many of the investors who approached
New Point about investing were members of the Iranian-Jewish community who

quarterly report to congress I July 25, 2012

had listened to Farahi’s daily Farsi-language investment radio show. Farahi admitted that New Point generally did not place the investors’ money in safe investments.
Instead, Farahi used investor money to support his lavish lifestyle, to make payments to previous New Point investors in order to perpetuate the Ponzi scheme,
and to finance and cover trading losses on speculative options trades. Farahi
acknowledged that the scheme caused investor losses of more than $7 million,
while prosecutors reserved the right to argue to the court that losses to victims
exceeded $20 million.
Facing massive trading losses at the end of 2008, Farahi borrowed millions of
dollars through lines of credit at banks, including TARP recipient banks Bank of
America and U.S. Bank. Farahi admitted to making false statements to these banks
about his financial situation in connection with these borrowings. Farahi also
admitted to illegally selling unregistered securities and then conspiring with David
Tamman, New Point’s former attorney, to obstruct an investigation by the SEC into
Farahi’s illegal sale of the unregistered securities. As previously reported, Tamman
was indicted in December 2011 for his role in allegedly obstructing the SEC investigation. Tamman is scheduled to go on trial on October 23, 2012.
This case is being investigated by SIGTARP, the United States Attorney’s Office
for the Central District of California, and the FBI.

Frederic Alan Gladle and Glen Alan Ward (aka Brandon Michaels)
On May 3, 2012, Frederic Alan Gladle was sentenced by the U.S. District Court
for the Western District of Texas to 61 months in Federal prison, following his
previous guilty plea to bankruptcy fraud and aggravated identity theft. The charges
stem from Gladle’s operation of a foreclosure-rescue scam involving more than
1,100 distressed homeowners and several banks, including TARP banks. As part of
the sentence, the court also ordered Gladle to pay $214,259 in restitution and to
forfeit $87,901.
Gladle admitted that, from 2007 to 2011, he promised homeowners whose
properties were being foreclosed upon that, in exchange for a monthly fee, he
would postpone the foreclosure for at least six months. After collecting fees from
a homeowner, Gladle would have the homeowner execute a deed granting a small
interest in their property to a random debtor in bankruptcy whose name Gladle
found in bankruptcy records. Neither the homeowner nor the bankruptcy debtor
was aware of Gladle’s misuse of the debtor’s bankruptcy petition. Gladle further
defrauded the bank that had issued the loan to the homeowner by providing the
bank a copy of the debtor’s bankruptcy petition showing that the debtor owned an
interest in the homeowner’s property that the lender was attempting to foreclose
upon. Upon receipt of these documents, the lender was legally obligated to and did
terminate the foreclosure proceeding against the homeowner. As a result, multiple
lenders, including TARP recipient banks Bank of America, Wells Fargo Bank and
U.S. Bank, incurred costs and delays while attempting to collect money that was
owed to them. Gladle admitted that he collected more than $1.6 million in fees
from homeowners through this scam.

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A defendant charged in the Northern and Central Districts of California
for a separate, similar foreclosure-rescue scheme, Glen Alan Ward, was arrested
in Canada in May 2012. Ward has been a fugitive sought by U.S. federal
authorities since 2000. According to court documents, Ward (aka Brandon
Michaels) is alleged to have worked with and taught Gladle how to perpetrate the
foreclosure-rescue scheme. Ward is currently being detained in Canada pending
his extradition to the United States.
The case was investigated by SIGTARP, the United States Attorney’s Office for
the Central District of California, the FBI, and the U.S. Trustee’s Office.

American Home Recovery
On May 17, 2012, after a 10-day jury trial in U.S. District Court for the Southern
District of New York, Isaak Khafisov was found guilty of conspiracy, mail fraud
and wire fraud for perpetrating a scheme to defraud distressed homeowners and
lenders. At sentencing on September 6, 2012, Khafisov faces a maximum sentence
of 80 years in Federal prison.
According to court documents and statements made during court proceedings,
around spring 2008, Khafisov founded a mortgage modification business named
American Home Recovery (“AHR”). Khafisov and AHR salespeople made false
assertions to fraudulently induce distressed homeowners to pay AHR thousands of
dollars in up-front fees for mortgage modifications. Specifically, Khafisov and AHR
informed homeowners that they had been “pre-approved” for a mortgage modification by their lenders; that AHR would ensure participation in the TARP-funded
Making Home Affordable program; and that AHR could obtain better interest rates
and lower monthly fees on their mortgage. Khafisov and AHR also falsely promised
to return the up-front fees if AHR did not secure a mortgage modification desired
by the homeowner. They also falsely claimed that AHR was affiliated with government agencies and programs established by the Economic Stimulus Act of 2008
and that AHR possessed unique expertise in mortgage modifications and had
special relationships with lenders. Khafisov also directed distressed homeowners to
stop paying their mortgages and to pay fees to AHR instead. After receiving up-front
fees from the distressed homeowners, Khafisov and AHR did little or no work to
try to renegotiate the homeowners’ mortgages. As a result, many AHR clients were
foreclosed upon by lenders and lost hundreds of thousands of dollars in fees.
Jaime Cassuto and David Cassuto founded AHR with Khafisov. As previously
reported, they each entered a guilty plea on April 2, 2012, relating to this mortgage
modification scheme. In March 2011, Raymond Pampillonio, a former AHR employee, also pled guilty in connection with this scheme.
This case is being investigated by SIGTARP, the U.S. Attorney’s Office for the
Southern District of New York, and the FBI.
The Shmuckler Group, LLC
On April 10, 2012, Howard R. Shmuckler pled guilty in the U.S. District Court
for the Eastern District of Virginia to wire fraud relating to his ownership and
operation of a fraudulent mortgage modification business known as The Shmuckler

quarterly report to congress I July 25, 2012

Group, LLC (“TSG”). Shmuckler admitted to falsely portraying himself to TSG
clients as an attorney licensed to practice in Virginia and to misrepresenting to
clients that TSG’s loan modification success rate was 97%. Shmuckler also assured
clients that their loans would be successfully modified. False representations by
Shmuckler and TSG employees induced homeowners to pay TSG fees ranging
from $2,500 to $25,000. Court records indicate that Shmuckler instructed clients
to terminate contact with their mortgage companies and to stop making payments
to their lenders. TSG never facilitated a modification of the mortgages referenced
in the statement of facts admitted to by Shmuckler. On June 25, 2012, Shmuckler
was sentenced to 90 months in Federal prison, a sentence that will run consecutive
to his current term of imprisonment that resulted from a conviction in the U.S.
District Court for the District of Columbia. Restitution to FDIC will be set by the
court at a later date.
As previously reported, on November 18, 2010, the Prince George’s County
State’s Attorney’s Office in Maryland obtained a 30-count indictment against
Shmuckler for conspiracy, theft, and operating a business without a license, in connection with a mortgage modification scam. On February 3, 2012, Shmuckler appeared before a judge in the Circuit Court for Prince George’s County, Maryland,
where he waived his right to a jury trial and consented to certain facts in connection with the mortgage modification scam. At the next hearing, which had been
postponed pending Shmuckler’s sentencing by the Eastern District of Virginia, the
Maryland judge will rule on the charge. Shmuckler faces a maximum sentence of
15 years on the theft charge.
The case brought in Federal court in Virginia resulted from a joint investigation conducted by SIGTARP, the FBI, FDIC OIG, and the U.S. Attorney’s Office
for the Eastern District of Virginia. The case brought in state court in Maryland
resulted from a joint investigation by SIGTARP, the Office of the State’s Attorney
for Prince George’s County, and the Maryland Department of Labor Licensing and
Regulation’s Financial Regulation Division.

CFSA Home Solutions
On May 16, 2012, Andrew M. Phalen pled guilty to felony charges for his role in
connection with a mortgage modification scheme. On June 6, 2012, Phalen was
sentenced by the Superior Court of California to one year in jail and five years
of supervised probation and prohibited by the Court from associating with the
other four defendants in the case and from engaging in services relating to loan
modification, refinancing, and foreclosure. As previously reported, Phalen, Jacob
J. Cunningham, Justine D. Koelle, Dominic A. Nolan, and John D. Silva were
arrested in California on March 2, 2012, and charged with allegedly operating
a mortgage modification scheme that defrauded hundreds of victims. According
to court documents, between January 2009 and March 2012, the defendants
allegedly enticed homeowners to participate in a fraudulent loan modification
program by making numerous false misrepresentations to homeowners through
advertisements, websites, promotional letters, and direct conversations. The
misrepresentations allegedly included statements that: (1) HAMP would apply

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to homeowners’ circumstances; (2) the defendants had a 100% success rate in
obtaining mortgage modifications for homeowners; and (3) homeowners would be
refunded their paid fees if the defendants could not modify a homeowner’s loan.
To evade detection by law enforcement, the defendants are accused of changing
the names, phone numbers, and addresses of sham companies they operated. One
company name the defendants used was CSFA Home Solutions.
Cunningham, Koelle, Nolan, and Silva have been charged with multiple felony
counts of violating California state law, including conspiracy to charge illegal upfront fees for mortgage modifications, conspiracy to commit forgery, grand theft by
false pretenses, theft from an elder, and money laundering. The charges are currently pending.
The case is being investigated by SIGTARP, Orange County, California,
District Attorney’s Office, U.S. Secret Service (“Secret Service”), Huntington
Beach Police Department, California Department of Real Estate, Orange County
Probation Department, Orange County Sheriff’s Department, Costa Mesa Police
Department, Irvine Police Department, and Santa Ana Police Department.

Flahive Law Corporation
On May 16, 2012, Michael Kent Johnson entered a plea of no contest to
misdemeanor conspiracy for his participation in a fraudulent loan modification
scheme perpetrated through the Flahive Law Corporation (“FLC”). FLC was a
law firm operated by Gregory and Cynthia Flahive. Johnson acted as the firm’s
managing attorney. Johnson is required to serve three years of probation and 200
hours of community service, to pay restitution of $10,560, and to not participate in
loan modification services.
As previously reported, Johnson, Gregory Flahive, and Cynthia Flahive were
arrested by SIGTARP agents and its law enforcement partners on March 8, 2012,
pursuant to an indictment returned by a California grand jury. According to the
indictment and court documents, from January 2009 to December 2010, FLC
promoted its loan modification services to homeowners through advertisements,
including a television infomercial. FLC falsely represented that experienced
lawyers would negotiate with banks on behalf of homeowners seeking modifications, including under HAMP, misrepresented that FLC’s law firm status would
give them extra leverage when negotiating with such banks, and overstated FLC’s
rate of success in obtaining loan modifications on behalf of homeowners. FLC allegedly collected up-front fees of up to $2,500 from homeowners for loan modification services that were never performed. Johnson admitted to creating and using
manipulative fee agreements in order to collect up-front fees from homeowners for
loan modification service. Gregory Flahive and Cynthia Flahive are scheduled to go
on trial on September 10, 2012.
The case is being investigated by SIGTARP, the California Attorney General,
Folsom Police Department, Rancho Cordova Police Department, and the El
Dorado Sheriff’s Department.

quarterly report to congress I July 25, 2012

Legacy Home Loans and Real Estate
As previously reported, on December 1, 2011, Magdalena Salas, Angelina Mireles,
and Julissa Garcia, the owner, manager, and CEO, respectively, of Legacy Home
Loans and Real Estate (“Legacy Home Loans”) in Stockton, California, were
arrested on charges of conspiracy, grand theft, and false advertising for a mortgage
modification scam. On July 10, 2012, all three defendants pled guilty in the San
Joaquin County, California, Superior Court to conspiracy to collect upfront fees for
mortgage modifications. Salas also pled guilty to felony foreclosure fraud.
According to the charges and other information presented in court, the defendants collected thousands of dollars in up-front fees from distressed homeowners
in Central California after making false promises to obtain loan modifications for
the homeowners. The defendants falsely promised homeowners that they would
receive loan modifications regardless of their financial situation through Federal
Government programs allegedly referred to as the “Obama Plan.” The defendants
also allegedly falsely overstated their success rate, made false money-back guarantees, and falsely represented that attorneys would work on the modifications. The
defendants advertised similar false promises in flyers, billboards, television and radio, in English and Spanish. The modification services promised by the defendants
allegedly were never carried out and many clients ended up losing their homes.
On July 11, 2012, the three defendants were sentenced to probation and
ordered to obey all laws, pay restitution, and complete 240 hours of community
service. Salas was also ordered not to engage in any professional services requiring
a license that she does not possess. The court will determine the restitution to be
paid by the defendants at a hearing scheduled for August 30, 2012.
The case is being investigated by SIGTARP, the California Attorney General’s
office, the San Joaquin District Attorney’s office, the California Department of Real
Estate, and the Stockton Police Department.
Oxford Collection Agency
On May 11, 2012, Richard Pinto and his son, Peter Pinto, each pled guilty in the
U.S. District Court for the District of Connecticut to using their debt collection
company, Oxford Collection Agency, Inc. (“Oxford”), to defraud business clients
and a TARP-recipient bank. The Pintos both pled guilty to wire fraud and
conspiracy to commit wire fraud, bank fraud, and money laundering, and face a
maximum of 35 years in Federal prison and a fine of up to $20 million at sentencing, which is scheduled for September 13, 2012.
According to court documents and statements made in court, Richard Pinto
was chairman of the board of directors at Oxford and Peter Pinto was Oxford’s
president and chief executive officer. From January 2007 through March 2011,
Oxford had agreements with business clients to collect debts from debtors, to
report such collections to the clients and to remit the collected payments back
to the clients. The clients would pay Oxford a portion of the monies collected by
Oxford as a fee. The Pintos admitted to collecting funds from debtors on behalf of
clients and failing to remit those funds to the clients. The Pintos also admitted to

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creating false documents and employing other deceptive means to cover up their
failure to remit collected funds to clients and their improper use of the funds.
The Pintos further admitted to causing Oxford to secure a line of credit from
TARP-recipient Webster Bank without disclosing to the bank that Oxford was
defrauding its clients and had significant outstanding payroll taxes. In the ensuing years, according to court documents and statements made in court, the Pintos
continued to defraud Webster Bank by inducing the bank to increase the line of
credit to $6 million by withholding Oxford’s true financial condition and submitting
falsified financial records to the bank. The Pintos laundered funds from the line of
credit by remitting those funds to clients in order to maintain the clients’ business
and thereby continue the scheme against the clients. The fraudulent scheme has
led victims to lose more than $10 million.
The case is being investigated by SIGTARP, IRS-CI, the FBI, the U.S.
Attorney’s Office for the District of Connecticut, and the Connecticut Securities,
Commodities and Investor Fraud Task Force.

Lynn Nunes
On April 24, 2012, Lynn Nunes, a New York mortgage broker, pled guilty in the
U.S. District Court for the Eastern District of New York to conspiracy to commit
fraud against mortgage lenders, including subsidiaries of TARP recipient banks
Wells Fargo & Company, SunTrust Banks, Inc., and JPMorgan Chase & Co.
From January 2005 through October 2010, Nunes and others recruited persons
interested in purchasing property but who had insufficient assets and income
to secure a mortgage. Nunes prepared fraudulent mortgage applications for the
potential purchasers by falsely inflating their bank account balances and income
to make the applicants appear more creditworthy. Nunes submitted these falsified
loan applications to the mortgage lenders, which issued mortgage loans in reliance
on the false applications. The lenders suffered losses on the properties when many
of the purchasers subsequently defaulted on the mortgage loans.
The case is being investigated by SIGTARP, the United States Attorney’s Office
for the Eastern District of New York, and the FBI.
Robin Brass
On April 25, 2012, Robin B. Brass pled guilty in the U.S. District Court for the
District of Connecticut to mail fraud for defrauding investors of more than $1
million. Brass is scheduled to be sentenced on July 27, 2012, and faces a maximum
sentence of 20 years in Federal prison and a fine of up to $250,000.
Brass admitted to devising a scheme to defraud investors by taking their money
and failing to invest it as promised. From March 2009 through November 2011,
Brass successfully solicited funds from investors by falsely representing herself
as a highly successful investment advisor, guaranteeing investors against losses,
and promising them a good rate of return on their investment. Brass used some
of the investor funds to pay off other investors (to keep the scheme going) and to
pay personal expenses for herself and her family, including her mortgage at Bank

quarterly report to congress I July 25, 2012

of America, a TARP-recipient bank. To perpetuate the fraud scheme, Brass sent
fraudulent account statements to investors that made it appear that their investments were performing well.
The case was investigated by SIGTARP, the United States Attorney’s Office for
the District of Connecticut, U.S. Postal Inspection Service (“USPIS”), the FBI, and
with assistance from the State of Connecticut Department of Banking as part of
the Connecticut Securities, Commodities and Investor Fraud Task Force.

Joint Task Force to Combat Mortgage Modification Scams
As previously reported, SIGTARP formed a joint task force (“Task Force”) with
the Consumer Financial Protection Bureau (“CFPB”) and Treasury to leverage
resources in investigating, combating, and shutting down mortgage modification
scams related to the Home Affordable Modification Program (“HAMP”), and to
provide awareness to vulnerable homeowners. The Task Force issued its initial
consumer fraud alert in December 2011 to educate homeowners on how to
recognize and avoid these scams. Since that time, SIGTARP has learned that
mortgage modification fraudsters are targeting the Armed Services community.
On May 24, 2012, the Task Force issued an additional fraud alert to combat the
rise in mortgage modification scams specifically targeting members of the Armed
Services community who are seeking to apply for mortgage assistance through
HAMP. The fraud alert warns servicemembers about the existence of these scams
and advises them how to report fraud. The alert also provides servicemembers with
a list of resources available to obtain more information and to obtain assistance
with mortgage-related questions. The alert is reproduced in the back of this report.

SIGTARP Audit Activity
SIGTARP has initiated 28 audits and three evaluations since its inception. As of
June 30, 2012, SIGTARP has issued 19 reports on audits and evaluations. Among
the ongoing audits and evaluations in process are reviews of: (i) Treasury’s and the
Federal banking regulators’ evaluation of applications submitted by recipients of
TARP funds to exit TARP by refinancing into the Small Business Lending Fund;
(ii) the Special Master’s 2012 decisions on executive compensation at American
International Group, Inc., General Motors Corporation, and Ally Financial, Inc.;
and (iii) Treasury’s role in General Motors’ decision to top up the pension plan for
hourly workers of Delphi Corporation.

Recent Audits Released
Factors Affecting Implementation of the Hardest Hit Fund Program

On April 12, 2012, SIGTARP released the audit report, “Factors Affecting
Implementation of the Hardest Hit Fund Program.” Conducted in response to a
request by Congressman Darrell Issa, this audit assessed the TARP program the
Hardest Hit Fund (“HHF”).

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special inspector general I troubled asset relief program

SIGTARP found that after two years, the Hardest Hit Fund has experienced
significant delay in providing help to homeowners due to several factors including a
lack of comprehensive planning by Treasury and a delay and limitation in participation in the program by large servicers and the Government-sponsored enterprises
(“GSEs”) (Fannie Mae and Freddie Mac). As of December 31, 2011, the latest data
available when the report was issued, the Hardest Hit Fund had spent only $217.4
million to provide assistance to 30,640 homeowners — approximately 3% of the
TARP funds allocated to HHF and approximately 7% of the minimum number of
homeowners that the state HFAs estimate helping over the life of the program,
which ends in 2017.
Nearly all (98%) of the help provided to homeowners under the Hardest Hit
Fund has been related to unemployment assistance or reinstatement of past due
amounts, the only types of assistance for which the GSEs had directed servicers
to participate. The great bulk (78%) of the HHF help to homeowners has been for
unemployment assistance. Unless there is a drastic change in the assistance the
GSEs and their conservator, the Federal Housing Finance Agency, will support, the
Hardest Hit Fund may be much narrower in scope and scale than what was originally expected due to the lack of servicer and GSE support for certain programs.
Without significant change, while the Hardest Hit Fund may be able to reach
unemployed homeowners as was originally intended, it is likely to be limited in
addressing negative equity for homeowners who are underwater.
SIGTARP found that Treasury consistently applied its criteria to choose states
to participate in the first three rounds of funding for HHF. However, in the second
round, it was unclear why Treasury determined that states with high percentages
of their population in counties with an unemployment rate greater than 12% were
economically distressed, but that states with 11% unemployment were not. The
cutoff for Treasury’s selection of states in Round Two was not transparent. For the
fourth round, no new states were selected. Rather, Treasury nearly doubled the
funds four days before the expiration of Treasury’s TARP investment authority.
Treasury determined that the five categories of assistance it approved were
compliant with TARP’s requirements but did not define “innovative” or perform an
analysis of whether the proposed programs were innovative or duplicative of other
programs.
Treasury has not set measurable goals and metrics that would allow Treasury,
the public, and Congress to measure the progress and success of HHF. Treasury
does require states to estimate the number of households to be assisted by their
HHF programs, but this number has limited usefulness because states can, and
have, changed estimates, creating a shifting baseline that makes it difficult to
measure performance against expectations. The states’ estimated number of homeowners to be assisted by the Hardest Hit Fund has steadily decreased over the last
year. Treasury has not adopted this estimate or even reported it. It is not too late
for Treasury to set measurable goals, including at a minimum, adopting the HFAs’
collective estimate or developing its own goal of how many homeowners Treasury
expects HHF to help. Treasury can also do more to improve transparency by publishing aggregate information on the program.

quarterly report to congress I July 25, 2012

SIGTARP found that several factors contributed to the Hardest Hit Fund’s
significant delay in getting assistance to homeowners. HHF lacked comprehensive
planning by Treasury, which rushed out the program without appropriate collaboration of key stakeholders. Several HFAs told SIGTARP that their primary challenge
was the lack of large servicer participation. Without large servicers, the HFAs could
not reach a large portion of struggling homeowners.
One great shortcoming in HHF’s implementation was Treasury’s lack of timely
action to enlist large servicer support for and participation in state HHF programs
while leaving it to the HFAs to negotiate with servicers. Treasury failed to recognize
the lack of bargaining power that states had for recruiting servicers. Large servicers
did not participate for nine months, citing the administrative burden of 50 different
programs, lack of program uniformity, and lack of GSE guidance. Servicers cited
the need for GSE guidance before they could begin participating in the program.
Treasury did not gain GSE support for HHF programs for eight months. Treasury,
responsible for HHF oversight and accountable for HHF results, should have been,
and still should be, the driving force to ensure that the GSEs and large servicers
support the HFAs’ programs.
In order to reach the number of homeowners that the HFAs collectively estimate helping through HHF, there needs to be a dramatic increase in the number of
homeowners helped. As was clear in the beginning of HHF, states need Treasury’s
help and support to increase the number of homeowners helped, and Treasury
should do everything it can to ensure the program’s success. Treasury should set
measurable goals, measure progress against those goals, and develop an action plan
to ensure that the next five years result in the Hardest Hit Fund fulfilling TARP’s
goal to preserve homeownership.
The Net Present Value Test’s Impact on the Home Affordable
Modification Program

On June 18, 2012, SIGTARP released the audit report “The Net Present Value
Test’s Impact on the Home Affordable Modification Program.” Conducted in
response to a request by Senator Jeff Merkley and eight other Senators, the audit
examined whether servicers are correctly applying the Net Present Value (“NPV”)
test to determine which homeowners qualify for HAMP. The NPV test estimates
whether a mortgage modification is in the best interest of the investor. As reported
in the audit, more than 160,000 HAMP-eligible homeowners have been turned
down for a HAMP mortgage modification by their mortgage servicer based on the
results of the NPV test.
SIGTARP’s audit report identified concerns, based upon its most recent analysis
from its sample, with the NPV test that may stand as barriers to homeowners getting much-needed help from HAMP.
• Treasury’s practice of protecting investors by allowing them to add a “risk
premium” to the NPV test calculation: SIGTARP found in its analysis of a
judgmental sample of HAMP applications that the discretion Treasury gave
to servicers to override the baseline discount rate in the NPV test by adding

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special inspector general I troubled asset relief program

a risk premium (of up to 2.5%) reduces the number of otherwise qualified
homeowners Treasury helps through HAMP. Only four servicers add a risk
premium, including Bank of America, N.A., and Wells Fargo Bank, N.A. More
than 100 servicers do not add a risk premium. In a SIGTARP analysis of 51
denied HAMP applications, SIGTARP found that if the servicer had not used
a risk premium, more than half (27) of the homeowners in SIGTARP’s sample
would have tested positive in the NPV test (which would require the servicer to
offer a HAMP modification).
• Errors inputting homeowner information and failure to maintain
documentation in SIGTARP’s sample: SIGTARP found in its sample
that servicers made errors using NPV inputs and did not properly maintain
records of all NPV inputs during the period of our review. Within SIGTARP’s
judgmental sample of 149 HAMP applications, SIGTARP found that the
servicers could provide both accurate inputs and documentation for only two
HAMP applications. SIGTARP found that servicers failed to comply with
HAMP guidelines on maintaining records on NPV inputs. Because of the
servicers’ failure to maintain documentation of the NPV inputs, SIGTARP was
unable to determine how many homeowners from its sample may have been
wrongly denied a HAMP modification.
• Errors in calculating homeowner gross income and in other areas in
SIGTARP’s sample: In 2010 and 2011, SIGTARP also found servicer errors or
lack of documentation in calculating the homeowner’s gross income and other
key inputs in the NPV test.
• Poor communication with homeowners on denial of HAMP modifications
in SIGTARP’s sample: In a sample of 26 denial letters sent by three servicers,
SIGTARP also found that servicers had poor communication with homeowners
on the denial of a HAMP modification due to the NPV test. SIGTARP found
that all but two of the letters in its sample failed to comply with at least one
requirement of HAMP guidelines. Treasury told SIGTARP that it has recently
made improvements in that area.

SIGTARP Hotline
One of SIGTARP’s primary investigative priorities is to operate the SIGTARP
Hotline and provide a simple, accessible way for the American public to report
concerns, allegations, information, and evidence of violations of criminal and
civil laws in connection with TARP. The SIGTARP Hotline has received and
analyzed more than 30,825 Hotline contacts. These contacts run the gamut
from expressions of concern over the economy to serious allegations of fraud
involving TARP, and a number of SIGTARP’s investigations were generated in
connection with Hotline tips. The SIGTARP Hotline can receive information
anonymously. SIGTARP honors all applicable whistleblower protections and will
provide confidentiality to the fullest extent possible. SIGTARP urges anyone aware
of waste, fraud, or abuse involving TARP programs or funds, whether it involves
the Federal Government, state and local entities, private firms, or individuals, to
contact its representatives at 877-SIG-2009 or www.sigtarp.gov.

quarterly report to congress I July 25, 2012

Communications with Congress
One of the primary functions of SIGTARP is to ensure that members of Congress
remain adequately and promptly informed of developments in TARP initiatives and
of SIGTARP’s oversight activities. To fulfill that role, the Special Inspector General
and her staff meet regularly with and brief members and Congressional staff.
• On July 10, 2012, the Special Inspector General, Christy Romero, testified
before the U.S. House Committee on Oversight and Reform Subcommittee on
TARP, Financial Services and Bailouts of Public and Private Programs regarding
TARP investments in the automotive industry and SIGTARP’s audit of the
decision making relating to General Motors’ topping-up the pensions of certain
hourly employees of Delphi Corporation.
• On April 26, 2012, the Special Inspector General, Christy Romero, submitted
written testimony to the U.S. Senate Committee on Homeland Security and
Governmental Affairs Subcommittee on Oversight of Government Management,
the Federal Workforce and the District of Columbia at a hearing entitled:
“Financial Literacy: Empowering Americans to Prevent the Next Financial
Crisis.” Ms. Romero provided testimony on SIGTARP’s efforts to raise public
awareness of mortgage modification scams and to shut down these scams.
• On April 24, 2012, SIGTARP’s Chief of Staff, Mia Levine, presented briefings
open to all Senate and House staff, respectively, on SIGTARP’s April 2012
Quarterly Report.
Copies of written Congressional testimony are posted at www.sigtarp.gov/pages/
testimony.aspx.

The SIGTARP Organization

SIGTARP leverages the resources of other agencies, and, where appropriate and
cost-effective, obtains services through SIGTARP’s authority to contract.

Hiring
As June 30, 2012, SIGTARP had 165 employees, plus two detailees from FHFA
OIG and one from the FBI. SIGTARP’s employees hail from private sector
businesses and many Federal agencies, including the Air Force Office of Special
Investigations, the Army Criminal Investigation Command, the Army Office
of Chief Legislative Liaison, the Congressional Oversight Panel for TARP, the
Department of Defense, the Department of Energy-Office of Inspector General,
the FBI, FDIC OIG, the Financial Crisis Inquiry Commission, the Government
Accountability Office, the Government Printing Office, the Department of
Homeland Security-Office of the Inspector General, IRS-CI, the Department
of Justice, the Naval Criminal Investigative Service, the Nuclear Regulatory
Commission, the Office of the Director of National Intelligence, the Secret
Service, the SEC, the Small Business Administration-Office of Inspector General,
the Department of State, the Department of Transportation, the Department of

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special inspector general I troubled asset relief program

Transportation-Office of Inspector General, the Department of Treasury-Office of
Inspector General, Treasury Inspector General for Tax Administration, and USPIS.
The SIGTARP organization chart as of July 2, 2012 can be found in Appendix I:
“Organizational Chart.”

Budget

Figure 1.1

SIGTARP ESTIMATED FY 2012
OPERATING PLAN
($ MILLIONS, PERCENTAGE OF $41.8 MILLION)
Other Services
$2.4, 6%
Advisory Services
$3.1
7%
Interagency
Agreements
$8.1

19%

64%

Salaries
and
$26.7

Travel
$1.5, 4%

Figure 1.2

On February 14, 2011, the Administration submitted to Congress Treasury’s
fiscal year 2012 budget request, which included SIGTARP’s funding request for
$47.4 million. The fiscal year 2012 House mark and Senate mark both provided
approximately $41.8 million. H.R. 2055/Public Law 112-74 Consolidated
Appropriations Act, 2012, provides $41.8 million in annual appropriations.
Figure 1.1 provides a detailed breakdown of SIGTARP’s FY 2012 budget that
reflects a total operating plan of $41.8 million, which includes spending from
SIGTARP’s initial funding.
On February 13, 2012, the Administration submitted to Congress Treasury’s
fiscal year 2013 budget request, which included SIGTARP’s funding request for
$40.2 million.
Figure 1.2 provides a detailed breakdown of SIGTARP’s fiscal year 2013
budget, which reflects a total operating plan of $46.8 million. This would include
$40.2 million in requested annual appropriation and portions of SIGTARP’s initial
funding.

Physical and Technical SIGTARP Infrastructure

SIGTARP FY 2013
PROPOSED BUDGET
($ MILLIONS, PERCENTAGE OF $46.8 MILLION)
Other Services
$2.2, 5%
Advisory Services
$3.2

SIGTARP’s headquarters are in Washington, DC, with regional offices in New York
City, Los Angeles, San Francisco, and Atlanta. SIGTARP posts all of its reports,
testimony, audits, and contracts on its website, www.sigtarp.gov. Since its inception
through June 30, 2012, SIGTARP’s website has had more than 58.4 million
web “hits,” and there have been more than 5.3 million downloads of SIGTARP’s
quarterly reports.i In addition to these web “hits,” SIGTARP’s website has recorded
32,968 page views since April 1, 2012, according to Treasury’s new tracking system.

7%
Interagency
Agreements
$9.9

21%

64%

Salaries
and
$30.2

Travel
$1.3, 3%

i

In October 2009, Treasury started to encounter challenges with its web analytics tracking system and as a result, migrated to a new
system in January 2010. SIGTARP has calculated the total number of website “hits” reported herein based on three sets of numbers:
• Numbers reported to SIGTARP as of September 30, 2009
• Archived numbers provided by Treasury for the period of October through December 2009
• Numbers generated from Treasury’s new system for the period of January 2010 through June 2012
Starting April 1, 2012, a new tracking system has been introduced that tracks a different metric, “page views,” which are not to be
confused with “hits” from the previous system. Moving forward, page views will be the primary metric to gauge use of the website.

Sect io n 2

TARP Overview

36

special inspector general I troubled asset relief program

quarterly report to congress I July 25, 2012

This section summarizes how the U.S. Department of the Treasury (“Treasury”) has
managed the Troubled Asset Relief Program (“TARP”). This section also reviews
TARP’s overall finances and provides updates on established TARP component
programs.

TARP Funds Update

Initial authorization for TARP funding came through the Emergency Economic
Stabilization Act of 2008 (“EESA”), which was signed into law on October 3,
2008.1 EESA appropriated $700 billion to “restore liquidity and stability to the
financial system of the United States.”2 On December 9, 2009, the Secretary of the
Treasury (“Treasury Secretary”) exercised the powers granted him under Section
120(b) of EESA and extended TARP through October 3, 2010.3 In accordance
with Section 106(e) of EESA, Treasury may expend TARP funds after October 3,
2010, as long as it does so pursuant to obligations entered into before that date.4
The Dodd-Frank Wall Street Reform and Consumer Protection Act (“DoddFrank Act”), which became law (Public Law 111-203) on July 21, 2010, amended
the timing and amount of TARP funding.5 The upper limit of the Treasury
Secretary’s authority to purchase and guarantee assets under TARP was reduced to
$475 billion from the original $700 billion.
Treasury’s investment authority under TARP expired on October 3, 2010. This
means that Treasury could not make new obligations after that date. However,
dollars that have already been obligated to existing programs may still be expended.
As of October 3, 2010, Treasury had obligated $474.8 billion to 13 announced
programs. Subsequent to the expiration of Treasury’s investment authority, Treasury
has deobligated funds previously designated for some programs. As of June 30,
2012, $467.2 billion is obligated to TARP programs.6 Of that amount, $416.1
billion had been spent and $45.8 billion remained obligated and available to
be spent.7 Taxpayers are owed $109.1 billion as of June 30, 2012. According to
Treasury, as of June 30, 2012, it had written off or realized losses of $15.6 billion
that taxpayers will never get back, leaving $93.5 billion in TARP funds outstanding.8 These amounts do not include $4.5 billion in TARP funds spent on housing
programs, which are designed as a Government subsidy, with no repayments to
taxpayers expected.
Table 2.1 details those write-offs and realized losses, but does not include
$20.3 million in realized losses at a June 25 to June 27, 2012, auction of the TARP
investment at seven banks because the sales closed after June 30, 2012.

Obligations: Definite commitments
that create a legal liability for the
Government to pay funds.
Deobligations: An agency’s cancellation
or downward adjustment of previously
incurred obligations.

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special inspector general I troubled asset relief program

Table 2.1

TREASURY’S STATEMENT OF REALIZED LOSSES AND WRITE-OFFS IN TARP, AS OF 6/30/2012
($ MILLIONS)

TARP
Program

Institution

TARP
Investment

Realized Loss
or Write-Off

Date

Description

Realized Losses

Autos

Chrysler

$1,888

$1,328

Autos

GMa

49,500

4,337d

SSFI

AIGa,b

67,835

4/30/2010

Sold 98,461 shares and equity
stake in the UAW Retiree
trust for $560,000,000 and
collected $48,055,721 for the
sale of collateral

11/17/2010 Sale of common stock at a loss

1,918

5/24/2011

1,984

3/13/2012

1,621

5/10/2012

3

2

3/9/2010

Sale of subordinated
debentures at a loss

17

11

5/3/2010

Sale of preferred stock at a loss
Sale of preferred stock at a loss

Sale of common stock at a loss

CPP

FBHC Holding Company

CPP

First Federal Bancshares of
Arkansas, Inc.

CPP

The Bank of Currituck

4

2

12/3/2010

CPP

Treaty Oak Bancorp, Inc.

3

3

2/15/2011 Sale of preferred stock at a loss

CPP

Central Pacific Financial Corp.

135

32d

6/22/2011

Exchange of preferred stock at
a loss

CPP

Cadence Financial Corporation

44

6

3/4/2011

Sale of preferred stock at a loss

CPP

First Community Bank
Corporation of America

11

3

5/31/2011

Sale of preferred stock at a loss

CPP

Cascade Financial Corporation

39

23

6/30/2011

Sale of preferred stock at a loss

CPP

Green Bankshares, Inc.

72

4

9/7/2011

Sale of preferred stock at a loss

CPP

Santa Lucia Bancorp

4

1

10/21/2011 Sale of preferred stock at a loss

CPP

MainSource Financial
Group, Inc.

57

4d

4/3/2012 Sale of preferred stock at a loss

CPP

Seacoast Banking Corporation
of Florida

50

9d

4/3/2012 Sale of preferred stock at a loss

CPP

Wilshire Bancorp, Inc.

62

4d

4/3/2012 Sale of preferred stock at a loss

CPP

Banner Corporation/Banner
Bank

124

14d

4/3/2012 Sale of preferred stock at a loss

CPP

First Financial Holdings Inc.

65

8d

4/3/2012 Sale of preferred stock at a loss

CPP

WSFS Financial Corporation

53

4d

4/3/2012 Sale of preferred stock at a loss

CPP

Central Pacific Financial Corp.

CPP
CPP

135

30

4/4/2012 Sale of common stock at a loss

Ameris Bancorp

52

d

4

6/19/2012 Sale of preferred stock at a loss

United Bancorp, Inc.

21

4d

6/19/2012 Sale of preferred stock at a loss

CPP

First Capital Bancorp, Inc.

11

d

1

6/19/2012 Sale of preferred stock at a loss

CPP

First Defiance Financial Corp.

37

1d

6/19/2012 Sale of preferred stock at a loss

CPP

LNB Bancorp, Inc.

25

d

3

6/19/2012 Sale of preferred stock at a loss

CPP

Farmers Capital Corporation

30

8d

6/19/2012 Sale of preferred stock at a loss

CPP

Taylor Capital Group, Inc.

Total Realized Losses

105

d

11

d

6/19/2012 Sale of preferred stock at a loss

$11,379
Continued on next page

quarterly report to congress I July 25, 2012

TREASURY’S STATEMENT OF REALIZED LOSSES AND WRITE-OFFS IN TARP, AS OF 6/30/2012
($ MILLIONS) (CONTINUED)

TARP
Program

Institution

TARP
Investment

Realized Loss
or Write-Off

Date

$3,500

$1,600

5/14/2010

2,330

2,330

12/10/2009 Bankruptcy

4

4

2/11/2010 Bankruptcy

347

217

9/30/2010

Sale of preferred stock at a loss

37

25

9/30/2010

Sale of preferred stock at a loss

Description

Write-Offs
Autos

Chrysler

CPP

CIT Group Inc.

CPP

Pacific Coast National Bancorp

CPP

South Financial Group, Inc.

CPP

TIB Financial Corpc

c

Total Write-Offs
Total of Realized Losses and Write-Offs

Accepted $1.9 billion as full
repayment for the debt of
$3.5 billion

$4,176
$15,555

Notes: Numbers may not total due to rounding. Total realized losses and write-offs does not include $20.3 million in realized losses for Treasury’s interests in seven CPP
banks that were sold at auction June 25-27, 2012, because the sales closed after June 30, 2012.
a
	Since this company remains in TARP, a final determination of realized loss incurred on Treasury’s investment cannot be calculated until the investments have been fully
divested.
b
	Treasury has sold a total of 459 million AIG common shares at an average price of $29.47 per share, consisting of 392,922,121 TARP shares and 202,499,020 nonTARP shares based upon the Treasury’s pro-rata holding of those shares. The non-TARP shares are those received from the trust created by the Federal Reserve Bank
of New York for the benefit of the Treasury. Receipts for non-TARP common stock totaled $5,968,645,637 and are not included in TARP collections. The realized loss
reflects the price at which TARP sold common shares in AIG and TARP’s cost basis of $43.53 per common share.
c
	According to Treasury, in the time since these transactions were classified as write-offs, Treasury has changed its practices and now classifies sales of preferred stock at
a loss as realized losses.
d
	Treasury changed its reporting methodology in calculating realized losses, effective June 30, 2012. Disposition expenses are no longer included in calculating realized
losses.
Sources: Treasury, Transactions Report, 6/27/2012; Treasury, Section 105(a) Report, 7/10/2012; Treasury Press Release, “Treasury Announces Agreement to Exit
Remaining Stake in Chrysler Group LLC,” 6/2/2011, www.treasury.gov/press-center/press-releases/Pages/tg1199.aspx, accessed 6/28/2012; Treasury, response to
SIGTARP data call, 7/5/2012.

With the expiration of TARP funding authorization, no new expenditures may
be made through 10 TARP programs because all obligated dollars have been spent.
For three programs — the housing programs, the Term Asset-Backed Securities
Loan Facility (“TALF”), and the Public-Private Investment Program (“PPIP”) —
$45.8 billion in TARP dollars that were obligated but unspent as of June 30, 2012,
are available to be spent. Table 2.2 provides a breakdown of program obligations,
changes in obligations, expenditures, principal repaid, amounts still owed to taxpayers, and obligations available to be spent as of June 30, 2012. Table 2.2 lists 10
TARP sub-programs, instead of all 13, because it excludes the Capital Assistance
Program (“CAP”), which was never funded, and summarizes three programs under
“Automotive Industry Support Programs.”

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special inspector general I troubled asset relief program

Table 2.2

Obligations, Expenditures, PRINCIPAL REPAID, AMOUNTS STILL OWED TO TAXPAYERS, and Obligations Available
to be Spent ($ Billions)
Program

Obligation After
Dodd-Frank
(As of 10/3/2010)

Current
Obligation

(As of 6/30/2012)

Expenditure

(As of 6/30/2012)

Principal Repaid

Still Owed to
Taxpayers

(As of 6/30/2012)

(As of 6/30/2012)a

$—

$—

Available
to Be Spent

(As of 6/30/2012)

Housing Support
Programsb

$45.6

$45.6

$4.5

Capital Purchase Program

204.9

204.9

204.9

191.1c

13.8

0.0

0.6

0.6

0.2

0.0*

0.6

0.0

Systemically Significant
Failing Institutions

69.8

67.8e

67.8

31.9

36.0

0.0

Targeted Investment
Program

40.0

40.0

40.0

40.0

0.0

0.0

Asset Guarantee Program

5.0

5.0

0.0

0.0

0.0

0.0

Term Asset-Backed
Securities Loan Facility

4.3

1.4f

0.1

0.0

0.1

1.3

Public-Private Investment
Program

22.4

21.9

18.5

4.4g

14.1

3.4h

Unlocking Credit for Small
Businesses

0.4

0.4

0.4

0.4

0.0

0.0

81.8i

79.7j

79.7

35.2

44.5

0.0

$474.8

$467.2

$302.9

$109.1

$45.8

Community Development
Capital Initiatived

Automotive Industry
Support Programs
Total

$416.1k

$41.1

Notes: Numbers may not total due to rounding.
a
	Amount taxpayers still owed includes amounts disbursed and still outstanding, plus write-offs and realized losses totaling $15.6 billion. It does not include $4.5 billion in TARP dollars spent on housing
programs. These programs are designed as Government subsidies, with no repayments to taxpayers expected. Realized losses do not reflect $20.3 million in losses incurred at a June 25-27, 2012,
auction of Treasury’s interests in seven banks, which settled after June 30, 2012.
b
	Housing support programs were designed as a Government subsidy, with no repayment to taxpayers expected.
c
	Does not include $204.4 million in proceeds from CPP auction held June 25-27, 2012, but not settled until after June 30, 2012. Includes $363.3 million in non-cash conversions from CPP to CDCI.
Includes $2.2 billion for CPP banks that exited TARP through SBLF.
d
	CDCI obligation amount of $570.1 million. There are no remaining dollars to be spent on CDCI. Of the total obligation, $363.3 million was related to CPP conversions for which no additional CDCI cash
was expended; this is not counted as an expenditure, but it is counted as money still owed to taxpayers. Another $100.7 million was expended for new CDCI expenditures for previous CPP participants.
Of the total obligation, only $106 million went to non-CPP institutions.
e
	Treasury deobligated $2 billion of an equity facility for AIG that was never drawn down.
f
Treasury deobligated $2.9 billion in TALF funding, bringing the total obligation to $1.4 billion.
g
	On April 10, 2012, Treasury changed its reporting methodology to reclassify as repayments of capital to the Government $958 million in receipts previously categorized as PPIP equity distributions. That
$958 million is included in this repayment total.
h
	Total obligation of $22.4 billion and expenditure of $18.5 billion for PPIP includes $356.3 million of the initial obligation to The TCW Group, Inc. (“TCW”) that was funded. TCW subsequently repaid the
funds that were invested in its PPIF; however, these dollars are not included in the amount available to be spent. Current obligation of $21.9 billion results because Invesco terminated its investment
period on September 26, 2011, without fully drawing down all committed equity and debt. The undrawn debt of $550 million was deobligated, but the undrawn equity was not.
i
	Includes $80.7 billion for Automotive Industry Financing Program, $0.6 billion for Auto Warranty Commitment Program, and $0.4 billion for Auto Supplier Support Program.
j
	Treasury deobligated $2.1 billion of a Chrysler credit facility that was never drawn down.
k
	The $5 billion reduction in exposure under AGP is not included in the expenditure total because this amount was not an actual cash outlay.
* Amount less than $50 million.
Sources: Treasury, Transactions Report, 6/27/2012; Treasury, Daily TARP Update, 7/2/2012; Treasury, response to SIGTARP data call, 7/5/2012.

quarterly report to congress I July 25, 2012

Cost Estimates
Several Government agencies are responsible under EESA for generating cost
estimates for TARP, including the Office of Management and Budget (“OMB”),
the Congressional Budget Office (“CBO”), and Treasury, whose estimated costs
are audited each year by the Government Accountability Office (“GAO”). Cost
estimates have decreased from CBO’s March 2009 cost estimate of a $356 billion
loss and OMB’s August 2009 cost estimate of a $341 billion loss.9
On February 13, 2012, OMB issued the Administration’s fiscal year 2013
budget, which included a TARP lifetime cost estimate of $67.8 billion, based upon
figures from November 30, 2011.10 That was an increase from its estimate of $53.2
billion based on June 30, 2011 data.11 Much of the difference is due to a lower value for Treasury’s common stock holdings in AIG, GM, and Ally Financial compared
with November 2010. This estimate assumes that all $45.6 billion of obligated
funds for housing will be spent. It also assumes that PPIP will make a profit of $2
billion and CPP will make a profit of $6.7 billion, including principal repayments
and revenue from dividends, warrants, interest, and fees.
On March 28, 2012, CBO issued an updated TARP cost estimate based on
its evaluation of data as of February 22, 2012. CBO estimated the ultimate cost
of TARP would be $32 billion, down $2 billion from its estimate of $34 billion in
December 2011.12 This decrease came primarily from an increase in the market
value of Treasury’s investments in AIG and GM, partially offset by added costs from
new initiatives in TARP housing programs. CBO estimated that only $16 billion of
obligated funds for housing will be spent.
On November 10, 2011, Treasury issued its September 30, 2011, fiscal year
audited agency financial statements for TARP, which contained a cost estimate of
$70 billion.13 This estimate is an increase from Treasury’s March 31, 2011, estimate of $49 billion. According to Treasury, “These costs fluctuate in large part due
to changes in the market prices of common stock for AIG and GM and the estimated value of the Ally [Financial] stock.”14 According to Treasury, the largest losses
from TARP are expected to come from housing programs and from assistance to
AIG and the automotive industry.15
The most recent TARP program cost estimates from each agency are listed in
Table 2.3.

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special inspector general I troubled asset relief program

TABLE 2.3

Cost (gain) of TARP Programs

Program Name
Report issued:
Data as of:
Housing Support Programs

($ Billions)

OMB Estimate

CBO Estimate

Treasury Estimate,
TARP Audited
Agency Financial
Statement

2/13/2012
11/30/2011

3/28/2012
2/22/2012

11/10/2011
9/30/2011

$46

$16

$46

CPP

(7)

(17)

(13)

SSFI

24

22

24

TIP and AGP

(7)

(8)

(8)

TALF

0

0

0

PPIP

(2)

0

(2.4)

Automotive Industry Support
Programsa

25

19

24

*

*

*

Otherb
Total

$78

Interest on Reestimatese

(10)

Adjusted Total

$32

c

$70d

$68d

Notes: Numbers may not total due to rounding.
a
	Includes AIFP, ASSP, and AWCP.
b
Consists of CDCI and UCSB, both of which are estimated between a cost of $500 million and a gain of $500 million.
c
The estimate is before administrative costs and interest effects.
d
The estimate includes interest on reestimates but excludes administrative costs.
e
	Cumulative interest on reestimates is an adjustment for interest effects on changes in TARP subsidy costs from original subsidy
estimates; such amounts are a component of the deficit impacts of TARP programs but are not a direct programmatic cost.
Sources: OMB Estimate—OMB, “OMB Report under the Emergency Economic Stabilization Act, Section 202,” 11/8/2011, www.
whitehouse.gov/sites/default/files/omb/reports/emergency-economic-stabilization-act-of-2008.pdf, accessed 6/28/2012; CBO
Estimate—CBO, “Report on the Troubled Asset Relief Program—March 2012,” 3/28/2012, www.cbo.gov/sites/default/files/cbofiles/
attachments/03-28-2012TARP.pdf, accessed 6/28/2012; Treasury Estimate—Treasury, “Office of Financial Stability–Troubled Asset
Relief Program Agency Financial Report Fiscal Year 2011,” 11/10/2011, www.treasury.gov/initiatives/financial-stability/briefing-room/
reports/agency_reports/Documents/2011_OFS_AFR_11-11-11.pdf, accessed 6/28/2012.

Financial Overview of TARP

Treasury had obligated $474.8 billion of the $475 billion ceiling under the DoddFrank Act, but in 2011 and 2012 deobligated funds for several programs, reducing
obligations to $467.2 billion as of June 30, 2012. Of the total obligations, $416.2
billion was expended as of June 30, 2012.16 There remains approximately $45.8
billion still available to be spent.17
According to Treasury, as of June 30, 2012, 306 TARP recipients (including
302 banks and credit unions, two auto companies, and two former PPIP managers) had paid back all of their principal or repurchased shares, sometimes at a loss
to Treasury, and 24 TARP recipients had partially repaid their principal or repurchased their shares, for a total of $302.5 billion.18 Some of these institutions repaid
TARP by refinancing into other TARP programs or other Government programs
such as the Small Business Lending Fund (“SBLF”). According to Treasury, one

quarterly report to congress I July 25, 2012

PPIP manager, Invesco, has fully repaid its debt and equity, but retains some capital to wind down operations. These repayments also include five PPIP managers
who have made partial payments over the lifetime of the program. Taxpayers are
still owed $109.1 billion as of June 30, 2012. According to Treasury, it has incurred
write-offs of $4.2 billion and realized losses of $11.4 billion as of June 30, 2012,
which taxpayers will never get back, leaving $93.5 billion in TARP funds outstanding (not including $4.5 billion in TARP funds spent as a subsidy for TARP housing
programs).19 Figure 2.1 provides a snapshot of the cumulative expenditures, repayments, and amount owed as of June 30, 2012. According to Treasury, as of June
30, 2012, the Government had also collected $41.1 billion in interest, dividends,
and other income, including $9.2 billion in proceeds from the sale of warrants and
stock received as a result of exercised warrants.20
Most of the outstanding TARP money is in the form of equity ownership in 410
institutions as of June 30, 2012 (325 banks in CPP, 82 banks and credit unions in
CDCI, plus AIG, GM, and Ally Financial). Treasury (and therefore the taxpayer)
remains a shareholder in companies that have not repaid the Government.
Treasury’s equity ownership is largely in two forms — common and preferred stock
— although it also has received debt in the form of senior subordinated debentures.
As of June 30, 2012, obligated funds totaling $45.8 billion were still available to
be drawn down by TARP recipients under three of TARP’s 13 announced programs.21 TARP’s component programs fall into four categories, depending on the
type of assistance offered:
• Housing Support Programs — These programs are intended to help
homeowners who are having trouble making their mortgage payments by
providing incentives for foreclosure alternatives.
• Financial Institution Support Programs — These programs share a common
stated goal of stabilizing financial markets and improving the economy.
• Asset Support Programs — These programs attempt to support asset values
and market liquidity by providing funding to certain holders or purchasers of
assets.
• Automotive Industry Support Programs — These programs are intended to
stabilize the U.S. automotive industry and promote market stability.

Common Stock: Equity ownership entitling
an individual to share in corporate
earnings and voting rights.

Preferred Stock: Equity ownership that
usually pays a fixed dividend before
distributions for common stock owners
but only after payments due to debt
holders. It typically confers no voting
rights. Preferred stock also has priority
over common stock in the distribution
of assets when a bankrupt company is
liquidated.

FIGURE 2.1

CURRENT TARP EXPENDITURES,
REPAYMENTS, AND AMOUNT
OWED ($ BILLIONS)
$500
400

$416.1

300
$302.9
200
100

$109.1

0
TARP
Expenditures

TARP
Repaymentsa

Amount
Owedb

Notes: As of 6/30/2012. Numbers may not total due
to rounding.
Repayments include $191.1 billion for CPP, $40 billion
for TIP, $35.2 billion for Auto Programs, $4.4 billion for
PPIP, and $31.9 billion for SSFI. The $191.1 billion for
CPP repayments does not include $204.4 million in
proceeds from CPP auction held June 25-27, 2012, but
includes $363.3 million in non-cash conversion from
CPP to CDCI and $2.2 billion for banks that refinanced
from TARP into SBLF. The $31.9 billion payment for
SSFI includes amounts applied to (i) pay accrued
preferred returns and (ii) redeem the outstanding
liquidation amount.
b
Amount owed includes $15.6 billion that Treasury has
written off or realized losses, but does not include
$20.3 million in losses realized after June 30, 2012,
in an auction of the investment in seven CPP banks. It
does not include $4.5 billion spent for housing
programs, which were designed as a Government
subsidy, with no repayment to taxpayers expected.
a

Sources: Treasury, Transactions Report, 6/27/2012;
Treasury, Daily TARP Update, 7/2/2012; Treasury,
response to SIGTARP data call, 7/5/2012.

Senior Subordinated Debentures: Debt
instrument ranking below senior debt but
above equity with regard to investors’
claims on company assets or earnings.

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special inspector general I troubled asset relief program

Some TARP programs are scheduled to last as late as 2019. Table 2.4 provides
details of those exit dates.
Table 2.4

TARP Program SCHEDULE
TARP Program

Scheduled Program Dates

Term Asset-Backed Securities Loan Facility

2015 maturity of last loan

Public-Private Investment Program

2017 for fund manager to sell securities (with
possibility to extend to 2019)

Home Affordable Modification Program

2019 for incentives on modifications

Hardest Hit Fund

2017 for states to use TARP funds

Other TARP programs have no scheduled ending date; TARP money will
remain invested until recipients pay Treasury back or until Treasury is able to sell
its investments in the companies. Table 2.5 provides details on the status of the
remaining Treasury investments under those programs.
Table 2.5

TARP INVESTMENTS IN FINANCIAL INSTITUTIONS
TARP Program

Remaining Treasury Investment

Capital Purchase Program

Preferred stock in 325 banks

Community Development Capital Initiative

Preferred stock in 82 banks/credit unions

Systemically Significant Failing Institutions

61% stake in AIG

Automotive Industry Financing Program

32% stake in GM
74% stake in Ally Financial

Housing Support Programs
The stated purpose of TARP’s housing support programs is to help homeowners
and financial institutions that hold troubled housing-related assets. Although
Treasury originally committed to use $50 billion in TARP funds for these programs,
it obligated only $45.6 billion.22 As of June 30, 2012, $4.5 billion, or 10% of this
amount, has been expended. However, some of these expended funds remain as
cash on hand or administrative expenses with the state Housing Finance Agencies
participating in the Hardest Hit Fund program.
• Making Home Affordable (“MHA”) Program — According to Treasury, this
umbrella program for Treasury’s foreclosure mitigation efforts is intended to
“help bring relief to responsible homeowners struggling to make their mortgage
payments, while preventing neighborhoods and communities from suffering
the negative spillover effects of foreclosure, such as lower housing prices,
increased crime, and higher taxes.”23 MHA, for which Treasury has obligated
$29.9 billion of TARP funds, consists of the Home Affordable Modification
Program (“HAMP”), which includes HAMP Tier 1 and HAMP Tier 2, which
both modify first-lien mortgages to reduce payments, the Federal Housing
Administration (“FHA”) HAMP loan modification option for FHA-insured

quarterly report to congress I July 25, 2012

mortgages (“Treasury/FHA-HAMP”), the U.S. Department of Agriculture Office
of Rural Development (“RD”) HAMP (“RD-HAMP”), the Home Affordable
Foreclosure Alternatives (“HAFA”) program, and the Second Lien Modification
Program (“2MP”).24 HAMP in turn encompasses various initiatives in addition
to the modification of first-lien mortgages, including Home Price Decline
Protection (“HPDP”), the Principal Reduction Alternative (“PRA”), and the
Home Affordable Unemployment Program (“UP”).25 Additionally, the overall
MHA obligation of $29.9 billion includes $2.7 billion to support the Treasury/
FHA Second-Lien Program (“FHA2LP”), which complements the FHA
Short Refinance program (discussed later) and is intended to support the
extinguishment of second-lien loans.26
Treasury made several changes to MHA in the first half of 2012. Notably,
the application period for HAMP was extended by a year to December 31,
2013, and investor incentives for principal reduction were doubled for 2MP
and tripled for PRA. Additionally, on June 1, 2012, HAMP was expanded under
“HAMP Tier 2” to open HAMP to non-owner-occupied rental properties and
to borrowers with a wider range of debt-to-income ratios.27 For more detailed
information, see the “Housing Support Programs” discussion in this section.
As of June 30, 2012, MHA had expended $3.4 billion of TARP money.28 As
of that date, there were 393,887 active permanent first-lien modifications under
the completed TARP-funded portion of HAMP, an increase of 12,994 active
permanent modifications over the past quarter.29 Total expenditures in incentives and payments for HAFA were $237.2 million in connection with 52,998
deed-in-lieu and short sale transactions. Expenditures in incentives and payments for 2MP were $192.1 million in connection with 18,974 full extinguishments, 4,547 partial extinguishments, and 63,769 permanent modifications of
second liens.30 For more detailed information, including participation numbers
for each of the MHA programs and subprograms, see the “Housing Support
Programs” discussion in this section.
• FHA Short Refinance Program — Treasury has allocated $8.1 billion of
TARP funding to this program to purchase a letter of credit to provide loss
protection on refinanced first liens. Additionally, to facilitate the refinancing of
non-FHA mortgages into new FHA-insured loans under this program, Treasury
has allocated approximately $2.7 billion in TARP funds for incentive payments
to servicers and holders of existing second liens for full or partial principal
extinguishments under the related FHA2LP; these funds are part of the
overall MHA funding of $29.9 billion, as noted above.31 As of June 30, 2012,
there have been 1,437 refinancings under the program.32 For more detailed
information, see the “Housing Support Programs” discussion in this section.
• Housing Finance Agency (“HFA”) Hardest Hit Fund (“HHF”) — The stated
purpose of this program was to provide TARP funding for “innovative measures
to help families in the states that have been hit the hardest by the aftermath
of the housing bubble.”33 Treasury obligated $7.6 billion for this program.34 As
of June 30, 2012, $1.1 billion had been drawn down by the states from HHF.
However, as of March 31, 2012, only $351 million has been spent assisting

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special inspector general I troubled asset relief program

43,580 homeowners, with the remaining funds used for administrative expenses
and cash-on-hand.35 For more detailed information, see the “Housing Support
Programs” discussion in this section.

Financial Institution Support Programs
Systemically Significant Institutions:
Term referring to any financial
institution whose failure would impose
significant losses on creditors and
counterparties, call into question the
financial strength of similar institutions,
disrupt financial markets, raise
borrowing costs for households and
businesses, and reduce household
wealth.
Qualifying Financial Institutions (“QFIs”):
Private and public U.S.-controlled
banks, savings associations, bank
holding companies, certain savings
and loan holding companies, and
mutual organizations.
Community Development Financial
Institutions (“CDFIs”): Financial
institutions eligible for Treasury funding
to serve urban and rural low-income
communities through the CDFI Fund.
CDFIs were created in 1994 by the
Riegle Community Development and
Regulatory Improvement Act. These
entities must be certified by Treasury;
certification confirms that they target
at least 60% of their lending and other
economic development activities
to areas underserved by traditional
financial institutions.

Treasury primarily invested capital directly into financial institutions including
banks, bank holding companies, and, if deemed by Treasury critical to the financial
system, some systemically significant institutions.36
• Capital Purchase Program (“CPP”) — Under CPP, Treasury directly
purchased preferred stock or subordinated debentures in qualifying financial
institutions (“QFIs”).37 CPP was intended to provide funds to “stabilize and
strengthen the U.S. financial system by increasing the capital base of an
array of healthy, viable institutions, enabling them [to] lend to consumers and
business[es].”38 Treasury invested $204.9 billion in 707 institutions through
CPP, which closed to new funding on December 29, 2009.39 As of June 30,
2012, 325 of those institutions remained in CPP.40 Of the 382 that have exited
CPP, 165, or 43.2%, did so through other Government programs — 28 of
them through TARP’s CDCI and 137 through SBLF, a non-TARP program.41
Only 164 of the banks that exited, or 42.9%, fully repaid CPP otherwise.42 In
addition, three CPP banks merged with other CPP banks, Treasury sold its
investments in 33 institutions at a loss, and 17 institutions or their subsidiary
banks failed, meaning Treasury lost its entire investment in those banks.43
As of June 30, 2012, taxpayers were still owed $13.8 billion related to CPP.
According to Treasury, it had write-offs and realized losses of $2.8 billion in
the program, leaving $11.1 billion in TARP funds outstanding.44 According to
Treasury, $191.1 billion of the CPP principal (or 93.3%) had been repaid as of
June 30, 2012. That repayment tally includes $245 million in proceeds from an
auction held June 11 through June 13, 2012, of Treasury’s preferred stock in
seven banks, but does not include $204.4 million in proceeds from an auction
held from June 25 through June 27, 2012, of preferred stock in seven other
banks because the sales closed after June 30, 2012. The repayment amount
also includes $363.3 million in preferred stock that was converted from CPP
investments into CDCI and therefore still represents outstanding obligations
to TARP, and $2.2 billion that was refinanced in 2011 into SBLF, a nonTARP Government program.45 Treasury continues to manage its portfolio of
CPP investments, including, for certain struggling institutions, converting its
preferred equity ownership into a more junior form of equity ownership, often
at a discount to par value (which may result in a loss) in an attempt to preserve
some value that might be lost if these institutions were to fail. For more detailed
information, see the “Capital Purchase Program” discussion in this section.
• Community Development Capital Initiative (“CDCI”) — Under CDCI,
Treasury used TARP money to buy preferred stock in or subordinated debt from
Community Development Financial Institutions (“CDFIs”). Treasury intended
for CDCI to “improve access to credit for small businesses in the country’s

quarterly report to congress I July 25, 2012

hardest-hit communities.”46 Under CDCI, TARP made capital investments
in the preferred stock or subordinated debt of eligible banks, bank holding
companies, thrifts, and credit unions.47 Eighty-four institutions received $570.1
million in funding under CDCI.48 However, 28 of these institutions converted
their existing CPP investment into CDCI ($363.3 million of the $570.1 million)
and 10 of those that converted received combined additional funding of $100.7
million under CDCI.49 Only $106 million of CDCI money went to institutions
that were not already TARP recipients. As of June 30, 2012, 82 institutions
remain in CDCI.
• Systemically Significant Failing Institutions (“SSFI”) Program — SSFI
enabled Treasury to invest in systemically significant institutions to prevent them
from failing.50 Only one firm received SSFI assistance: American International
Group, Inc. (“AIG”), which remained in SSFI as of June 30, 2012. The
Government’s rescue of AIG involved several different funding facilities provided
by the Federal Reserve Bank of New York (“FRBNY”) and Treasury, with various
changes to the transactions over time. The rescue of AIG was led by FRBNY and
the Board of Governors of the Federal Reserve System (“Federal Reserve”). With
the passage of EESA in October 2008, Treasury took on a greater role in the AIG
rescue as the Government expanded and restructured its aid.
There were two TARP investments in AIG. On November 25, 2008,
Treasury bought $40 billion of AIG’s preferred stock, the proceeds of which
were used to repay a portion of AIG’s debt to FRBNY. Then, on April 17, 2009,
Treasury obligated approximately $29.8 billion to an equity capital facility that
AIG was allowed to draw on as needed.51
On January 14, 2011, AIG executed its previously announced
Recapitalization Plan with the Government. According to Treasury, the intent
of the restructuring was to facilitate the repayment of AIG’s government loans
and investments and to promote AIG’s transition from a majority government
owned and supported entity to a financially sound and independent entity.52
Under the Recapitalization Plan, AIG fully repaid FRBNY’s revolving credit
facility, purchased the remainder of FRBNY’s preferred equity interests in two
AIG subsidiaries (which it then transferred to Treasury), and Treasury converted
its preferred stock holdings (along with the preferred stock holdings held by
the AIG Trust) into an approximately 92.1% common equity ownership stake
in AIG. The three main steps of the Recapitalization Plan are briefly described
below.
çç AIG repaid and terminated its revolving credit facility with FRBNY with
cash proceeds that it had received from sales of equity interests in two
companies: American International Assurance Co., Ltd. (“AIA”) and
American Life Insurance Company (“ALICO”).53
çç AIG applied cash proceeds from the AIA IPO and ALICO sale to retire
a portion of FRBNY’s preferred interests in the special purpose vehicle
(“SPV”) that held ALICO.54 AIG next drew down an additional $20.3 billion
in available TARP funds from the equity capital facility to repurchase the

Special Purpose Vehicle (“SPV”):
A legal entity, often off-balancesheet, that holds transferred assets
presumptively beyond the reach of the
entities providing the assets, and that
is legally isolated from its sponsor or
parent company.

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special inspector general I troubled asset relief program

Senior Preferred Stock: Shares that
give the stockholder priority dividend
and liquidation claims over junior
preferred and common stockholders.

remainder of FRBNY’s preferred interests in the ALICO SPV and all of
FRBNY’s preferred interests in the AIA SPV. AIG then transferred the
preferred interests to Treasury. AIG designated its remaining $2 billion
TARP equity capital facility to a new Series G standby equity commitment
available for general corporate purposes, which has been subsequently
terminated without drawdown.
çç AIG issued common stock in exchange for the preferred shares held by
Treasury and the AIG Trust. The conversion resulted in Treasury holding a
common equity ownership in AIG of approximately 92.1%.55
On May 27, 2011, Treasury sold 200 million shares of AIG’s common stock
for $5.8 billion in proceeds, which decreased Treasury’s equity ownership to
77%. On March 8, 2012, Treasury sold approximately 206.9 million shares
of AIG’s common stock for $6 billion in proceeds, which further decreased
Treasury’s equity ownership to 70%. On May 6, 2012, Treasury sold approximately 188.5 million shares of AIG’s common stock for $5.8 billion in proceeds.
This sale decreased Treasury’s equity ownership to 61%.56
Through two payments in February 2011 and March 2011, AIG fully repaid
the Government’s preferred interests in the ALICO SPV. Through a series of
repayments between February 2011 and March 2012, AIG fully repaid the
Government’s preferred interests in the AIA SPV.
As of June 30, 2012, taxpayers were still owed $36 billion related to AIG’s
bailout. According to Treasury’s TARP books and records, taxpayers have
realized losses on the TARP investment from an accounting standpoint of
$5.5 billion on Treasury’s sale of AIG stock. However, given the January 2011
restructuring of the FRBNY and Treasury investment, according to Treasury,
the Government overall has made a gain thus far on the stock sales. According
to Treasury, this leaves $30.4 billion in TARP funds outstanding. In return,
for that investment, Treasury holds 61% of AIG’s common stock (1.06 billion
shares).
For more detailed information on the Recapitalization Plan, the sale of AIG
common stock, and other AIG transactions, see the “Systemically Significant
Failing Institutions Program” discussion in this section. For discussion of how
AIG has changed while in TARP, see Section 3, “AIG Remains in TARP as the
Largest TARP Investment.”
• Targeted Investment Program (“TIP”) — Through TIP, Treasury invested in
financial institutions it deemed critical to the financial system.57 There were two
expenditures under this program, totaling $40 billion — the purchases of $20
billion each of senior preferred stock in Citigroup Inc. (“Citigroup”) and Bank
of America Corp. (“Bank of America”).58 Treasury also accepted common stock
warrants from each, as required by EESA. Both banks fully repaid Treasury
for its TIP investments.59 Treasury auctioned its Bank of America warrants on
March 3, 2010, and auctioned its Citigroup warrants on January 25, 2011.60
For more information on these two transactions, see the “Targeted Investment
Program and Asset Guarantee Program” discussion in this section.

quarterly report to congress I July 25, 2012

• Asset Guarantee Program (“AGP”) — AGP was designed to provide
insurance-like protection for a select pool of mortgage-related or similar assets
held by participants whose portfolios of distressed or illiquid assets threatened
market confidence.61 Treasury, the Federal Deposit Insurance Corporation
(“FDIC”), and the Federal Reserve offered certain loss protections in connection
with $301 billion in troubled Citigroup assets.62 In exchange for providing
the loss protection, Treasury received $4 billion of preferred stock that was
later converted to trust preferred securities (“TRUPS”), and FDIC received
$3 billion.63 On December 23, 2009, in connection with Citigroup’s TIP
repayment, Citigroup and the Government terminated the AGP agreement
and the Government suffered no loss. For more information on this program,
including more detailed information on the agreements between Treasury,
Citigroup, and FDIC, regarding these TRUPS, see the “Targeted Investment
Program and Asset Guarantee Program” discussion in this section.

Asset Support Programs
The stated purpose of these programs was to support the liquidity and market value
of assets owned by financial institutions. These assets included various classes of
asset-backed securities (“ABS”) and several types of loans. Treasury’s asset support
programs sought to bolster the balance sheets of financial firms and help free
capital so that these firms could extend more credit to support the economy.
• Term Asset-Backed Securities Loan Facility (“TALF”) — TALF was
originally designed to increase credit availability for consumers and small
businesses through a $200 billion Federal Reserve loan program. TALF provided
investors with non-recourse loans secured by certain types of ABS, including
credit card receivables, auto loans, equipment loans, student loans, floor
plan loans, insurance-premium finance loans, loans guaranteed by the Small
Business Administration (“SBA”), residential mortgage servicing advances, and
commercial mortgage-backed securities (“CMBS”).64 TALF closed to new loans
in June 2010.65 TALF ultimately provided $71.1 billion in Federal Reserve
financing. Of that amount, $4.5 billion remained outstanding as of June 30,
2012.66 FRBNY made 13 rounds of TALF loans with non-mortgage-related
ABS as collateral, totaling approximately $59 billion, with $3.4 billion of TALF
borrowings outstanding as of June 30, 2012.67 FRBNY also made 13 rounds of
TALF loans with CMBS as collateral, totaling $12.1 billion, with $1.1 billion in
loans outstanding as of June 30, 2012.68 Treasury originally obligated $20 billion
of TARP funds to support this program by providing loss protection to the loans
extended by FRBNY in the event that a borrower surrendered the ABS collateral
and walked away from the loan.69 Treasury has since reduced its obligation for
TALF to $1.4 billion.70 As of June 30, 2012, there had been no surrender of
collateral.71 As of June 30, 2012, $2.3 million in TARP funds had been allocated
under TALF for administrative expenses.72 For more information on these
activities, see the “TALF” discussion in this section.

Illiquid Assets: Assets that cannot be
quickly converted to cash.
Trust Preferred Securities (“TRUPS”):
Securities that have both equity and
debt characteristics, created by
establishing a trust and issuing debt
to it.
Asset-Backed Securities (“ABS”): Bonds
backed by a portfolio of consumer
or corporate loans, e.g., credit card,
auto, or small-business loans. Financial
companies typically issue ABS backed
by existing loans in order to fund new
loans for their customers.
Commercial Mortgage-Backed
Securities (“CMBS”): Bonds backed by
one or more mortgages on commercial
real estate (e.g., office buildings, rental
apartments, hotels).

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special inspector general I troubled asset relief program

Legacy Securities: Real estate-related
securities originally issued before
2009 that remained on the balance
sheets of financial institutions because
of pricing difficulties that resulted from
market disruption.
Non-Agency Residential MortgageBacked Securities (“non-agency
RMBS”): Financial instrument backed
by a group of residential real estate
mortgages (i.e., home mortgages for
residences with up to four dwelling
units) not guaranteed or owned by
a Government-sponsored enterprise
(“GSE”) (Fannie Mae or Freddie Mac) or
a Government agency.

• Public-Private Investment Program (“PPIP”) — PPIP’s goal was to restart
credit markets by using a combination of private equity, matching Government
equity, and Government debt to purchase legacy securities, i.e., CMBS and
non-agency residential mortgage-backed securities (“non-agency RMBS”).73
Under the program, nine Public-Private Investment Funds (“PPIFs”) managed
by private asset managers invested in non-agency RMBS and CMBS. Treasury
obligated $22.4 billion in TARP funds to the program, which was decreased
to $21.9 billion after Invesco Legacy Securities Master Fund, L.P. (“Invesco”)
terminated its investment period.74 As of June 30, 2012, seven PPIFs remained
active after one PPIP manager withdrew from the program and Invesco sold all
investments and is winding down the PPIF. As of June 30, 2012, the PPIFs had
drawn down $18.5 billion in debt and equity financing from Treasury funding
out of the total obligation, which includes $4.4 billion that has been repaid.75
As the PPIFs continue to make purchases, they will continue to have access to
draw down the remaining funding through the end of their investment periods,
the last of which will expire in December 2012.76 Following the expiration of the
investment period, the fund managers will have five years to manage and sell
the investment portfolio in the PPIF and return proceeds to private investors
and taxpayers. This period may be extended up to a maximum of two years. For
details about the program structure and fund-manager terms, see the “PublicPrivate Investment Program” discussion in this section.
• Unlocking Credit for Small Businesses (“UCSB”)/Small Business
Administration (“SBA”) Loan Support Initiative — In March 2009, Treasury
officials announced that Treasury would buy up to $15 billion in securities
backed by SBA loans under UCSB.77 Treasury obligated a total of $400 million
for UCSB and made purchases of $368.1 million in 31 securities under the
program. Treasury sold the last of its UCSB securities on January 24, 2012,
ending the program with a net investment gain of about $9 million.78 For more
information on the program, see the discussion of “Unlocking Credit for Small
Businesses/Small Business Administration Loan Support” in this section.

Automotive Industry Financing Program (“AIFP”)
TARP’s automotive industry support through AIFP aimed to “prevent a significant
disruption of the American automotive industry, which would pose a systemic
risk to financial market stability and have a negative effect on the economy of
the United States.”79 As of June 30, 2012, General Motors Company (“GM”)
and Ally Financial Inc. (“Ally Financial”), formerly GMAC Inc., remain in TARP.
Taxpayers are still owed $44.5 billion. This includes about $27 billion for the TARP
investment in GM and $14.7 billion for the TARP investment in Ally Financial, for
which Treasury holds common stock in GM and Ally Financial. This amount also
includes a $2.9 billion loss taxpayers suffered on the TARP investment in Chrysler.
Chrysler Financial fully repaid the TARP investment.80
Through AIFP, Treasury made emergency loans to Chrysler Holding LLC
(“Chrysler”), Chrysler Financial Services Americas LLC (“Chrysler Financial”), and
GM. Additionally, Treasury bought senior preferred stock from Ally Financial and

quarterly report to congress I July 25, 2012

assisted Chrysler and GM during their bankruptcy restructurings. Treasury obligated $84.8 billion to AIFP, then reduced the total obligation to $81.8 billion (including approximately $2.1 billion in loan commitments to New Chrysler that were never drawn down).81 As of June 30, 2012, $79.7 billion had been disbursed through
AIFP and Treasury had received $35.2 billion in principal repayments, preferred
stock redemption proceeds, and stock sale proceeds. As of June 30, 2012, Treasury
had received approximately $22.5 billion related to its GM investment, $7.6 billion
related to its Chrysler investment, $2.5 billion related to its Ally Financial/GMAC
investment, and $1.5 billion related to its Chrysler Financial investment.82 As of
June 30, 2012, Treasury had also received approximately $4.8 billion in dividends
and interest under AIFP and its two subprograms, ASSP and AWCP.83
In return for a total of $49.5 billion in loans to GM, Treasury received $6.7
billion in debt in GM (which was subsequently repaid), in addition to $2.1 billion
in preferred stock and a 60.8% common equity stake.84 As of June 30, 2012,
Treasury has an $849.2 million claim against Old GM’s bankruptcy, a bankruptcy
that recently terminated.85 Treasury does not expect any significant additional proceeds from this claim.86 On December 2, 2010, GM closed an initial public offering (“IPO”) in which Treasury sold a portion of its ownership stake for $18.1 billion
in gross proceeds, reducing its ownership percentage to 33.3%.87 On December
15, 2010, GM repurchased the $2.1 billion in preferred stock from Treasury. On
January 31, 2011, Treasury’s ownership in GM was diluted from 33.3% to 32% as
a result of GM contributing 61 million of its common shares to fund GM’s hourly
and salaried pension plans.88 As of June 30, 2012, Treasury had received $22.5
billion in principal repayments, proceeds from preferred stock redemptions, and
proceeds from the sale of common stock from GM, including approximately $136.6
million in repayments related to its right to recover proceeds from Old GM.89
Treasury provided approximately $12.5 billion in loan commitments to Chrysler,
Inc. (“Old Chrysler”), and Chrysler Group LLC (“New Chrysler”), of which $2.1
billion was never drawn down.90 Treasury also received a 9.9% equity stake, which
was diluted to 8.6% in April 2011 after Fiat increased its ownership interest by
meeting certain performance metrics. Upon full repayment of New Chrysler’s
TARP debt obligations on May 24, 2011, Fiat simultaneously exercised an equity
call option, which increased its stake in New Chrysler to 46% from 30%. As a
result, Treasury’s equity stake in New Chrysler was diluted and further decreased to
6.6%.91 On July 21, 2011, Treasury sold to Fiat for $500 million Treasury’s remaining equity ownership interest in New Chrysler.92 Treasury also sold to Fiat for $60
million Treasury’s rights to receive proceeds under an agreement with the United
Auto Workers (“UAW”) retiree trust pertaining to the trust’s shares in New Chrysler
on a fully diluted basis.93 Treasury retains the right to recover certain proceeds from
Old Chrysler’s bankruptcy but according to Treasury, it is unlikely to recover its full
investment.
Treasury invested a total of $17.2 billion in Ally Financial. On December
30, 2010, Treasury’s investment was restructured to provide for a 73.8% common equity stake, $2.7 billion in TRUPS (including amounts received in warrants that were immediately converted into additional securities), and $5.9 billion

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special inspector general I troubled asset relief program

in mandatorily convertible preferred shares.94 Treasury sold the $2.7 billion in
TRUPS on March 2, 2011.95 On March 31, 2011, Ally Financial announced that
it had filed a registration statement with the Securities and Exchange Commission
(“SEC”) for a proposed IPO of common stock owned by Treasury. On a number of
subsequent occasions, Ally Financial disclosed additional details about its proposed
IPO in amended registration statements filed with the SEC. Concurrent with the
proposed IPO, Treasury plans to convert $2.9 billion of its existing $5.9 billion of
mandatorily convertible preferred shares (“MCP”) into common stock.96 Treasury
will exchange the remaining $3 billion of its MCP into so-called tangible equity
units, a type of preferred stock, and will offer a portion of these tangible equity
units alongside the proposed common equity offering.97 On May 14, 2012, Ally
Financial announced that its mortgage subsidiary, Residential Capital, LLC, and
certain of its subsidiaries filed for bankruptcy court relief under Chapter 11 of
the U.S. Bankruptcy Code, and that it was exploring strategic alternatives for its
international operations, which include auto finance, insurance, and banking and
deposit operations in Canada, Mexico, Europe, the U.K. and South America.
Treasury provided a $1.5 billion loan to Chrysler Financial, which was fully
repaid with interest in July 2009.98
For details on assistance to these companies, see the “Automotive Industry
Support Programs” discussion in this section.
AIFP also included two subprograms:
• Auto Supplier Support Program (“ASSP”) — According to Treasury, this
program was intended to provide auto suppliers “with the confidence they need
to continue shipping their parts and the support they need to help access loans
to pay their employees and continue their operations.”99 Under the program,
which ended in April 2010, Treasury made loans for GM ($290 million) and
Chrysler ($123.1 million) that were fully repaid with $115.9 million in interest,
fees and other income.100 For more information, see the “Auto Supplier Support
Program” discussion in this section.
• Auto Warranty Commitment Program (“AWCP”) — This program was
designed to bolster consumer confidence by guaranteeing Chrysler and GM
vehicle warranties during the companies’ restructuring through bankruptcy. It
ended in July 2009 after Chrysler fully repaid its AWCP loan of $280.1 million
with interest and GM repaid just the principal — $360.6 million — of its
loan.101 For more information, see the “Auto Warranty Commitment Program”
discussion in this section.

quarterly report to congress I July 25, 2012

The following tables and figures summarize the status of TARP and TARPrelated initiatives:
•
•
•
•

Table 2.6 — total funds subject to SIGTARP oversight as of June 30, 2012
Table 2.7 — obligations/expenditures by program as of June 30, 2012
Table 2.8 and Table 2.9 — summary of TARP terms and agreements
Table 2.10 — summary of largest warrant positions held by Treasury, by
program, as of June 30, 2012
• Table 2.11 — summary of dividends, interest payments, and fees received, by
program, as of June 30, 2012
For a report of all TARP purchases, obligations, expenditures, and revenues, see
Appendix C: “Reporting Requirements.”

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special inspector general I troubled asset relief program

TABLE 2.6

TOTAL FUNDS SUBJECT TO SIGTARP OVERSIGHT, AS OF 6/30/2012

($ Billions)

Numbers in parentheses represent repayments and reductions in exposure

Total
Funding

TARP Funding
after DoddFrank

TARP
Funding as of
6/30/2012

Program

Brief Description or Participant

Housing Support Programs

Modification of mortgage loans

$70.6a

$45.6b

$45.6

Capital Purchase Program (“CPP”)

Investments in 707 banks; received $191.1 billion in
principal repayments, including $363.3 million in noncash conversion from CPP to CDCI

204.9

204.9

204.9

CLOSED
Community Development Capital
Initiative (“CDCI”)
CLOSED
Systemically Significant Failing
Institutions (“SSFI”)
CLOSED
Targeted Investment Program (“TIP”)
CLOSED
Asset Guarantee Program (“AGP”)
CLOSED

Investments in Community Development Financial
Institutions (“CDFIs”), received $350,000 in principal
repayment
AIG Investment; received $34.7 billion in repayments and
reductions in exposure
Citigroup, Bank of America Investments
Citigroup, ring-fence asset guarantee

(191.1)

(191.1)

0.6

0.6

c

69.8

c

0.6

69.8

(34.7)

d

(191.1)c

67.8

(34.7)

d

(34.7)d

40.0

40.0

40.0

(40.0)

(40.0)

(40.0)

301.0

5.0

5.0

(301.0)

(5.0)

(5.0)

4.3e

1.4e

Term Asset-Backed Securities
Loan Facility (“TALF”)

FRBNY non-recourse loans for purchase of asset-backed
securities

71.1
(0.0)

(0.0)

(0.0)

Public-Private Investment Program
(“PPIP”)

Investments in legacy mortgage-backed securities using
private and Government equity, along with Government
debt

29.8

22.4

21.9

(4.4)

(4.4)

(4.4)

0.4h

0.4h

0.4h

(0.4)

(0.4)

(0.4)

80.7

80.7

79.7

(36.2)

(36.2)

(36.2)

Unlocking Credit for Small Businesses
(“UCSB”)

Purchase of securities backed by SBA loans

CLOSED
Automotive Industry Financing Program
(“AIFP”)
CLOSED
Auto Suppliers Support Program
(“ASSP”)
CLOSED
Auto Warranty Commitment Program
(“AWCP”)
CLOSED
Total Obligations

GM, Chrysler, Ally Financial Inc. (formerly GMAC),
Chrysler Financial; received $34.2 billion in loan
repayments, preferred stock redemptions and proceeds
from the sale of common stock; terminated Chrysler’s
$2.1 billion in undrawn loan commitments

f

g

Government-backed protection for auto parts suppliers;
received $0.4 billion in loan repayments

0.4i

0.4i

0.4

(0.4)

(0.4)

(0.4)

Government-backed protection for warranties of cars
sold during the GM and Chrysler bankruptcy restructuring
periods

0.6

0.6

0.6

(0.6)

(0.6)

(0.6)

$869.9

$474.8

$467.2

Notes: Numbers may not total due to rounding.
a
	Program was initially announced as a $75 billion initiative with $50 billion funded through TARP. Treasury reduced the commitment from $50 billion to an obligation of $45.6 billion; therefore, including
the $25 billion estimated to be spent by the GSEs, the total program amount is $70.6 billion.
b
	Treasury reduced its commitment from $50 billion to an obligation of $45.6 billion.
c
	Does not include $204.4 million in proceeds from CPP auction held June 25-27, 2012, but not settled until after June 30, 2012.
d
	The $34.7 billion in reduced exposure and repayment for SSFI includes amounts applied to pay (i) accrued preferred returns, (ii) redeem the outstanding liquidation amount, and (iii) the cancellation of the
series G capital facility. Does not include AIG investment proceeds from the sale of AIG stock that Treasury received from the AIG credit facility trust in the January 2011 recapitalization.
e
	Treasury reduced obligation from $20 billion to $4.3 billion in 2010, then further reduced obligation from $4.3 billion to $1.4 billion in 2012.
f
	PPIP funding includes $7.4 billion of private-sector equity capital. Includes $0.4 billion of initial obligations to The TCW Group, Inc., which has been repaid.
g
	Treasury reduced its commitment from $30 billion to approximately $22.4 billion in debt and equity obligations to the Public-Private Investment Funds. Invesco terminated its investment period on
September 26, 2011, without fully drawing down all committed equity and debt.
h
	Treasury reduced commitment from $15 billion to an obligation of $400 million.
i
	Treasury’s original commitment under this program was $5 billion, which was reduced to $3.5 billion effective 7/1/2009. Of the $3.5 billion available, only $413 million was borrowed.
Sources: Treasury, Transactions Report, 6/27/2012; Treasury, Daily TARP Update, 7/2/2012; Treasury Press Release, “U.S. Government Finalizes Terms of Citi Guarantee Announced in November,”
1/16/2009, www.treasury.gov/press-center/press-releases/Pages/hp1358.aspx, accessed 6/28/2012; FRBNY, response to SIGTARP data call, 7/5/2012; Treasury, “Making Home Affordable Updated
Detailed Program Description,” 3/4/2009, www.treasury.gov/press-center/press-releases/Documents/housing_fact_sheet.pdf, accessed 6/28/2012; Treasury, Legacy Securities Public-Private
Investment Program, Program Update – Quarter Ended March 31, 2012, 4/19/2012, www.treasury.gov/initiatives/financial-stability/programs/Credit%20Market%20Programs/ppip/Documents/PPIP%20
Report%20-%20Q1-12.pdf, accessed 7/10/2012.

quarterly report to congress I July 25, 2012

TABLE 2.7

OBLIGATION/EXPENDITURE LEVELS BY PROGRAM, as of 6/30/2012
Amount
Authorized Under EESA

($ Billions)

Percent (%)

$700.0

Released Immediately

250.0

52.6%

Released Under Presidential Certificate of Need

100.0

21.1%

Released Under Presidential Certificate of Need &
Resolution to Disapprove Failed

350.0

73.7%

Helping Families Save Their Home Act of 2009
The Dodd-Frank Act
Total Released

(1.2)

-0.3%

(223.8)

-47.1%

$475.0

100.0%

Obligations
after DoddFrank Act

Current
Obligations as
of 6/30/2012

Making Home Affordable
(“MHA”)

$29.9

$29.9

6.4%

Housing Finance Agency:
Hardest Hit Fund (“HHF”)

$7.6

$7.6

1.6%

FHA Short Refinance
Program

$8.1

$8.1

1.7%

$45.6

$45.6

9.8%

Capital Purchase
Program (“CPP”)

$204.9

$204.9

43.9%

($191.1)c

CPP Total

$204.9

$204.9

43.9%

($191.1)c

Community Development
Capital Initiative (“CDCI”)

$0.6

$0.6

0.1%

CDCI Total

$0.6

$0.6

0.1%

Less: Obligations by
Treasury under TARPa

Housing Support
Programs Total

Current
Obligation as %
of Released

Repaid/
Reduced
Exposure

Obligation
Outstandingb

“Housing Support Programs”

—

$45.6
“Financial Institution Support
Programs”
$13.8
“Financial Institution Support
Programs”

*
$0.0

$0.6

Systemically Significant
Failing Institutions
(“SSFI”) Program:
American International
Group, Inc. (“AIG”)d

“Financial Institution Support
Programs”
$69.8

$67.8

14.5%

($34.7)

$69.8

$67.8

14.5%

($34.7)

Bank of America
Corporation

$20.0

$20.0

4.3%

($20.0)

Citigroup, Inc.

$20.0

$20.0

4.3%

($20.0)

$40.0

$40.0

8.6%

($40.0)

SSFI Total

$33.1

Targeted Investment
Program (“TIP”):

TIP Total

“Financial Institution Support
Programs”

—

Asset Guarantee
Program (“AGP”):
Citigroup, Inc.

e

AGP Total

$5.0

$5.0

1.1%

($5.0)

$5.0

$5.0

1.1%

($5.0)

“Financial Institution Support
Programs”
—

Term Asset-Backed
Securities Loan Facility
(“TALF”):
TALF LLC
TALF Total

Section Reference

“Asset Support Programs”
$4.3

$1.4

0.3%

($0.0)

$4.3

$1.4

0.3%

($0.0)

$1.4
Continued on next page

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special inspector general I troubled asset relief program

OBLIGATION/EXPENDITURE LEVELS BY PROGRAM

($ Billions) (CONTINUED)

Obligations
after DoddFrank Act

Current
Obligations as
of 6/30/2012

AG GECC PPIF Master
Fund, L.P.

$3.7

$3.7

0.8%

($0.8)

AllianceBernstein
Legacy Securities
Master Fund, L.P.

$3.5

$3.5

0.7%

($1.1)

Less: Obligations by
Treasury under TARPa

Current
Obligation as %
of Released

Repaid/
Reduced
Exposure

Obligation
Outstandingb

Section Reference

Legacy Securities
Public-Private Investment
Program (“PPIP”):

BlackRock PPIF, L.P.

$2.1

$2.1

0.4%

—

Invesco Legacy
Securities Master
Fund, L.P.f

$2.6

$2.0

0.4%

($1.7)

Marathon Legacy
Securities PublicPrivate Investment
Partnership, L.P.

$1.4

$1.4

0.3%

—

Oaktree PPIP Fund,
L.P.

$3.5

$3.5

0.7%

($0.2)

RLJ Western Asset
Public/Private Master
Fund, L.P.

$1.9

$1.9

0.4%

UST/TCW Senior
Mortgage Securities
Fund, L.P.g

$0.4

$0.4

0.1%

($0.4)

Wellington
Management Legacy
Securities PPIF
Master Fund, LP

$3.4

$3.4

0.7%

($0.1)

PPIP Totalh

“Asset Support Programs”

*

$22.4

$21.9

4.7%

($4.4)

Unlocking Credit for
Small Businesses
(“UCSB”)

$0.4

$0.4

0.1%

($0.4)

UCSB Total

$0.4

$0.4

0.1%

($0.4)

General Motors
Corporation (“GM”)

$49.5

$49.5

10.6%

($22.5)

Ally Financial
(formerly GMAC)

$17.2

$17.2

3.7%

($2.5)

Chrysler Holding LLCi

$12.5

$10.5

2.2%

($9.7)

$1.5

$1.5

0.3%

($1.5)

$80.7

$78.7

16.8%

($36.2)

$17.5
“Asset Support Programs”
*

Automotive Industry
Financing Program
(“AIFP”):

Chrysler Financial
Services Americas
LLC
AIFP Total

“Automotive Industry Support
Programs”

$42.5
Continued on next page

quarterly report to congress I July 25, 2012

OBLIGATION/EXPENDITURE LEVELS BY PROGRAM
Less: Obligations by
Treasury under TARPa

Obligations
after DoddFrank Act

($ Billions) (CONTINUED)

Current
Obligations as
of 6/30/2012

Current
Obligation as %
of Released

Repaid/
Reduced
Exposure

Obligation
Outstandingb

Automotive Supplier
Support Program
(“ASSP”):
GM Suppliers
Receivables LLCj

$0.3

$0.3

0.1%

($0.3)

Chrysler Holding LLC

$0.1

$0.1

0.0%

($0.1)

$0.4

$0.4

0.1%

($0.4)

ASSP Total

j

“Automotive Industry Support
Programs”

—

Automotive Warranty
Commitment Program
(“AWCP”):
General Motors
Corporation (“GM”)
Chrysler Holding LLC
AWCP Total
TARP Obligations
Subtotal
TARP Repayments/
Reductions in
Exposure Subtotal
TARP Obligations
Outstanding Subtotal

$0.4

$0.4

0.1%

“Automotive Industry Support
Programs”

($0.4)

$0.3

$0.3

0.0%

($0.3)

$0.6

$0.6

0.1%

($0.6)

$474.8

$467.2

Section Reference

—

100%

($312.8)
$154.4

Notes: Numbers may not total due to rounding.
a
From a budgetary perspective, what Treasury has obligated to spend (e.g., signed agreements with TARP fund recipients).
b
Figure does not subtract losses incurred from failed banks.
c
	Does not include $204.4 million in proceeds from CPP auction held June 25-27, 2012, but not settled until after June 30, 2012. Does include $363.3 million non-cash conversion from CPP to CDCI.
d
	The $34.7 billion in reduced exposure and repayment for SSFI includes amounts applied to pay (i) accrued preferred returns, (ii) redeem the outstanding liquidation amount, and (iii) the cancellation of the
series G capital facility. Does not include AIG investment proceeds from the sale of AIG stock that Treasury received from the AIG credit facility trust in the January 2011 recapitalization.
e
	Treasury committed $5 billion to Citigroup under AGP; however, the funding was conditional based on losses that could potentially be realized and may potentially never be expended. This amount was not
an actual outlay of cash.
f
	Invesco paid the remainder of its debt, $284.5 million, to Treasury on March 14, 2012.
g
The TCW Group, Inc. repaid the funds invested in its PPIF, which is now liquidated.
h
	Treasury selected nine fund management firms to establish PPIFs. One PPIP manager, TCW, subsequently withdrew. According to Treasury, the current PPIP obligation is $21.9 billion, and includes
$365.25 million of an initial obligation to TCW that was funded. TCW repaid the funds.
i
	The $9.7 billion in repayments and reductions in exposure includes (i) loan repayments from New Chrysler, (ii) proceeds related to the liquidation of Old Chrysler, (iii) a settlement payment for a loan to
Chrysler Holding, (iv) termination of New Chrysler’s ability to draw the remaining $2.1 billion under a loan facility made available in May 2009, and (v) proceeds related to the sale to Fiat of Treasury’s
remaining equity ownership stake in New Chrysler and the sale to Fiat of Treasury’s rights to receive proceeds under an agreement with the United Auto Workers (“UAW”) retiree trust pertaining to the
trust’s shares in New Chrysler.
j
	Represents an SPV created by the manufacturer. Balance represents the maximum loan amount, which will be funded incrementally. Treasury’s original commitment under this program was $5 billion, but
subsequently reduced to $3.5 billion effective 7/1/2009. Of the $3.5 billion available, only $413 million was borrowed.
*Amount less than $50 million.
Sources: Emergency Economic Stabilization Act, P.L. 110-343, 10/3/2008; Library of Congress, “A joint resolution relating to the disapproval of obligations under the Emergency Economic Stabilization
Act of 2008,” 1/15/2009, http://thomas.loc.gov/cgi-bin/bdquery/D?d111:5:./list/bss/d111SJ.lst::, accessed 6/28/2012; Helping Families Save Their Homes Act of 2009, P.L. 111-22, 5/20/2009;
Treasury, Transactions Report, 6/27/2012; Treasury, Transactions Report-Housing Programs, 7/2/2012; Treasury, response to SIGTARP data call, 7/5/2012; Treasury, Section 105(a) Report,
7/10/2012.

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special inspector general I troubled asset relief program

TABLE 2.8

Debt Agreements, as of 6/30/2012
TARP
Program

CPP –
S-Corps

CDCI –
Credit
Unions

Company

Originally
52 QFIs

Date of
Agreement

1/14/2009a

Cost
Assigned

$0.5 billion

All

CDCI –
S-Corps

PPIP

All

9/30/2009
and later

$20 billion

Description of
Investment

Investment Information

Interest/
Dividends

Term of
Agreement

Senior
Subordinated
Securities

Each QFI may issue senior
securities with an aggregate
principal amount of 1% – 3% of
its risk-weighted assets, but not
to exceed $25 billion.

7.7% for first 5
years; 13.8%
thereafter

30 years

Senior
Subordinated
Security Warrants
that are exercised
immediately

Treasury will receive warrants
to purchase an amount equal
to 5% of the senior securities
purchased on the date of
investment.

13.8%

30 years

Subordinated
Debt for Credit
Unions

Each QCU may issue CDCI
Senior Securities with an
aggregate principal amount equal
2% for first 8 years,
to not more than 3.5% of its total
9% thereafter
assets and not more than 50%
of the capital and surplus of the
QCU.

CDCI – Credit
Unions

Subordinated
Debt for S-corps

Each QFI may issue CDCI Senior
Securities with an aggregate
principal amount equal to not
more than 5% of (i), if the QFI is a
Certified Entity the risk-weighted
assets of the QFI, or (ii), if the
QFI is not a Certified Entity, the
sum of the RWAs of each of the
Certified Entities, in each case
less the aggregate capital or,
as the case may be, principal
amount of any outstanding TARP
assistance of the QFI.

3.1% for first 8
years, 13.8%
thereafter

CDCI –
S-Corps

LIBOR + 1%

The debt
obligation for
each fund
matures at
the earlier
of the
dissolution of
the fund or
10 years.

Debt Obligation
with Contingent
Interest
Promissory Note

Each of the loans will be funded
incrementally, upon demand by
the fund manager.

Notes: Numbers may be affected by rounding.
a
Announcement date of CPP S-Corporation Term Sheet.
Sources: Treasury, “Loan and Security Agreement By and Between General Motors Corporation as Borrower and The United States Department of Treasury as Lender Dated as of December 31, 2008,”
12/31/2008; OFS, response to SIGTARP draft report, 1/30/2009; Treasury, Transactions Report, 9/30/2010; Treasury, response to SIGTARP data call, 10/7/2010; Treasury’s “TARP Community
Development Capital Initiative Program Agreement, CDFI Bank/Thrift Senior Preferred Stock, Summary of CDCI Senior Preferred Terms,” 4/26/2010; Treasury’s “TARP Community Development Capital
Initiative CDFI Credit Unions Senior Securities Summary of Terms of CDCI Senior Securities,” 4/26/2010; Treasury’s “TARP’s Community Development Capital Initiative CDFI Subchapter S Corporation
Senior Securities Summary of Terms of CDCI Senior Securities,” 4/26/2010; Treasury, “Legacy Securities Public-Private Investment Partnership Summary of Indictive Terms and Conditions,” 7/8/2009.

quarterly report to congress I July 25, 2012

TABLE 2.9

Equity Agreements, as of 6/30/2012
TARP
Program

CPP –
Public

CPP –
Private

CDCI

SSFI

SSFI

Company

Originally 286
QFIs

Originally 369
QFIs

Date of
Agreement

10/14/2008a
and later

11/17/2008b
and later

American
International
Group, Inc.

$200.1
billion

$4 billion

$780.2
million

All

American
International
Group, Inc.

Cost
Assigned

4/17/2009

4/17/2009

$41.6
billionc

$29.8
billiond

Description
of Investment

Investment Information

Dividends

Term of
Agreement

Senior
Preferred
Equity

1-3% of risk-weighted assets,
not to exceed $25 billion for
each QFI

5% for first
5 years, 9%
thereafter

Perpetual

Common
Stock
Purchase
Warrants

15% of senior preferred
amount

—

Up to 10 years

Preferred
Equity

1-3% of risk-weighted assets,
not to exceed $25 billion for
each QFI

5% for first
5 years, 9%
thereafter

Perpetual

Preferred
Stock
Purchase
Warrants that
are exercised
immediately

5% of preferred amount

9%

Perpetual

Preferred
Equity for
banks & thrift
institutions

5% of risk-weighted assets
for banks and bank holding
companies

2% for first
8 years, 9%
thereafter

Perpetual

NonCumulative
Preferred
Equity

$41.6 billion aggregate
liquidation preference

10%

Perpetual

Common
Stock
Purchase
Warrants

2% of issued and outstanding
common stock on investment
date of 11/25/2008; the
warrant was originally for
53,798,766 shares and had a
$2.50 exercise price, but after
the 6/30/2009 split, it is for
2,689,938.30 shares and has
an exercise price of $50.

—

Up to 10 years

NonCumulative
Preferred
Equity

Up to $29.8 billion aggregate
liquidation preference. As of
9/30/2009, the aggregate
liquidation preference was $3.2
billion.

10%

Perpetual (life of
the facility is 5
years)

Common
Stock
Purchase
Warrants

150 common stock warrants
outstanding; $0.0002 exercise
price

—

Up to 10 years
Continued on next page

59

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special inspector general I troubled asset relief program

Equity Agreements, as of 6/30/2012
TARP
Program

SSFI

Company

American
International
Group, Inc.

Date of
Agreement

(continued)

Cost
Assigned

Description
of Investment

Investment Information

Dividends

Term of
Agreement

AIA Preferred
units, ALICO
Junior
Preferred
Interests,
Common
Stock

Exchanged preferred Series F
shares for $16.9 billion of AIA
Preferred Units, $3.4 billion
in ALICO Junior Preferred
Interests, and 167.6 million
shares of Common stock at
an exercise price of $43.53.
Following the repayments to
Treasury on March 8, 2012,
for $6 billion, March 15,
2012, for $1.5 billion, March
22, 2012, for $1.5 billion,
and May 6, 2012, for $5.8
billion, AIG successfully retired
the remainder if Treasury’s
preferred equity interests in the
AIA SPV.

—

Up to 10 years

$41.6 billion

Common
Stock

Exchanged preferred Series
D shares for 924.5 million
shares of common stock at an
exercise price of $45

—

Perpetual

$10 billion

Membership
interest in a
partnership

Each membership interest will
be funded upon demand from
the fund manager.

—

8 years with the
possibility of
extension for 2
additional years

Mandatorily
Convertible
Preferred
Stock

$5 billion

9%

Converts to
common equity
interest after 7
years

9%

Converts to
common equity
interest after 7
years

9%

Converts to
common equity
interest after 7
years

$29.8
billione
1/14/2011

f

PPIP

AIFP

All

Ally Financial
Inc. (formerly
GMAC)

9/30/2009 and
later

12/29/2008

$5 billion

Preferred
Stock
Purchase
Warrants that
are exercised
immediately
Mandatorily
Convertible
Preferred
Stockg

AIFP

Ally Financial
Inc. (formerly
GMAC)

5/21/2009

$7.5 billion

5% of original preferred amount

$4.5 billion

Preferred
Stock
Purchase
Warrants that
are exercised
immediately

5% of original preferred amount

9%

Converts to
common equity
interest after 7
years

Common
Equity Interesth

$3 billion

—

Perpetual
Continued on next page

quarterly report to congress I July 25, 2012

Equity Agreements, as of 6/30/2012
TARP
Program

AIFP

AIFP

AIFP

AIFP

Company
Ally Financial
Inc. (formerly
GMAC)

Ally Financial
Inc. (formerly
GMAC)

Ally Financial
Inc. (formerly
GMAC)

Ally Financial
Inc. (formerly
GMAC)

Date of
Agreement

5/29/2009

12/30/2009

12/30/2009

12/30/2009

(continued)

Cost
Assigned

$0.9 billion

$2.5 billion

$1.3 billion

$5.5 billion

Description
of Investment

Investment Information

Dividends

Term of
Agreement

Common
Equity Interest

This equity interest was
obtained by exchanging a
prior debt obligation with
General Motors. See “Debt
Agreements” table for more
information.

—

Perpetual

Trust Preferred
Securities

$2.5 billion

8%

Trust Preferred
purchase
warrants that
are exercised
immediately

5% of trust preferred amount

—

Mandatorily
Convertible
Preferred
Stock

$1.3 billion

9%

Preferred
Stock
Purchase
Warrants that
are exercised
immediately

5% of preferred amount

—

Common
Equity Interesth

$5.5 billion

—

Redeemable upon
the repayment of
the debenture

Converts to
common equity
interest after 7
years

Perpetual

Notes: Numbers may be affected by rounding.
a
Announcement date of CPP Public Term Sheet.
b
Announcement date of CPP Private Term Sheet.
c
AIG exchanged Treasury’s $40 billion investment in cumulative preferred stock (obtained on 11/25/2008) for non-cumulative preferred stock, effectively cancelling the original $40 billion investment.
d
The Equity Capital Facility was announced as a $30 billion commitment, but Treasury reduced this amount by the value of the AIGFP Retention Payment amount of $165 million.
e
	On 1/14/2011, (A) Treasury exchanged $27.84 billion of Treasury’s investment in AIG’s Fixed Rate Non-Cumulative Perpetual Preferred Stock (Series F) which is equal to the amount funded (including
amounts drawn at closing) under the Series F equity capital facility, for (i) the transferred SPV preferred interests and (ii) 167,623,733 shares of AIG Common Stock, and (B) Treasury exchanged $2
billion of undrawn Series F for 20,000 shares of preferred stock under the new Series G Cumulative Mandatory Convertible Preferred Stock equity capital facility under which AIG has the right to draw up
to $2 billion. The Series G equity capital facility was subsequently terminated without drawdown.
f
	On 1/14/2011, Treasury exchanged an amount equivalent to the $40 billion initial investment plus capitalized interest from the April 2009 exchange (see note 1 above) of Fixed Rate Non-Cumulative
Perpetual Preferred Stock (Series E) for 924,546,133 shares of AIG Common Stock.
g
On 12/31/2009, Treasury exchanged $5.25 billion of preferred stock, which it acquired on December 29, 2009, into mandatorily convertible preferred stock (“MCP”).
h
	On 12/31/2010, Treasury converted $5.5 billion of its existing MCP, which was invested in May 2009, into common equity. Treasury’s equity ownership of Ally Financial Inc. (formerly GMAC) increased
from 56% to 74% due to this conversion.
Sources: Treasury, “TARP Capital Purchase Program Agreement, Senior Preferred Stock and Warrants, Summary of Senior Preferred Terms,” 10/14/2008; Treasury, “TARP Capital Purchase Program
Agreement, (Non-Public QFIs, excluding S Corps and Mutual Organizations) Preferred Securities, Summary of Warrant Terms,” 11/17/2008; Treasury, “Securities Purchase Agreement dated as of
November 25, 2008 between American International Group, Inc. and United States Department of Treasury,” 11/25/2008; Treasury, “TARP AIG SSFI Investment, Senior Preferred Stock and Warrant,
Summary of Senior Preferred Terms,” 11/25/2008; Treasury, “Securities Purchase Agreement dated as of January 15, 2009 between Citigroup, Inc. and United States Department of Treasury,”
1/15/2009; Treasury, “Citigroup, Inc. Summary of Terms, Eligible Asset Guarantee,” 11/23/2008; “Securities Purchase Agreement dated as of January 15, 2009 between Bank of America Corporation
and United States Department of Treasury,” 1/15/2009; Treasury, “Bank of America Summary of Terms, Preferred Securities,” 1/16/2009; Treasury, “GMAC LLC Automotive Industry Financing Program,
Preferred Membership Interests, Summary of Preferred Terms,” 12/29/2008; Treasury, Transactions Report, 3/31/2011; Treasury, response to SIGTARP data call, 10/7/2010; Treasury, “TARP
Community Development Capital Initiative Program Agreement, CDFI Bank/Thrift Senior Preferred Stock, Summary of CDCI Senior Preferred Terms,” 4/26/2010; Treasury, “TARP Community Development
Capital Initiative CDFI Credit Unions Senior Securities Summary of Terms of CDCI Senior Securities,” 4/26/2010; Treasury, “TARP’s Community Development Capital Initiative CDFI Subchapter S
Corporation Senior Securities Summary of Terms of CDCI Senior Securities,” 4/26/2010; Treasury, “Treasury Converts Nearly Half of Its Ally Preferred Shares to Common Stock,” 12/30/2010; Ally
Financial Inc. (GOM), 8−K, 12/30/2010; Treasury, Transactions Report, 7/2/2012; Treasury, “Master Transaction Agreement for American International Group. INC, ALICO Holdings LLC, AIA Aurora LLC,
Federal Reserve Bank of New York, United States Treasury, and AIG Credit Facility Trust,” 12/8/2010; Treasury, “Legacy Securities Public-Private Investment Partnership Summary of Indictive Terms and
Conditions,” 7/8/2009.

61

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special inspector general I troubled asset relief program

TABLE 2.10

LARGEST POSITIONS IN WARRANTS HELD BY TREASURY, BY PROGRAM, AS OF 6/30/2012

Participant

Investment Date

Current Number
of Warrants
Outstanding

Strike Price

Stock Price as of
6/29/2012

Capital Purchase Program (“CPP”)
Synovus Financial Corp.

12/19/2008

15,510,737

$9.36

$1.98

Flagstar Bancorp, Inc.

1/16/2009

6,451,379

$6.20

$0.84

Zions Bancorporation

11/14/2008

5,789,909

$36.27

$19.42

Popular, Inc.

12/5/2008

2,093,284

$67.00

$16.61

Cathay General Bancorp

12/5/2008

1,846,378

$20.96

$16.51

Citizens Republic Bancorp, Inc.

12/12/2008

1,757,813

$25.60

$17.13

International Bancshares Corporation

12/23/2008

1,326,238

$24.43

$19.51

M&T Bank Corporationc

12/5/2008

1,218,522

$73.86

$82.00

PrivateBancorp, Inc.

2/27/2009

645,013

$28.35

$14.76

United Community Banks, Inc.

12/5/2008

219,908

$61.39

$8.57

AIGa

11/25/2008

2,689,938

$50.00

$32.09

AIG

4/17/2009

150

$0.00

$32.09

Systemically Significant Failing Institutions
(“SSFI”) Program
a

b

Notes: Numbers may be affected by rounding.
a
All warrant and stock data for AIG are based on the 6/30/2009 reverse stock split of 20 for 1.
b
	Strike price is $0.00002.
c
	M&T Bank Corporation assumed additional warrant positions in conjunction with two acquired CPP investments. These additional positions are 407,542 shares at a strike price of $55.76 and 95,383
shares at a strike price of $518.96.
Sources: Treasury, Transactions Report, 6/27/2012; Treasury, Dividends and Interest Report, 7/11/2012; Treasury, response to SIGTARP data call, 7/10/2012; Market Data, Bloomberg L.P., accessed
7/9/2012.

TABLE 2.11

DIVIDENDS, INTEREST, DISTRIBUTIONS, AND OTHER INCOME PAYMENTS, AS OF 6/30/2012
Dividends

Interest

Distributionsa

Other Incomeb

Total

c

$11,561,231,819

$106,750,371

$—

$14,527,500,194

$26,195,482,384

CDCI

13,031,228

6,196,474

—

—

19,227,702

—

—

—

457,105,652

457,105,652

3,004,444,444

—

—

1,427,190,941

4,431,635,385

CPP

SSFI

d

TIP
AGP

442,964,764

—

—

2,589,197,045

3,032,161,809

PPIP

—

275,850,318

694,785,028

24,078,780

994,714,126

UCSB

—

13,347,352

—

29,201,848

42,549,200

AIFPe

3,140,957,051

1,665,336,675

—

530,000,000

5,336,293,726

ASSP

—

31,949,931

—

84,000,000

115,949,931

Total

$18,162,629,306

$2,099,431,121

$694,785,028

$19,668,274,460

$40,625,119,915

Notes: Numbers may not total due to rounding.
a
	Distributions are investment proceeds from the PPIF’s trading activities allocated to the partners, including Treasury, not later than 30 days after the end of each quarter.
b
	Other income includes Citigroup common stock gain for CPP, Citigroup payment for AGP, warrant sales, additional note proceeds from the auto programs and the Consumer and Business Lending
Initiative/SBA 7(a) programs, principal repayments on the SBA 7(a) program, and repayments associated with the termination of the TCW fund for PPIP.
c
	Includes $13 million fee received as part of the Popular exchange.
d
	Pursuant to the recapitalization plan on 1/14/2011, AIG had an additional obligation to Treasury of $641,275,676 to reflect the cumulative unpaid interest which further converted into AIG common stock.
Other income from SSFI includes $165 million in fees and approximately $292.1 million representing return on securities held in the AIA and ALICO SPVs.
e
	Includes AWCP.
Sources: Treasury, Transactions Report, 6/27/2012; Treasury, Section 105(a) Report, 7/10/2012; Treasury, Dividends and Interest Report, 7/11/2012; Treasury, response to SIGTARP data call,
7/10/2012.

quarterly report to congress I July 25, 2012

Housing Support Programs
On February 18, 2009, the Administration announced a foreclosure prevention
plan that became the Making Home Affordable (“MHA”) program, an umbrella
program for the Administration’s homeowner assistance and foreclosure prevention
efforts.102 MHA initially consisted of the Home Affordable Modification Program
(“HAMP”), a Treasury program that uses TARP funds to provide incentives for
mortgage servicers to modify eligible first mortgages, and two initiatives at the
Government-sponsored enterprises (“GSEs”) that use non-TARP funds.103 HAMP
was originally intended “to help as many as three to four million financially
struggling homeowners avoid foreclosure by modifying loans to a level that is
affordable for borrowers now and sustainable over the long term.”104 On June 1,
2012, HAMP expanded the pool of homeowners potentially eligible to be assisted
through the launch of HAMP Tier 2; however, Treasury has not estimated the
number of homeowners that HAMP Tier 2 is intended to assist.105
Treasury over time expanded MHA to include sub-programs designed to
overcome obstacles to sustainable HAMP modifications. Treasury also allocated
TARP funds to support two additional housing support efforts: a Federal Housing
Administration (“FHA”) refinancing program and TARP funding for 19 state
housing finance agencies, called the Housing Finance Agency Hardest Hit Fund
(“Hardest Hit Fund” or “HHF”).
Not all housing support programs are funded, or completely funded, by TARP.
Of the originally anticipated $75 billion cost for MHA, $50 billion was to be
funded by TARP, with the remainder funded by the GSEs.106 Treasury has obligated
TARP funds of $45.6 billion, which includes $29.9 billion for MHA incentive payments, $8.1 billion for FHA Short Refinance, and $7.6 billion for the Hardest Hit
Fund.107 Housing support programs include the following initiatives:
• Home Affordable Modification Program (“HAMP”) — HAMP is intended
to use incentive payments to encourage loan servicers (“servicers”) and
investors to modify eligible first-lien mortgages so that the monthly payments
of homeowners who are currently in default or generally at imminent risk of
default will be reduced to affordable and sustainable levels. Incentive payments
for modifications to loans owned or guaranteed by the GSEs are paid by the
GSEs, not TARP.108 As of June 30, 2012, there were 818,803 active permanent
HAMP modifications, 393,887 of which were under TARP, with the remainder
under the GSE portion of the program.109 While HAMP generally refers to
the first-lien mortgage modification program, it also includes the following
subprograms:
çç Home Price Decline Protection (“HPDP”) — HPDP is intended to
encourage additional investor participation and HAMP modifications in
areas with recent price declines by providing TARP-funded incentives to
offset potential losses in home values.110 As of June 30, 2012, there were
133,182 loan modifications under HPDP.111

Government-Sponsored Enterprises
(“GSEs”): Private corporations created
and chartered by the Government to
reduce borrowing costs and provide
liquidity in the market, the liabilities
of which are not officially considered
direct taxpayer obligations. On
September 7, 2008, the two largest
GSEs, the Federal National Mortgage
Association (“Fannie Mae”) and
the Federal Home Loan Mortgage
Corporation (“Freddie Mac”), were
placed into Federal conservatorship.
They are currently being financially
supported by the Government.
Loan Servicers: Companies that
perform administrative tasks on
monthly mortgage payments until the
loan is repaid. These tasks include
billing, tracking, and collecting monthly
payments; maintaining records of
payments and balances; allocating
and distributing payment collections
to investors in accordance with
each mortgage loan’s governing
documentation; following up
on delinquencies; and initiating
foreclosures.
Investors: Owners of mortgage loans
or bonds backed by mortgage loans
who receive interest and principal
payments from monthly mortgage
payments. Servicers manage the
cash flow from borrowers’ monthly
payments and distribute them to
investors according to Pooling and
Servicing Agreements (“PSAs”).

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special inspector general I troubled asset relief program

•

Short Sale: Sale of a home for less
than the unpaid mortgage balance. A
borrower sells the home and the lender
accepts the proceeds as full or partial
satisfaction of the unpaid mortgage
balance, thus avoiding the foreclosure
process.
Deed-in-Lieu of Foreclosure: Instead
of going through foreclosure, the
borrower voluntarily surrenders the
deed to the home to the home lender,
as satisfaction of the unpaid mortgage
balance.

•

•

•

•

çç Principal Reduction Alternative (“PRA”) — PRA is intended to encourage
the use of principal reduction in modifications for eligible borrowers whose
homes are worth significantly less than the remaining outstanding balances
of their first-lien mortgage loans. It provides TARP-funded incentives to
offset a portion of the principal reduction provided by the investor.112 As
of June 30, 2012, 60,778 homeowners received permanent modifications
through PRA.113
çç Home Affordable Unemployment Program (“UP”) — UP is intended to
offer assistance to unemployed homeowners through temporary forbearance
of all or a portion of their payments.114 As of May 31, 2012, 7,235 borrowers
are participating in UP.115
Home Affordable Modification Program Tier 2 (“HAMP Tier 2”) — HAMP
Tier 2 is an expansion of HAMP to permit HAMP modifications on nonowner-occupied “rental” properties, and to allow borrowers with a wider range
of debt-to-income ratios to receive modifications.116 The expanded program
became effective on June 1, 2012. There are no borrowers with HAMP Tier 2
active permanent modifications as of June 30, 2012. The first Tier 2 trial will be
eligible for permanent modification beginning in September 2012.
Home Affordable Foreclosure Alternatives (“HAFA”) — HAFA is intended
to provide incentives to servicers, investors, and borrowers to pursue short sales
and deeds-in-lieu of foreclosure for borrowers in cases in which the borrower
is unable or unwilling to enter or sustain a modification. Under this program,
the servicer releases the lien against the property and the investor waives all
rights to seek a deficiency judgment against a borrower who uses a short sale or
deed-in-lieu when the property is worth less than the outstanding amount of the
mortgage.117 As of June 30, 2012, there were 52,998 short sales and deeds-inlieu under HAFA.118
Second-Lien Modification Program (“2MP”) — 2MP is intended to modify
second-lien mortgages when a corresponding first lien is modified under HAMP
by a participating servicer.119 As of June 30, 2012, 17 servicers are participating
in 2MP.120 These servicers represent approximately 55% to 60% of the secondlien servicing market.121 As of June 30, 2012, there were 63,769 active
permanently modified second liens in 2MP.122
Agency-Insured Programs — These programs are similar in structure to
HAMP, but apply to eligible first-lien mortgages insured by FHA or guaranteed
by the Department of Agriculture’s Office of Rural Development (“RD”) and
the Department of Veterans Affairs (“VA”).123 Treasury provides TARP-funded
incentives to encourage modifications under the FHA and RD modification
programs. As of June 30, 2012, there were seven RD-HAMP permanent
modifications and 6,013 FHA-HAMP permanent modifications.124
Treasury/FHA Second-Lien Program (“FHA2LP”) — In FHA2LP, Treasury
uses TARP funds to provide incentives to servicers and investors who agree to
principal reduction or extinguishment of second liens associated with an FHA
refinance.125 As of June 30, 2012, no second liens had been extinguished under
the program.126

quarterly report to congress I July 25, 2012

• FHA Short Refinance Program — This program, which is partially supported
by TARP funds, is intended to provide borrowers who are current on their
mortgage an opportunity to refinance existing underwater mortgage loans that
are not currently insured by FHA into FHA-insured mortgages with lower
principal balances. Treasury has provided a TARP-funded letter of credit for up
to $8 billion in loss coverage on these newly originated FHA loans. As of June
30, 2012, 1,437 loans had been refinanced under FHA Short Refinance.127
• Housing Finance Agency Hardest Hit Fund (“HHF”) — A TARP-funded
program, HHF is intended to fund foreclosure prevention programs run by state
housing finance agencies in states hit hardest by the decrease in home prices
and in states with high unemployment rates. Eighteen states and Washington,
DC, received approval for aid through the program.128 As of March 31, 2012,
the latest data available, 43,580 borrowers had received assistance under
HHF.129

Status of TARP Funds Obligated to Housing Support
Programs
Treasury obligated $45.6 billion to housing support programs, of which $4.5
billion, or 10%, has been expended as of June 30, 2012.130 However, some of the
expended funds remain as cash on hand or paid for administrative expenses at state
housing finance agencies (“HFAs”) participating in the Hardest Hit Fund program.
Treasury has capped the aggregate amount available to pay servicer, borrower, and
investor incentives under MHA programs at $29.9 billion, of which $3.4 billion, or
11%, has been spent.131 Treasury allocated $8.1 billion for FHA Short Refinance, of
which $6.6 million has been spent on administrative expenses. Treasury allocated
$7.6 billion to the Hardest Hit Fund. As of March 31, 2012, only 5% of those
funds have gone to help 43,580 homeowners. HFAs have drawn down $1.1 billion,
as of June 30, 2012, but not all of that has gone to assist homeowners.132
Table 2.12 shows the breakdown in expenditures and estimated funding allocations for these housing support programs.

Underwater Mortgage: Mortgage loan
on which a homeowner owes more
than the home is worth, typically as
a result of a decline in the home’s
value. Underwater mortgages are also
referred to as having negative equity.

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special inspector general I troubled asset relief program

TABLE 2.12

TARP Allocations and Expenditures by housing Support programs,
AS OF 6/30/2012 ($ BILLIONS)
ALLOCATIONS

EXPENDITURES

MHA
HAMP
$19.1

$2.7

PRA Modification

First Lien Modification

2.0

0.1

HPDP

1.6

0.3

UP

—a
HAMP Total

—

$22.7

$3.0

HAFA

4.2

0.2

2MP

0.1

0.2

Treasury FHA-HAMP

0.2

RD-HAMP

—b

—

—

c

FHA2LP

2.7

—

MHA Total

$29.9

$3.4

FHA Short Refinance

8.1

0.1

HHF (Drawdown by States)e

7.6

1.1

Total

$45.6

$4.5

d

Notes: Numbers may not total due to rounding. According to Treasury, these numbers are “approximate.”
a
Treasury does not allocate TARP funds to UP.
b
Treasury has expended $0.01 billion for the Treasury FHA-HAMP program.
c
Treasury has allocated $0.02 billion to the RD-HAMP program. As of June 30, 2012, $1,834 has been expended for RD-HAMP.
d
This amount includes up to $117 million in fees Treasury will incur for the availability and usage of the $8 billion letter of credit.
e
	Not all of the funds drawn down by HFAs have been used to assist homeowners. As of March 31, 2012, the latest data available,
only $350.8 million was spent to assist homeowners.
Source: Treasury, response to SIGTARP data call, 7/9/2012.

quarterly report to congress I July 25, 2012

As of June 30, 2012, Treasury had active agreements with 105 servicers. That
compares with 145 servicers that had agreed to participate in MHA as of October
3, 2010.133 According to Treasury, of the $29.9 billion obligated to participating
servicers under their Servicer Participation Agreements (“SPAs”), as of June 30,
2012, only $3.4 billion (11%) has been spent, broken down as follows: $3 billion
had been spent on completing permanent modifications of first liens (393,887
of which remain active); $192.1 million under 2MP on completing 18,974 full
extinguishments, 4,547 partial extinguishments (principal reductions), and 63,769
permanent modifications of second liens under 2MP; and $237.2 million on incentives for 52,998 short sales or deeds-in-lieu of foreclosure under HAFA.134 Of the
combined amount of incentive payments, according to Treasury, approximately
$1.2 billion went to pay servicer incentives, $1.6 billion went to pay investor incentives, and $644 million went to pay borrower incentives.135 As of June 30, 2012,
Treasury had disbursed approximately $1.1 billion of the $7.6 billion allocated to
HFAs participating in HHF, more than half of which sits as cash on hand with
HFAs or is used for administrative expenses.136 The remaining $8.1 billion has been
obligated under FHA Short Refinance to purchase a letter of credit to provide up
to $8 billion in first loss coverage and to pay $117 million in fees for the letter of
credit. According to Treasury, it has not paid any claims for defaults on the 1,437
loans refinanced under the program. However, Treasury has pre-funded a reserve
account with $50 million to pay future claims and spent $6.6 million on administrative expenses.137 The breakdown of TARP-funded expenditures related to housing support programs (not including the GSE-funded portion of HAMP) are shown
in Table 2.13.

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TABLE 2.13

Breakdown of TARP Expenditures, As of 6/30/2012
MHA

($ MILLIONs)

TARP Expenditures

HAMP
HAMP First Lien Modification Incentives
Servicer Incentive Payment
Servicer Current Borrower Incentive Payment
Annual Servicer Incentive Payment
Investor Current Borrower Incentive Payment
Investor Monthly Reduction Cost Share
Annual Borrower Incentive Payment
HAMP First Lien Modification Incentives Total
PRA
HPDP
UP
HAMP Program Incentives Total

$503.0
16.4
534.9
51.2
1,057.8
492.2
$2,655.5
$63.2
$251.9
—a
$2,970.6

HAFA Incentives
Servicer Incentive Payment
Investor Reimbursement
Borrower Relocation
HAFA Incentives Total

$70.5
25.8
140.9
$237.2

Second-Lien Modification Program Incentives
2MP Servicer Incentive Payment

$41.0

2MP Annual Servicer Incentive Payment

7.1

2MP Annual Borrower Incentive Payment

6.5

2MP Investor Cost Share

50.0

2MP Investor Incentive

87.5

Second-Lien Modification Program Incentives Total

$192.1

Treasury/FHA-HAMP Incentives
Annual Servicer Incentive Payment

$5.1

Annual Borrower Incentive Payment

4.7

Treasury/FHA-HAMP Incentives Total

$9.8

RD-HAMP

—b

FHA2LP

—

MHA Incentives Total
FHA Short Refinance (Loss-Coverage)

$3,410.0
$56.6

HHF Disbursements (Drawdowns by State HFAs)

$1,071.6

Total Expenditures

$4,537.9

Notes: Numbers may not total due to rounding.
a
	TARP funds are not used to support the UP program, which provides forbearance of a portion of the homeowner’s
mortgage payment.
b
RD-HAMP expenditures equal $1,834 as of June 30, 2012.
Source: Treasury, response to SIGTARP data call, 7/10/2012.

quarterly report to congress I July 25, 2012

HAMP
According to Treasury, HAMP was intended “to help as many as three to four
million financially struggling homeowners avoid foreclosure by modifying loans to
a level that is affordable for borrowers now and sustainable over the long term.”138
Although HAMP contains several subprograms, the term “HAMP” is most often
used to refer to the HAMP First-Lien Modification Program, described below.

HAMP First-Lien Modification Program
The HAMP First-Lien Modification Program, which went into effect on April
6, 2009, modifies the terms of first-lien mortgages to provide borrowers with
lower monthly payments. A HAMP modification consists of two phases: a trial
modification that was originally designed to last three months, followed by a
permanent modification. Treasury continues to pay incentives for five years.139 In
designing HAMP, the Administration envisioned a “shared partnership” between
the Government and investors to bring distressed borrowers’ first lien monthly
payments down to an “affordable” and sustainable level — defined by Treasury in
the case of HAMP Tier 1 as 31% of the borrower’s monthly gross income.140 The
program description immediately below refers only to the original HAMP program,
which after the launch of HAMP Tier 2 has been renamed “HAMP Tier 1.”
HAMP Modification Statistics
As of June 30, 2012, a total of 818,803 mortgages were in active permanent
modifications under both TARP (non-GSE) and GSE HAMP. Some 71,110 were
in active trial modifications. For borrowers receiving permanent modifications,
97.4% received an interest rate reduction, 60% received a term extension, 31.3%
received principal forbearance, and 9.7% received principal forgiveness.141 HAMP
modification activity, broken out by TARP and GSE loans, is shown in Table 2.14.
TABLE 2.14

Cumulative HAMP modification activity by TARP/GSE, as of 6/30/2012
Trials
Started

Trials
Cancelled

Trials
Active

Trials
Converted to
Permanent

Permanents
Cancelled

Permanents
Active

TARP

899,407

347,352

40,059

511,996

118,109

393,887

GSE

984,333

421,807

31,051

531,475

106,559

424,916

1,883,740

769,159

71,110

1,043,471

224,668

818,803

Total

Source: Treasury, response to SIGTARP data call, 7/20/2012.

Starting a HAMP Modification
Borrowers may request participation in HAMP.142 Borrowers who have missed two
or more payments must be solicited for participation by their servicers.143 Before
offering the borrower a trial modification, also known as a trial period plan (“TPP”),
the servicer must verify the accuracy of the borrower’s income and other eligibility
criteria. In order to verify the borrower’s eligibility for a modification under the
program, borrowers must submit the following documents as part of an “initial
package.”144

Trial Modification: Under HAMP, a
period of at least three months in
which a borrower is given a chance
to establish that he or she can make
lower monthly mortgage payments and
qualify for a permanent modification.

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special inspector general I troubled asset relief program

For more information on the RMA
form and what constitutes hardship,
see SIGTARP’s April 2011 Quarterly
Report, page 62.
For more information on the
Verification Policy, see SIGTARP’s
April 2011 Quarterly Report, page 63.

For more about the HAMP NPV test,
see the June 18, 2012, SIGTARP
audit report “The NPV Test’s Impact
on HAMP.”

• an MHA “request for mortgage assistance” (“RMA”) form, which provides the
servicer with the borrower’s financial information, including the cause of the
borrower’s hardship;
• signed and completed requests for Federal tax return transcripts or the most
recent Federal income tax return, including all schedules and forms;
• income verification documentation, such as recent pay stubs or evidence of
other sources of income; and
• Dodd-Frank certification (either as part of the RMA form or as a standalone
document) that the borrower has not been convicted in the past 10 years of any
of the following in connection with a mortgage or real estate transaction: felony
larceny, theft, fraud, or forgery; money laundering, or tax evasion.
In order for a loan to be eligible for a HAMP modification, the borrower’s initial
package, consisting of the four documents described above, must be submitted by
the borrower on or before December 31, 2013. Additionally, in order to be eligible
for incentive payments, the permanent modification must be effective on or before
September 30, 2014.145
Participating servicers verify monthly gross income for the borrower and the
borrower’s household, as well as other eligibility criteria.146 Then, in the case of
HAMP Tier 1, the servicer follows the “waterfall” of modification steps prescribed
by HAMP guidelines to calculate the reduction in the borrower’s monthly mortgage
payment needed to achieve a 31% debt-to-income (“DTI”) ratio, that is, a payment
equal to 31% of his or her monthly gross income.147
In the first step, the servicer capitalizes any unpaid interest and fees (i.e., adds
them to the outstanding principal balance). Second, the servicer reduces the interest rate in incremental steps to as low as 2%. If the 31% DTI ratio threshold has
still not been reached, in the third step the servicer extends the term of the mortgage to a maximum of 40 years from the modification date. If these steps are still
insufficient to reach the 31% threshold, the servicer may forbear principal (defer its
due date), subject to certain limits.148 The forbearance amount is not interest bearing and results in a lump-sum payment due upon the earliest of the sale date of the
property, the payoff date of the interest-bearing mortgage balance, or the maturity
date of the mortgage.149
Servicers are not required to forgive principal under HAMP. However, servicers
may forgive principal in order to lower the borrower’s monthly payment to achieve
the HAMP Tier 1 DTI ratio goal of 31% on a stand-alone basis, at any point in the
HAMP waterfall described above, or as part of PRA.150
After completing these modification calculations, all loans that meet HAMP
eligibility criteria and are either deemed generally to be in imminent default or
delinquent by two or more payments must be evaluated using a standardized net
present value (“NPV”) test that compares the NPV result for a modification to
the NPV result for no modification.151 The NPV test compares the expected cash
flow from a modified loan with the expected cash flow from the same loan with
no modifications to determine which option will be more valuable to the mortgage
investor. A positive NPV test result indicates that a modified loan is more valuable

quarterly report to congress I July 25, 2012

to the investor than the existing loan. In that case, under HAMP rules, the servicer
must offer the borrower a mortgage modification. If the test generates a negative
result, modification is optional.152 Servicers cannot refuse to evaluate a borrower
for a modification simply because the outstanding loan currently has a low loan-tovalue (“LTV”) ratio, meaning the borrower owes less than the value of the home.
The lower the LTV ratio is, the higher the probability that a foreclosure will be
more profitable to an investor than a modification.
Since September 1, 2011, 19 of the 20 largest mortgage servicers participating
in MHA (i.e., those servicers that had Program Participation Caps of $75 million
or more as of May 18, 2011) have been required to assign a single point of contact
to borrowers potentially eligible for evaluation under HAMP, HAFA, or UP.153 The
single point of contact has the primary responsibility for communicating with the
borrower about options to avoid foreclosure, his/her status in the process, coordination of receipt of documents, and coordination with other servicer personnel to
promote compliance with MHA timelines and requirements throughout the entire
delinquency, imminent default resolution process, or foreclosure.154

How HAMP First-Lien Modifications Work
Treasury originally intended that HAMP trial modifications would last three
months. Historically, many trial modifications have lasted longer. According to
Treasury, as of June 30, 2012, of a combined total of 71,110 active trials under
both GSE and TARP (non-GSE) HAMP, 11,440, or 16.1%, had lasted more
than six months.155 This is a decrease from the 19% that SIGTARP reported last
quarter.156
Borrowers in trial modifications may qualify for conversion to a permanent
modification as long as they make the required modified payments on time and
provide proper documentation, including a signed modification agreement.157 The
terms of permanent modifications under HAMP Tier 1 remain fixed for at least five
years.158 After five years, the loan’s interest rate can increase if the modified interest
rate had been reduced below the 30-year conforming fixed interest rate on the date
of the initial modification. The interest rate can rise incrementally by up to 1%
per year until it reaches that rate.159 Otherwise, the modified interest rate remains
permanent.
If the borrower misses a payment during the trial or is denied a permanent
modification for any other reason, the borrower is, in effect, left with the original
terms of the mortgage. The borrower is responsible for the difference between
the original mortgage payment amount and the reduced trial payments that were
made during the trial. In addition, the borrower may be liable for late fees that were
generated during the trial. In other words, a borrower can be assessed late fees for
failing to make the original pre-modification scheduled payments during the trial
period, even though under the trial modification the borrower is not required to
make these payments. Late fees are waived only for borrowers who receive a permanent modification.160
Since May 1, 2011, if a borrower is denied a HAMP Tier 1 permanent modification because of missed trial payments, the servicer must re-calculate the

Loan-to-Value (“LTV”) Ratio: Lending
risk assessment ratio that mortgage
lenders examine before approving a
mortgage; calculated by dividing the
outstanding amount of the loan by
the value of the collateral backing the
loan. Loans with high LTV ratios are
generally seen as higher risk because
the borrower has less of an equity
stake in the property.

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special inspector general I troubled asset relief program

borrower’s income using the original income documentation to ensure that the
trial payment was correctly calculated. The servicer is not required to re-run the
calculation if the borrower missed a trial payment because of a significant change
in circumstances resulting in a reduction in income. If the re-calculation shows
that the borrower’s trial payment exceeded the proper payment by 10% or more, the
servicer must offer the borrower a new trial period with the correct payment.161
What Happens When a HAMP Modification Is Denied: Servicer Obligations and
Borrower Rights

For more information on HAMP
servicer obligations and borrower
rights, see SIGTARP’s April 2011
Quarterly Report, pages 67-76.

Treasury has issued a series of guidance governing both the obligations of servicers
and the rights of borrowers in connection with the denial of loan modification
requests. Borrowers must receive a Non-Approval Notice if they are rejected
for a HAMP modification. A borrower who is not approved for HAMP Tier 1 is
automatically considered for HAMP Tier 2. If the servicer offers the borrower a
Tier 2 trial, no Non-Approval notice would be issued on the HAMP Tier 1. The
Non-Approval Notice is sent only if the Tier 2 is not offered. Borrowers can request
reconsideration or re-evaluation if they believe one or more NPV analysis inputs is
incorrect or if they experience a change in circumstance. Servicers are obligated to
have written procedures and personnel in place to respond to borrower inquiries
and disputes that constitute “escalated cases” in a timely manner.162
Treasury’s web-based NPV calculator at www.CheckMyNPV.com can be
used by borrowers prior to applying for a HAMP modification or after a denial
of a HAMP modification. Borrowers can enter the NPV input values listed in
the HAMP Non-Approval Notice received from their servicer, or substitute with
estimated NPV input values, to compare the estimated outcome provided by
CheckMyNPV.com against that on the Non-Approval Notice.
Modification Incentives

Originally, servicers received a one-time incentive fee payment of $1,000 for each
permanent modification completed under HAMP, and additional compensation of
$500 if the borrower was current but at imminent risk of default before enrolling in
the trial plan. Effective for new HAMP trials on or after October 1, 2011, Treasury
changed the flat $1,000 incentive to a sliding scale based on the length of time
the loan was delinquent as of the effective date of the TPP. For loans less than or
equal to 120 days delinquent, servicers receive $1,600.163 For loans 121-210 days
delinquent, servicers receive $1,200. For loans more than 210 days delinquent,
servicers receive only $400. Additionally, under this system, the $500 borrower
incentive for being current on the loan is no longer paid.
For borrowers whose monthly mortgage payment was reduced through HAMP
by 6% or more, servicers also receive incentive payments of up to $1,000 annually
for three years if the borrower remains in good standing (defined as less than three
full monthly payments delinquent).164
For HAMP Tier 1, borrowers whose monthly mortgage payment is reduced
through HAMP by 6% or more and who make monthly payments on time earn

quarterly report to congress I July 25, 2012

an annual principal reduction of up to $1,000.165 The principal reduction accrues
monthly and is payable for each of the first five years as long as the borrower
remains in good standing.166
An investor is entitled to compensation under HAMP Tier 1, for up to five
years, equal to one-half of the dollar difference between the borrower’s monthly
payment (principal and interest) under the modification, based on 31% of monthly
gross income, and the lesser of (1) the borrower’s monthly principal and interest at 38% or (2) the borrower’s pre-modification monthly principal and interest
payment.167 Under HAMP Tier 2 modifications of owner-occupied properties, if
applicable, investors also earn an extra one-time, up-front payment of $1,500 for
modifying a loan that was current before the trial period (i.e., at risk of imminent
default) and whose monthly payment was reduced by at least 6%.168
As of June 30, 2012, of the $29.9 billion in TARP funds allocated to the 105
servicers participating in MHA, approximately 89.6% was allocated to the 10 largest servicers.169 Table 2.15 outlines these servicers’ relative progress in implementing the HAMP modification programs.
TABLE 2.15

TARP INCENTIVE PAYMENTS BY 10 LARGEST SERVICERS, AS OF 6/30/2012

SPA Cap Limit

Incentive
Payments
to Borrowers

Incentive
Payments
to Investors

Incentive
Payments
to Servicers

Total Incentive
Payments

Bank of America, N.A.a

$8,108,092,562

$120,691,028

$299,568,357

$212,318,268

$632,577,652

Wells Fargo Bank, N.A.

5,121,436,025

93,044,464

227,894,233

166,925,508

487,864,205

JPMorgan Chase Bank, NAc

3,770,020,191

145,696,464

269,205,338

232,731,483

647,633,285

Ocwen Loan Servicing, LLCd

2,670,711,437

52,434,101

144,352,452

109,027,924

305,814,477

OneWest Bank

1,836,213,784

25,975,117

87,841,858

47,391,810

161,208,785

GMAC Mortgage, LLC

1,500,173,461

28,423,250

80,202,635

55,138,210

163,764,096

Homeward Residential

1,306,356,674

31,654,995

99,560,346

69,454,750

200,670,091

CitiMortgage Inc

1,050,340,843

35,034,563

116,114,690

70,121,075

221,270,328

Select Portfolio Servicing

851,284,429

34,417,040

74,497,723

59,049,968

167,964,731

National City Bank

558,602,227

1,171,443

4,218,459

2,706,837

8,096,738

$26,773,231,663

$568,542,465

$1,403,456,090

$1,024,865,832

$2,996,864,388

b

Total

Notes: Numbers may not total due to rounding.
a
Bank of America, N.A. includes the former Countrywide Home Loans Servicing, Wilshire Credit Corp. and Home Loan Services.
b
Wells Fargo Bank, N.A. includes Wachovia Mortgage, FSB.
c
JPMorgan Chase Bank, NA includes EMC Mortgage.
d
Ocwen Loan Servicing, LLC includes the former Litton Loan Servicing, LP.
Source: Treasury, Transactions Report-Housing, 7/2/2012.

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special inspector general I troubled asset relief program

For SIGTARP’s recommendations for
the improvement of HAMP Tier 2,
see SIGTARP’s April 2012 Quarterly
Report, pages 185-189.

HAMP Tier 2
On June 1, 2012, Treasury launched an expansion of HAMP, “HAMP Tier 2,”
which permits HAMP modifications on non-owner-occupied “rental” properties,
and allows borrowers with a wider range of debt-to-income situations to receive
modifications.170 Before this, only owner-occupied homes were eligible for
HAMP — rental properties had been expressly excluded.171 Treasury’s stated
policy objectives for HAMP Tier 2 are that it “will provide critical relief to both
renters and those who rent their homes, while further stabilizing communities
from the blight of vacant and foreclosed properties.”172 A borrower may have up
to three loans with HAMP Tier 2 modifications, as well as a single HAMP Tier 1
modification on the mortgage for his or her primary residence.173
Even though Treasury announced the HAMP Tier 2 expansion in January, on
June 1, 2012, the program’s launch date, only three of the 10 largest servicers had
fully implemented HAMP Tier 2.174 According to Treasury, as of June 30, 2012, a
total of 51 of the 105 servicers with active MHA servicer agreements had fully implemented HAMP Tier 2. Some of the largest servicers, including Bank of America,
N.A., and JPMorgan Chase Bank, NA, have reported that they will not have fully
implemented HAMP Tier 2 until August 2012 or September 2012, respectively.175
HAMP Tier 2 Eligibility

HAMP Tier 2 expands the eligibility criteria related to a borrower’s debt-to-income
ratio and also allows modifications on loans secured by “rental” properties. Owneroccupied loans that are ineligible for a HAMP Tier 1 modification due to excessive
forbearance or negative NPV are also eligible for Tier 2. Vacant rental properties
are permitted in the program, as are those occupied by legal dependents, parents,
or grandparents, even if no rent is charged. The program is not, however, according
to Treasury, intended for vacation homes, second homes, or properties that are
rented only seasonally. Additionally, loans on rental properties must be at least two
payments delinquent – those in imminent default are not eligible.176
However, Treasury does not require that the property be rented. Treasury
requires only that a borrower certify intent to rent the property to a tenant on a yearround basis for at least five years, or make “reasonable efforts” to do so; and does not
intend to use the property as a second residence for at least five years.177 According
to Treasury, servicers are not typically required to obtain third party verifications of
the borrower’s rental property certification when evaluating a borrower for HAMP.178
To be considered for HAMP Tier 2, borrowers must satisfy several basic HAMP
requirements: the loan origination date must be on or before January 1, 2009;
the borrower must have a documented hardship; the property must conform to
the MHA definition of a “single-family residence” (1-4 dwelling units, including
condominiums, co-ops, and manufactured housing); the property must not be
condemned; and the loan must fall within HAMP’s unpaid principal balance limitations.179 If a borrower satisfies these requirements, and in addition, the loan has
never been previously modified under HAMP, the servicer is required to solicit the
borrower for HAMP Tier 2. In certain other cases, the borrower may still be eligible
for HAMP Tier 2, but the servicer is not required to solicit the borrower.180

quarterly report to congress I July 25, 2012

How HAMP Tier 2 Modifications Work

As with HAMP Tier 1, HAMP Tier 2 evaluates borrowers using an NPV test that
considers the value of the loan to the investor before and after a modification.
Owner-occupant borrowers are evaluated for both HAMP Tier 1 and Tier 2 in a
single process. If a borrower is eligible for both modifications, he or she will receive
a HAMP Tier 1 modification.181
As discussed above, HAMP Tier 1 modifications are structured using a waterfall
of incremental steps that may stop as soon as the 31% post-modification DTI ratio
target is reached. In HAMP Tier 2, the proposed permanent modification must
meet two affordability requirements: (1) a post-modification DTI ratio of not less
than 25% or greater than 42% and (2) a reduction of the monthly principal and interest payment by 10%. If the borrower was previously in a HAMP Tier 1 modification (either trial or permanent), then the new payment must be at least 10% below
the previously modified payment. Because HAMP Tier 2 does not target a specific
DTI ratio, the HAMP Tier 2 waterfall is not a series of incremental steps, but a
consistent set of actions that are applied to the loan. After these actions are applied,
if the result of the NPV test is positive and the modification also achieves the DTI
and payment reduction goals, the servicer must offer the borrower a HAMP Tier 2
modification. If the result of the HAMP Tier 2 NPV test is negative, modification is
optional.182
As in the HAMP Tier 1 waterfall, the first step in structuring a HAMP Tier 2
modification is to capitalize any unpaid interest and fees. The second step changes
the interest rate to the “Tier 2 rate,” which is the current Freddie Mac Primary
Mortgage Market Survey rate plus a 0.5% risk adjustment. The third step extends
the term of the loan by up to 40 years from the modification effective date. Finally,
if the loan’s pre-modification mark-to-market LTV ratio is greater than 115%, the
servicer forbears principal in an amount equal to the lesser of (1) an amount that
would create a post-modification LTV ratio of 115%, or (2) an amount equal to
30% of the post-modification principal balance. Unlike HAMP Tier 1, there is no
excessive forbearance limit in HAMP Tier 2. The HAMP Tier 2 guidelines also include several exceptions to this waterfall to allow for investor restrictions on certain
types of modification.183
The HAMP Tier 2 NPV model also evaluates the loan using an “alternative
modification waterfall” in addition to the one described here. This waterfall uses
principal reduction instead of forbearance. However, as in HAMP Tier 1, principal
reduction is optional. Servicers may also reduce principal on HAMP Tier 2 modifications using PRA.184
HAMP Tier 2 incentives are the same as those for HAMP Tier 1, with some
exceptions, notably that HAMP Tier 2 modifications do not pay annual borrower or
servicer incentives.185

Home Price Decline Protection (“HPDP”)
HPDP provides investors with incentives for modifications of loans on properties
located in areas where home prices have recently declined and where investors are
concerned that price declines may persist. HPDP incentive payments are linked

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special inspector general I troubled asset relief program

to the rate of recent home price decline in a local housing market, as well as the
unpaid principal balance and mark-to-market LTV ratio of the mortgage loan.186
HPDP is intended to address the fears of investors who may withhold their
consent to loan modifications because of potential future declines in the value of
the homes that secure the mortgages, should the modification fail and the loan go
into foreclosure.
Under HPDP, Treasury has published a standard formula, based on the principal balance of the mortgage, the recent decline in area home prices during the six
months before the start of the HAMP modification, and the LTV ratio, that will
determine the size of the incentive payment.187 The HPDP incentive payments
accrue monthly over a 24-month period and are paid annually on the first and
second anniversaries of the initial HAMP trial period. Accruals are discontinued
if the borrower loses good standing under HAMP because they are delinquent by
three mortgage payments. As of June 30, 2012, according to Treasury, approximately $252 million in TARP funds had been paid for incentives on 133,182 loan
modifications under HPDP.188

Principal Reduction Alternative (“PRA”)
PRA is intended to encourage principal reduction in HAMP loan modifications for
underwater borrowers by providing mortgage investors with incentive payments
in exchange for lowering the borrower’s principal balance. PRA is an alternative
method to the standard HAMP modification waterfall for structuring a HAMP
modification. Although servicers are required to evaluate every non-GSE HAMPeligible borrower with an LTV of 115% or greater for PRA, whether to actually offer
principal reduction or not is up to the servicer.189
Because the GSEs, Fannie Mae and Freddie Mac, have refused to participate
in PRA, the program applies only to loans modified under TARP-funded HAMP.190
On January 27, 2012, Treasury offered to pay PRA incentives for the GSEs from
TARP by tripling the incentives it pays to investors, subsidizing up to 63% of principal reductions.191
According to Treasury, as of June 30, 2012, there were 60,778 active permanent
modifications in PRA.192 According to Treasury, 87% of borrowers who received
PRA modifications were seriously delinquent on their mortgages at the start of the
trial modification.193
Borrowers receiving PRA modifications were also significantly further underwater before modification than was the overall HAMP population. According to
Treasury, PRA borrowers had a pre-modification median LTV ratio of 157%. After
modification, however, PRA borrowers lowered their LTVs to a median ratio of
115%.194 According to Treasury, PRA modifications reduced principal balances by
a median amount of $69,586 or 31.4%, thereby lowering the LTV ratio. On the
other hand, according to the data, HAMP modifications without the PRA feature
on average increased the principal balance. Treasury attributes this increase to the
capitalization of unpaid interest and fees.195
Borrowers in PRA appear to fare better after modification than the overall
population of HAMP borrowers, who overwhelmingly have received the HAMP

quarterly report to congress I July 25, 2012

modification without the PRA feature. According to Treasury, as of June 30, 2012,
servicers had started 89,444 PRA trial modifications, of which 15,501 were active
as of that date, 67,083 had converted to permanent modifications, and 6,860 (or
7.7%) were subsequently disqualified from the program or the loan was paid off.196
According to Treasury, of the PRA trials that converted to permanent modifications,
60,778 were still active as of June 30, 2012, and 6,305 (9.4%) had either redefaulted or were paid off. Although not directly comparable, the redefault rate for HAMP
permanent modifications is 23.1%.197
Who Is Eligible

Borrowers who meet all HAMP eligibility requirements and who owe more than
115% of their home’s market value (LTV >115%) are eligible for PRA.198 The
principal balance used in this LTV calculation includes any amounts that would
be capitalized under a HAMP modification.199 Eligible borrowers are evaluated by
running NPV tests. There are standard and alternative NPV tests for HAMP Tier
1 and HAMP Tier 2. If the standard waterfall produces a positive NPV result, the
servicer must offer a HAMP modification (with or without principal reduction).
If the PRA waterfall using principal reduction produces a positive NPV result,
the servicer may, but is not required to, offer a modification using principal
reduction.200
How PRA Works

For HAMP Tier 1, the PRA waterfall uses principal forbearance (which later
becomes principal reduction) prior to interest rate reduction as the second step
in structuring the modification. Under PRA, the servicer determines the modified
mortgage payment by first capitalizing unpaid interest and fees as in a standard
HAMP modification. After capitalization, the servicer reduces the loan balance
through principal forbearance until either a DTI ratio of 31% or an LTV ratio of
115% is achieved. No interest will be collected on the forborne amount. If an LTV
ratio of 105% to 115% is achieved first, the servicer then applies the remaining
HAMP waterfall steps (interest rate reduction, term extension, forbearance) until
the 31% DTI ratio is reached. If the principal balance has been reduced by more
than 5%, the servicer is allowed additional flexibility in implementing the remaining
waterfall steps. Principal reduction is not immediate; it is earned over three years.
On each of the first three anniversaries of the modification, one-third of the
PRA forborne principal is forgiven. Therefore, after three years the borrower’s
principal balance is permanently reduced by the amount that was placed in PRA
forbearance.201
Who Gets Paid

For PRA trials effective on or after March 1, 2012, Treasury will triple the amount
of these incentives paid to investors. Under PRA, the mortgage investors now
earn an incentive of $0.18 to $0.63 per dollar of principal reduced, depending on
delinquency status of the loan and the level to which the outstanding LTV ratio was

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special inspector general I troubled asset relief program

TABLE 2.16

PRA incentives to investors per
dollar of First Lien principal
reduced
Mark-to-Market
Loan-to-Value
Ratio (“LTV”)
Rangea
Incentive
Amounts

105%

115%

to

to

115%

140%

$0.63

$0.45

> 140%

$0.30

Notes: This incentive structure applies to loans less than or
equal to six months past due. For loans that were more than
six months delinquent within the previous year, investors
receive $0.18 per dollar of principal reduced in compensation,
regardless of the LTV ratio. These incentives are effective for
trials beginning on or after 3/1/2012.
a
The mark-to-market LTV is based on the pre-modified principal
balance of the first-lien mortgage plus capitalized interest and
fees divided by the market value of the property.
Source: Treasury, “Supplemental Directive 12-01: Making
Home Affordable Program – Principal Reduction Alternative and
Second Lien Modification Program Investor Incentives Update,”
2/16/2012, www.hmpadmin.com/portal/news/docs/2012/
hampupdate021612.pdf, accessed 6/28/2012.

reduced.202 For loans that are more than six months delinquent, investors receive
only $0.18 per dollar of principal reduction, regardless of LTV.203 The incentive
schedule in Table 2.16 applies only to loans that have been six months delinquent
or less within the previous year.
Under certain conditions an investor may enter into an agreement with the borrower to share any future increase in the value of the property.204
According to Treasury, as of June 30, 2012, Treasury had paid a total of $63.2
million in PRA incentives.205

Home Affordable Unemployment Program (“UP”)
UP, which was announced on March 26, 2010, provides temporary assistance to
unemployed borrowers.206 Under the program, unemployed borrowers who meet
certain qualifications can receive forbearance for a portion of their mortgage
payments. Originally, the forbearance period was a minimum of three months,
unless the borrower found work during this time. However, on July 7, 2011, after a
SIGTARP recommendation to extend the term, Treasury announced that it would
increase the minimum UP forbearance period from three months to 12 months.
As of May 31, 2012, which according to Treasury is the latest data available, 7,235
borrowers were actively participating in UP.207
Who Is Eligible

Borrowers who are approved to receive unemployment benefits and who also
request assistance under HAMP must be evaluated by servicers for an UP
forbearance plan and, if eligible, offered one. As of June 1, 2012, a servicer may
consider a borrower for UP whose loan is secured by a vacant or tenant-occupied
property and still must consider owner-occupied properties. The servicer must
consider a borrower for UP regardless of the borrower’s monthly mortgage payment
ratio and regardless of whether the borrower had a payment default on a HAMP
trial plan or lost good standing under a permanent HAMP modification. Servicers
are not required to offer an UP forbearance plan to borrowers who are more than
12 months delinquent at the time of the UP request.208 Alternatively, the servicers
may evaluate unemployed borrowers for HAMP and offer a HAMP trial period plan
instead of an UP forbearance plan if, in the servicer’s business judgment, HAMP is
the better loss mitigation option. If an unemployed borrower is offered a trial period
plan but requests UP forbearance instead, the servicer may then offer UP, but is
not required to do so.209
Eligible borrowers may request a HAMP trial period plan after the UP forbearance plan is completed. If an unemployed borrower in bankruptcy proceedings
requests consideration for HAMP, the servicer must first evaluate the borrower
for UP, subject to any required bankruptcy court approvals.210 A borrower who has
been determined to be ineligible for HAMP may request assessment for an UP
forbearance plan if he or she meets all the eligibility criteria.211 If a borrower who
is eligible for UP declines an offer for an UP forbearance plan, the servicer is not
required to offer the borrower a modification under HAMP or 2MP while the borrower remains eligible for an UP forbearance plan.212

quarterly report to congress I July 25, 2012

How UP Works

For qualifying homeowners, the mortgage payments during the forbearance
period are lowered to no more than 31% of monthly gross income, which includes
unemployment benefits.213 If the borrower regains employment, but because of
reduced income still has a hardship, the borrower must be considered for HAMP.
If the borrower is eligible, any payments missed prior to and during the period of
the UP forbearance plan are capitalized as part of the normal HAMP modification
process.214 If the UP forbearance period expires and the borrower is ineligible for
HAMP, the borrower may be eligible for MHA foreclosure alternatives, such as
HAFA.215

Home Affordable Foreclosure Alternatives (“HAFA”)
HAFA provides $4.2 billion in incentives to servicers, borrowers, and subordinate
lien holders to encourage a short sale or deed-in-lieu of foreclosure as an
alternative to foreclosure.216 Under HAFA, the servicer forfeits the ability to pursue
a deficiency judgment against a borrower when the proceeds from the short sale
or deed-in-lieu are less than the outstanding amount on the mortgage.217 HAFA
incentives include a $3,000 relocation incentive payment to borrowers or tenants,
a $1,500 incentive payment to servicers, and incentive payments to subordinate
mortgage lien holders of up to $2,000 in exchange for a release of the lien and the
borrower’s liability.218 The program was announced on November 30, 2009.219
Treasury allows each servicer participating in HAFA to determine its own policies for borrower eligibility and many other aspects of how it operates the program,
but requires the servicers to post criteria and program rules on their websites.
According to Treasury, as of June 30, 2012, two servicers had not yet complied
with this requirement. Servicers must notify eligible borrowers in writing about the
availability of the HAFA program and allow the borrower a minimum of 14 calendar days to apply.220 Servicers are not required by Treasury to verify a borrower’s
financial information or determine whether the borrower’s total monthly payment
exceeds 31% of his or her monthly gross income.221
Effective March 9, 2012, Treasury no longer required properties in HAFA to
be occupied, allowing vacant properties to enter the program. However, borrower
relocation incentives will be paid only on occupied properties.222
As of June 30, 2012, approximately $237.2 million from TARP had been paid
to investors, borrowers, and servicers in connection with 52,998 short sales or
deeds-in-lieu of foreclosure transfers completed under HAFA.223 As of May 31,
2012, the latest data available, Treasury reported that the nine largest servicers
alone had completed 241,837 short sales and deeds-in-lieu outside HAMP for borrowers whose HAMP trial modifications had failed, borrowers who had chosen not
to participate, or were ineligible for the program.224 The greater volume of activity
outside HAFA may be explained, in part, by the fees and deficiency judgments that
servicers are able to collect from the borrower in non-HAFA transactions, which
are not available within HAFA.

For more information on additional
UP eligibility criteria, see SIGTARP’s
April 2011 Quarterly Report, pages
80-81.

Deficiency Judgment: Court order
authorizing a lender to collect all or
part of an unpaid and outstanding debt
resulting from the borrower’s default
on the mortgage note securing a debt.
A deficiency judgment is rendered
after the foreclosed or repossessed
property is sold when the proceeds are
insufficient to repay the full mortgage
debt.

For more information about relocation
incentives and borrower requirements
related to primary residences in
HAFA, see SIGTARP’s January 2012
Quarterly Report, pages 70-71.

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special inspector general I troubled asset relief program

Second-Lien Modification Program (“2MP”)

Servicing Advances: If borrowers’
payments are not made promptly
and in full, servicers are contractually
obligated to advance the required
monthly payment amount in full to the
investor. Once a borrower becomes
current or the property is sold or
acquired through foreclosure, the
servicer is repaid all advanced funds.

TABLE 2.17

2mp compensation per dollar of
Second-Lien principal Reduced
(for 2MP modifications with
an effective date on or after
6/1/2012)
Combined Loanto-Value (“CLTV”)
Ratio Rangea
Incentive
Amounts

115%
< 115%

to

> 140%

140%
$0.42

$0.30

$0.20

Notes: This incentive structure applies to loans less than or
equal to six months past due. For loans that were more than
six months delinquent within the previous year, investors
receive $0.12 per dollar of principal reduced in compensation,
regardless of the CLTV ratio.
a
Combined Loan-to-Value is the ratio of the sum of the
outstanding principal balance of the HAMP-modified first
lien and the outstanding principal balance of the unmodified
second lien divided by the property value determined in
connection with the permanent HAMP modification.
Source: Treasury, “Supplemental Directive 12-03: Making Home
Affordable Program – Handbook Mapping for MHA Extension
and Expansion and Administrative Clarifications on Tier 2,”
4/17/2012, www.hmpadmin.com//portal/programs/docs/
hamp_servicer/sd1203.pdf, accessed 7/14/2012.

According to Treasury, 2MP, which was announced on August 13, 2009, is
designed to provide modifications to the loans of borrowers with second mortgages
of at least $5,000 with monthly payments of at least $100 that are serviced by
a participating 2MP servicer, or full extinguishment of second mortgages below
those thresholds. When a borrower’s first lien is modified under HAMP and the
servicer of the second lien is a 2MP participant, that servicer must offer to modify
or may extinguish the borrower’s second lien. Treasury pays the servicer a lump
sum for full extinguishment of the second-lien principal or in exchange for a partial
extinguishment (principal reduction) and modification of the remainder of the
second lien.225 Second-lien servicers are not required to verify any of the borrower’s
financial information and do not perform a separate NPV analysis.226
There is no minimum principal balance for a full extinguishment of a second
lien under 2MP. For a second-lien modification under 2MP, the servicer first capitalizes any accrued interest and servicing advances, then reduces the interest rate
to 1% to 2% for the first five years. After the five-year period, the rate increases to
match the rate on the HAMP-modified first lien. When modifying the second lien,
the servicer must, at a minimum, extend the term to match the term of the first
lien, but can also extend the term up to a maximum of 40 years. To the extent that
there is forbearance or principal reduction for the modified first lien, the secondlien holder must forbear or forgive at least the same percentage on the second
lien.227
The servicer receives a $500 incentive payment upon modification of a second
lien. If the loan is in good standing and a borrower’s monthly second-lien payment
is reduced by 6% or more, the servicer is eligible for an annual incentive payment
of $250 per year for up to three years, and the borrower is eligible for an annual
principal reduction payment of up to $250 per year for up to five years.228 Investors
receive modification incentive payments equal to an annualized amount of 1.6% of
the unmodified principal balance, paid on a monthly basis for up to five years.229
In addition, investors also receive incentives for fully or partially extinguishing the
second lien on 2MP modifications. On February 16, 2012, Treasury doubled the
amount of these incentives on 2MP modifications effective on or after June 1,
2012. The current incentive schedule for loans six months delinquent or less is
shown in Table 2.17. For loans that have been more than six months delinquent
within the previous 12 months, investors are paid $0.12 for each dollar of principal
reduced, regardless of the combined LTV ratio.230
According to Treasury, as of June 30, 2012, 119,938 HAMP modifications had
second liens that were eligible for 2MP. As of that date, there were 63,769 active
permanent modifications of second liens.231 New 2MP modifications sharply
peaked in March 2011 and have been generally declining since then. Most of the
activity under the program has been modifications to the terms of the second liens.
Median principal reduction was $8,674 for partial extinguishments of second liens
and $61,641 for full extinguishments of second liens.232 According to Treasury,
as of June 30, 2012, approximately $192.1 million in TARP funds had been paid

quarterly report to congress I July 25, 2012

to servicers and investors in connection with 110,173 second-lien full and partial
extinguishments and modifications under 2MP.233

Agency-Insured Loan Programs (FHA-HAMP, RD-HAMP, and
VA-HAMP)
Some mortgage loans insured or guaranteed by the Federal Housing Administration
(“FHA”), Department of Veterans Affairs (“VA”), or the U.S. Department of
Agriculture Rural Development (“RD”) are eligible for modification under programs
similar to HAMP Tier 1 that reduce borrowers’ monthly mortgage payments to
31% of their monthly gross income. Borrowers are eligible to receive a maximum
$1,000 annual incentive for five years and servicers are eligible to receive a
maximum $1,000 annual incentive from Treasury for three years on mortgages in
which the monthly payment was reduced by at least 6%.234 As of June 30, 2012,
according to Treasury, approximately $9.8 million in TARP funds had been paid
to servicers and borrowers in connection with 6,013 permanent Treasury/FHAHAMP modifications. According to Treasury, only $1,834 of TARP funds has been
spent on the seven modifications under RD-HAMP.235 Treasury does not provide
incentive compensation related to VA-HAMP.236

Treasury/FHA Second-Lien Program (“FHA2LP”)
FHA2LP, which was launched on September 27, 2010, provides incentives for
partial or full extinguishment of non-GSE second liens of at least $2,500 originated
on or before January 1, 2009, associated with an FHA refinance.237 Borrowers must
also meet the eligibility requirements of FHA Short Refinance. TARP has allocated
$2.7 billion for incentive payments to (1) investors ranging from $0.10 to $0.21
based on the LTV of pre-existing second-lien balances that are partially or fully
extinguished under FHA2LP, or they may negotiate with the first-lien holder for a
portion of the new loan, and (2) servicers, in the amount of $500 for each secondlien mortgage in the program.238 According to Treasury, as of June 30, 2012, it had
not made any incentive payments under FHA2LP, and no second liens had been
extinguished.239

MHA Servicer Assessments
Since June 2011, Treasury has published quarterly Servicer Assessments of the
10 largest mortgage servicers participating in MHA. The most recent assessment
covering the first quarter of 2012 was published on June 6, 2012. During the
fourth quarter of 2011, Ocwen Loan Servicing, LLC acquired the servicing
portfolio of Litton Loan Servicing, LP (“Litton”), another top 10 servicer.240 At that
time, Treasury changed from assessing the 10 largest MHA servicers to assessing
only nine servicers.241
Servicer Assessments focus on compliance with the requirements of the MHA
program and on program results. The compliance assessment portion is based on
the findings of servicer compliance reviews conducted by Treasury’s compliance
agent. These findings are divided into three performance categories: Identifying and

For more information concerning
FHA2LP eligibility, see SIGTARP’s
April 2011 Quarterly Report, pages
85-87.

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special inspector general I troubled asset relief program

For more information on MHA
Servicer Assessments, see Section 5:
“SIGTARP Recommendations” of
this report.

Contacting Homeowners; Homeowner Evaluation and Assistance; and Program
Management, Reporting, and Governance. These categories in turn contain several
quantitative and qualitative metrics, which Treasury scores using benchmarks set
by Treasury.242 The servicers are also rated on the effectiveness of their internal
controls in each of the three categories. Because not all of the performance metrics
Treasury examines are reassessed each quarter, some assessment data is typically
carried over from the prior quarter.243
Program results are reported for Aged Trials as a Percentage of Active Trials;
Conversion Rate for Trials Started On or After June 1, 2010; Average Calendar
Days to Resolve Escalated Cases; and Percentage of Missing Modification Status
Reports. The servicer’s performance in each of the four metrics is not scored and
Treasury has not set benchmarks. Treasury compares servicer performance to the
best and worst performances among the other servicers.244
Treasury issues overall servicer ratings indicating whether the servicer requires
minor improvement, moderate improvement, or substantial improvement. In
the first quarter 2012 MHA servicer assessment, Treasury determined that three
servicers needed minor improvement (OneWest Bank, Select Portfolio Servicing,
and Wells Fargo Bank, N.A.) and that six servicers needed moderate improvement:
Homeward Residential (formerly known as American Home Mortgage Servicing,
Inc.); Bank of America, N.A.; CitiMortgage, Inc; GMAC Mortgage, LLC;
JPMorgan Chase Bank, NA; and Ocwen Loan Servicing, LLC.245
Prior to this quarter, Treasury had withheld MHA incentives from JPMorgan
Chase Bank, NA, (“JPMorgan”) and Bank of America, N.A. However, as part of
the “robo-signing” settlement between the Federal Government, state Attorneys
General, and major servicers, Treasury released all MHA incentives that it was
withholding.246 The only additional incentives reported as newly withheld from
any servicers for the first quarter of 2012, according to Treasury, total $6,000 and
$2,000 withheld from JPMorgan and Ocwen, respectively, and will be withheld
until certain data is verified.247

FHA Short Refinance Program
On March 26, 2010, Treasury and HUD announced the FHA Short Refinance
program, which gives borrowers the option of refinancing an underwater, nonFHA-insured mortgage into an FHA-insured mortgage at 97.75% of the home’s
value. Treasury has allocated TARP funds of (1) up to $8 billion to provide
loss protection to FHA through a letter of credit; and (2) up to $117 million in
fees for the letter of credit.248 FHA Short Refinance is voluntary for servicers.
Therefore, not all underwater borrowers who qualify may be able to participate in
the program.249 As of June 30, 2012, according to Treasury, 1,437 loans had been
refinanced under the program.250 As of June 30, 2012, Treasury has not paid any
claims for defaults under the program. According to Treasury, to its knowledge,
no FHA Short Refinance Loans have defaulted; however, it is possible that one or
more loans have defaulted but FHA has not yet evaluated the claims.251 Treasury
has deposited $50 million into a reserve account for future claims.252 It has also

quarterly report to congress I July 25, 2012

spent approximately $6.6 million on administrative expenses associated with the
letter of credit.253

Who Is Eligible
To be eligible for FHA Short Refinance, a homeowner must be current on the
existing first-lien mortgage or have made three successful trial period payments; be
in a negative equity position; occupy the home as a primary residence; qualify for
the new loan under standard FHA underwriting and credit score requirements and
have an existing loan that is not insured by FHA.254 According to the Department
of Housing and Urban Development (“HUD”), it evaluates the credit risk of the
loans.255
How FHA Short Refinance Works
Servicers must first determine the current value of the home using a third-party
appraisal by a HUD-approved appraiser. The borrower is then reviewed for credit
risk and, if necessary, referred for a review to confirm that the borrower’s total
monthly mortgage payments on all liens after the refinance is not greater than
31% of the borrower’s monthly gross income and the borrower’s total household
debt is not greater than 50%.256 Next, the lien holders must forgive principal that is
more than 115% of the value of the home. In addition, the original first-lien lender
must forgive at least 10% of the unpaid principal balance of the first-lien loan,
in exchange for a cash payment for 97.75% of the current home value from the
proceeds of the refinance. The lender may maintain a subordinate second lien for
up to 17.25% of that value (for a total balance of 115% of the home’s value).257
If a borrower defaults, the letter of credit purchased by TARP compensates the
investor for a first percentage of losses, up to specified amounts.258 FHA is potentially responsible for the remaining approximately 86.6% of potential losses on each
mortgage, until the earlier of either (1) the time that the $8 billion letter of credit is
exhausted, or (2) 10 years from the issuance of the letter of credit (October 2020),
at which point FHA will bear all of the remaining losses.259

Housing Finance Agency Hardest Hit Fund (“HHF”)
On February 19, 2010, the Administration announced a housing support program
known as the Hardest Hit Fund. Under HHF, TARP dollars would fund “innovative
measures” developed by 19 state housing finance agencies (“HFAs”) and approved
by Treasury to help families in the states that have been hit the hardest by the
aftermath of the housing bubble.260 The first round of HHF allocated $1.5 billion
of the amount initially allocated for MHA initiatives. According to Treasury, these
funds were designated for five states where the average home price had decreased
more than 20% from its peak. The five states were Arizona, California, Florida,
Michigan, and Nevada.261 Plans to use these funds were approved by Treasury on
June 23, 2010.262
On March 29, 2010, Treasury expanded HHF to include five additional states
and increased the program’s potential funding by $600 million, bringing total
funding to $2.1 billion. The additional $600 million was designated for North

For more information concerning
FHA Short Refinance eligibility, see
SIGTARP’s April 2011 Quarterly
Report, pages 85-87.

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special inspector general I troubled asset relief program

Carolina, Ohio, Oregon, Rhode Island, and South Carolina. Treasury indicated that
these states were selected because of their high concentrations of people living in
economically distressed areas, defined as counties in which the unemployment rate
exceeded 12%, on average, in 2009.263 Plans to use these funds were approved by
Treasury on August 3, 2010.264
On August 11, 2010, Treasury pledged a third round of HHF funding of $2
billion to states with unemployment rates at or above the national average.265
The states designated to receive funding were Alabama, California, Florida,
Georgia, Illinois, Indiana, Kentucky, Michigan, Mississippi, Nevada, New Jersey,
North Carolina, Ohio, Oregon, Rhode Island, South Carolina, Tennessee, and
Washington, DC.266 Treasury approved third round proposals on September 23,
2010.267 On September 29, 2010, a fourth round of HHF funding of an additional
$3.5 billion was made available to existing HHF participants.268
Treasury approved state programs and allocated the $7.6 billion in TARP funds
in five categories of assistance:269
•
•
•
•
•

$4.4 billion for unemployment assistance
$1.4 billion allocated for principal reduction
$817 million for reinstatement of past-due amounts
$83 million for second-lien reduction
$45 million for transition assistance, including short sales and deed-in-lieu of
foreclosure

Each state’s HFA reports program results (i.e., number of applications approved
or denied and assistance provided) on a quarterly basis on its own state website.
Treasury does not publish the data either by individual HFA or in the aggregate.
Treasury indicated that states can reallocate funds between programs and modify
existing programs as needed, with Treasury approval, until funds are expended
or returned to Treasury after December 31, 2017. According to Treasury, since
December 31, 2011, eight states have reallocated funds, modified or eliminated
existing programs, or established new HHF programs with Treasury approval,
bringing the total number of HHF programs in 18 states and Washington, DC, as
of June 30, 2012, to 56.270
Table 2.18 shows the obligation of funds and funds drawn for states participating in the four rounds of HHF as of June 30, 2012. As of that date, according to
Treasury, the states had drawn down $1.1 billion under the program. According
to Treasury, the states had spent only a limited portion of the amount drawn on
assisting borrowers; see Table 2.18. More than half of the amount drawn is held as
unspent cash-on-hand with HFAs or is used for administrative expenses.271

quarterly report to congress I July 25, 2012

TABLE 2.18

HHF Funding Obligated and drawdowns by State, as of 6/30/2012
Recipient

Amount Obligated

Amount Drawn*

Alabama

$162,521,345

$28,000,000

Arizona

267,766,006

21,255,000

California

1,975,334,096

217,490,000

Florida

1,057,839,136

89,800,000

339,255,819

38,200,000

Georgia
Illinois

445,603,557

96,500,000

Indiana

221,694,139

22,000,000

Kentucky

148,901,875

24,000,000

Michigan

498,605,738

47,317,776

Mississippi

101,888,323

7,641,624

Nevada

194,026,240

17,922,000

New Jersey

300,548,144

22,513,704

North Carolina

482,781,786

128,000,000

Ohio

570,395,099

96,100,000

Oregon

220,042,786

107,501,070

79,351,573

26,000,000

Rhode Island
South Carolina

295,431,547

40,000,000

Tennessee

217,315,593

31,315,593

Washington, DC
Total

20,697,198

10,034,860

$7,600,000,000

$1,071,591,627

Source: Treasury, response to SIGTARP data call, 7/5/2012.
*Amount drawn includes funds for program expenses (direct assistance to borrowers), administrative expenses, and cash-on-hand.

As of March 31, 2012, the latest data available, HHF had provided $350.8
million in assistance to 43,580 homeowners.272 Each state estimates the number of
borrowers to be helped in its programs. Treasury allows the HFAs to change this
estimate. The aggregate of these estimated ranges has decreased in the last year.
As of March 31, 2012, the 19 state HFAs collectively estimate helping between
452,034 and 476,672 homeowners over the life of the program.273 Table 2.19 provides this estimate as well as the actual number of borrowers helped by state using
data as of March 31, 2012.

For more information on HHF,
see SIGTARP’s April 12, 2012,
audit report, “Factors Affecting
Implementation of the Hardest Hit
Fund Program.”

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special inspector general I troubled asset relief program

TABLE 2.19

HHF Estimated and Actual Number of Borrowers Assisted and
assistance provided, by state, as of 3/31/2012

Recipient
Alabama
Arizona
California
Florida
Georgia
Illinois
Indiana

Estimated Number
of Participating
Households to
be Assisted by
12/31/2017*

Actual Borrowers
Receiving Assistance
as of 3/31/2012**

Assistance Provided
as of 3/31/2012**

8,500

1,579

$10,113,978

3,207

484

9,262,887

88,774

6,681

58,554,423

106,000

4,745

20,849,632

18,300

872

4,535,143

17,000 to 29,000

1,569

16,926,236

13,392

546

3,635,792

Kentucky

5,342 to 13,000

1,519

11,296,861

Michigan

38,687

4,165

15,086,894

3,800

398

3,064,124

10,371

891

5,188,469

6,900

171

970,886

North Carolina

22,290

5,258

48,922,052

Ohio

57,300

5,020

48,353,363

Oregon

13,630

4,579

49,879,568

Mississippi
Nevada
New Jersey

Rhode Island
South Carolina
Tennessee
Washington, DC
Total

2,921

1,340

10,299,394

21,600 to 26,100

2,233

19,726,540

13,500

1,267

10,858,838

520 to 1,000

263

3,305,577

452,034 to 476,672

43,580

$350,820,656

* Source: Estimates are from the latest HFA Participation Agreements as of 3/31/2012. Later amendments are not included for
consistency with Quarterly Performance reporting.
States report the Estimated Number of Participating Households individually for each HHF program they operate. This column
shows the totals of the individual program estimates for each state. Therefore, according to Treasury, these totals do not
necessarily translate into the number of unique households that the states expect to assist because some households may
participate in more than one HHF program.
** Sources: First quarter 2012 HFA Performance Data quarterly reports and First Quarter 2012 HFA Aggregate Quarterly Report.
Both sources are as of 3/31/2012.

As of March 31, 2012, 76% of the HHF assistance received by homeowners
was for unemployment assistance. The remaining assistance can be broken down
to 20% for reinstatement of past due amounts, 4% for principal reduction, 1% for
second-lien reduction, and 0.1% for transition assistance.274

quarterly report to congress I July 25, 2012

Financial Institution Support Programs
Treasury created six TARP programs through which it made capital investments
or asset guarantees in exchange for equity in participating financial institutions.
Three of the programs, the Capital Purchase Program (“CPP”), the Community
Development Capital Initiative (“CDCI”), and the Capital Assistance Program
(“CAP”), were open to all qualifying financial institutions (“QFIs”). The other
three, the Systemically Significant Failing Institutions (“SSFI”) program, the
Targeted Investment Program (“TIP”), and the Asset Guarantee Program (“AGP”),
were available on a case-by-case basis to institutions that needed assistance beyond
that available through CPP. With the expiration of TARP funding authorization, no
new investments can be made through these six programs.
To help improve the capital structure of some struggling TARP recipients,
Treasury has agreed to modify its investment in certain cases by converting the preferred stock it originally received into other forms of equity, such as common stock
or mandatorily convertible preferred stock (“MCP”).275

Mandatorily Convertible Preferred
Stock (“MCP”): A type of preferred
share (ownership in a company that
generally entitles the owner of the
shares to collect dividend payments)
that can be converted to common
stock under certain parameters at the
discretion of the company — and must
be converted to common stock by a
certain time.

Capital Purchase Program
Treasury’s stated goal for CPP was to invest in “healthy, viable institutions” as a
way to promote financial stability, maintain confidence in the financial system, and
enable lenders to meet the nation’s credit needs.276 CPP was a voluntary program
open to all QFIs through an application process. QFIs included U.S.-controlled
banks, savings associations, and certain bank and savings and loan holding
companies.277
Under CPP, Treasury used TARP funds predominantly to purchase preferred
equity interests in QFIs. The QFIs issued Treasury senior preferred shares that pay
a 5% annual dividend for the first five years and a 9% annual dividend thereafter. In
addition to the senior preferred shares, publicly traded QFIs issued Treasury warrants to purchase common stock with an aggregate market price equal to 15% of
the senior preferred share investment. Privately held QFIs issued Treasury warrants
to purchase additional senior preferred stock worth 5% of Treasury’s initial preferred stock investment.278 In total, Treasury invested $204.9 billion of TARP funds
in 707 QFIs through CPP.279
As of June 30, 2012, 325 of those 707 institutions remained in CPP, according to Treasury.280 Of the 382 that have exited CPP, 165, or 43.2%, did so through
other government programs — 28 of them through TARP’s CDCI and 137 through
the Small Business Lending Fund (“SBLF”), a non-TARP program.281 Only 164 of
the banks that exited, or 42.9%, fully repaid CPP otherwise.282 In addition, three
CPP banks merged with other CPP banks; Treasury sold its investments in 33
institutions at a loss; and 17 institutions or their subsidiary banks failed, meaning
Treasury lost its entire investment in those banks.283

For discussion of SIGTARP’s
recommendations on TARP exit paths
for community banks, see SIGTARP’s
October 2011 Quarterly Report, pages
167-169.

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special inspector general I troubled asset relief program

Subordinated Debentures: Form of
debt security that ranks below other
loans or securities with regard to
claims on assets or earnings.

Status of Funds
According to Treasury, through CPP, Treasury purchased $204.9 billion in
preferred stock and subordinated debentures from 707 QFIs in 48 states, the
District of Columbia, and Puerto Rico. Although the 10 largest investments
accounted for $142.6 billion of the program, CPP made many smaller investments:
331 of 707 recipients received $10 million or less.284 Table 2.20 shows the
distribution of investments by amount.
TABLE 2.20

CPP INVESTMENT SIZE BY INSTITUTION, AS OF 6/30/2012
$10 billion or more
$1 billion to $10 billion
$100 million to $1 billion

Originala

Outstandingb

6

0

19

0

57

17

Less than $100 million

625

308

Total

707

325

Notes: Data based on the institutions’ total CPP investments. There are more than 30 institutions that have received multiple
transactions through CPP.
a
These numbers are based on total Treasury CPP investment since 10/28/2008.
b
	Amount does not include those investments that have already been repaid, sold to a third party at a discount, merged out of the
CPP portfolio, exchanged their CPP investments for an investment under CDCI, or are related to institutions that filed for bankruptcy
protection or had a subsidiary bank fail. Figures are based on total investments outstanding. Included in those figures are the six
banks that were converted to common shares at a discount. The outstanding amount represented is the original par value of the
investment. Treasury does not include in the number of banks with outstanding CPP investments those institutions that have repaid
their CPP principal but still have warrants outstanding.
Source: Treasury, response to SIGTARP data call, 7/5/2012.

As of June 30, 2012, 325 banks remained in CPP and taxpayers were still owed
$13.8 billion related to CPP. According to Treasury, it had write-offs and realized
losses of $2.8 billion in the program, leaving $11.1 billion in TARP funds outstanding. According to Treasury, $191.1 billion of the CPP principal (or 93.3%) had been
repaid as of June 30, 2012. That repayment tally includes $245 million in proceeds
from an auction held from June 11 through June 13, 2012, of preferred stock in
seven banks, but does not include $204.4 million in proceeds from an auction held
from June 25 through June 27, 2012, of preferred stock in another seven banks.
The repayment amount also includes $363.3 million in preferred stock that was
converted from CPP investments into CDCI and therefore still represents outstanding obligations to TARP, and $2.2 billion that was refinanced in 2011 into
SBLF, a non-TARP Government program.285 As of June 30, 2012, Treasury had
received approximately $11.7 billion in interest and dividends from CPP recipients.
Treasury also had received $7.7 billion through the sale of CPP warrants that were
obtained from TARP recipients.286 Figure 2.2 provides a snapshot of CPP funds
outstanding and associated repayments. For a complete list of CPP share repurchases, see Appendix D: “Transaction Detail.”

quarterly report to congress I July 25, 2012

FIGURE 2.2

SNAPSHOT OF CPP FUNDS REPAID AND OWED TO TAXPAYERS,
BY QUARTER ($ BILLIONS)

200
177.5
177.5

198.8 203.2 204.6 204.9 204.9 204.9 204.9 204.9 204.9 204.9 204.9 204.9 204.9 204.9
0.4 70.1 70.7 121.9 135.8 146.9 152.8 167.9 179.1 180.6 184.9 185.5 186.9 191.1
198.4

150

100

115.0
115.0

133.1 133.9

83.0
69.1
50

58.0

52.1
37.0

0

25.9

24.3

20.0

19.5 18.0
13.8

Q308 Q408 Q109 Q209 Q309 Q409 Q110 Q210 Q310 Q410 Q111 Q211 Q311 Q411 Q112 Q212

CPP Funds Repaid at Quarter’s End
CPP Funds Owed to Taxpayers at Quarter’s End
Notes: Numbers may be affected by rounding. Data presented for calendar quarters.
Source: Treasury, Transactions Report, 6/27/2012.

CPP Banks Exiting TARP by Refinancing into SBLF
On September 27, 2010, the President signed into law the Small Business Jobs
Act of 2010 (“Jobs Act”), which created the non-TARP program SBLF for Treasury
capital investments in institutions with less than $10 billion in total assets.287
The Jobs Act specifically contemplated that some CPP institutions could apply
to exit TARP by refinancing into SBLF. According to Treasury, it received a total of
935 SBLF applications, of which 320 were TARP recipients under CPP (315) or
CDCI (5).288
Treasury approved the exit of 137 CPP participants from TARP, which included
refinancing Treasury’s TARP preferred stock into $2.7 billion in SBLF preferred
stock.289
An institution was not eligible for the program if at the time of application it
was on the FDIC’s problem bank list or if it had been removed from that list in the
90 days preceding its application to SBLF.290 Treasury consulted with Federal and,
where applicable, state regulators about the bank’s financial condition and whether
it was eligible to receive funding from SBLF.291

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special inspector general I troubled asset relief program

For SIGTARP’s recommendations
to Treasury about applying SBLF
to TARP recipients, see SIGTARP’s
January 2011 Quarterly Report, pages
185-192.
For further discussion of Treasury
policies regarding missed dividend
payments and of how Treasury adjusts
dividend rates of SBLF banks, see
SIGTARP’s April 2011 Quarterly
Report, pages 128-129.
For a discussion of the impact of TARP
and SBLF on community banks, see
SIGTARP’s April 2012 Quarterly
report, pages 145-167.

In order for these 137 banks to exit TARP, the following conditions had to be
met:292
• Banks that refinanced into SBLF were required to end participation in CPP or
CDCI.
• Banks that used SBLF to refinance their CPP or CDCI investments were
required to redeem all outstanding preferred stock issued under those programs
on or before the date of Treasury’s SBLF investment. Banks could use the SBLF
funding to meet this requirement.
• Banks were required to be in material compliance with all the terms, conditions,
and covenants of CPP or CDCI in order to refinance through SBLF.
• Banks were required to be current in their dividend payments and to pay any
accrued and unpaid dividends due to Treasury under CPP or CDCI. In addition,
banks could not have missed more than one previous dividend payment under
CPP or CDCI (defined as a payment submitted more than 60 days late).
Table 2.21 is a list of the 137 banks that exited TARP by refinancing into SBLF.

quarterly report to congress I July 25, 2012

Table 2.21

CPP BANKS THAT EXITED TARP BY REFINANCING INTO SBLF
Institution
1st Enterprise Banka
Adbanc, Inc.
AMB Financial Corp.
AmeriBank Holding Company

CPP Principal
Investment

CPP Warrant
Disposition Proceeds

TARP Exit Date

SBLF Principal
Investment

$10,400,000

$220,000

9/1/2011

$16,400,000

12,720,000

636,000

7/21/2011

21,905,000

3,674,000

184,000

9/22/2011

3,858,000

2,492,000

125,000

9/15/2011

5,347,000

21,000,000

825,000

8/11/2011

21,000,000

7,400,000

370,000

9/15/2011

18,950,000

BancIndependent, Inc.

21,100,000

1,055,000

7/14/2011

30,000,000

Bancorp Financial, Inc.

13,669,000

410,000

8/18/2011

14,643,000

Bank of Commerce Holdings

17,000,000

125,000

9/27/2011

20,000,000

BankFirst Capital Corporation

15,500,000

775,000

9/8/2011

20,000,000

Banner County Ban Corporation

795,000

40,000

7/28/2011

2,427,000

Bern Bancshares, Inc.

985,000

50,000

9/1/2011

1,500,000

AmeriServ Financial, Inc.
Avenue Financial Holdings, Inc.

Birmingham Bloomfield Bancshares, Inc.

3,379,000

82,000

7/28/2011

4,621,000

BNC Financial Group, Inc.

4,797,000

240,000

8/4/2011

10,980,000

BOH Holdings, Inc.

10,000,000

500,000

7/14/2011

23,938,350

Brotherhood Bancshares, Inc.

a

11,000,000

550,000

9/15/2011

16,000,000

Cache Valley Banking Companya

9,407,000

238,000

7/14/2011

11,670,000

California Bank of Commerce

4,000,000

200,000

9/15/2011

11,000,000

Cardinal Bancorp II, Inc.

6,251,000

313,000

9/8/2011

6,251,000

6,500,000

263,000

7/21/2011

9,681,000

Center Bancorp, Inc.

10,000,000

245,000

9/15/2011

11,250,000

Central Bancorp, Inc.

Catskill Hudson Bancorp, Inc.

a

10,000,000

2,525,000

8/25/2011

10,000,000

Central Valley Community Bancorp

7,000,000

185,017

8/18/2011

7,000,000

Centric Financial Corporation

6,056,000

182,000

7/14/2011

7,492,000

Centrix Bank & Trust

7,500,000

375,000

7/28/2011

24,500,000

Citizens Community Bank

3,000,000

150,000

7/28/2011

4,000,000

Citizens South Banking Corporation

20,500,000

225,157

9/22/2011

20,500,000

CoBiz Financial Inc.

64,450,000

143,677

9/8/2011

57,366,000

Codorus Valley Bancorp, Inc.

16,500,000

526,604

8/18/2011

25,000,000

2,260,000

113,000

9/22/2011

6,050,000

Community Bank Shares of Indiana, Inc.

19,468,000

1,100,870

9/15/2011

28,000,000

Community First Bancshares Inc.

20,000,000

1,000,000

8/18/2011

30,852,000

9,000,000

460,000

8/11/2011

12,000,000

Community Trust Financial Corporation

24,000,000

1,200,000

7/6/2011

48,260,000

D. L. Evans Bancorp

19,891,000

995,000

9/27/2011

29,891,000

2,639,000

132,000

9/8/2011

Columbine Capital Corp.

Community Partners Bancorp

Deerfield Financial Corporation

3,650,000
Continued on next page

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special inspector general I troubled asset relief program

CPP BANKS THAT EXITED TARP BY REFINANCING INTO SBLF
CPP Principal
Investment

Institution
DNB Financial Corporation
Eagle Bancorp, Inc.

(Continued)

CPP Warrant
Disposition Proceeds

TARP Exit Date

SBLF Principal
Investment

$11,750,000

$458,000

8/4/2011

$13,000,000

38,235,000

2,794,422

7/14/2011

56,600,000

Emclaire Financial Corp.

7,500,000

51,113

8/18/2011

10,000,000

Encore Bancshares, Inc.

34,000,000

637,071

9/27/2011

32,914,000

Enterprise Financial Services Group, Inc.

4,000,000

200,000

8/25/2011

5,000,000

Equity Bancshares, Inc.

8,750,000

438,000

8/11/2011

16,372,000

700,000

40,000

7/21/2011

700,000

FCB Bancorp, Inc.

9,294,000

465,000

9/22/2011

9,759,000

Financial Security Corporation

5,000,000

250,000

7/21/2011

5,000,000

Farmers State Bankshares, Inc.

Financial Services of Winger, Inc.
First Bancorp
First Bank of Charleston, Inc.
First Bankers Trustshares, Inc.
First Busey Corporation
First California Financial Group, Inc
First Colebrook Bancorp, Inc.

3,742,000

112,000

9/1/2011

4,069,000

65,000,000

924,462

9/1/2011

63,500,000

3,345,000

167,000

7/21/2011

3,345,000

10,000,000

500,000

9/8/2011

10,000,000

100,000,000

63,677

8/25/2011

72,664,000

25,000,000

599,042

7/14/2011

25,000,000

4,500,000

225,000

9/22/2011

8,623,000

First Financial Bancshares, Inc.

3,756,000

113,000

9/22/2011

3,905,000

First Guaranty Bancshares, Inc.

20,699,000

1,030,000

9/22/2011

39,435,000

First Menasha Bancshares, Inc.

4,797,000

240,000

9/15/2011

10,000,000

116,000,000

367,500

9/22/2011

90,782,940

First NBC Bank Holding Company

17,836,000

892,000

8/4/2011

37,935,000

First Northern Community Bancorp

17,390,000

375,000

9/15/2011

22,847,000

a

First Resource Bank

5,017,000

130,000

9/15/2011

5,083,000

First Texas BHC, Inc.

13,533,000

677,000

9/15/2011

29,822,000

9,495,000

475,000

9/22/2011

15,360,000

12,000,000

600,000

9/15/2011

12,600,000

3,100,000

155,000

9/15/2011

3,255,000

First Merchants Corporation

Florida Business BancGroup, Inc.
FNB Bancorp
Fortune Financial Corporation

4,000,000

200,000

9/8/2011

5,200,000

GrandSouthBancorporationa

Grand Capital Corporation

15,319,000

450,000

9/8/2011

15,422,000

Great Southern Bancorp

58,000,000

6,436,364

8/18/2011

57,943,000

Guaranty Bancorp, Inc.

6,920,000

346,000

9/15/2011

7,000,000

Gulfstream Bancshares, Inc.

7,500,000

375,000

8/18/2011

7,500,000

Heartland Financial USA, Inc.

81,698,000

1,800,000

9/15/2011

81,698,000

Heritage Bankshares, Inc.

10,103,000

303,000

8/11/2011

7,800,000

Highlands Bancorp, Inc.

a

Horizon Bancorp
Howard Bancorp, Inc.

5,450,000

155,000

9/22/2011

6,853,000

25,000,000

1,750,551

8/25/2011

12,500,000

5,983,000

299,000

9/22/2011

12,562,000
Continued on next page

quarterly report to congress I July 25, 2012

CPP BANKS THAT EXITED TARP BY REFINANCING INTO SBLF

(Continued)

CPP Principal
Investment

CPP Warrant
Disposition Proceeds

TARP Exit Date

SBLF Principal
Investment

Illinois State Bancorp, Inc.a

$10,272,000

$406,000

9/22/2011

$13,368,000

Katahdin Bankshares Corp.

10,449,000

522,000

8/18/2011

11,000,000

Liberty Bancshares, Inc. (AR)

57,500,000

2,875,000

7/21/2011

52,500,000

Liberty Bancshares, Inc. (MO)

21,900,000

1,095,000

8/18/2011

22,995,000

Magna Bank

13,795,000

690,000

8/18/2011

18,350,000

6,000,000

300,000

8/18/2011

6,000,000

21,498,000

645,000

7/21/2011

26,303,000

Mercantile Capital Corp.

3,500,000

175,000

8/4/2011

7,000,000

Merchants and Manufacturers Bank
Corporation

3,510,000

176,000

9/8/2011

6,800,000

Merchants and Planters Bancshares, Inc.

1,881,000

94,000

9/8/2011

2,000,000

MidSouth Bancorp, Inc.

20,000,000

206,557

8/25/2011

32,000,000

Moneytree Corporation

9,516,000

476,000

9/15/2011

9,992,000

Institution

McLeod Bancshares, Inc.
Medallion Bank

a

Monument Bank

4,734,000

237,000

8/11/2011

11,355,000

MutualFirst Financial, Inc.

32,382,000

900,194

8/25/2011

28,923,000

New Hampshire Thrift Bancshares, Inc.

10,000,000

737,100

8/25/2011

20,000,000

Nicolet Bankshares, Inc.

14,964,000

748,000

9/1/2011

24,400,000

Northway Financial, Inc.

10,000,000

500,000

9/15/2011

23,593,000

Oak Valley Bancorp

13,500,000

560,000

8/11/2011

13,500,000

Pacific Coast Bankers’ Bancshares

11,600,000

580,000

7/28/2011

11,960,000

Pathfinder Bancorp, Inc.

6,771,000

537,633

9/1/2011

13,000,000

Penn Liberty Financial Corp.

9,960,000

498,000

9/1/2011

20,000,000

Peoples Bancorp

18,000,000

900,000

8/4/2011

18,000,000

PFSB Bancorporation, Inc.

1,500,000

71,000

8/25/2011

1,500,000

PlainsCapital Corporation

87,631,000

4,382,000

9/27/2011

114,068,000

4,000,000

175,000

9/15/2011

4,250,000

Providence Bank
Puget Sound Bank

4,500,000

225,000

8/11/2011

9,886,000

QCR Holdings, Inc.

38,237,000

1,100,000

9/15/2011

40,090,000

Redwood Capital Bancorp

3,800,000

190,000

7/21/2011

7,310,000

Redwood Financial, Inc.

2,995,000

150,000

8/18/2011

6,425,000

Regent Capital Corporation

2,655,000

133,000

7/21/2011

3,350,000

Salisbury Bancorp, Inc.

8,816,000

205,000

8/25/2011

16,000,000

SBT Bancorp, Inc.

4,000,000

200,000

8/11/2011

9,000,000

Seacoast Commerce Bank

1,800,000

90,000

9/1/2011

4,000,000

Security Business Bancorp

5,803,000

290,000

7/14/2011

8,944,500

6,815,000

341,000

9/15/2011

7,200,000

12,500,000

625,000

9/22/2011

22,000,000

Security California Bancorp
Security State Bancshares, Inc.

Continued on next page

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special inspector general I troubled asset relief program

CPP BANKS THAT EXITED TARP BY REFINANCING INTO SBLF
Institution
Southern Heritage Bancshares, Inc.
Southern Illinois Bancorp, Inc.

(Continued)

CPP Principal
Investment

CPP Warrant
Disposition Proceeds

TARP Exit Date

SBLF Principal
Investment

$4,862,000
5,000,000

$243,000

9/8/2011

$5,105,000

250,000

8/25/2011

9,000,000

7/21/2011

20,000,000

Sovereign Bancshares, Inc.

18,215,000

9,550,000
911,000

9/22/2011

24,500,000

Steele Street Bank Corporation

11,019,000

331,000

9/1/2011

11,350,000

Stewardship Financial Corporation

10,000,000

107,398

9/1/2011

15,000,000

8,500,000

315,000

8/4/2011

13,750,000

13,644,000

682,000

9/15/2011

17,000,000

9,720,000

292,000

9/8/2011

8,640,000

20,000,000

1,000,000

Southern Missouri Bancorp, Inc.

b

Summit State Bank
Sword Financial Corporation
TCB Corporation
The ANB Corporation
The Elmira Savings Bank, FSBb

9,090,000

The Landrum Company
The Private Bank of California

8/25/2011

37,000,000

8/25/2011

14,063,000

15,000,000

750,000

8/18/2011

20,000,000

5,450,000

273,000

9/1/2011

10,000,000

The State Bank of Bartley

1,697,000

51,000

9/22/2011

2,380,000

The Victory Bancorp, Inc.a

2,046,000

61,000

9/22/2011

3,431,000

9/22/2011

76,458,000

TowneBankb

76,458,000

Triad Bancorp, Inc.

3,700,000

185,000

9/22/2011

5,000,000

Tri-County Financial Corporation

15,540,000

777,000

9/22/2011

20,000,000

Two Rivers Financial Group, Inc.

12,000,000

600,000

9/1/2011

23,240,000

8,950,000

450,000

8/11/2011

16,500,000

UBT Bancshares, Inc.
Union Bank & Trust Company

6,191,000

160,000

9/22/2011

6,200,000

United Financial Banking Companies, Inc.

5,658,000

283,000

9/15/2011

3,000,000

Valley Financial Group, Ltd.

1,300,000

65,000

9/22/2011

2,000,000

Veritex Holdings, Inc.(Fidelity Resources
Company)

3,000,000

150,000

8/25/2011

8,000,000

110,000,000

5,500,000

9/15/2011

89,142,000

WashingtonFirst Bankshares, Inc.

13,475,000

332,000

8/4/2011

17,796,000

Western Alliance Bancorporation

140,000,000

415,000

9/27/2011

141,000,000

4,871,000

244,000

7/14/2011

5,115,000

$2,240,465,000

$77,321,409

a

W.T.B. Financial Corporation
a

York Traditions Bank
Total

$2,689,763,790

Notes: Banks are not required to repurchase warrants from Treasury that were provided as a condition of receiving funds under CPP.
a
	Institution received multiple investments under CPP.
b
As of the drafting of this report, Treasury still held warrants to purchase common stock in this institution.
Sources: Treasury, Transactions Report, 6/27/2012, www.treasury.gov/initiatives/financial-stability/briefing-room/reports/tarp-transactions/DocumentsTARPTransactions/07-02-12%20Transactions%20
Report%20as%20of%2006-27-12_INVESTMENT.pdf, accessed 7/5/2012; Treasury, SBLF Transactions Report, 9/28/2011, www.treasury.gov/resource-center/sb-programs/DocumentsSBLFTransactions/
SBLF_Bi-Weekly_Transactions_Report_THRU_09272011.pdf, accessed 6/29/2012.

95

quarterly report to congress I July 25, 2012

Program Administration
Although Treasury’s investment authority for CPP has ended, Treasury still has
significant responsibilities for managing the existing CPP portfolio, including the
following:

Table 2.22

•
•
•
•

collecting dividends and interest payments on outstanding investments
monitoring the performance of outstanding investments
disposing of warrants as investments are repaid
selling or restructuring Treasury’s investment in some troubled financial
institutions
• selecting observers for recipients that have missed five quarterly dividend
payments
• potentially selecting directors for recipients that have missed six or more
quarterly dividend payments

Quarter
End

Dividends and Interest
As of June 30, 2012, Treasury had received $11.7 billion in dividends on its CPP
investments.293 However, as of that date, 203 QFIs had unpaid dividend or interest
payments to Treasury totaling approximately $455 million, an increase from the
200 QFIs that had unpaid dividend (or interest) payments totaling approximately
$416 million as of March 31, 2012. Approximately $21.1 million of the unpaid
amounts are non-cumulative, meaning that the institution has no legal obligation
to pay Treasury unless the institution declares a dividend.294 Table 2.22 shows the
number of QFIs and total unpaid amount of dividend and interest payments by
quarter from September 30, 2009, to June 30, 2012.
Treasury’s Policy on Missed Dividend and Interest Payments

According to Treasury, it “evaluates its CPP investments on an ongoing basis with
the help of outside advisors, including external asset managers. The external asset
managers provide a valuation for each CPP investment” that results in Treasury
assigning the institution a credit score.295 For those that have unfavorable credit
scores, including any institution that has missed more than three dividend (or
interest) payments, Treasury has stated that the “asset manager dedicates more
resources to monitoring the institution and may talk to the institution on a more
frequent basis.”296
Under the terms of the preferred shares or subordinated debentures held by
Treasury as a result of its CPP investments, in certain circumstances, such as
when a participant misses six dividend (or interest) payments, Treasury has the
right to appoint up to two additional members to the institution’s board of directors.297 Treasury has stated that it will prioritize the institutions for which it appoints directors based on “the size of its investment, Treasury’s assessment of the
extent to which new directors may make a contribution and Treasury’s ability to
find appropriate directors for a given institution.”298 These directors will not represent Treasury, but rather will have the same fiduciary duties to shareholders as all
other directors. They will be compensated by the institution in a manner similar to

Missed dividend/interest
payments by QFIS,
9/30/2009 to 6/30/2012
($ millions)

Number
of QFIs

Value of
Unpaid
Amountsa,b,c

9/30/2009

38

$75.7

12/31/2009

43

137.4

3/31/2010

67

182.0

6/30/2010

109

209.7

9/30/2010

137

211.3

12/31/2010

155

276.4

3/31/2011

173

277.3

6/30/2011

188

320.8

9/30/2011

193

356.9

12/31/2011

197

377.0

3/31/2012

200

416.0

6/30/2012

203

455.0

d

Notes:
a
	Includes unpaid cumulative dividends, non-cumulative
dividends, and Subchapter S interest payments
but does not include interest accrued on unpaid
cumulative dividends.
b
	Excludes institutions that missed payments but (i) had
fully caught up on missed payments at the end of the
quarter reported in column 1 or (ii) had repaid their
investment amounts and exited CPP.
c
	Includes institutions that missed payments and
(i) entered into a recapitalization or restructuring
with Treasury, (ii) for which Treasury sold the CPP
investment to a third party or otherwise disposed of
the investment to facilitate the sale of the institution to
a third party without receiving full repayment of unpaid
dividends, (iii) filed for bankruptcy relief, or (iv) had a
subsidiary bank fail.
d
	Includes four QFIs and their missed payments not
reported in Treasury’s Capital Purchase Program
Missed Dividends & Interest Payments Report as of
6/30/2010 but reported in Treasury’s Dividends and
Interest Report as of the same date. The four QFIs are
CIT, Pacific Coast National Bancorp, UCBH Holdings,
Inc., and Midwest Banc Holdings, Inc.
Sources: Treasury, Dividends and Interest Report,
7/11/2012; Treasury, responses to SIGTARP
data calls, 10/7/2009, 1/12/2010, 4/8/2010,
6/30/2010, 10/11/2011,1/5/2012, 4/5/2012,
7/5/2012, and 7/10/2012; SIGTARP Quarterly Report
to Congress, 1/30/2010, 4/20/2010, 7/21/2010,
and 10/26/2010.

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special inspector general I troubled asset relief program

other directors.299 Treasury has engaged an executive search firm to identify suitable candidates for board of directors’ positions and has begun interviewing such
candidates.300
According to Treasury, it continues to prioritize institutions for nominating
directors in part based on whether its investment exceeds $25 million.301 When
Treasury’s right to nominate a new board member becomes effective, it evaluates
the institution’s condition and health and the functioning of its board to determine
whether additional directors are necessary.302 As of June 30, 2012, Treasury had
made director appointments to the boards of directors of 11 CPP banks.303
According to Treasury, on April 19, 2012, it appointed James Kane to the board
of Bridgeview Bancorp, Inc., Bridgeview, Illinois (“Bridgeview”).304 Bridgeview
received $38 million under CPP and had missed nine quarterly dividend payments
prior to the director appointment.305
According to Treasury, on April 25, 2012, it appointed Dennis Battles to the
board of Centrue Financial Corporation, St. Louis, Missouri (“Centrue”).306
Centrue received $32.7 million under CPP and had missed 12 quarterly dividend
payments prior to the director appointment.307
According to Treasury, on June 12, 2012, it appointed Randall Howard to the
board of First Trust Corporation, New Orleans, Louisiana (“First Trust”).308 First
Trust received $18 million under CPP and had missed nine quarterly dividend payments prior to the director appointment.309
For institutions that miss five or more dividend (or interest) payments, Treasury
has stated that it would seek consent from such institutions to send observers to
the institutions’ board meetings.310 According to Treasury, the observers would be
selected from the Office of Financial Stability (“OFS”) and assigned to “gain a better understanding of the institution’s condition and challenges and to observe how
the board is addressing the situation.”311 Their participation would be “limited to
inquiring about distributed materials, presentations, and actions proposed or taken
during the meetings, as well as addressing any questions concerning” their role.312
The findings of the observers are taken into account when Treasury evaluates
whether to appoint individuals to an institution’s board of directors.313 As of June
30, 2012, Treasury had assigned observers to 49 current CPP recipients.314
SIGTARP and Treasury do not use the same methodology to report unpaid
dividend and interest payments. For example, Treasury generally excludes institutions from its “non-current” reporting: (i) that have completed a recapitalization,
restructuring, or exchange with Treasury (though Treasury does report such institutions as non-current during the pendency of negotiations); (ii) for which Treasury
sold the CPP investment to a third party, or otherwise disposed of the investment
to facilitate the sale of the institution to a third party; (iii) that filed for bankruptcy
relief; or (iv) that had a subsidiary bank fail.315 SIGTARP generally includes such
activity in Table 2.23 under “Value of Unpaid Amounts” with the value set as of
the date of the bankruptcy, restructuring, or other event that relieves the institution of the legal obligation to continue to make dividend and interest payments. If
a completed transaction resulted in payment to Treasury for all unpaid dividends
and interest, SIGTARP does not include the institution’s obligations under unpaid

quarterly report to congress I July 25, 2012

amounts. SIGTARP, unlike Treasury, does not include in its table institutions that
have “caught up” by making previously missed dividend and interest payments.316
According to Treasury, as of June 30, 2012, 117 QFIs had missed at least six dividend (or interest) payments (up from 101 last quarter) and 23 banks had missed
five dividend (or interest) payments totaling $413 million.317 Table 2.23 lists CPP
recipients that had unpaid dividend (or interest) payments as of June 30, 2012. For
a complete list of CPP recipients and institutions making dividend or interest payments, see Appendix D: “Transaction Detail.”

97

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special inspector general I troubled asset relief program

Table 2.23

CPP RELATED MISSED DIVIDEND AND INTEREST PAYMENTS, AS OF 6/30/2012
Observer
Number
Assigned
of Missed to Board of
Payments
Directors1

Company

Dividend or
Payment type

Saigon National Bank

Non-Cumulative

14

Anchor BanCorp Wisconsin, Inc.

Cumulative

13

Blue Valley Ban Corp

Cumulative

13

Lone Star Bank

Non-Cumulative

13

ü

OneUnited Bank

Non-Cumulative

13

ü

United American Bank

Non-Cumulative

13

Centrue Financial Corporation

Cumulative

12

Dickinson Financial Corporation II

Cumulative

First Banks, Inc.

Cumulative

Georgia Primary Bank
Grand Mountain Bancshares, Inc.

Value of Missed
Payments2

Value of Unpaid
Amounts2,3,4

$286,423

$286,423

18,104,167

18,104,167

3,534,375

3,534,375

548,432

548,432

1,960,238

1,960,238

1,534,402

1,534,402

n

4,900,200

4,900,200

12

ü

23,879,760

23,879,760

12

n

48,297,900

48,297,900

Non-Cumulative

12

ü

745,288

745,288

Cumulative

12

ü

496,460

496,460

Idaho Bancorp

Cumulative

12

ü

1,128,150

1,128,150

Pacific City Financial Corporation

Cumulative

12

2,648,700

2,648,700

Premier Service Bank

Non-Cumulative

12

ü

650,972

650,972

Royal Bancshares of Pennsylvania, Inc.

Cumulative

12

n

4,561,050

4,561,050

Citizens Commerce Bancshares, Inc.

Cumulative

11

944,213

944,213

FC Holdings, Inc.

Cumulative

11

ü

3,153,645

3,153,645

Northern States Financial Corporation

Cumulative

11

ü

2,366,513

2,366,513

Omega Capital Corp.

Cumulative

11

422,098

422,098

Pathway Bancorp

Cumulative

11

558,498

558,498

Premierwest Bancorp

Cumulative

11

n

5,692,500

5,692,500

Ridgestone Financial Services, Inc.

Cumulative

11

ü

1,633,638

1,633,638

Rising Sun Bancorp

Cumulative

11

896,665

896,665

Rogers Bancshares, Inc.

Cumulative

11

n

3,746,875

3,746,875

Cumulative

11

ü

1,199,000

1,199,000

Syringa Bancorp

n

Alliance Financial Services, Inc.

Interest

10

2,517,000

2,517,000

BNCCORP, Inc.

Cumulative

10

ü

2,737,750

2,737,750

Cecil Bancorp, Inc.

Cumulative

10

ü

1,445,000

1,445,000

Central Virginia Bankshares, Inc.

Cumulative

10

1,423,125

1,423,125

Citizens Bancshares Co. (MO)

Cumulative

10

ü

3,405,000

3,405,000

Citizens Republic Bancorp, Inc.

Cumulative

10

n

37,500,000

37,500,000

City National Bancshares Corporation

Cumulative

10

1,179,875

1,179,875

Community 1st Bank

Non-Cumulative

10

323,994

323,994

Fidelity Federal Bancorp

Cumulative

10

879,074

879,074

First Security Group, Inc.

Cumulative

10

4,125,000

4,125,000

First Sound Bank

Non-Cumulative

10

925,000

925,000

First Southwest Bancorporation, Inc.

Cumulative

10

749,375

749,375

Intermountain Community Bancorp

Cumulative

10

3,375,000

3,375,000

*

n

Continued on next page

quarterly report to congress I July 25, 2012

CPP RELATED MISSED DIVIDEND AND INTEREST PAYMENTS, AS OF 6/30/2012
Observer
Number
Assigned
of Missed to Board of
Payments
Directors1

Company

Dividend or
Payment type

Intervest Bancshares Corporation

Cumulative

10

Investors Financial Corporation of
Pettis County, Inc.*

Interest

Monarch Community Bancorp, Inc.

(Continued)

Value of Missed
Payments2

Value of Unpaid
Amounts2,3,4

$3,125,000

$3,125,000

10

839,000

839,000

Cumulative

10

848,125

848,125

Tennessee Valley Financial
Holdings, Inc.

Cumulative

10

408,750

408,750

U.S. Century Bank

Non-Cumulative

10

ü

6,844,700

6,844,700

Bridgeview Bancorp, Inc.

Cumulative

9

n,ü

4,659,750

4,659,750

Commonwealth Business Bank

Non-Cumulative

9

944,325

944,325

First Community Bancshares, Inc (KS)

Cumulative

9

ü

1,814,850

1,814,850

First Trust Corporation*

Interest

9

n,ü

3,391,958

3,391,958

Gold Canyon Bank

Non-Cumulative

9

190,508

190,508

Goldwater Bank, N.A.

Non-Cumulative

9

384,780

314,820

Gregg Bancshares, Inc.

Cumulative

9

101,115

101,115

Madison Financial Corporation

Cumulative

9

413,348

413,348

**

n

Midtown Bank & Trust Company

Non-Cumulative

9

711,475

640,328

Millennium Bancorp, Inc.**

Cumulative

9

989,175

890,258

Northwest Bancorporation, Inc.

Cumulative

9

1,287,563

1,287,563

Patapsco Bancorp, Inc.

Cumulative

9

735,750

735,750

Plumas Bancorp

Cumulative

9

1,344,263

1,344,263

Prairie Star Bancshares, Inc.

Cumulative

9

343,350

343,350

Premier Bank Holding Company

Cumulative

9

1,164,938

1,164,938

Santa Clara Valley Bank, N.A.

Non-Cumulative

9

355,613

355,613

Stonebridge Financial Corp.

Cumulative

9

ü

1,345,635

1,345,635

TCB Holding Company

Cumulative

9

ü

1,438,493

1,438,493

1st FS Corporation

Cumulative

8

ü

1,636,900

1,636,900

**

ü
ü

BNB Financial Services Corporation

Cumulative

8

817,500

817,500

Boscobel Bancorp, Inc*

Interest

8

937,248

937,248

Capital Commerce Bancorp, Inc.

Cumulative

8

555,900

555,900

Harbor Bankshares Corporation**

Cumulative

8

850,000

680,000

Market Bancorporation, Inc.

Cumulative

8

224,540

224,540

Pacific International Bancorp Inc

Cumulative

8

650,000

650,000

Pinnacle Bank Holding Company

Cumulative

8

478,320

478,320

Premier Financial Corp

Interest

8

1,065,238

1,065,238

Provident Community Bancshares, Inc.

Cumulative

8

926,600

926,600

The Queensborough Company

Cumulative

8

1,308,000

1,308,000

Western Community Bancshares, Inc.

Cumulative

8

794,700

794,700

*

ü

Continued on next page

99

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special inspector general I troubled asset relief program

CPP RELATED MISSED DIVIDEND AND INTEREST PAYMENTS, AS OF 6/30/2012

Dividend or
Payment type

Company

Observer
Number
Assigned
of Missed to Board of
Payments
Directors1

(Continued)

Value of Missed
Payments2

Value of Unpaid
Amounts2,3,4

$1,549,868

$1,205,453

Bankers’ Bank of the West
Bancorp, Inc.

Cumulative

7

CalWest Bancorp

Cumulative

7

444,098

444,098

Central Federal Corporation

Cumulative

7

632,188

632,188

CSRA Bank Corp.

Cumulative

7

228,900

228,900

First Financial Service Corporation

Cumulative

7

ü

1,750,000

1,750,000

First United Corporation

Cumulative

7

ü

2,625,000

2,625,000

Florida Bank Group, Inc.

Cumulative

7

ü

1,952,493

1,952,493

1,233,330

1,233,330

1,648,080

1,648,080

286,125

286,125

6,387,500

6,387,500

419,184

363,866

Great River Holding Company

Interest

7

Liberty Shares, Inc.

Cumulative

7

Marine Bank & Trust Company

Non-Cumulative

7

*

Old Second Bancorp, Inc.

Cumulative

7

Pacific Commerce Bank**

Non-Cumulative

7

ü

ü
ü

Private Bancorporation, Inc.

Cumulative

7

758,485

758,485

Regent Bancorp, Inc**

Cumulative

7

1,088,020

952,018

Spirit BankCorp, Inc.

Cumulative

7

ü

2,861,250

2,861,250

Tidelands Bancshares, Inc

Cumulative

7

ü

1,264,200

1,264,200

Bank of the Carolinas Corporation

Cumulative

6

ü

988,425

988,425

Coastal Banking Company, Inc.

Cumulative

6

746,250

746,250

Community Financial Shares, Inc.

Cumulative

6

569,865

474,888

Eastern Virginia Bankshares, Inc.

Cumulative

6

1,800,000

1,800,000

Greer Bancshares Incorporated

Cumulative

6

816,975

816,975

HCSB Financial Corporation

Cumulative

6

967,125

967,125

Highlands Independent
Bancshares, Inc.

Cumulative

6

547,725

547,725

HMN Financial, Inc.

Cumulative

6

1,950,000

1,950,000

Monadnock Bancorp, Inc.

Cumulative

6

149,970

149,970

Naples Bancorp, Inc.

Cumulative

6

327,000

327,000

National Bancshares, Inc.

Cumulative

6

ü

2,016,255

2,016,255

Patriot Bancshares, Inc.

Cumulative

6

ü

2,128,620

2,128,620

Princeton National Bancorp, Inc.

Cumulative

6

ü

1,881,225

1,881,225

ü
ü

ü

Reliance Bancshares, Inc.

Cumulative

6

ü

3,270,000

3,270,000

Security State Bank Holding-Company*

Interest

6

ü

2,029,487

1,352,991

SouthCrest Financial Group, Inc.

Cumulative

6

ü

1,054,575

1,054,575

Southern Community Financial Corp.

Cumulative

6

ü

3,206,250

3,206,250

White River Bancshares Company

Cumulative

6

1,373,400

1,373,400

AB&T Financial Corporation

Cumulative

5

218,750

218,750

Atlantic Bancshares, Inc.

Cumulative

5

136,025

136,025
Continued on next page

101

quarterly report to congress I July 25, 2012

CPP RELATED MISSED DIVIDEND AND INTEREST PAYMENTS, AS OF 6/30/2012

Dividend or
Payment type

Company

Observer
Number
Assigned
of Missed to Board of
Payments
Directors1

(Continued)

Value of Missed
Payments2

Value of Unpaid
Amounts2,3,4

Metropolitan Bank Group, Inc (Archer
Bank)***

Cumulative

5

$7,959,128

$5,035,523

Bank of George

Non-Cumulative

5

182,075

182,075

BCB Holding Company, Inc.

Cumulative

5

116,188

116,188

Carrollton Bancorp

Cumulative

5

575,063

575,063

Central Bancorp, Inc.

Cumulative

5

1,532,813

1,532,813

Citizens Bank & Trust Company

Non-Cumulative

5

163,500

163,500

Clover Community Bankshares, Inc.

Cumulative

5

204,375

204,375

CoastalSouth Bancshares, Inc.

Cumulative

5

1,054,938

1,054,938

Community Bankers Trust Corporation

Cumulative

5

1,547,000

1,105,000

Community First, Inc.

Cumulative

5

1,213,000

970,400

Community Pride Bank Corporation

Interest

5

446,270

446,270

First Place Financial Corp.

Cumulative

5

4,557,938

4,557,938

*

Mid-Wisconsin Financial Services, Inc.

Cumulative

5

681,250

681,250

Suburban Illiniois Bancorp, Inc.*

Interest

5

1,573,125

1,573,125

Timberland Bancorp, Inc.

Cumulative

5

1,664,100

691,910

Valley Community Bank

Non-Cumulative

5

374,688

374,688

Village Bank and Trust Financial Corp.

Cumulative

5

921,125

921,125

Yadkin Valley Financial Corporation

Cumulative

5

3,082,000

3,082,000

Allied First Bancorp, Inc.

Cumulative

4

199,070

199,070

Brogan Bankshares, Inc.

Interest

4

201,360

201,360

Coloeast Bankshares, Inc.

Cumulative

4

545,000

545,000

First Intercontinental Bank

Non-Cumulative

4

348,700

348,700

GulfSouth Private Bank

Non-Cumulative

4

395,250

395,250

Maryland Financial Bank

Non-Cumulative

4

92,650

92,650

NCAL Bancorp

Cumulative

4

545,000

545,000

RCB Financial Corporation

Cumulative

4

469,120

469,120

Southwest Bancorp, Inc.

Cumulative

4

3,500,000

3,500,000

Standard Bancshares, Inc.

Cumulative

4

3,270,000

3,270,000

The Connecticut Bank and Trust
Company

Non-Cumulative

4

246,673

N/A

Bank of Commerce

Non-Cumulative

3

122,625

122,625

Carolina Trust Bank

Non-Cumulative

3

150,000

150,000

Delmar Bancorp

Cumulative

3

367,875

367,875

First Reliance Bancshares, Inc.

Cumulative

3

627,360

627,360

Indiana Bank Corp.

Cumulative

3

53,655

53,655

Northwest Commercial Bank

Non-Cumulative

3

81,450

81,450

Porter Bancorp, Inc.

Cumulative

3

1,312,500

1,312,500

Randolph Bank & Trust Company

Non-Cumulative

3

254,580

254,580

*

Continued on next page

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special inspector general I troubled asset relief program

CPP RELATED MISSED DIVIDEND AND INTEREST PAYMENTS, AS OF 6/30/2012

Company

Dividend or
Payment type

Alarion Financial Services, Inc.

Cumulative

Blue Ridge Bancshares, Inc.

Cumulative

Observer
Number
Assigned
of Missed to Board of
Payments
Directors1

(Continued)

Value of Missed
Payments2

Value of Unpaid
Amounts2,3,4

2

$177,520

$177,520

2

327,000

327,000

Carolina Bank Holdings, Inc.

Cumulative

2

800,000

400,000

Colony Bankcorp, Inc.

Cumulative

2

700,000

700,000

Flagstar Bancorp, Inc.

Cumulative

2

6,666,425

6,666,425

Fresno First Bank

Non-Cumulative

2

33,357

33,357

Ojai Community Bank

Non-Cumulative

2

56,680

56,680

**

SouthFirst Bancshares, Inc.

Cumulative

2

75,210

75,210

US Metro Bank**

Non-Cumulative

2

159,818

77,960

Worthington Financial Holdings, Inc.

Cumulative

2

74,120

74,120

BancTrust Financial Group, Inc.

Cumulative

1

625,000

625,000

Community West Bancshares

Cumulative

1

195,000

195,000

Exchange Bank

Non-Cumulative

1

585,875

585,875

OneFinancial Corporation

Interest

1

351,000

351,000

Plato Holdings Inc.*

Interest

1

51,817

51,817

Severn Bancorp, Inc.

Cumulative

1

292,413

292,413

Independent Bank Corporation***,9

Cumulative

9

9,542,371

7,742,371

Citizens Bancorp****

Cumulative

9

1,275,300

1,275,300

Broadway Financial Corporation

Cumulative

8

1,500,000

1,500,000

One Georgia Bank

Non-Cumulative

8

605,328

605,328

Integra Bank Corporation****

Cumulative

7

7,313,775

7,313,775

Cascade Financial Corporation*****

Cumulative

7

3,409,875

3,409,875

Fort Lee Federal Savings Bank****

Non-Cumulative

6

106,275

106,275

FPB Bancorp, Inc. (FL)

Cumulative

6

435,000

435,000

Central Pacific Financial Corp.***,9

Cumulative

6

10,125,000

10,125,000

FNB United Corp.***

Cumulative

6

3,862,500

—

First Federal Bancshares of Arkansas,
Inc.*****

Cumulative

5

1,031,250

1,031,250

First BanCorp (PR)***

Cumulative

5

ü

42,681,526

—

Pacific Capital Bancorp

Cumulative

5

ü

13,547,550

—

CB Holding Corp.

Cumulative

4

224,240

224,240

Pierce County Bancorp****

Cumulative

4

370,600

370,600

First Community Bank Corporation of
America*****

Cumulative

4

534,250

534,250

Green Bankshares, Inc.*****

Cumulative

4

3,613,900

3,613,900

Santa Lucia Bancorp*****

Cumulative

4

200,000

200,000

Non-Cumulative

4

72,549

*

Exchanges, Sales,
Recapitalizations, and Failed
Banks with Missing Payments

***

****

****

***,9

****

Community Bank of the Bay

6

ü
ü

72,549
Continued on next page

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quarterly report to congress I July 25, 2012

CPP RELATED MISSED DIVIDEND AND INTEREST PAYMENTS, AS OF 6/30/2012
Observer
Number
Assigned
of Missed to Board of
Payments
Directors1

(Continued)

Company

Dividend or
Payment type

The Bank of Currituck*****

Non-Cumulative

4

$219,140

$219,140

Hampton Roads Bankshares, Inc.***

Cumulative

4

4,017,350

4,017,350

Sterling Financial Corporation (WA)***,9

Cumulative

4

18,937,500

18,937,500

Midwest Banc Holdings, Inc.5

Cumulative

4

4,239,200

4,239,200

TIB Financial Corp

Cumulative

4

1,850,000

1,850,000

Blue River Bancshares, Inc.****

Cumulative

3

204,375

204,375

Legacy Bancorp, Inc.

Cumulative

3

206,175

206,175

Sonoma Valley Bancorp

Cumulative

3

353,715

353,715

Superior Bancorp Inc.****

Cumulative

3

2,587,500

2,587,500

Tennessee Commerce Bancorp,
Inc.****

Cumulative

3

1,125,000

1,125,000

Commerce National Bank*****

Non-Cumulative

3

150,000

150,000

Treaty Oak Bancorp, Inc.*****

Cumulative

3

135,340

135,340

The South Financial Group, Inc.

Cumulative

3

13,012,500

13,012,500

CIT Group Inc.****,8

Cumulative

2

29,125,000

29,125,000

Pacific Coast National Bancorp

Cumulative

2

112,270

112,270

Colonial American Bank*****

Non-Cumulative

2

15,655

15,655

FBHC Holding Company

Interest

2

123,127

123,127

Gateway Bancshares, Inc.*****

Cumulative

2

163,500

163,500

*****

Cadence Financial Corporation

Cumulative

2

550,000

550,000

Metropolitan Bank Group, Inc. (NC
Bancorp, Inc.)***

Cumulative

1

1,400,225

1,119,005

Tifton Banking Company****

Non-Cumulative

1

51,775

51,775

UCBH Holdings, Inc.****

Cumulative

1

3,734,213

3,734,213

$524,276,922

$455,077,966

*****,7

****
****

*****,7

****

*,*****

Total

ü

Value of Missed
Payments2

Value of Unpaid
Amounts2,3,4

Notes: Numbers may not total due to rounding. Approximately $21.1 million of the $455 million in unpaid CPP dividend/interest payments are non-cumulative and Treasury has no legal right to missed
dividends that are non-cumulative.
* Missed interest payments occur when a Subchapter S recipient fails to pay Treasury interest on a subordinated debenture in a timely manner.
** Partial payments made after the due date.
*** Completed an exchange with Treasury. For an exchange of mandatorily convertible preferred stock or trust preferred securities, dividend payments normally continue to accrue. For an exchange of
mandatorily preferred stock for common stock, no additional preferred dividend payments will accrue.
**** Filed for bankruptcy or subsidiary bank failed. For completed bankruptcy proceedings, Treasury’s investment was extinguished and no additional dividend payments will accrue. For bank failures,
Treasury may elect to file claims with bank receivers to collect current and/or future unpaid dividends.
***** Treasury sold or is selling its CPP investment to the institution or a third party. No additional preferred dividend payments will accrue after a sale, absent an agreement to the contrary.
n

Treasury has appointed one or more directors to the Board of Directors.

	For First BanCorp and Pacific Capital Bancorp, Treasury had a contractual right to assign an observer to the board of directors. For the remainder, Treasury obtained consent from the institution to
assign an observer to the board of directors.
2
	Includes unpaid cumulative dividends, non-cumulative dividends, and Subchapter S interest payments but does not include interest accrued on unpaid cumulative dividends.
3
	Excludes institutions that missed payments but (i) have fully caught-up or exchanged new securities for missed payments, or (ii) have repaid their investment amounts and exited the Capital Purchase
Program.
4
	Includes institutions that missed payments and (i) completed an exchange with Treasury for new securities, (ii) purchased their CPP investment from Treasury, or saw a third party purchase its CPP
investment from Treasury, or (iii) are in, or have completed bankruptcy proceedings or its subsidiary bank failed.
5
	For Midwest Banc Holdings, Inc., the number of missed payments is the number last reported from SIGTARP Quarterly Report to Congress 4/20/2010, prior to bankruptcy filing; missed payment
amounts are from Treasury’s response to SIGTARP data call, 10/13/2010.
6
	Treasury reported four missed payments by Community Bank of the Bay before it was allowed to transfer from CPP to CDCI. Upon transfer, Treasury reset the number of missed payments to zero.
7
	For South Financial Group, Inc. and TIB Financial Corp, the number of missed payments and unpaid amounts reflect figures Treasury reported prior to the sale.
8
	For CIT Group Inc., the number of missed payments is from the number last reported from SIGTARP Quarterly Report to Congress 1/30/2010, shortly after the bankruptcy filing; missed payment
amounts are from Treasury’s response to SIGTARP data call, 10/13/2010.
9
	Completed exchanges:
- The exchange between Treasury and Hampton Roads, and the exchange between Treasury and Sterling Financial did not account for unpaid dividends. The number of missed payments and unpaid
amounts reflect the figures Treasury reported prior to the exchange.
- The exchange between Treasury and Central Pacific Financial Corp., and the exchange between Treasury and Pacific Capital Bancorp did account for unpaid dividends, thereby eliminating any unpaid
amounts. The number of missed payments reflects the amount Treasury reported prior to the exchange.
1

Sources: Treasury, Dividends and Interest Report, 7/11/2012; Treasury, responses to SIGTARP data call, 1/7/2011, 4/6/2011, 7/8/2011, 10/11/2011, 1/10/2012, 4/5/2012, and 7/10/2012;
SIGTARP Quarterly Report to Congress, 1/30/2010, 4/20/2010, 4/28/2011, 7/28/2011, 10/27/2011, 1/25/2012, 4/25/2012, and 7/25/2012.

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special inspector general I troubled asset relief program

For more information on warrant
disposition, see SIGTARP’s audit
report of May 10, 2010, “Assessing
Treasury’s Process to Sell Warrants
Received from TARP Recipients.”

Exercise Price: Preset price at which
a warrant holder may purchase each
share. For warrants in publicly traded
institutions issued through CPP, this
was based on the average stock price
during the 20 days before the date
that Treasury granted preliminary CPP
participation approval.

Warrant Disposition
As required by EESA, Treasury received warrants when it invested in troubled
assets from financial institutions, with an exception for certain small institutions.
With respect to financial institutions with publicly traded securities, these warrants
gave Treasury the right, but not the obligation, to purchase a certain number of
shares of common stock at a predetermined price.318 Because the warrants rise in
value as a company’s share price rises, they permit Treasury (and the taxpayer) to
benefit from a firm’s potential recovery.319
For publicly traded institutions, the warrants received by Treasury under CPP
allowed Treasury to purchase additional shares of common stock in a number
equal to 15% of the value of the original CPP investment at a specified exercise
price.320 Treasury’s warrants constitute assets with a fair market value that Treasury
estimates using relevant market quotes, financial models, and/or third-party valuations.321 As of June 30, 2012, Treasury had not exercised any of these warrants.322
For privately held institutions, Treasury received warrants to purchase additional
preferred stock or debt in an amount equal to 5% of the CPP investment. Treasury
exercised these warrants immediately.323 Unsold and unexercised warrants expire 10
years from the date of the CPP investment.324
Repurchase of Warrants by Financial Institutions

Upon repaying its CPP investment, a recipient may seek to negotiate with Treasury
to buy back its warrants. As of June 30, 2012, 108 publicly traded institutions had
bought back $3.8 billion worth of warrants, of which $51.1 million was purchased
this quarter. As of that same date, 106 privately held institutions, the warrants
of which had been immediately exercised, bought back the resulting additional
preferred shares for a total of $45.1 million, of which $1.3 million was bought back
this quarter.325 Table 2.24 lists publicly traded institutions that repaid TARP and
repurchased warrants in the quarter ended June 30, 2012. Table 2.25 lists privately
held institutions that had done so in the same quarter.326

quarterly report to congress I July 25, 2012

Table 2.24

CPP WARRANT SALES AND REPURCHASES (PUBLIC) FOR THE QUARTER ENDING 6/30/2012
Number of
Warrants
Repurchased

Amount of
Repurchase
($Thousands)

Repurchase Date

Company

5/2/2012

Regions Financial Corporation

48,253,677

$45,000.0

5/2/2012

Park National Corporation

227,376

2,842.4

5/2/2012

MB Financial, Inc.

506,024

1,518.1

4/19/2012

The Connecticut Bank and Trust Companya

175,742

792.8

6/20/2012

Wilshire Bancorp, Inc.

949,460

760.0

4/4/2012

Peapack-Gladstone Financial Corporation

150,296

110.0

5/30/2012

Seacoast Banking Corporation of Florida

Total

589,623

55.0

50,852,198

$51,078.3

Notes: Numbers may not total due to rounding. This table represents warrants for common stock issued to Treasury by publicly traded TARP recipients.
Treasury may hold one warrant for millions of underlying shares rather than millions of warrants of an individual financial institution.
a
	Warrant sales to third parties.
Sources: Treasury, Transactions Report, 6/27/2012; Treasury, responses to SIGTARP data call, 1/4/2011, 1/7/2011, 4/6/2011, 7/8/2011, 10/7/2011,
10/11/2011, 1/11/2012, 4/5/2012, and 7/9/2012.

Table 2.25

CPP WARRANT SALES AND REPURCHASES (PRIVATE) FOR THE QUARTER ENDING 6/30/2012
Number of
Warrants
Repurchased

Amount of
Repurchase
($Thousands)

Repurchase Date

Company

4/24/2012

Peoples Bancorporation, Inc.

633,000

$633.0

6/27/2012

Beach Business Bank

300,000

300.0

4/13/2012

Gateway Bancshares, Inc.

300,000

300.0

4/4/2012

Titonka Bancshares, Inc.

106,000

106.0

1,339,000

$1,339.0

Total

Notes: Numbers may not total due to rounding. This table represents the preferred shares held by Treasury as a result of the exercise of warrants issued by
non-publicly traded TARP recipients. These warrants were exercised immediately upon the transaction date. Treasury may hold one warrant for millions of
underlying shares rather than millions of warrants of an individual financial institution.
Sources: Treasury, Transactions Report, 6/27/2012; Treasury, response to SIGTARP data call, 7/9/2012.

105

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special inspector general I troubled asset relief program

Treasury Warrant Auctions
Dutch Auction: A type of auction in
which multiple bidders bid for different
quantities of the asset; the price the
seller accepts is set at the lowest bid
of the group of high bidders whose
collective bids fulfill the amount of
shares offered. As an example, three
investors place bids to own a portion
of 100 shares offered by the issuer:
• Bidder A wants 50 shares at $4/
share.
• Bidder B wants 50 shares at $3/
share.
• Bidder C wants 50 shares at $2/
share.
The seller selects Bidders A and B
as the two highest bidders, and their
collective bids consume the 100
shares offered. The winning price is
$3, which is what both bidders pay
per share. Bidder C’s bid is not filled.
Treasury uses a modified version of
a Dutch Auction in the dispensation
of its warrants and in some sales of
preferred stock.
Auction Agent: Firm (such as an
investment bank) that buys a series of
securities from an institution for resale.

If Treasury and the repaying QFI cannot agree upon the price for the institution
to repurchase its warrants, Treasury may conduct a public or private offering
to auction the warrants.327 As of June 30, 2012, the combined proceeds from
Treasury’s public and private warrant auctions totaled $5.4 billion.328
Public Warrant Auctions

In November 2009, Treasury began using a modified Dutch auction to sell the
warrants publicly.329 On the announced auction date, potential investors (which
may include the CPP recipient) submit bids to the auction agent that manages
the sale (for CPP-related warrants, Deutsche Bank) at specified increments above
a minimum price set by Treasury.330 Once the auction agent receives all bids, it
determines the final price and distributes the warrants to the winning bidders.331
Treasury did not conduct any public warrant auctions this quarter.332 Through
June 30, 2012, Treasury had held 24 public auctions for warrants it received under
CPP, TIP, and AGP, raising a total of approximately $5.4 billion.333 Final closing
information for all public auctions is shown in Table 2.26.

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quarterly report to congress I July 25, 2012

TABLE 2.26

PUBLIC TREASURY WARRANT AUCTIONS, AS OF 6/30/2012
Auction Date
3/3/2010

Company
Bank of America A Auction (TIP)a
Bank of America B Auction (CPP)

a

Number of
Warrants Offered

Minimum
Bid Price

Selling
Price

Proceeds to Treasury
($ Millions)

150,375,940

$7.00

$8.35

$1,255.6

121,792,790

1.50

2.55

310.6

88,401,697

8.00

10.75

950.3

110,261,688

6.50

7.70

849.0

12/10/2009

JPMorgan Chase

5/20/2010

Wells Fargo and Company

9/21/2010

Hartford Financial Service Group, Inc.

52,093,973

10.50

13.70

713.7

4/29/2010

PNC Financial Services Group, Inc.

16,885,192

15.00

19.20

324.2

Citigroup A Auction (TIP & AGP)

255,033,142

0.60

1.01

257.6

Citigroup B Auction (CPP)a

210,084,034

0.15

0.26

54.6

a

1/25/2011
9/16/2010

Lincoln National Corporation

13,049,451

13.50

16.60

216.6

5/6/2010

Comerica Inc.

11,479,592

15.00

16.00

183.7

12/3/2009

Capital One

12,657,960

7.50

11.75

148.7

2/8/2011

Wintrust Financial Corporation

1,643,295

13.50

15.80

26.0

6/2/2011

Webster Financial Corporation

9/22/2011

3,282,276

5.50

6.30

20.4

b

SunTrust A Auction

6,008,902

2.00

2.70

16.2

SunTrust B Auctionb

11,891,280

1.05

1.20

14.2

3/9/2010

Washington Federal, Inc.

3/10/2010

Signature Bank

12/15/2009

TCF Financial

3/11/2010

Texas Capital Bancshares, Inc.

2/1/2011

Boston Private Financial Holdings, Inc.

5/18/2010

Valley National Bancorp

2,532,542

1.70

2.20

5.6

11/30/2011

Associated Banc-Corpc

3,983,308

0.50

0.90

3.6

6/2/2010

First Financial Bancorp

465,117

4.00

6.70

3.1

6/9/2010

Sterling Bancshares Inc.

2,615,557

0.85

1.15

3.0

Total

1,707,456

5.00

5.00

15.6

595,829

16.00

19.00

11.3

3,199,988

1.50

3.00

9.6

758,086

6.50

6.50

6.7

2,887,500

1.40

2.20

6.4

1,083,686,595

$5,406.3

Notes: Numbers may not total due to rounding.
a
Treasury held two auctions each for the sale of Bank of America and Citigroup warrants.
b
Treasury held two auctions for SunTrust’s two CPP investments dated 11/14/2008 (B auction) and 12/31/2008 (A auction).
c
According to Treasury, the auction grossed $3.6 million and netted $3.4 million.
Sources: The PNC Financial Services Group, Inc., “Final Prospectus Supplement,” 4/29/2010, www.sec.gov/Archives/edgar/data/713676/000119312510101032/d424b5.htm, accessed
6/28/2012; Valley National Bancorp, “Final Prospectus Supplement,” 5/18/2010, www.sec.gov/Archives/edgar/data/714310/000119312510123896/d424b5.htm, accessed 6/28/2012; Comerica
Incorporated, “Final Prospectus Supplement,” 5/6/2010, www.sec.gov/Archives/edgar/data/28412/000119312510112107/d424b5.htm, accessed 6/28/2012; Wells Fargo and Company, “Definitive
Prospectus Supplement,” 5/20/2010, www.sec.gov/Archives/edgar/data/72971/000119312510126208/d424b5.htm, accessed 6/28/2012; First Financial Bancorp, “Prospectus Supplement,”
6/2/2010, www.sec.gov/Archives/edgar/data/708955/000114420410031630/v187278_424b5.htm, accessed 6/28/2012; Sterling Bancshares, Inc., “Prospectus Supplement,” 6/9/2010,
www.sec.gov/Archives/edgar/data/891098/000119312510136584/dfwp.htm, accessed 6/28/2012; Signature Bank, “Prospectus Supplement,” 3/10/2010, files.shareholder.com/downloads/
SBNY/1456015611x0x358381/E87182B5-A552-43DD-9499-8B56F79AEFD0/8-K__Reg_FD_Offering_Circular.pdf, accessed 6/28/2012; Texas Capital Bancshares, Inc., “Prospectus Supplement,”
3/11/2010, www.sec.gov/Archives/edgar/data/1077428/000095012310023800/d71405ae424b5.htm, accessed 6/28/2012; Bank of America, “Form 8-K,” 3/3/2010, www.sec.gov/Archives/edgar/
data/70858/000119312510051260/d8k.htm, accessed 6/28/2012; Bank of America, “Prospectus Supplement,” 3/1/2010, www.sec.gov/Archives/edgar/data/70858/000119312510045775/
d424b2.htm, accessed 6/28/2012; Washington Federal, Inc., “Prospectus Supplement,” 3/9/2010, www.sec.gov/Archives/edgar/data/936528/000119312510052062/d424b5.htm, accessed
6/28/2012; TCF Financial, “Prospectus Supplement,” 12/16/2009, www.sec.gov/Archives/edgar/data/814184/000104746909010786/a2195869z424b5.htm, accessed 6/28/2012; JPMorgan
Chase, “Prospectus Supplement,” 12/11/2009, www.sec.gov/Archives/edgar/data/19617/000119312509251466/d424b5.htm, accessed 6/28/2012; Capital One Financial, “Prospectus Supplement,”
12/3/2009, www.sec.gov/Archives/edgar/data/927628/000119312509247252/d424b5.htm, accessed 6/28/2012; Treasury, Transactions Report, 7/2/2012; Hartford Financial Services Group,
Prospectus Supplement to Prospectus filed with the SEC 8/4/2010, www.sec.gov/Archives/edgar/data/874766/000095012310087985/y86606b5e424b5.htm, accessed 6/28/2012; Hartford
Financial Agreement, 8/21/2010, www.sec.gov/Archives/edgar/data/874766/000095012310087985/y86606b5e424b5.htm, accessed 6/28/2012; Treasury, “Treasury Announces Pricing of Public
Offering to Purchase Common Stock of The Hartford Financial Services Group, Inc.,” 9/22/2010, www.treasury.gov/press-center/press-releases/Pages/tg865.aspx, accessed 6/28/2012; Lincoln
National Corporation, Prospectus Supplement to Prospectus filed with SEC 3/10/2009, www.sec.gov/Archives/edgar/data/59558/000119312510211941/d424b5.htm, accessed 6/28/2012; Lincoln
National Corporation, 8-K, 9/22/2010, www.sec.gov/Archives/edgar/data/59558/000119312510214540/d8k.htm, accessed 6/28/2012; Treasury, Section 105(a) Report, 1/31/2011; Treasury,
“Treasury Announces Public Offerings of Warrants to Purchase Common Stock of Citigroup Inc.,” 1/24/2011, www.treasury.gov/press-center/press-releases/Pages/tg1033.aspx, accessed 6/28/2012;
Citigroup, Prospectus, 1/24/2011, www.sec.gov/Archives/edgar/data/831001/000095012311004665/y89177b7e424b7.htm, accessed 6/28/2012; Citigroup, Prospectus, 1/24/2011, www.sec.
gov/Archives/edgar/data/831001/000095012311004665/y89177b7e424b7.htm, accessed 6/28/2012; Boston Private Financial Holdings, Inc., Prospectus, 1/28/2011, www.sec.gov/Archives/edgar/
data/821127/000119312511021392/d424b5.htm, accessed 6/28/2012; Boston Private Financial Holdings, Inc. 8-K, 2/7/2011, www.sec.gov/Archives/edgar/data/821127/000144530511000189/
tarpwarrant020711.htm, accessed 6/28/2012; Wintrust Financial Corporation, Prospectus, 2/8/2011, www.sec.gov/Archives/edgar/data/1015328/000095012311011007/c62806b5e424b5.htm,
accessed 6/28/2012; Wintrust Financial Corporation, 8-K, 2/8/2011, www.sec.gov/Archives/edgar/data/1015328/000095012311013436/c62955e8vk.htm, accessed 6/28/2012; Treasury, Section
105(a) Report, 1/31/2011; Treasury, “Treasury Announces Public Offerings of Warrants to Purchase Common Stock of Citigroup Inc.,” 1/24/2011, www.treasury.gov/press-center/press-releases/Pages/
tg1033.aspx, accessed 6/28/2012; Treasury, Citigroup Preliminary Prospectus – CPP Warrants, 1/24/2011, www.sec.gov/Archives/edgar/data/831001/000095012311004666/y89178b7e424b7.
htm, accessed 6/28/2012; Citigroup, Preliminary Prospectus – TIP & AGP Warrants, 1/24/2011, www.sec.gov/Archives/edgar/data/831001/000095012311004665/y89177b7e424b7.htm, accessed
6/28/2012; Treasury, responses to SIGTARP data call, 4/6/2011, 7/14/2011, 10/5/2011, 10/11/2011, and 1/11/2012; Treasury Press Release, “Treasury Department Announces Public Offerings of
Warrants to Purchase Common Stock of Suntrust Banks, Inc.,” 9/21/2011, www.treasury.gov/press-center/press-releases/Pages/tg1300.aspx, accessed 6/28/2012; “Treasury Department Announces
Public Offering of Warrants to Purchase Common Stock of Associated Banc-Corp,” 11/29/2011, www.treasury.gov/press-center/press-releases/Pages/tg1372.aspx, accessed 6/28/2012.

108

special inspector general I troubled asset relief program

Private Warrant Auctions
Qualified Institutional Buyers (“QIB”):
Institutions that under U.S. securities
law are permitted to buy securities
that are exempt from registration
under investor protection laws and
to resell those securities to other
QIBs. Generally these institutions own
and invest at least $100 million in
securities, or are registered brokerdealers that own or invest at least $10
million in securities.
Accredited Investors: Individuals or
institutions that by law are considered
financially sophisticated enough so
that they can invest in ventures that
are exempt from investor protection
laws. Under U.S. securities laws, these
include many financial companies,
pension plans, wealthy individuals,
and top executives or directors of the
issuing companies.

In late 2011, Treasury devised a new method for selling warrants. On November
17, 2011, Treasury conducted its first private auction to sell warrants of CPP
participants. In the auction, Treasury sold its warrant positions in a group of 17
financial institutions listed in Table 2.27 for $12.7 million.334 Treasury stated that
a private auction was necessary because the warrants did not meet the listing
requirements for the major exchanges, it would be more cost-effective for these
smaller institutions, and that grouping the warrants of the 17 institutions in a
single auction would raise investor interest in the warrants.335 The private auction
was a discrete, or winner-takes-all, auction. The warrants were not registered under
the Securities Act of 1933 (the “Act”). As a result, Treasury stated that the warrants
were offered only in private transactions to “(1) ‘qualified institutional buyers’ as
defined in Rule 144A under the Act, (2) the issuer, and (3) a limited number of
‘accredited investors’ affiliated with the issuer.”336 Treasury did not conduct any
private warrant auctions this quarter.
Table 2.27

PRIVATE TREASURY WARRANT AUCTIONS ON 11/17/2011
Number of
Warrants Offered

Proceeds to
Treasury

Eagle Bancorp, Inc.

385,434

$2,794,422

Horizon Bancorp

212,188

1,750,551

Company

Bank of Marin Bancorp

154,908

1,703,984

First Bancorp (of North Carolina)

616,308

924,462

Westamerica Bancorporation

246,698

878,256

Lakeland Financial Corp

198,269

877,557

F.N.B. Corporation

651,042

690,100

Encore Bancshares

364,026

637,071

LCNB Corporation

217,063

602,557

Western Alliance Bancorporation

787,107

415,000

First Merchants Corporation

991,453

367,500

1st Constitution Bancorp

231,782

326,576

Middleburg Financial Corporation

104,101

301,001

MidSouth Bancorp, Inc.

104,384

206,557

CoBiz Financial Inc.

895,968

143,677

First Busey Corporation

573,833

63,677

First Community Bancshares, Inc.
Total

88,273

30,600

6,822,837

$12,713,548

Source: “Treasury Announces Completion of Private Auction to Sell Warrant Positions,” 11/18/2011, www.treasury.gov/presscenter/press-releases/Pages/tg1365.aspx, accessed 6/28/2012.

quarterly report to congress I July 25, 2012

Restructurings, Recapitalizations, Exchanges, and Sales of CPP
Investments
Certain CPP institutions continue to experience high losses and financial
difficulties, resulting in inadequate capital or liquidity. To avoid insolvency or
improve the quality of their capital, these institutions may ask Treasury to convert
its CPP preferred shares into a more junior form of equity or accept a lower
valuation, resulting in Treasury taking a discount or loss. If a CPP institution
is undercapitalized and/or in danger of becoming insolvent, it may propose to
Treasury a restructuring (or recapitalization) plan to avoid failure (or to attract
private capital) and to “attempt to preserve value” for Treasury’s investment.337
Treasury may also sell its investment in a troubled institution to a third party at
a discount in order to facilitate that party’s acquisition of a troubled institution.
Treasury has explained to SIGTARP that although it may incur partial losses on its
investment in the course of these transactions, such an outcome may be deemed
necessary to avoid the total loss of Treasury’s investment that would occur if the
institution failed.338
Under these circumstances, the CPP participant asks Treasury for a formal
review of its proposal. The proposal details the institution’s recapitalization plan
and may estimate how much capital the institution plans to raise from private
investors and whether Treasury and other preferred shareholders will convert
their preferred stock to common stock. The proposal may also involve a proposed
discount on the conversion to common stock, although Treasury would not realize
any loss until it disposes of the stock.339 In other words, Treasury would not know
whether a loss will occur, or the extent of such a loss, until it sells the common
stock it receives as part of such an exchange. According to Treasury, when it
receives such a request, it asks one of the external asset managers that it has
hired to analyze the proposal and perform due diligence on the institution.340 The
external asset manager interviews the institution’s managers, gathers non-public
information, and conducts loan-loss estimates and capital structure analysis. The
manager submits its evaluation to Treasury, which then decides whether to restructure its CPP investment.341
Table 2.28 shows all realized losses and write-offs recorded by Treasury on CPP
investments through June 30, 2012. Table 2.29 shows all restructurings, recapitalizations, exchanges, and sales of CPP investments through June 30, 2012.

Undercapitalized: Condition in which a
financial institution does not meet its
regulator’s requirements for sufficient
capital to operate under a defined level
of adverse conditions.
Due Diligence: Appropriate level of
attention or care a reasonable person
should take before entering into an
agreement or a transaction with
another party. In finance, it often refers
to the process of conducting an audit
or review of the institution before
initiating a transaction.

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special inspector general I troubled asset relief program

TABLE 2.28

Realized Losses and Write-Offs in CPP, as of 6/30/2012 ($ MILLIONS)
TARP
Investment

Realized Loss
or Write-Off

Date

FBHC Holding Company

$3

$2

3/9/2010

Sale of subordinated
debentures at a loss

First Federal Bancshares of
Arkansas, Inc.

17

11

5/3/2010

Sale of preferred stock at a loss

The Bank of Currituck

4

2

12/3/2010

Sale of preferred stock at a loss

Treaty Oak Bancorp, Inc.

3

3

2/15/2011

Sale of preferred stock at a loss

Central Pacific Financial Corp.

135

32

2/18/2011

Exchange of preferred stock at
a loss

Cadence Financial Corporation

44

6

First Community Bank Corporation
of America

11

3

5/31/2011

Sale of preferred stock at a loss

Cascade Financial Corporation

39

23

6/30/2011

Sale of preferred stock at a loss

Green Bankshares, Inc.

72

4

9/7/2011 Sale of preferred stock at a loss

Institution

Description

Realized Losses

Santa Lucia Bancorp

3/4/2011 Sale of preferred stock at a loss

4

1

10/21/2011 Sale of preferred stock at a loss

MainSource Financial Group, Inc.

57

4

4/3/2012 Sale of preferred stock at a loss

Seacoast Banking Corporation of
Florida

50

9

4/3/2012 Sale of preferred stock at a loss

Wilshire Bancorp, Inc.

62

4

4/3/2012 Sale of preferred stock at a loss

124

14

65

8

Banner Corporation/Banner Bank
First Financial Holdings Inc.
WSFS Financial Corporation

4/3/2012

Sale of preferred stock at a loss

4/3/2012 Sale of preferred stock at a loss

53

4

135

30

4/4/2012

Sale of common stock at a loss

Ameris Bancorp

52

4

6/19/2012

Sale of preferred stock at a loss

United Bancorp, Inc.

21

4

6/19/2012

Sale of preferred stock at a loss

First Capital Bancorp, Inc.

11

1

6/19/2012

Sale of preferred stock at a loss

First Defiance Financial Corp.

37

1

6/19/2012

Sale of preferred stock at a loss

LNB Bancorp, Inc.

25

3

6/19/2012

Sale of preferred stock at a loss

30

8

6/19/2012

Sale of preferred stock at a loss

105

11

6/19/2012

Sale of preferred stock at a loss

Central Pacific Financial Corp.

Farmers Capital Corporation
Taylor Capital Group, Inc.
Total CPP Realized Losses

4/3/2012 Sale of preferred stock at a loss

$192

Write-Offs
CIT Group Inc.
Pacific Coast National Bancorp
South Financial Group, Inc.

1

TIB Financial Corp1

$2,330

$2,330

4

4

347

217

9/30/2010

Sale of preferred stock at a loss

37

25

9/30/2010

Sale of preferred stock at a loss

Total CPP Write-Offs

$2,576

Total of CPP Realized Losses
and Write-offs

$2,768

12/10/2009 Bankruptcy
2/11/2010

Bankruptcy

Notes: Numbers may not total due to rounding. Losses from the second lien auction have not been realized.
1
	In the time since these transactions were classified as write-offs, Treasury has changed its practices and now classifies sales of preferred stock at a loss as
realized losses.
Sources: Treasury, Transactions Report, 6/27/2012; Treasury, response to SIGTARP data call, 7/5/2012.

quarterly report to congress I July 25, 2012

Recent Exchanges and Sales
Millennium Bancorp, Inc.

On April 3, 2009, Treasury invested $7.3 million in Millennium Bancorp, Inc.,
Edwards, Colorado (“Millennium”) through CPP in return for preferred stock
and warrants.342 On April 20, 2012, Treasury entered into an agreement with CIC
Bancshares, Inc. (“CIC”) to sell to CIC all of Treasury’s preferred stock investment
in Millennium for $2.9 million.343 The closing of the sale is subject to certain
conditions, including completion of the acquisition and merger of Millennium by
CIC. If the sale is finalized, it will result in a loss of $4.4 million.344
Treasury Sold Its TARP Investments in 14 Banks at a Loss at Auction

In two auctions this quarter, Treasury sold its TARP preferred stock investment
in 14 banks. The first auction was held from June 11 through June 13, 2012,
for seven banks.345 Treasury initially invested $280.6 million in the seven banks,
but netted only $245 million in the auction, resulting in a $35.6 million loss. On
November 21, 2008, Treasury invested $104.8 million in Taylor Capital Group,
Rosemont, Illinois (“Taylor Capital”); its shares netted $92 million at auction. On
November 21, 2008, Treasury invested $52 million in Ameris Bancorp, Moultrie,
Georgia (“Ameris”); its shares netted $48 million at auction. On December 5,
2008, Treasury invested $37 million in First Defiance Financial Corp., Defiance,
Ohio (“First Defiance”); its shares netted $35 million at auction. First Defiance
repurchased 44.8% of its shares that were offered at auction at a discounted
price.346 On January 9, 2009, Treasury invested $30 million in Farmers Capital
Bank Corporation, Frankfort, Kentucky (“Farmers Capital”); its shares netted $22
million at auction. On December 12, 2008, Treasury invested $25.2 million in
LNB Bancorp Inc., Lorain, Ohio (“LNB”); its shares netted $22 million at auction.
On April 3, 2009, Treasury invested $11 million in First Capital Bancorp, Inc.,
Glen Ellen, Virginia (“First Capital Bancorp”); its shares netted $10 million at
auction. First Capital repurchased 50% of its shares that were offered at auction
at a discounted price.347 On January 16, 2009, Treasury invested $20.6 million in
United Bancorp, Inc., Tecumseh, Michigan (“United Bancorp”); its shares netted
$17 million at auction.348
The second auction was held from June 25 through June 27, 2012, for seven
banks. Treasury initially invested $224.3 million in the seven banks, but only netted
$204 million in the auction, resulting in a $20.3 million loss.349 On December 19,
2008, Treasury invested $48.2 million in Fidelity Southern Corporation, Atlanta,
Georgia (“Fidelity Southern”); its shares netted $43 million at auction. On January
30, 2009, Treasury invested $33 million in Firstbank Corporation, Alma, Michigan
(“Firstbank”); its shares netted $31 million at auction. Firstbank repurchased
48.5% of its shares that were offered at auction at a discounted price.350 On January
23, 2009, Treasury invested $23.2 million in First Citizens Banc Corp, Sandusky,
Ohio (“First Citizens Banc”); its shares netted $21 million at auction. On January
16, 2009, Treasury invested $45 million in MetroCorp Bancshares, Inc., Houston,
Texas (“MetroCorp”); its shares netted $43 million at auction. MetroCorp repurchased 97.2% of its shares that were offered at auction at a discounted price.351 On

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special inspector general I troubled asset relief program

December 23, 2008, Treasury invested $25.1 million in Peoples Bancorp of North
Carolina, Inc., Newton, North Carolina (“Peoples Bancorp of NC”); its shares
netted $23 million at auction. Peoples Bancorp of NC repurchased 53.5% of its
shares that were offered at auction at a discounted price.352 On January 16, 2009,
Treasury invested $32.5 million in Pulaski Financial Corp, Creve Coeur, Missouri
(“Pulaski”); its shares netted $28 million at auction. On February 27, 2009,
Treasury invested $17.3 million in Southern First Bancshares, Inc., Greenville,
South Carolina (“Southern First”); its shares netted $15 million at auction.353
Southern First repurchased 5.8% of its shares that were offered at auction at a
discounted price.354

113

quarterly report to congress I July 25, 2012

TABLE 2.29

TREASURY RESTRUCTURINGS, RECAPITALIZATIONS, EXCHANGES, & SALES, AS OF 6/30/2012
Company

Investment
Date

Original
Investments

Combined
Investments

($ MILLIONS)

Investment Status

Citigroup Inc.

10/28/2008

$2,500.0

Provident Bankshares

11/14/2008

151.5

M&T Bank Corporation

12/23/2008

600.0

Wilmington Trust Corporation

12/12/2008

330.0

12/5/2008

935.0

Exchanged for trust preferred securities

Popular, Inc.
First BanCorp

Exchanged for common stock/warrants and sold
1,081.5a

Provident preferred stock exchanged for new M&T Bank
Corporation preferred stock; Wilmington Trust preferred stock
redeemed by M&T Bank Corporation

1/6/2009

400.0

Exchanged for mandatorily convertible preferred stock

South Financial Group, Inc.

12/5/2008

347.0

Sold

Sterling Financial Corporation

12/5/2008

303.0

Exchanged for common stock

Whitney Holding Corporation

6/3/2011

300.0

Sold

Pacific Capital Bancorp

11/21/2008

180.6

Exchanged for common stock

Wilmington Trust Corporation

5/13/2011

151.5

Sold

Central Pacific Financial Corp.

1/9/2009

135.0

Exchanged for common stock

Banner Corporation

11/21/2008

124.0

Sold at loss in auction

BBCN Bancorp, Inc.

11/21/2008

67.0

Center Financial Corporation

12/12/2008

55.0

2/20/2009

116.0

Exchanged for trust preferred securities and preferred stock
Sold at loss in auction

First Merchants
Taylor Capital Group

122.0d

Exchanged for a like amount of securities of
BBCN Bancorp, Inc.

11/21/2008

104.8

Metropolitan Bank Group Inc.

6/26/2009

71.5

NC Bank Group, Inc.

6/26/2009

6.9

Hampton Roads Bankshares

12/31/2008

80.3

Exchanged for common stock

Green Bankshares

12/23/2008

72.3

Sold

Independent Bank Corporation

12/12/2008

72.0

Exchanged for mandatorily convertible preferred stock

12/5/2008

69.0

Exchanged for trust preferred securities

Superior Bancorp, Inc.c
First Financial Holdings Inc.

81.9b

Exchanged for new preferred stock in
Metropolitan Bank Group, Inc.

12/5/2008

65.0

Sold at loss in auction

12/12/2008

62.2

Sold at loss in auction

MainSource Financial Group, Inc.

1/16/2009

57.0

Sold at loss in auction

WSFS Financial Corporation

1/23/2009

52.6

Sold at loss in auction

Ameris Bancorp

11/21/2008

52.0

Sold at loss in auction

Seacoast Banking Corporation of
Florida

12/19/2008

50.0

Sold at loss in auction

Fidelity Southern Corporation

12/19/2008

48.2

Sold at loss in auction

MetroCorp Bancshares, Inc.

1/16/2009

45.0

Sold at loss in auction

Wilshire Bancorp, Inc.

Cadence Financial Corporation

1/9/2009

44.0

Sold at loss in auction

12/12/2008

41.3

Sold

Cascade Financial Corporation

6/30/2011

39.0

Sold at loss in auction

TIB Financial Corp.

12/5/2008

37.0

Sold

Capital Bank Corporation

Continued on next page

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special inspector general I troubled asset relief program

TREASURY RESTRUCTURINGS, RECAPITALIZATIONS, EXCHANGES, & SALES, AS OF 6/30/2012
Company

Investment
Date

Original
Investments

First Defiance Financial Corp.

12/5/2008

$37.0

Sold at loss in auction

Firstbank Corporation

1/30/2009

33.0

Sold at loss in auction

Pulaski Financial Corp

1/16/2009

32.5

Sold at loss in auction

1/9/2009

30.0

Sold at loss in auction

LNB Bancorp Inc.

12/12/2008

25.2

Sold at loss in auction

Peoples Bancorp of North Carolina,
Inc.

12/23/2008

25.1

Sold at loss in auction

First Citizens Banc Corp

1/23/2009

23.2

Sold at loss in auction

United Bancorp, Inc.

1/16/2009

20.6

Sold at loss in auction

Southern First Bancshares, Inc.

2/27/2009

17.3

Sold at loss in auction

5/3/2011

16.5

Sold

11/14/2008

15.0

Exchanged for common stock

4/3/2009

11.0

Sold at loss in auction

12/23/2008

10.7

Sold

Farmers Capital Bank Corporation

First Federal Bankshares of
Arkansas, Inc.
Broadway Financial Corporation
First Capital Bancorp, Inc.
First Community Bank Corporation
of America
Bank of Currituck

Combined
Investments

($ MILLIONS) (Continued)

Investment Status

2/6/2009

4.0

Sold

12/19/2008

4.0

Sold

Treaty Oak Bancorp, Inc.

1/16/2009

3.3

Sold

FBHC Holding Company

12/29/2009

3.0

Sold

Fidelity Resources Company

6/26/2009

3.0

Exchanged for preferred stock in Veritex Holding

Berkshire Bancorp

6/12/2009

2.9

Exchanged for preferred stock in Customers Bancorp

Santa Lucia Bancorp

Notes: Numbers may be affected by rounding.
a
	M&T Bank Corporation (“M&T”) has redeemed the entirety of the preferred shares issued by Wilmington Trust Corporation plus accrued dividends. In addition, M&T has also repaid $370 million of
Treasury’s original $600 million investment. As of June 30, 2012, Treasury’s remaining principal investment in M&T is $381.5 million.
b
	The new investment amount of $81.9 million includes the original investment amount in Metropolitan Bank Group, Inc. or $71.5 million plus the original investment amount in NC Bank Group, Inc. or
$6.9 million plus unpaid dividends of $3.5 million.
c
	The subsidiary bank of Superior Bancorp, Inc. failed on April 15, 2011. All of Treasury’s TARP investment in Superior Bancorp is expected to be lost.
d
	The new investment amount of $122 million includes the original investment amount in BBCN Bancorp, Inc. (formerly Nara Bancorp, Inc.) of $67 million and the original investment of Center Financial
Corporation of $55 million.
Sources: Treasury, Transactions Report, 6/27/2012; Treasury responses to SIGTARP data call, 10/11/2011, 4/5/2012, 7/5/2012; SIGTARP, October Quarterly Report, 10/26/2010; Treasury,
Section 105(a) Report, 9/30/2010; Treasury Press Release, “Taxpayers Receive $10.5 Billion in Proceeds Today from Final Sale of Treasury Department Citigroup Common Stock,” 12/10/2010;
Treasury Press Release, “Treasury Announces Pricing of Citigroup Common Stock Offering,” 12/7/2010; Treasury, Section 105(a) Report, 7/10/2012; Treasury Press Release, “Treasury Announces
Intent to Sell Warrant Positions in Public Dutch Auctions,” 1/14/2011; Broadway Financial Corporation, 8-K, 2/17/2011, www.sec.gov/Archives/edgar/data/1001171/000119312511039152/
d8k.htm, accessed 6/28/2012; FDIC and Texas Department of Banking, In the Matter of Treaty Oak Bank, Consent Order, 2/5/2010, www.fdic.gov/bank/individual/enforcement/2010-02-34.pdf,
accessed 6/28/2012; Fort Worth Business Press, “Shareholders Approve Sale of Treaty Bank to Fort Worth Investors,” www.timesleader.com/FwBp/news/breaking/Shareholders-approve-sale-ofTreaty-Oak-bank-to-Fort-Worth-investors.html, accessed 6/28/2012; Central Pacific Financial Corp., 8-K, 11/4/2010, www.sec.gov/Archives/edgar/data/701347/000070134710000055/form8-k.
htm, accessed 6/28/2012; Central Pacific Financial Corp., 8-K, 2/17/2011, www.sec.gov/Archives/edgar/data/701347/000110465911008879/a11-6350_18k.htm, accessed 6/28/2012;
Central Pacific Financial Corp., 8-K, 2/22/2011, www.sec.gov/Archives/edgar/data/701347/000110465911008879/a11-6350_18k.htm, accessed 7/5/2012; Scottrade, Central Pacific
Financial Corp., 2/18/2011, research.scottrade.com/qnr/Public/Stocks/Snapshot?symbol=cpf, accessed 6/28/2012; Cadence Financial Corporation, 8-K, 3/4/2011, www.sec.gov/Archives/
edgar/data/742054/000089882211000148/kbody.htm, accessed 6/28/2012; M&T Bank Corporation, 10-K, 2/19/2010, www.sec.gov/Archives/edgar/data/36270/000095012310014582/
l38289e10vk.htm, accessed 6/28/2012; Green Bankshares Inc., 9/8/2011, www.sec.gov/Archives/edgar/data/764402/000089882211000784/grnb-nafhmerger8k.htm, accessed 6/28/2012;
Customers Bancorp, Inc., 8-K, 9/22/2011, www.sec.gov/Archives/edgar/data/1488813/000095015911000609/form8k.htm, accessed 6/28/2012; Santa Lucia Bancorp, 8-K, 10/6/2011,
www.sec.gov/Archives/edgar/data/1355607/000114420411057585/v237144_8k.htm, accessed 6/28/2012; BBCN Bancorp, Inc., 8-K, 11/30/2011, www.sec.gov/Archives/edgar/
data/1128361/000119312511330628/d265748d8k.htm, accessed 6/28/2012.

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quarterly report to congress I July 25, 2012

CPP Recipients: Bankrupt or with Failed Subsidiary Banks
Despite Treasury’s stated goal of limiting CPP investments to “healthy, viable
institutions,” a number of CPP participants went bankrupt or had a subsidiary bank
fail, as indicated in Table 2.30.355
TABLE 2.30

CPP RECIPIENTS: BANKRUPT OR WITH FAILED SUBSIDIARY BANKS, AS OF 6/30/2012

($ MILLIONS)

Company

Initial
Invested
Amount

Investment
Date

CIT Group Inc., New York, NY

$2,330.0

12/31/2008

298.7

11/14/2008

In bankruptcy; subsidiary bank failed

11/6/2009

4.1

1/16/2009

Bankruptcy proceedings completed
with no recovery of Treasury’s
investment; subsidiary bank failed

11/13/2009

89.4b

12/5/2008

In bankruptcy; subsidiary bank failed

5/14/2010

8.7

2/20/2009

Subsidiary bank failed

8/20/2010

6.8

1/23/2009

Subsidiary bank failed

11/5/2010

3.8

4/17/2009

Failed

11/12/2010

5.5

1/30/2009

Subsidiary bank failed

3/11/2011

69.0

12/5/2008

Subsidiary bank failed

4/15/2011

83.6

2/27/2009

Subsidiary bank failed

7/29/2011

5.5

5/8/2009

Failed

7/15/2011

5.8

12/5/2008

Subsidiary bank failed

7/15/2011

10.4

12/23/2008

Subsidiary bank failed

9/23/2011

4.1

5/29/2009

Subsidiary bank failed

10/14/2011

30.0

12/19/2008

Subsidiary bank failed

1/27/2012

UCBH Holdings Inc.,
San Francisco, CA
Pacific Coast National Bancorp,
San Clemente, CA
Midwest Banc Holdings, Inc.,
Melrose Park, IL
Sonoma Valley Bancorp,
Sonoma, CA
Pierce County Bancorp,
Tacoma, WA
Tifton Banking Company,
Tifton, GA
Legacy Bancorp, Inc.,
Milwaukee, WI
Superior Bancorp, Inc.,
Birmingham, AL
Integra Bank Corporation,
Evansville, IN
One Georgia Bank, Atlanta, GA
FPB Bancorp,
Port Saint Lucie, FL
Citizens Bancorp,
Nevada City, CA
CB Holding Corp.,
Aledo, IL
Tennessee Commerce Bancorp, Inc.,
Franklin, TN

Status
Bankruptcy proceedings completed
with no recovery of Treasury’s
investment; subsidiary bank remains
active

Bankruptcy/
Failure Datea
11/1/2009

Subsidiary Bank
CIT Bank
Salt Lake City, UT
United Commercial
Bank, San Francisco, CA
Pacific Coast
National Bank
San Clemente, CA
Midwest Bank and
Trust Company,
Elmwood Park, IL
Sonoma Valley Bank
Sonoma, CA
Pierce Commercial Bank
Tacoma, WA
N/A
Legacy Bank
Milwaukee, WI
Superior Bank
Birmingham, AL
Integra Bank
Evansville, IN
N/A
First Peoples Bank
Port Saint Lucie, FL
Citizens Bank of
Northern California
Nevada City, CA
Country Bank,
Aledo, IL
Tennessee Commerce
Bank, Franklin, TN
Continued on next page

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special inspector general I troubled asset relief program

CPP RECIPIENTS: BANKRUPT OR WITH FAILED SUBSIDIARY BANKS, AS OF 6/30/2012
Company
Blue River Bancshares, Inc.,
Shelbyville, IN
Fort Lee Federal Savings Bank
Total

($ MILLIONS) (Continued)

Initial
Invested
Amount

Investment
Date

Status

Bankruptcy/
Failure Datea

$5.0

3/6/2009

Subsidiary bank failed

2/10/2012

1.3

5/22/2009

Failed

4/20/2012

Subsidiary Bank
SCB Bank,
Shelbyville, IN
N/A

$2,961.7

Notes: Numbers may not total due to rounding.
a
	Date is the earlier of the bankruptcy filing by holding company or the failure of subsidiary bank.
b
	The amount of Treasury’s investment prior to bankruptcy was $89,874,000. On 3/8/2010, Treasury exchanged its $84,784,000 of preferred stock in Midwest Banc Holdings, Inc. (MBHI) for
$89,388,000 of MCP, which is equivalent to the initial investment amount of $84,784,000, plus $4,604,000 of capitalized previously accrued and unpaid dividends.
Sources: Treasury, Transactions Report, 6/27/2012; Treasury, response to SIGTARP data call, 7/5/2012; FDIC, “Failed Bank List,” no date, www.fdic.gov/bank/individual/failed/banklist.html, accessed
6/28/2012; FDIC, “Institution Directory,” no date, www2.fdic.gov/idasp/main.asp, accessed 6/28/2012; CIT, “CIT Board of Directors Approves Proceeding with Prepackaged Plan of Reorganization with
Overwhelming Support of Debt holders,” 11/1/2009, news.cit.com/portal/site/cit/index.jsp?ndmViewId=news_view&newsId=20091101005053&newsLang=en, accessed 6/28/2012; Pacific Coast
National Bancorp, 8-K, 12/17/2009, www.sec.gov/Archives/edgar/data/1302502/000092708909000240/pcnb-8k122209.htm, accessed 6/28/2012; Sonoma Valley Bancorp, 8-K, 8/20/2010,
www.sec.gov/Archives/edgar/data/1120427/000112042710000040/form8k_receivership.htm, accessed 6/28/2012; Midwest Banc Holdings, Inc., 8-K, 8/20/2010, www.sec.gov/Archives/edgar/
data/1051379/000095012310081020/c60029e8vk.htm, accessed 6/28/2012; UCBH Holdings, Inc., 8-K, 11/6/2009, www.sec.gov/Archives/edgar/data/1061580/000095012309062531/
f54084e8vk.htm, accessed 6/28/2012; FDIC Press Release, “Heritage Bank, Olympia, Washington, Assumes All of the Deposits of Pierce Commercial Bank, Tacoma, Washington,” 11/5/2010, www.
fdic.gov/news/news/press/2010/pr10244.html, accessed 6/28/2012; FDIC Press Release, “Ameris Bank, Moultrie, Georgia, Acquires All of the Deposits of Two Georgia Institutions,” 11/12/2010,
www.fdic.gov/news/news/press/2010/pr10249.html, accessed 6/28/2012; Federal Reserve Board Press Release, 5/10/2010, www.federalreserve.gov/newsevents/press/enforcement/20100510b.
htm, accessed 6/28/2012; Board of Governors of the Federal Reserve System, Written Agreement by and among Legacy Bancorp, Inc., Legacy Bank, Federal Reserve Bank of Chicago, and State of
Wisconsin Department of Financial Institutions, Madison, Wisconsin, www.federalreserve.gov/newsevents/press/enforcement/enf20100505b1.pdf, accessed 6/28/2012; FDIC Press Release, “Seaway
Bank and Trust Company, Chicago, Illinois Assumes All of the Deposits of Legacy Bank, Milwaukee, Wisconsin,” 3/11/2011, www.fdic.gov/news/news/press/2011/pr11055.html, accessed 6/28/2012;
FDIC Press Release, “Superior Bank, N.A., Birmingham, Alabama, Assumes All of the Deposits of Superior Bank, Birmingham, Alabama,” 4/15/2011, www.fdic.gov/news/news/press/2011/pr11073.
html, accessed 6/28/2012; FDIC Press Release, “Old National Bank, Evansville, Indiana, Assumes All of the Deposits of Integra Bank, National Association, Evansville, Indiana,” 7/29/2011, www.fdic.gov/
news/news/press/2011/pr11128.html, accessed 6/28/2012; FDIC Press Release, “Old National Bank, Evansville, Indiana, Assumes All of the Deposits of Integra Bank, National Association, Evansville,
Indiana,” 7/29/2011, www.fdic.gov/news/news/press/2011/pr11128.html, accessed 6/28/2012; FDIC Press Release, “Ameris Bank, Moultrie, Georgia, Acquires All the Deposits of Two Georgia
Institutions,” 7/15/2011, www.fdic.gov/news/news/press/2011/pr11120.html, accessed 6/28/2012; FDIC Press Release, “Premier American Bank, National Association, Miami, Florida, Assumes All of
the Deposits of First Peoples Bank, Port Saint Lucie, Florida,” 7/15/2011, www.fdic.gov/news/news/press/2011/pr11121.html, accessed 6/28/2012; FDIC Press Release, “Tri Counties Bank, Chico,
California, Assumes All of the Deposits of Citizens Bank of Northern California, Nevada City, California,” 9/23/2011, www.fdic.gov/news/news/press/2011/pr11154.html, accessed 6/28/2012; FDIC
Press Release, “Tri Counties Bank, Chico, California, Assumes All of the Deposits of Citizens Bank of Northern California, Nevada City, California,” 9/23/2011, www.fdic.gov/news/news/press/2011/
pr11154.html, accessed 6/28/2012; FDIC Press Release, “Old National Bank, Evansville, Indiana, Assumes All of the Deposits of Integra Bank, National Association, Evansville, Indiana,” 7/29/2011, www.
fdic.gov/news/news/press/2011/pr11128.html, accessed 6/28/2012; FDIC Press Release, “Ameris Bank, Moultrie, Georgia, Acquires All the Deposits of Two Georgia Institutions,” 7/15/2011, www.
fdic.gov/news/news/press/2011/pr11120.html, accessed 6/28/2012; FDIC, In the Matter of First Peoples Bank, Docket No. FDIC-09-717b, Consent Order, 3/18/2010, www.fdic.gov/bank/individual/
enforcement/2010-03-09.pdf, accessed 6/28/2012; FDIC, In the Matter of Citizens Bank of Northern California, Nevada City, California, Order No. FDIC-11-358PCAS, Supervisory Prompt Corrective Action
Directive, 6/28/2011, www.fdic.gov/bank/individual/enforcement/2011-06-029.pdf, accessed 6/28/2012 ; “Blackhawk Bank & Trust, Milan, Illinois, Assumes All of the Deposits of Country Bank, Aledo,
Illinois” 10/14/2011, www.fdic.gov/news/news/press/2011/pr11167.html, accessed 6/28/2012 ; FDIC Press Release, “Republic Bank & Trust Company, Assumes all of the Deposits of Tennessee
Commerce Bank, Franklin, Tennessee,” 1/27/2012, www.fdic.gov/news/news/press/2012/pr12011.html, accessed 7/10/2012; FDIC Press Release ,“First Merchants Bank, National Association,
Muncie, Indiana, Assumes All of the Deposits of SCB Bank, Shelbyville, Indiana,” 2/10/2012, www.fdic.gov/news/news/press/2012/pr12018.html, accessed 6/28/2012; FDIC Press Release, “Alma
Bank, Astoria, New York, Assumes All of the Deposits of Fort Lee Federal Savings Bank, FSB, Fort Lee, New Jersey,” www.fdic.gov/news/news/press/2012/pr12043.html, accessed 7/5/2012.

quarterly report to congress I July 25, 2012

Closure of Fort Lee Federal Savings Bank

On May 22, 2009, Treasury invested $1.3 million in Fort Lee Federal Savings
Bank, Fort Lee, New Jersey (“Fort Lee”) through CPP in return for preferred stock
and warrants.356 On April 20, 2012, the Office of the Comptroller of the Currency
(“OCC”) closed Fort Lee and named the Federal Deposit Insurance Corporation
(“FDIC”) as receiver.357 FDIC entered into a purchase and assumption agreement
with Alma Bank, Astoria, New York, to assume all of Fort Lee’s deposits. FDIC
estimates that the cost of Fort Lee’s failure to the deposit insurance fund will be
$14 million. All of Treasury’s investment in Fort Lee is expected to be lost.358

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Community Development Capital Initiative

Community Development Financial
Institutions (“CDFIs”): Financial
institutions eligible for Treasury funding
to serve urban and rural low-income
communities through the CDFI Fund.
CDFIs were created in 1994 by the
Riegle Community Development and
Regulatory Improvement Act. These
entities must be certified by Treasury;
certification confirms they target at
least 60% of their lending and other
economic development activities
to areas underserved by traditional
financial institutions.
Risk-Weighted Assets: Risk-based
measure of total assets held by
a financial institution. Assets are
assigned broad risk categories. The
amount in each risk category is then
multiplied by a risk factor associated
with that category. The sum of the
resulting weighted values from each of
the risk categories is the bank’s total
risk-weighted assets.
Subchapter S Corporations (“S
corporations”): Corporate form that
passes corporate income, losses,
deductions, and credit through to
shareholders for Federal tax purposes.
Shareholders of S corporations report
the flow-through of income and losses
on their personal tax returns and are
taxed at their individual income tax
rates.

The Administration announced the Community Development Capital Initiative
(“CDCI”) on October 21, 2009. According to Treasury, it was intended to help
small businesses obtain credit.359 Under CDCI, TARP made $570.1 million in
investments in the preferred stock or subordinated debt of 84 eligible banks, bank
holding companies, thrifts, and credit unions certified as Community Development
Financial Institutions (“CDFIs”) by Treasury. According to Treasury, these lowercost capital investments were intended to strengthen the capital base of CDFIs
and enable them to make more loans in low and moderate-income communities.360
CDCI was open to certified, qualifying CDFIs or financial institutions that applied
for CDFI status by April 30, 2010.361
According to Treasury, CPP-participating CDFIs that were in good standing
could exchange their CPP investments for CDCI investments.362 CDCI closed to
new investments on September 30, 2010.363
As of June 30, 2012, 82 institutions remain in CDCI. One institution repaid
the Government this quarter and one institution previously had its subsidiary bank
fail.364
Terms for Senior Securities and Dividends

An eligible bank, bank holding company, or thrift could apply to receive capital in
an amount up to 5% of its risk-weighted assets. A credit union (which is a memberowned, nonprofit financial institution with a capital and governance structure
different from that of for-profit banks) could apply for Government funding of
up to 3.5% of its total assets — roughly equivalent to the 5% of risk-weighted
assets for banks.365 Participating credit unions and subchapter S corporations
(“S corporations”) issued subordinated debt to Treasury in lieu of the preferred
stock issued by other CDFI participants.366 Many CDFI investments have an
initial dividend rate of 2%, which increases to 9% after eight years. Participating
S corporations pay an initial rate of 3.1%, which increases to 13.8% after eight
years.367 A CDFI participating in CPP had the opportunity to request to convert
those shares into CDCI shares, thereby reducing the annual dividend rate it pays
the Government from 5% to as low as 2%.368 According to Treasury, CDFIs were
not required to issue warrants because of the de minimis exception in EESA, which
grants Treasury the authority to waive the warrant requirement for qualifying
institutions in which Treasury invested $100 million or less.
If during the application process a CDFI’s primary regulator deemed it to be undercapitalized or to have “quality of capital issues,” the CDFI had the opportunity
to raise private capital to achieve adequate capital levels. Treasury would match the
private capital raised on a dollar-for-dollar basis, up to a total of 5% of the financial
institution’s risk-weighted assets. In such cases, private investors had to agree to
assume any losses before Treasury.369
CDCI Investment Update

Treasury invested $570.1 million in 84 institutions under the program — 36 banks
or bank holding companies and 48 credit unions.370 Of the 36 investments in banks

quarterly report to congress I July 25, 2012

and bank holding companies, 28 were conversions from CPP (representing $363.3
million of the total $570.1 million); the remaining eight were not CPP participants.
Treasury provided an additional $100.7 million in CDCI funds to 10 of the banks
converting CPP investments. Only $106 million of the total CDCI funds went
to institutions that were not in CPP. As of June 30, 2012, Treasury had received
approximately $19.2 million in dividends and interest from CDCI recipients.371
Only one CDCI participant had repaid TARP as of June 30, 2012. Greater Kinston
Credit Union, Kinston, North Carolina (“Greater Kinston”) repurchased its shares
at par on April 10, 2012, for $350,000.372 As of June 30, 2012, four institutions
(Community Bank of the Bay, First American International Corporation, First
Vernon Bancshares, Inc., and PGB Holdings, Inc.) had unpaid dividend or interest
payments to Treasury totaling $707,650.373 A list of all CDCI investments is
included in Appendix D: “Transaction Detail.”

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Systemically Significant Failing Institutions Program

For more information on AIG and how
the company has changed under TARP,
see Section 3, “AIG Remains in TARP
as the Largest TARP Investment.”

Revolving Credit Facility: Line of
credit for which borrowers pay a
commitment fee, allowing them to
repeatedly draw down funds up to a
guaranteed maximum amount. The
amount of available credit decreases
and increases as funds are borrowed
and then repaid.
Credit Default Swap (“CDS”): A contract
where the seller receives payments
from the buyer in return for agreeing to
pay the buyer when a particular credit
event occurs, such as when the credit
rating on a bond is downgraded or a
loan goes into default. The buyer does
not need to own the asset covered by
the contract, meaning the swap can
serve essentially as a bet against the
underlying bond or loan.

According to Treasury, the Systemically Significant Failing Institutions (“SSFI”)
program was established to “provide stability and prevent disruptions to financial
markets from the failure of a systemically significant institution.”374 Through
SSFI, between November 2008 and April 2009, Treasury invested $67.8 billion
in TARP funds in American International Group, Inc. (“AIG”), the program’s sole
participant.375 As of June 30, 2012, taxpayers were still owed more than half of the
original TARP investment. Taxpayers are owed $36 billion of the $67.8 billion.376
According to Treasury’s TARP books and records, taxpayers have realized losses on
the TARP investment from an accounting standpoint of $5.5 billion on Treasury’s
sale of AIG stock.377 However, given the January 2011 restructuring of the Federal
Reserve Bank of New York (“FRBNY”) and Treasury investment, according to
Treasury, the Government overall has made a gain thus far on the stock sales.378
According to Treasury, this leaves $30.4 billion in TARP funds outstanding.379 In
return for that investment, Treasury holds 61% of AIG’s common stock (1.06 billion
shares).380
The Government’s rescue of AIG involved several different funding facilities
provided by FRBNY and Treasury, with various changes to the transactions over
time. The rescue of AIG was initially led by FRBNY and the Board of Governors of
the Federal Reserve System (“Federal Reserve”). Prior to Treasury’s investment in
AIG, FRBNY extended an $85 billion revolving credit facility to AIG in September
2008. With the passage of EESA on October 3, 2008, Treasury, through SSFI, took
on a greater role in AIG’s bailout as the Government expanded and later restructured its aid.
The amount and types of Treasury’s outstanding AIG investments have changed
over time as a result of the execution of AIG’s January 2011 Recapitalization Plan
(discussed in greater detail in this section, which resulted in the termination of
FRBNY’s revolving credit facility, the transfer of FRBNY’s preferred SPV interests
to Treasury, and the conversion of preferred shares into common stock), preferred
equity interest repayments, and Treasury’s sale of common stock. These various
investments, as well as their stages and restructurings, are described below.
Treasury’s preferred equity interests have been fully retired.381

FRBNY Revolving Credit Facility
In September 2008, FRBNY extended an $85 billion revolving credit facility to
AIG, which was secured by AIG’s assets, in an effort to stabilize the company. In
return, AIG committed 79.8% of its voting equity to a trust for the sole benefit of
the United States Treasury (the “AIG Trust”).382 While the $85 billion revolving
credit facility was necessary to address the company’s severe liquidity shortage
resulting from collateral calls related to the company’s credit default swap (“CDS”)
business and securities lending activities, because the entire facility was drawn
upon, AIG’s leverage ratios increased significantly. The rapid deterioration in
AIG’s CDS and securities lending businesses, combined with this increased
leverage, put downward pressure on its credit rating.383 Federal officials feared
that future downgrades in AIG’s credit rating could have “catastrophic” effects on

quarterly report to congress I July 25, 2012

the company, forcing it into bankruptcy.384 FRBNY and Treasury determined that
this possibility posed a threat to the nation’s financial system and decided that
additional transactions were necessary to modify the revolving credit facility.385

Restructurings of AIG Assistance
In November 2008 and March 2009, FRBNY and Treasury took several actions to
stabilize AIG’s operations.386
Initial TARP Investment

First, on November 25, 2008, Treasury purchased $40 billion in AIG preferred
shares under TARP, the proceeds of which went directly to FRBNY to pay down
a portion of the outstanding balance of the existing revolving credit facility. In
return, Treasury received AIG Series D cumulative preferred stock and warrants
to purchase AIG common stock.387 After that payment, the total amount available
to AIG under FRBNY’s revolving credit facility was reduced from $85 billion to
$60 billion.
Creation of Maiden Lane II & III

Second, also in November 2008, FRBNY created Maiden Lane II, a special
purpose vehicle (“SPV”), to take significant mortgage-backed securities off AIG’s
books. FRBNY lent $19.5 billion to Maiden Lane II to fund the purchase of
residential mortgage-backed securities (“RMBS”) associated with AIG’s securities
lending program. This RMBS was in the securities-lending portfolios of several of
AIG’s U.S.-regulated insurance subsidiaries.
Finally, also in November 2008, FRBNY created Maiden Lane III, another
SPV, to which FRBNY lent $24.3 billion to buy from AIG’s counterparties some of
the collateralized debt obligations (“CDOs”) underlying the CDS contracts written
by AIG.
Second TARP Investment

On March 2, 2009, Treasury and FRBNY announced a restructuring of Government assistance to AIG that, according to Treasury, was designed to strengthen the
company’s capital position.388 These measures included the conversion of Treasury’s
first TARP investment and Treasury’s commitment to fund a second TARP investment in AIG.
On April 17, 2009, AIG and Treasury signed a securities exchange agreement
under which Treasury exchanged the Series D cumulative preferred stock, which
required AIG to make quarterly dividend and interest payments, for $41.6 billion (including $1.6 billion in missed dividend payments) of less valuable Series E
non-cumulative preferred stock, which required AIG to make dividend and interest payments only if AIG’s board of directors declared a dividend. Additionally, on
April 17, 2009, Treasury committed to fund an equity capital facility under which
AIG could draw down up to $29.8 billion in exchange for Series F non-cumulative
preferred stock (that had similar terms to the Series E) and additional warrants, of
which AIG drew down $27.8 billion.389

Cumulative Preferred Stock: Stock
requiring a defined dividend payment. If
the company does not pay the dividend
on schedule, it still owes the missed
dividend to the stock’s owner.
Special Purpose Vehicle (“SPV”):
A legal entity, often off-balancesheet, that holds transferred assets
presumptively beyond the reach of the
entities providing the assets, and that
is legally isolated from its sponsor or
parent company.
Collateralized Debt Obligation (“CDO”):
A security that entitles the purchaser
to some part of the cash flows from a
portfolio of assets such as mortgagebacked securities, bonds, loans, or
other CDOs.
Non-Cumulative Preferred Stock:
Preferred stock with a defined
dividend, without the obligation to pay
missed dividends.
Equity Capital Facility: Commitment
to invest equity capital in a firm
under certain future conditions. An
equity facility when drawn down is
an investment that increases the
provider’s ownership stake in the
company. The investor may be able to
recover the amount invested by selling
its ownership stake to other investors
at a later date.

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Creation of Additional Special Purpose Vehicles and Sale of Assets Under SPVs

For a more detailed description of the
disposition of Treasury’s interest in
the SPVs, see SIGTARP’s April 2012
Quarterly Report, pages 112-113.

The March 2009 restructuring measures also included an authorization for FRBNY
to acquire up to $26 billion of preferred equity interests in two SPVs, AIA Aurora
LLC (“AIA SPV”) and ALICO Holdings LLC (“ALICO SPV”). The creation of the
SPVs also facilitated the independence of these two subsidiaries in anticipation of a
sale or initial public offering (“IPO”).390 Treasury received payments for its interest
in the SPVs and no longer holds an investment in the two SPVs.
Under the transaction’s original terms, with limited exceptions, all proceeds
from the voluntary sale, public offering, or other liquidation of the assets or businesses held by the SPVs had to be used first to fully redeem FRBNY’s interests in
the SPVs and then to reduce the outstanding principal balance of AIG’s revolving
credit facility. On December 1, 2009, FRBNY received $16 billion in preferred
equity interests in the AIA SPV and $9 billion in the ALICO SPV.391 AIG later completed an IPO of 8.1 billion shares of AIA Group Limited and a sale of 1.72 billion
shares of AIA and applied the $26.5 billion in total proceeds to amounts owed to
FRBNY and Treasury.392
On November 1, 2010, AIG sold ALICO to MetLife, Inc., for $16.2 billion,
$7.2 billion of which was paid in cash and $9 billion in equity interests in MetLife.
These equity interests were initially held in the ALICO SPV and were sold on
March 8, 2011, for $9.6 billion.393

TARP Dividend Payments
When AIG failed to pay dividends for four consecutive quarters on the Series E
preferred stock, this gave Treasury the right to appoint to AIG’s board the greater
of either two directors or a number (rounded upward) of directors equal to 20% of
all AIG directors.394 On April 1, 2010, Treasury appointed Donald H. Layton and
Ronald A. Rittenmeyer as directors of AIG.395 On May 10, 2012, AIG announced
that, due to his appointment as chief executive officer of the Federal Home Loan
Mortgage Corporation (“Freddie Mac”), Layton had submitted his resignation as
an AIG director.396 On July 11, 2012, a retired AIG director, Morris W. Offit, was
reelected to the board.397

For a more detailed description of
the AIG Recapitalization Plan, see
SIGTARP’s January 2011 Quarterly
Report, pages 135-139.

AIG Recapitalization Plan
On January 14, 2011, AIG executed its Recapitalization Plan with the Government, which resulted in extinguishing FRBNY’s revolving credit facility, retiring
FRBNY’s remaining interests in the SPVs and transferring those interests to
Treasury, and increasing Treasury’s TARP investment in AIG. AIG repaid $20.7
billion owed to FRBNY’s revolving credit facility with proceeds from the AIA IPO
and ALICO sale. AIG drew down $20.3 billion in TARP funds under a Series F
equity capital facility to purchase certain of FRBNY’s interests in the ALICO SPV
and AIA SPV and transferred those interests to Treasury. AIG exchanged all prior
outstanding preferred shares held by the Government and issued new common
stock to Treasury representing a 92.1% interest in AIG. Treasury also created a
new $2 billion Series G equity capital facility, which was never drawn down.398

quarterly report to congress I July 25, 2012

For the period November 25, 2008, to January 14, 2011, AIG had failed to pay
a total of $7.9 billion in dividend payments.399 After the Recapitalization Plan was
executed, AIG no longer had an obligation to pay dividends.

Treasury’s Equity Ownership Interest in AIG
As part of the Recapitalization Plan, AIG extinguished all prior outstanding
preferred shares held by the Government, comprising $41.6 billion of Series E
preferred shares and $7.5 billion drawn from the Series F equity capital facility.
In exchange, it issued 1.655 billion shares of common stock (which included 563
million Series C shares held by the AIG Trust for the benefit of the U.S. Treasury),
representing 92.1% of the common stock of AIG.400 The AIG Trust was then
terminated. AIG issued 10-year warrants to its existing non-Government common
shareholders to purchase up to a cumulative total of 75 million shares of common
stock at a strike price of $45 per share.401
On May 27, 2011, Treasury sold 200 million shares of AIG common stock for
$29.00 per share.402 The total proceeds to Treasury from the sale were $5.8 billion.
In addition, the undrawn Series G equity capital facility was terminated and AIG
cancelled all Series G preferred stock.403 On March 8, 2012, Treasury sold approximately 206.9 million shares of AIG common stock for $29.00 per share.404 The
total proceeds to Treasury from the sale were $6 billion. On May 6, 2012, Treasury
sold approximately 188.5 million shares of AIG’s common stock for $30.50 per
share, for $5.8 billion in proceeds (including 24.6 million shares sold pursuant to
the exercise in full of the underwriters’ over-allotment option).405 As of June 30,
2012, Treasury owned 1.06 billion shares of AIG’s common stock, representing an
ownership stake of 61%.406 According to Treasury’s TARP books and records, taxpayers have realized losses on the TARP investment from an accounting standpoint
of $5.5 billion on Treasury’s sale of AIG stock.407 However, given the January 2011
restructuring of the FRBNY and Treasury investment, according to Treasury, the
Government overall has made a gain thus far on the stock sales.408
Under an agreement with Treasury, until Treasury’s ownership of AIG’s voting
securities falls below 33%, AIG will have to obtain Treasury’s consent to the terms,
conditions, and pricing of any equity offering. AIG is required to pay Treasury’s expenses for the registration of shares and underwriting fees, up to 1% of the amount
offered by Treasury.409
FRBNY’s Sales of Maiden Lane II Securities
On February 28, 2012, FRBNY completed the final sale of securities in the Maiden
Lane II portfolio.410 FRBNY completed 12 sales of a total of 773 CUSIP numbers
(“CUSIPs”) from the Maiden Lane II portfolio, with a face amount totaling $29
billion.411
According to FRBNY, its management of the Maiden Lane II portfolio resulted
in full repayment of the $19.5 billion loan extended by FRBNY to Maiden Lane II
and generated a net gain for the benefit of the public of approximately $2.8 billion,
including $580 million in accrued interest on the loan.412

CUSIP number (“CUSIP”): Unique
identifying number assigned to all
registered securities in the United
States and Canada; the name
originated with the Committee on
Uniform Securities Identification
Procedures.

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Table 2.31 details the sales of securities in the Maiden Lane II portfolio.
Table 2.31

FRBNY Maiden LANE II Securities Sales
Number of
Bonds Sold

Current Face Amount
of Bonds Solda

4/6/2011

42

$1,326,856,873

4/13/2011

37

626,080,072

4/14/2011

8

534,127,946

4/28/2011

8

1,122,794,209

5/4/2011

38

1,773,371,055

5/10/2011

74

427,486,898

5/12/2011

34

1,373,506,029

5/19/2011

29

878,641,682

Trade Date

6/9/2011

36

1,898,594,878

1/19/2012

161

7,005,379,336b

2/8/2012

154

6,223,369,695

2/28/2012

152

6,023,606,497

Total

773

$29,213,815,170

Notes: Numbers may not total due to rounding.
a
The current face amount represents the most recent balance of principal outstanding on the securities at the time of the offering. It
does not reflect the market value of the bonds nor the price originally paid by Maiden Lane II LLC for the bonds.
b
According to FRBNY, the total face amount sold on the January 19, 2012, trade date differs slightly from the figure published in the
FRBNY press release due to factor adjustments that reduced the face amount sold prior to the actual settlement date.
Sources: FRBNY, “Maiden Lane II LLC: Bid List Offering,” no date, www.newyorkfed.org/markets/MLII/maidenlane.cfm?showMore=1,
accessed 6/28/2012; FRBNY, response to SIGTARP data call, 4/12/2012; FRBNY, response to SIGTARP vetting draft, 7/11/2012.

FRBNY’s Sales of Maiden Lane III Securities
In April 2012, FRBNY announced that in light of improving market conditions,
it had revised its investment objective for Maiden Lane III “to allow for the
exploration of sales of the assets held in the portfolio” through its investment
manager BlackRock Solutions.413 According to FRBNY, there is no fixed time
frame for the sales. After each sale, FRBNY will provide the circulation date
of the offering, bid submission deadline, CUSIP number(s) and current face
amount offered, and, if a sale is executed, the name of the buyer and trade date
of the sale.414 FRBNY also announced that, along with providing monthly reports
that include a list of the assets sold during the month by current face amount, it
will provide quarterly updates on total proceeds from sales and the total amount
purchased by each counterparty.415 Finally, after Maiden Lane III sells its last
security, FRBNY will provide a security-by-security listing that shows which entity
purchased each security and the price it paid.416
In the quarter ended June 30, 2012, FRBNY completed eight sales of a total of
46 CUSIPs from the Maiden Lane III portfolio, with a face amount totaling $26.8
billion.417 Maiden Lane III continues to hold other securities.

quarterly report to congress I July 25, 2012

According to FRBNY, on June 14, 2012, Maiden Lane III LLC fully repaid its
liabilities to FRBNY, with interest.418
Table 2.32 details the sales of securities in the Maiden Lane III portfolio.
Table 2.32

FRBNY Maiden LANE III Securities Sales FOR THE QUARTER ENDING
6/30/2012
Trade Date

Number of
Bonds Sold

Current Face Amount
of Bonds Solda

4/26/2012

2

$7,500,000,000

5/10/2012

4

2,427,840,275

5/22/2012

6

690,567,610

5/24/2012

2

1,672,896,114

6/13/2012

3

1,925,643,949

6/15/2012

10

5,165,583,984

6/25/2012

11

4,240,009,909

6/28/2012
Total
a

8

3,139,442,673

46

$26,761,984,514

 he current face amount represents the most recent balance of principal outstanding on the securities at the time of the offering. It
T
does not reflect the market value of the bonds nor the price originally paid by Maiden Lane III LLC for the bonds.

Sources: FRBNY, “Maiden Lane III LLC: Security Offerings,” no date, www.newyorkfed.org/markets/ml3_sec_offerings.html, accessed
6/28/2012; FRBNY, response to SIGTARP data call, 7/9/2012.

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Targeted Investment Program
Treasury invested a total of $40 billion in two financial institutions, Citigroup
Inc. (“Citigroup”) and Bank of America Corp. (“Bank of America”), through the
Targeted Investment Program (“TIP”). Treasury invested $20 billion in Citigroup
on December 31, 2008, and $20 billion in Bank of America on January 16, 2009,
in return for preferred shares paying quarterly dividends at an annual rate of 8%
and warrants from each institution.419 According to Treasury, TIP’s goal was to
“strengthen the economy and protect American jobs, savings, and retirement
security [where] the loss of confidence in a financial institution could result in
significant market disruptions that threaten the financial strength of similarly
situated financial institutions.”420 Both banks repaid TIP in December 2009.421 On
March 3, 2010, Treasury auctioned the Bank of America warrants it received under
TIP for $1.24 billion.422 On January 25, 2011, Treasury auctioned the Citigroup
warrants it had received under TIP for $190.4 million.423

Asset Guarantee Program

Trust Preferred Securities (“TRUPS”):
Securities that have both equity
and debt characteristics created by
establishing a trust and issuing debt
to it.

For a discussion of the basis of the
decision to provide Federal assistance
to Citigroup, see SIGTARP’s audit
report, “Extraordinary Financial
Assistance Provided to Citigroup,
Inc.,” dated January 13, 2011.

Under the Asset Guarantee Program (“AGP”), Treasury, the Federal Deposit
Insurance Corporation (“FDIC”), the Federal Reserve, and Citigroup agreed to
provide loss protection on a pool of Citigroup assets valued at approximately $301
billion. In return, as a premium, the Government received warrants to purchase
Citigroup common stock and $7 billion in preferred stock. The preferred stock was
subsequently exchanged for trust preferred securities (“TRUPS”).424
Treasury received $4 billion of the TRUPS and FDIC received $3 billion.425
Although Treasury’s asset guarantee was not a direct cash investment, it exposed
taxpayers to a potential TARP loss of $5 billion. On December 23, 2009, in connection with Citigroup’s TIP repayment, Citigroup and Treasury terminated the
AGP agreement. Although at the time of termination the asset pool suffered a
$10.2 billion loss, this number was below the agreed-upon deductible and the
Government suffered no loss.426
Treasury agreed to cancel $1.8 billion of the TRUPS issued by Citigroup,
reducing the premium it received from $4 billion to $2.2 billion, in exchange for
the early termination of the loss protection. FDIC retained all of its $3 billion in
securities.427 Under the termination agreement, however, FDIC will transfer up to
$800 million of those securities to Treasury if Citigroup’s participation in FDIC’s
Temporary Liquidity Guarantee Program closes without a loss.428
On September 29, 2010, Treasury entered into an agreement with Citigroup
to exchange the entire $2.2 billion in Citigroup TRUPS that it held under AGP for
new TRUPS. Because the interest rate necessary to receive par value was below
the interest rate paid by Citigroup to Treasury, Citigroup increased the principal
amount of the securities sold by Treasury by an additional $12 million, thereby
enabling Treasury to receive an additional $12 million in proceeds from the $2.2
billion sale of the Citigroup TRUPS, which occurred on September 30, 2010.429
On January 25, 2011, Treasury auctioned the Citigroup warrants it had received
under AGP for $67.2 million.430 According to Treasury, it has realized a gain of

quarterly report to congress I July 25, 2012

approximately $12.3 billion over the course of Citigroup’s participation in AGP,
TIP, and CPP, including dividends, other income, and warrant sales.431
Bank of America announced a similar asset guarantee agreement with respect
to approximately $118 billion in Bank of America assets, but the final agreement
was never executed. Bank of America paid $425 million to the Government as a
termination fee.432 Of this $425 million, $276 million was paid to Treasury, $92
million was paid to FDIC, and $57 million was paid to the Federal Reserve.433

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special inspector general I troubled asset relief program

Asset Support Programs

Non-Recourse Loan: Secured loan
in which the borrower is relieved of
the obligation to repay the loan upon
surrendering the collateral.
Collateral: Asset pledged by a
borrower to a lender until a loan is
repaid. Generally, if the borrower
defaults on the loan, the lender gains
ownership of the pledged asset and
may sell it to satisfy the debt. In TALF,
the ABS or CMBS purchased with
the TALF loan is the collateral that is
posted with FRBNY.

Three TARP programs have focused on supporting markets for specific asset
classes: the Term Asset-Backed Securities Loan Facility (“TALF”), the PublicPrivate Investment Program (“PPIP”), and the Unlocking Credit for Small
Businesses (“UCSB”) program.
TALF was designed to support asset-backed securities (“ABS”) transactions
by providing eligible borrowers $71.1 billion in non-recourse loans through the
Federal Reserve Bank of New York (“FRBNY”) to purchase non-mortgage-backed
ABS and commercial mortgage-backed securities (“CMBS”). On June 28, 2012,
Treasury reduced its obligation in TALF from $4.3 billion to $1.4 billion, the
amount of TARP funds available to manage collateral for the TALF loans in the
event that borrowers surrender collateral and walk away from the loans or if the
collateral is seized in the event of default.434 Of the $71.1 billion in TALF loans,
$4.5 billion remains outstanding as of June 30, 2012.435
PPIP uses a combination of private equity and Government equity and debt
through TARP to facilitate purchases of legacy mortgage-backed securities (“MBS”)
held by financial institutions. In July 2009, Treasury announced the selection of
nine Public-Private Investment Fund (“PPIF”) managers. Treasury has obligated
$21.9 billion in TARP funds to the program. In January 2010, PPIP manager The
TCW Group Inc. (“TCW”) withdrew from the program. On April 3, 2012, PPIP
manager Invesco announced it had sold all remaining securities in its portfolio and
was in the process of winding up the fund.436 As of June 30, 2012, the remaining
seven PPIP managers are purchasing investments and managing their portfolios.
Through the UCSB loan support initiative, Treasury purchased $368.1 million
in 31 SBA 7(a) securities, which are securitized small-business loans.437 According
to Treasury, on January 24, 2012, Treasury sold its remaining securities and ended
the program with a total investment gain of about $9 million for all the securities,
including sale proceeds and payments of principal, interest, and debt.438

TALF
TALF, which was announced in November 2008, issued loans collateralized by
eligible ABS.439 According to FRBNY, TALF was “designed to increase credit
availability and support economic activity by facilitating renewed issuance of
consumer and business ABS.”440
TALF is divided into two parts:441
• a lending program, TALF, in which FRBNY originated and managed nonrecourse loans to eligible borrowers using eligible ABS and CMBS as collateral.
TALF’s lending program closed in 2010
• an asset disposition facility, TALF LLC, that purchases the collateral from
FRBNY if borrowers choose to surrender it and walk away from their loans or if
the collateral is seized in the event of default

quarterly report to congress I July 25, 2012

The asset disposition facility, TALF LLC, is managed by FRBNY and remains in
operation.442 TALF loans are non-recourse (unless the borrower has made any misrepresentations or breaches warranties or covenants), which means that FRBNY
cannot hold the borrower liable for any losses beyond the surrender of collateral for
the TALF loan.443
TALF LLC’s funding first comes from a fee charged to FRBNY for the commitment to purchase any collateral surrendered by the borrowers. This fee is derived
from the principal balance of each outstanding TALF program loan.444 TARP is
obligated to lend to TALF LLC up to $1.4 billion to cover losses on TALF loans.445
TALF LLC may use TARP funds to purchase surrendered assets from FRBNY
and to offset losses associated with disposing of the surrendered assets. As of June
30, 2012, $4.5 billion in TALF loans was outstanding.446 “To date, the program
has experienced no losses and the Board continues to see it as highly unlikely that
recourse to TARP funds will be necessary,” the Federal Reserve Board of Governors
(“FRB”) said on June 28, 2012, after the amount of TARP money available as
credit protection was reduced to $1.4 billion.447 According to FRBNY, no TALF
borrowers have surrendered collateral in lieu of repayment and consequently no
collateral has been purchased by TALF LLC since its inception.448

Lending Program
TALF’s lending program made secured loans to eligible borrowers.449 The loans
were issued with terms of three or five years and were available for non-mortgagebacked ABS, newly issued CMBS, and legacy CMBS.450 The final maturity date of
loans in the TALF portfolio is March 30, 2015.451
To qualify as TALF collateral, the non-mortgage-backed ABS had to have underlying loans for automobile, student, credit card, or equipment debt; insurance
premium finance; SBA-guaranteed small business loans; or receivables for residential mortgage servicing advances (“servicing advance receivables”). Collateral was
also required to hold the highest investment grade credit ratings from at least two
nationally recognized statistical rating organizations (“NRSROs”).452
To qualify as TALF collateral, newly issued CMBS and legacy CMBS had
to have been issued by an institution other than a non-Government-sponsored
enterprise (“GSE”) or an agency or instrumentality of the U.S. Government, offer
principal and interest payments, not be junior to other securities with claims on the
same pool of loans, and possess the highest long-term investment grade credit
rating from at least two rating agencies.453 Newly issued CMBS had to be issued on
or after January 1, 2009, while legacy CMBS were issued before that date.454
Loan Terms

TALF participants were required to use a TALF agent to apply for a TALF loan.455
After the collateral (the particular asset-backed security financed by the TALF loan)
was deemed eligible by FRBNY, the collateral was assigned a haircut. A haircut,
which represents the amount of money put up by the borrower (the borrower’s
“skin in the game”), was required for each TALF loan.456 Haircuts for nonmortgage-backed ABS varied based on the riskiness and maturity of the collateral,

Nationally Recognized Statistical Rating
Organization (“NRSRO”): Credit rating
agency registered with the SEC. Credit
rating agencies provide their opinion
of the creditworthiness of companies
and the financial obligations issued
by companies. The ratings distinguish
between investment grade and non–
investment grade equity and debt
obligations.

For a discussion of the credit rating
agency industry and an analysis of
the impact of NRSROs on TARP
and the overall financial market, see
SIGTARP’s October 2009 Quarterly
Report, pages 113–148.

TALF Agent: Financial institution that
is party to the TALF Master Loan
and Security Agreement and that
occasionally acts as an agent for the
borrower. TALF agents include primary
and nonprimary broker-dealers.
Haircut: Difference between the value
of the collateral and the value of the
loan (the loan value is less than the
collateral value).
“Skin in the Game”: Equity stake in an
investment; down payment; the amount
an investor can lose.

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Custodian Bank: Bank holding the
collateral and managing accounts for
FRBNY; for TALF the custodian is Bank
of New York Mellon.

and generally ranged between 5% and 16% for non-mortgage-backed ABS with
average lives of five years or less.457 The haircut for legacy and newly issued CMBS
was generally 15% but increased above that amount if the average life of the CMBS
was greater than five years.458
FRBNY lent each borrower the amount of the market price of the pledged collateral minus the haircut, subject to certain limitations.459 The borrower delivered
the collateral to the custodian bank, which collects payments generated by the
collateral and distributes them to FRBNY (representing the borrower’s payment of
interest on the TALF loan).460 Any excess payments from the collateral above the
interest due and payable to FRBNY on the loan go to the TALF borrower.461
TALF Loan

TALF provided $59 billion of loans to purchase non-mortgage-backed ABS during
the lending phase of the program, which ended on March 11, 2010. As of June 30,
2012, $3.4 billion was outstanding.462 Table 2.33 lists all TALF loans collateralized
by non-mortgage-backed ABS, by ABS sector.
Table 2.33

TALF Loans BACKED BY ABS (Non-mortgage-backed Collateral)
($ Billions)

ABS Sector
Auto Loans
Credit Card Receivables

$12.8
26.3

Equipment Loans

1.6

Floor Plan Loans

3.9

Premium Finance

2.0

Servicing Advance Receivables

1.3

Small-Business Loans

2.2

Student Loans

8.9

Total

$59.0

Notes: Numbers may be affected by rounding. Data as of 6/30/2012.
Sources: FRBNY, “Term Asset-Backed Securities Loan Facility: non-CMBS,” no date, www.newyorkfed.org/markets/talf_
operations.html, accessed 7/21/2012; FRBNY, “Term Asset-Backed Securities Loan Facility: non-CMBS,” no date, www.
newyorkfed.org/markets/TALF_recent_operations.html, accessed 7/21/2012.

TALF provided $12.1 billion of loans to purchase CMBS during the lending
phase of the program, which ended on June 28, 2010. Approximately 99% of the
loan amount was used to purchase legacy CMBS, with 1% newly issued CMBS.463
As of June 30, 2012, $1.1 billion was outstanding.464 Table 2.34 includes all TALF
CMBS loans.

quarterly report to congress I July 25, 2012

Table 2.34

TALF LOANS BACKED BY CMBS

($ Billions)

Type of Collateral
Assets
Newly Issued CMBS
Legacy CMBS
Total

$ 0.1
12.0
$12.1

Notes: Numbers may be affected by rounding. Data as of 6/30/2012.
Sources: FRBNY, “Term Asset-Backed Securities Loan Facility: CMBS,” no date, www.newyorkfed.org/markets/cmbs_operations.
html, accessed 7/21/2012; FRBNY, “Term Asset-Backed Securities Loan Facility: CMBS,” no date, www.newyorkfed.org/
markets/CMBS_recent_operations.html, accessed 7/21/2012.

The Federal Reserve posted on its website detailed information on the 177
TALF borrowers, including:465
• the names of all the borrowers from TALF (some of which share a parent
company)
• each borrower’s city, state, and country
• the name of any material investor in the borrower (defined as a 10% or greater
beneficial ownership interest in any class of security of a borrower)
• the amount of the loan
• outstanding loan amount as of September 30, 2010
• the loan date
• the loan maturity date
• the date of full repayment (if applicable)
• the date of loan assignment (if applicable)
• the loan rate (fixed or floating)
• the market value of the collateral associated with the loan at the time the loan
was extended
• the name of the issuer of the ABS collateral associated with the loan
• the collateral asset and subclass
As of June 30, 2012, $66.5 billion in TALF loans had been repaid. According to
FRBNY, the outstanding collateral on the remaining $4.5 billion in TALF loans was
performing as expected.466

Asset Disposition Facility
When FRBNY created TALF LLC, TARP loaned the facility $100 million. Of this
initial funding, $15.8 million was allocated to cover administrative costs.467 TARP
will continue to fund TALF LLC, as needed to cover losses, until TARP’s entire
$1.4 billion obligation has been disbursed, all TALF loans are retired, or the loan
commitment term expires. The last loan matures in 2015. Any additional funds, if
needed, will be provided by a loan from FRBNY that will be collateralized by the
assets of TALF LLC and will be senior to the TARP loan.468 Payments by TALF
LLC from the proceeds of its holdings will be made in the following order:469

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special inspector general I troubled asset relief program

•
•
•
•
•
•

operating expenses of TALF LLC
principal due to FRBNY and funding of FRBNY’s senior loan commitment
principal due to Treasury
interest due to FRBNY
interest due to Treasury
other secured obligations
Any remaining money will be shared by Treasury (90%) and FRBNY (10%).470

Current Status
As of June 30, 2012, TALF LLC had assets of $845 million, which included the
$100 million in initial TARP funding.471 The remainder consisted of interest and
other income and fees earned from permitted investments. From its February 4,
2009, formation through June 30, 2012, TALF LLC had spent approximately $2.3
million on administration.472
When TALF closed for new loans in June 2010, FRBNY’s responsibilities under
the program shifted primarily to portfolio management, which includes the following duties:473
Excess Spread: Funds left over
after required payments and other
contractual obligations have been met.
In TALF it is the difference between
the periodic amount of interest paid
out by the collateral and the amount
of interest charged by FRBNY on the
nonrecourse loan provided to the
borrower to purchase the collateral.

•
•
•
•

maintaining documentation
overseeing the custodian that is responsible for holding ABS collateral
calculating and collecting principal and interest on TALF loans
disbursing excess spread to TALF borrowers in accordance with the governing
documents
• monitoring the TALF portfolio
• collecting and managing collateral assets if a borrower defaults or surrenders the
collateral in lieu of repayment
• paying TALF LLC interest that borrowers pay FRBNY on TALF loans, in excess
of FRBNY’s cost of funding

quarterly report to congress I July 25, 2012

Public-Private Investment Program
According to Treasury, the purpose of the Public-Private Investment Program
(“PPIP”) is to purchase legacy securities from banks, insurance companies, mutual
funds, pension funds, and other eligible financial institutions as defined in EESA,
through Public-Private Investment Funds (“PPIFs”).474 PPIFs are partnerships,
formed specifically for this program, that invest in mortgage-backed securities using
equity capital from private-sector investors combined with TARP equity and debt.
A private-sector fund management firm oversees each PPIF on behalf of these
investors. According to Treasury, the aim of PPIP was to “restart the market for
legacy securities, allowing banks and other financial institutions to free up capital
and stimulate the extension of new credit.”475 PPIP originally included a Legacy
Loans subprogram that would have involved purchases of troubled legacy loans
with private and Treasury equity capital, as well as an FDIC guarantee for debt
financing. TARP funds were never disbursed for this subprogram.
Treasury selected nine fund management firms to establish PPIFs. One PPIP
manager, The TCW Group, Inc., (“TCW”) subsequently withdrew, and another
PPIP manager, Invesco, has sold all remaining securities in its PPIP fund. Private
investors and Treasury co-invested in the PPIFs to purchase legacy securities from
financial institutions. The fund managers raised private-sector capital. Treasury
matched the private-sector equity dollar-for-dollar and provided debt financing
in the amount of the total combined equity. Each PPIP manager was also required to invest at least $20 million of its own money in the PPIF.476 Each PPIF
is approximately 75% TARP funded. PPIP was designed as an eight-year program
giving PPIP managers until 2017 to sell the assets in their portfolio. Under certain
circumstances, Treasury can terminate the program early or extend it for up to two
additional years.477
Treasury, the PPIP managers, and the private investors share PPIF profits and
losses on a pro rata basis based on their limited partnership interests. Treasury also
received warrants in each PPIF that give Treasury the right to receive a portion of
the fund’s profits that would otherwise be distributed to the private investors along
with its pro rata share of program proceeds.478
The PPIP portfolio was valued at $19.8 billion as of June 30, 2012, according
to a process administered by Bank of New York Mellon, acting as valuation agent.479
That was $1.4 billion lower than the portfolio value at the end of the previous quarter. The PPIP portfolio consists of eligible securities and cash assets to be used to

Debt: Investment in a business that is
required to be paid back to the investor,
usually with interest.

Pro Rata: Refers to dividing something
among a group of participants according
to the proportionate share that each
participant holds as a part of the whole.

Legacy Securities: Real estate-related
securities originally issued before
2009 that remained on the balance
sheets of financial institutions because
of pricing difficulties that resulted from
market disruption.
Equity: Investment that represents an
ownership interest in a business.

For more information on the selection
of PPIP managers, see SIGTARP’s
October 7, 2010, audit report entitled
“Selecting Fund Managers for the
Legacy Securities Public-Private
Investment Program.”
For more information on the
withdrawal of TCW as a PPIP
manager, see SIGTARP’s January
2010 Quarterly Report, page 88.

Limited Partnership: Partnership in which
there is at least one partner whose
liability is limited to the amount invested
(limited partner) and at least one partner
whose liability extends beyond monetary
investment (general partner).

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special inspector general I troubled asset relief program

Non-Agency Residential MortgageBacked Securities (“non-agency
RMBS”): Financial instrument backed
by a group of residential real estate
mortgages (i.e., home mortgages for
residences with up to four dwelling
units) not guaranteed or owned by
a Government-sponsored enterprise
(“GSE”) (Fannie Mae or Freddie Mac),
or a Government agency.

purchase securities. The securities eligible for purchase by PPIFs (“eligible
assets”) are non-agency residential mortgage-backed securities (“non-agency
RMBS”) and commercial mortgage-backed securities (“CMBS”) that meet the
following criteria:480
• issued before January 1, 2009 (legacy)
• rated when issued AAA or equivalent by two or more credit rating agencies
designated as nationally recognized statistical rating organizations (“NRSROs”)
• secured directly by actual mortgages, leases, or other assets, not other securities
(other than certain swap positions, as determined by Treasury)
• located primarily in the United States (the loans and other assets that secure the
non-agency RMBS and CMBS)
• purchased from financial institutions that are eligible for TARP participation

PPIP Process
The following steps describe the process by which funds participate in PPIP:481
1. Fund managers applied to Treasury to participate in the program.
2. Pre-qualified fund managers raised the necessary private capital for the PPIFs.
3. Treasury matched the capital raised, dollar-for-dollar, up to a preset maximum.
Treasury also received warrants so that it could benefit further if the PPIFs turn
a profit.
4. Fund managers may borrow additional funds from Treasury up to 100% of the
total equity investment (including the amount invested by Treasury).
5. Each fund manager purchases and manages the legacy securities and provides
monthly reports to its investors, including Treasury.
Obligated funds are not given immediately to PPIP managers. Instead, PPIP
managers send a notice to Treasury and the private investors requesting a “draw
down” of portions of obligated contributions in order to purchase specific investments or to pay certain expenses and debts of the partnerships.482
PPIF Purchasing Power

During the capital-raising period, the eight PPIP fund managers raised $7.4 billion
of private-sector equity capital, which Treasury matched with a dollar-for-dollar
obligation, for a total of $14.7 billion in equity capital. Treasury also obligated
$14.7 billion of debt financing, resulting in $29.4 billion of PPIF purchasing
power. The fund-raising stage for PPIFs was completed in December 2009.
After the capital-raising stage, Treasury obligated $22.4 billion in a combination
of matching equity funds and debt financing for PPIP; that was reduced to $21.9
billion after PPIP manager Invesco terminated its investment period in September
2011.483 As of June 30, 2012, there is $28.9 billion in PPIF purchasing power from
private and TARP capital. Table 2.35 shows equity and debt committed by Treasury
for current PPIFs under the program.

quarterly report to congress I July 25, 2012

TABLE 2.35

Public-private investment program PURCHASING POWER, AS OF
6/30/2012 ($ Billions)
PrivateSector Equity
Capital

Treasury
Equity

Treasury
Debt

Total
Purchasing
Power

$1.2

$1.2

$2.5

$5.0

AllianceBernstein Legacy
Securities Master Fund, L.P.

1.2

1.2

2.3

4.6

BlackRock PPIF, L.P.

0.7

0.7

1.4

2.8

Marathon Legacy Securities PublicPrivate Investment Partnership,
L.P.

0.5

0.5

0.9

1.9

Oaktree PPIP Fund, L.P.

1.2

1.2

2.3

4.6

RLJ Western Asset Public/Private
Master Fund, L.P.

0.6

0.6

1.2

2.5

Wellington Management Legacy
Securities PPIF Master Fund, LP

1.1

1.1

2.3

4.6

$6.5

$6.5

$13.0

$26.0

Invesco Legacy Securities Master
Fund, L.P.b

$0.9

$0.9

$1.2

$2.9

Totals for All Funds

$7.4

$7.4

$14.2

Manager
Active Funds
AG GECC PPIF Master Fund, L.P.

Totals for Active Funds
Inactive Funds

a

$28.9C

Notes: Numbers may not total due to rounding.
a
	Purchasing power figures show what was available to funds when they were actively investing.
b
	Invesco did not draw down all committed equity and debt available before terminating its investment period. Treasury has reduced
its debt obligation to the fund, but will not reduce its equity obligation until the fund is formally liquidated.
c
	Treasury initially funded $356 million to TCW, which TCW repaid in full in early 2010. As this PPIF has liquidated, the amount is not
included in the total purchasing power.
Source: Treasury, response to SIGTARP data call, 7/5/2012.

Each current PPIP manager has up to three years (the “PPIF investment
period”) from closing its first private-sector equity contribution to draw upon the
TARP funds obligated for the PPIF and buy legacy securities on behalf of private
and Government investors.484 During this period, the program will strive to maintain “predominantly a long-term buy and hold strategy.”485 The last of the three-year
investment periods expires in December 2012.
At the end of the PPIF investment period, fund managers have five years ending
in 2017 to manage and sell off the fund’s investment portfolio and return proceeds
to taxpayers and investors. This period may be extended up to two years.486

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special inspector general I troubled asset relief program

Amounts Drawn Down

The eight PPIP managers (including Invesco) had drawn down approximately
$24.2 billion to buy legacy securities and cash assets through June 30, 2012,
spending $6.1 billion in private-sector equity capital and $18.1 billion in TARP
equity and debt funding.487 That included a combined $873 million drawn down
by two fund managers, Oaktree PPIP Fund, L.P. (“Oaktree”) and Wellington
Management Legacy Securities PPIF Master Fund, LP (“Wellington”), in the
quarter ended June 30, 2012.488 Treasury also disbursed $356.3 million to TCW,
which TCW fully repaid in early 2010 when it withdrew from the program.489
Five PPIP managers have drawn down at least 90% of their available PPIP
capital to purchase legacy securities as of June 30, 2012.490 Among the active
funds, Oaktree, the only fund limited solely to purchasing CMBS, had drawn down
the smallest amount, 48%, of its available capital. Table 2.36 shows how much
each PPIF has drawn down from the private and Government money available to it
to buy real-estate backed securities.
Table 2.36

PPIP CAPITAL DRAWN DOWN, AS OF 6/30/2012 ($ BILLIONS)
Purchasing
Power
Available

PrivateSector Equity
Drawn Down

Treasury
Equity Drawn
Down

Treasury
Debt Drawn
Down

Total Drawn
Down

Purchasing
Power Used

$5.0

$1.1

$1.1

$2.2

$4.5

90%

AllianceBernstein Legacy
Securities Master Fund, L.P.

4.6

1.1

1.1

2.1

4.3

92%

Manager
Active Funds
AG GECC PPIF Master Fund, L.P.

BlackRock PPIF, L.P.

2.8

0.5

0.5

1.1

2.1

76%

Marathon Legacy Securities
Public-Private Investment
Partnership, L.P.

1.9

0.5

0.5

0.9

1.9

100%

Oaktree PPIP Fund, L.P.

4.6

0.6

0.6

1.1

2.2

48%

RLJ Western Asset Public/
Private Master Fund, L.P.

2.5

0.6

0.6

1.2

2.5

100%

Wellington Management Legacy
Securities PPIF Master Fund, LP

4.6

1.1

1.1

2.2

4.5

97%

$26.0

$5.5

$5.5

$10.9

$21.9

84%

$2.9

$0.6

$0.6

$1.2

$2.3

81%

$28.9

$6.1

$6.1

$12.0

$24.2

84%

Totals for Active Funds
Inactive Funds
Invesco Legacy Securities
Master Fund, L.P.a
Totals for All Fundsb

Notes: Numbers may not total due to rounding.
a
	Invesco did not fully draw down all committed equity and debt available to it. Treasury has reduced its debt obligation to the fund, but will not reduce its equity obligation until the fund
is formally liquidated.
b
	Treasury initially funded $356 million to TCW, which TCW repaid in full in early 2010. As this PPIF has liquidated, the amount is not included in the total purchasing power.
Source: Treasury, response to SIGTARP data call, 7/5/2012.

quarterly report to congress I July 25, 2012

Amounts Paid to Treasury

PPIP managers make monthly debt interest payments to Treasury. In addition,
through June 30, 2012, five of the seven active PPIP managers have repaid $1.6
billion in TARP debt. Invesco finished repaying its $1.2 billion in debt earlier this
year and another $200 million in debt was repaid by TCW when it liquidated its
fund in 2010, for a total of $3 billion in debt repayments to Treasury to date.491
Most of the active PPIFs have also begun repaying Treasury’s equity investments. They repaid $687 million through June 30, 2012, in addition to repayments
by Invesco and TCW. All seven active PPIFs also paid a total of $1.3 billion to
the Government through June 30, 2012, in equity distributions, which Treasury
defined as profits from sales of PPIF securities.492 Table 2.37 shows each fund’s
payments to Treasury through June 30, 2012.
Table 2.37

PPIP MANAGERS’ PAYMENTS TO TREASURY, AS OF 6/30/2012

($ MILLIONS)

Debt
Principal
Payments

Debt
Interest
Payments

Equity
Capital
Paymentsa

Equity
Distribution
Payments

Equity
Warrant
Paymentsb

$523

$57

$262

$420

$—

805

56

342

517

—

BlackRock PPIF, L.P.

—

30

—

3

—

Marathon Legacy Securities PublicPrivate Investment Partnership, L.P.

—

22

—

44

—

158

9

79

92

—

RLJ Western Asset Public/Private
Master Fund, L.P.

14

35

5

114

—

Wellington Management Legacy
Securities PPIF Master Fund, LP

125

48

—

110

—

$1,624

$257

$687

$1,301

$—

UST/TCW Senior Mortgage Securities
Fund, L.P.

$200

$0.3

$156

$176

$0.5

Invesco Legacy Securities Master
Fund, L.P.

1,162

18

581

718

3

$2,986

$276

$1,424

$2,195

$4

Manager
Active Funds
AG GECC PPIF Master Fund, L.P.
AllianceBernstein Legacy Securities
Master Fund, L.P.

Oaktree PPIP Fund, L.P.

Totals for Active Funds
Inactive Funds

Totals for All Funds

Notes: Numbers may not total due to rounding. Excludes management fees and expenses.
a
	In April 2012, Treasury reclassified about $1 billion in combined payments from five PPIFs as equity capital payments instead of equity distributions.
b
	Treasury received equity warrants from the PPIFs, which give Treasury the right to receive a percentage of any profits that would otherwise be distributed to
the private partners in excess of their contributed capital.
Source: Treasury, response to SIGTARP data call, 7/5/2012.

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PPIP Manager Invesco Sells Portfolio

Invesco was the first of the eight remaining PPIP funds to sell its portfolio. It
announced on April 3, 2012, that it had sold all of its PPIP-eligible securities
at a profit and returned “substantially all of its proceeds” to investors, including
Treasury.493 Invesco said the fund, which began in October 2009, earned an
internal rate of return of about 18%.494 Over the life of the fund, which invested
solely in RMBS, according to Treasury, it received approximately $18 million in
interest, $3 million in equity warrant proceeds, and $135 million in cumulative
realized gains, net of fees and expenses, on Treasury’s equity investment of $581
million.495 Treasury also loaned $1.2 billion to the Invesco fund, which was repaid
with interest.496 While Invesco’s PPIF no longer holds any RMBS, Treasury said
Invesco had kept about $2.3 million in temporary investments to pay final audit
and other expenses of the fund until it is formally liquidated in the next few
months.497 The Invesco fund invested $2.3 billion of the $3.4 billion in total private
and Government purchasing power available to it.

Fund Performance
The program’s three-year investment period draws to a close in the final months of
2012 for the remaining PPIP funds. Four funds — AG GECC, AllianceBernstein,
BlackRock, and Wellington — face October deadlines to make any additional
investments in eligible securities. The investment period terminates in November
for RLJ Western and Marathon, and in December for Oaktree.
Each fund has reported rates of return for its portfolio of investments during
the past two and one-half years, based on a methodology requested by Treasury.
The lifetime net internal rates of return range from 7.4% for Wellington to 21.2%
for Oaktree. Each PPIF’s performance — its gross and net returns since inception
— as reported by PPIP managers, is listed in Table 2.38.
The data in Table 2.38 constitutes a snapshot of the funds’ performance during
the quarter ended June 30, 2012, and may not predict the funds’ performance over
the long term. According to some PPIP managers, it would be premature to draw
any long-term conclusions because, among other reasons, some managers have not
fully executed their investment strategies or fully drawn down Treasury’s capital or
debt obligations.

quarterly report to congress I July 25, 2012

TABLE 2.38

PPIF investment status, AS OF 6/30/2012

1-Month
Return
(percent)

Manager

3-Month
Return
(percent)a

Cumulative
Since Inception
(percent)

Internal
Rate of
Return Since
Inception
(percent)b

Investment Period Open
AG GECC PPIF Master
Fund, L.P.

Gross

4.60

2.57

78.91

19.64

Net

4.59

2.48

75.64

19.16

AllianceBernstein Legacy
Securities Master Fund,
L.P.

Gross

3.51

2.45

51.29

17.00

Net

3.54

2.21

45.57

15.52

Gross

2.01

1.88

58.91

17.22

Net

1.97

1.64

53.96

15.88

Gross

2.12

2.23

52.89

15.15

Net

2.06

1.95

46.37

13.72

Gross

6.12

3.99

55.32

22.65

BlackRock PPIF, L.P.
Marathon Legacy
Securities Public-Private
Investment Partnership,
L.P.
Oaktree PPIP Fund, Inc.

Net

6.09

3.71

46.33

21.17

RLJ Western Asset
Public/Private Master
Fund, L.P.

Gross

2.15

1.06

58.03

18.78

Net

2.11

0.78

53.25

17.45

Wellington Management
Legacy Securities PPIF
Master Fund, LP

Gross

2.07

1.75

30.98

8.75

Net

2.01

1.75

26.37

7.35

Investment Period Closed
UST/TCW Senior
Mortgage Securities
Fund, L.P.c

Net

N/A

N/A

N/A

N/A

Invesco Legacy
Securities Master Fund,
L.P.

Net

N/A

N/A

33.50

18.24

Notes: The performance indicators are listed as reported by the PPIP managers without further analysis by SIGTARP. The net returns
include the deduction of management fees and partnership expenses attributable to Treasury.
a
Time-weighted, geometrically linked returns.
b
	Dollar-weighted rate of return.
c
	According to Treasury, rates of return are not available for TCW because it operated for only three months before withdrawing from
the program.
Sources: PPIF Monthly Performance Reports submitted by each PPIP manager, June 2012, received 7/16/2012 and 7/17/2012;
Treasury response to SIGTARP data call, 7/18/2012.

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Figure 2.3

AGGREGATE COMPOSITION OF PPIF
PURCHASES, AS OF 6/30/2012
Percentage of $19.8 Billion

CMBS

28%
72%

RMBS

Notes: Numbers may be affected by rounding. Calculated
based on monthly data supplied by the PPIF managers.
Source: PPIF Monthly Performance Reports, June 2012.

Figure 2.4

AGGREGATE CMBS PURCHASES BY
SECTOR, AS OF 6/30/2012
Percentage of $5.5 Billion
Others

8%
Lodging/
Hotel

12%

31%

Industrial 6%
Multi-family

15%

28%
Retail

Notes: Numbers may be affected by rounding. Calculated
based on monthly data supplied by the PPIF managers.
Source: PPIF Monthly Performance Reports, June 2012.

Securities Purchased by PPIFs
According to their agreements with Treasury, PPIP managers may trade in both
RMBS and CMBS, except for Oaktree, which may purchase only CMBS.498 Figure
2.3 shows the collective value of securities purchased by all PPIFs as of June 30,
2012, broken down by RMBS and CMBS.
PPIF investments can be classified by underlying asset type. All non-agency
RMBS investments are considered residential. The underlying assets are mortgages
for residences with up to four dwelling units. For CMBS, the assets are commercial real estate mortgages: office, retail, multi-family, hotel, industrial (such
as warehouses), mobile home parks, mixed-use (combination of commercial and/
or residential uses), and self-storage. Figure 2.4 breaks down CMBS investment
distribution by sector. As of June 30, 2012, the aggregate CMBS portfolio had large
concentrations in office (31%) and retail (28%) loans.
Non-agency RMBS and CMBS can be classified by the degree of estimated
default risk (sometimes referred to as “quality”). Investors are most concerned
about whether borrowers will default and the underlying collateral will be sold at a
loss. Estimated risk, or quality, attempts to measure the likelihood of that outcome.
There are no universal standards for ranking mortgage quality, and the designations
vary depending on context. In general, the highest-quality rankings are granted to
mortgages that have the strictest requirements regarding borrower credit, completeness of documentation, and underwriting standards. Treasury characterizes these
investment-quality levels of risk for the types of mortgage loans that support nonagency RMBS as follows:499
• Prime — mortgage loan made to a borrower with good credit that generally
meets the lender’s strictest underwriting criteria. Non-agency prime loans
generally exceed the dollar amount eligible for purchase by GSEs (jumbo loans)
but may include lower-balance loans as well.
• Alt-A — mortgage loan made to a borrower with good credit but with limited
documentation or other characteristics that do not meet the standards for prime
loans. An Alt-A loan may have a borrower with a lower credit rating, a higher
loan-to-value ratio, or limited or no documentation, compared with a prime
loan.
• Subprime — mortgage loan made to a borrower with a poor credit rating.
• Option Adjustable Rate Mortgage (“Option ARM”) — mortgage loan that
gives the borrower a set of choices about how much interest and principal to
pay each month. This may result in negative amortization (an increasing loan
principal balance over time).
• Other (RMBS) — RMBS that do not meet the definitions for prime, Alt-A,
subprime, or option ARM but meet the definition of “eligible assets” above.

quarterly report to congress I July 25, 2012

Treasury characterizes CMBS according to the degree of “credit enhancement”
supporting them:500
• Super Senior — most senior originally rated AAA bonds in a CMBS
securitization with the highest level of credit enhancement. Credit enhancement
refers to the percentage of the underlying mortgage pool by balance that
must be written down before the bond suffers any losses. Super senior bonds
often compose approximately 70% of a securitization and, therefore, have
approximately 30% credit enhancement at issuance.
• AM (Mezzanine) — mezzanine-level originally rated AAA bond. Creditors
receive interest and principal payments after super senior creditors but before
junior creditors.501 AM bonds often compose approximately 10% of a CMBS
securitization.
• AJ (Junior) — the most junior bond in a CMBS securitization that attained a
AAA rating at issuance.
• Other (CMBS) — CMBS that do not meet the definitions for super senior,
AM, or AJ but meet the definition of “eligible assets” above.
Figure 2.5 and Figure 2.6 show the distribution of non-agency RMBS and
CMBS investments held in PPIP by respective risk levels, as reported by PPIP
managers.
Figure 2.5

Figure 2.6

AGGREGATE RMBS PURCHASES BY
QUALITY, AS OF 6/30/2012

AGGREGATE CMBS PURCHASES BY
QUALITY, AS OF 6/30/2012

Percentage of $14.3 Billion
Other - RMBS a 0%

Other - CMBS 1% Super Senior

Option ARM

10%

Subprime

29%

12%

Percentage of $5.5 Billion

7%

Prime
AJ (Junior) 33%

Alt-A

59% AM (Mezzanine)

50%

Notes: Numbers may be affected by rounding. Calculated
based on monthly data supplied by the PPIF managers.
a
The actual percentage for “Other RMBS” is 0.32%.

Notes: Numbers may be affected by rounding. Calculated
based on monthly data supplied by the PPIF managers.

Source: PPIF Monthly Performance Reports, June 2012.

Source: PPIF Monthly Performance Reports, June 2012.

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Non-agency RMBS and CMBS can be classified geographically, according to
the states where the underlying mortgages are held. Figure 2.7 and Figure 2.8 show
the states with the greatest representation in the underlying non-agency RMBS and
CMBS investments in PPIFs, as reported by PPIP managers.
Figure 2.7

Figure 2.8

AGGREGATE GEOGRAPHICAL
DISTRIBUTION — PERCENT OF
TOTAL RMBS, AS OF 6/30/2012

AGGREGATE GEOGRAPHICAL
DISTRIBUTION — PERCENT OF
TOTAL CMBS, AS OF 6/30/2012

40%

15%

42%

15%

30

12%

10

20

8%

7%

5
10
9%
0
CA

FL

6%
NY

3%
0
VA

CA

NY

TX

FL

Notes: Only states with the largest representation shown.
Calculated based on monthly data supplied by PPIF managers.

Notes: Only states with largest representation shown. Calculated
based on monthly data supplied by the PPIF managers.

Source: PPIF Monthly Performance Reports, June 2012.

Source: PPIF Monthly Performance Reports, June 2012.

Non-agency RMBS and CMBS can also be classified by the delinquency of
the underlying mortgages. Figure 2.9 and Figure 2.10 show the distribution of
non-agency RMBS and CMBS investments held in PPIP by delinquency levels, as
reported by PPIP managers.
Figure 2.9

Figure 2.10

AGGREGATE AVERAGE RMBS
DELINQUENCIES BY MARKET VALUE,
AS OF 6/30/2012

AGGREGATE AVERAGE CMBS
DELINQUENCIES BY MARKET VALUE,
AS OF 6/30/2012

Percentage of $14.3 Billion

Percentage of $5.5 Billion

1% 30−59 Days

60+ Days

11%
60+ Days

27%

30−59 3%
Days

70% Current
88%

Current

Notes: Numbers may be affected by rounding. Calculated
based on monthly data supplied by the PPIF managers.

Notes: Numbers may be affected by rounding. Calculated
based on monthly data supplied by the PPIF managers.

Source: PPIF Monthly Performance Reports, June 2012.

Source: PPIF Monthly Performance Reports, June 2012.

quarterly report to congress I July 25, 2012

Unlocking Credit for Small Businesses (“UCSB”)/Small
Business Administration (“SBA”) Loan Support Initiative
On March 16, 2009, Treasury announced the Unlocking Credit for Small
Businesses (“UCSB”) program, which according to Treasury was designed to
encourage banks to increase lending to small businesses. Through UCSB, Treasury
purchased $368.1 million in securities backed by pools of loans from the Small
Business Administration’s (“SBA”) 7(a) Loan Program.502
Treasury signed contracts with two pool assemblers, Coastal Securities, Inc.
(“Coastal Securities”), and Shay Financial Services, Inc. (“Shay Financial”), on
March 2, 2010, and August 27, 2010, respectively.503 Under the governing agreement, EARNEST Partners, on behalf of Treasury, purchased SBA pool certificates
from Coastal Securities and Shay Financial without confirming to the counterparties that Treasury was the buyer.504 From March 19, 2010, to September 28, 2010,
Treasury purchased 31 floating-rate 7(a) securities from Coastal Securities and
Shay Financial for a total of approximately $368.1 million.505
In a series of sales from June 2011 through January 2012, Treasury sold all its
SBA 7(a) securities, for total proceeds of $334.9 million, ending the program.506
According to Treasury, over the life of the program Treasury also had received
$29 million and $13.3 million in amortizing principal and interest payments,
respectively.507

7(a) Loan Program: SBA loan program
guaranteeing a percentage of loans for
small businesses that cannot otherwise
obtain conventional loans at reasonable
terms.
Pool Assemblers: Firms authorized
to create and market pools of SBAguaranteed loans.
SBA Pool Certificates: Ownership
interest in a bond backed by SBAguaranteed loans.

For more information on SBA 7(a)
Loan Program mechanics and TARP
support for the program, see SIGTARP’s
April 2010 Quarterly Report, pages
105-106.
For a full listing of the SBA 7(a)
securities Treasury purchased through
UCSB, including investment amounts,
sales proceeds, and other proceeds
received by Treasury, see SIGTARP’s
April 2012 Quarterly Report, page 134.

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Automotive Industry Support Programs
During the financial crisis, Treasury, through TARP, launched three automotive
industry support programs: the Automotive Industry Financing Program (“AIFP”),
the Auto Supplier Support Program (“ASSP”), and the Auto Warranty Commitment
Program (“AWCP”). According to Treasury, these programs were established “to
prevent a significant disruption of the American automotive industry that poses
a systemic risk to financial market stability and will have a negative effect on the
economy of the United States.”508 As of June 30, 2012, General Motors Company
(“New GM” or “GM”) and GMAC Inc. (“GMAC”), now Ally Financial Inc. (“Ally
Financial”), remain in TARP.
AIFP has not expended any TARP funds for the automotive industry since
December 30, 2009.509 ASSP, designed to “ensure that automotive suppliers receive
compensation for their services and products,” was terminated in April 2010 after
all $413.1 million in loans made through it were fully repaid.510 AWCP, a $640.7
million program, was designed to assure car buyers that the warranties on any
vehicles purchased during the bankruptcies of General Motors Corp. (“Old GM”)
and Chrysler LLC (“Old Chrysler”) would be guaranteed by the Government. It
was terminated in July 2009 after all loans under the program were fully repaid
upon the companies’ emergence from bankruptcy.511
Treasury obligated approximately $84.8 billion through these three programs
to Old GM and GM, Ally Financial, the Chrysler entities (Chrysler Holding LLC
[now called CGI Holding LLC], Chrysler LLC [collectively, with CGI Holding
LLC, “Old Chrysler”], Chrysler Group LLC [“New Chrysler”]), and Chrysler
Financial Services Americas LLC (“Chrysler Financial”).512 Treasury originally obligated $5 billion under ASSP but adjusted this amount to $413.1 million to reflect
actual borrowings, thereby reducing at that time the total obligation for all automotive industry support programs to approximately $81.8 billion. Treasury spent $79.7
billion in TARP funds on the auto bailout because $2.1 billion in loan commitments to New Chrysler were never drawn down.513 As of June 30, 2012, Treasury
had received approximately $35.2 billion in principal repayments, proceeds from
preferred stock redemptions, and stock sale proceeds in addition to $4.8 billion in
dividends and interest.514 Taxpayers are owed $44.5 billion in TARP auto funds.
This includes the $2.9 billion loss on Chrysler. The amount and types of Treasury’s
outstanding AIFP investments have changed over time as a result of principal
repayments, preferred stock redemptions by the issuer, Treasury’s sale of common
stock, old loan conversions (into equity), and post-bankruptcy restructurings.
Treasury now holds 32% of the common equity in New GM.515 Treasury
also holds an administrative claim in Old GM’s bankruptcy with an outstanding
principal amount of approximately $849.2 million based on loans made to Old
GM. However, according to Treasury, it does not expect to recover any significant
additional proceeds from this claim.516 Additionally, Treasury holds $5.9 billion in
mandatorily convertible preferred shares (“MCP”) and approximately 74% of the
common equity in Ally Financial.517 On July 21, 2011, Treasury sold to Fiat North
America LLC (“Fiat”) Treasury’s remaining equity ownership interest in New

quarterly report to congress I July 25, 2012

Chrysler and Treasury’s rights to receive proceeds under an agreement with the
United Auto Workers (“UAW”) retiree trust pertaining to the trust’s shares in New
Chrysler. Treasury retains the right to recover certain proceeds from Old Chrysler’s
bankruptcy but, according to Treasury, it is unlikely to fully recover this claim.
Treasury’s investments in these three programs and the companies’ payments
of principal are summarized in Table 2.39 and, for Chrysler and GM, categorized
by the timing of the investment in relation to the companies’ progressions through
bankruptcy.
Table 2.39

TARP Automotive programs expenditures and payments,
AS OF 6/30/2012 ($ BILLIONS)
Chryslera

GMb

Chrysler
Financial

Ally Financial Inc.
(formerly GMAC)d

Total

Pre-Bankruptcy
AIFP
ASSP

c

AWCP
Subtotal

$4.0

$19.4

0.1

0.3

0.3

0.4

$4.4

$20.1

$1.5

$17.2

$42.1
0.4
0.6

$1.5

$17.2

$43.1

In-Bankruptcy
(DIP Financing)
AIFP

$1.9

$30.1

$32.0

Subtotal

$1.9

$30.1

$32.0

Post-Bankruptcy
(Working Capital)
AIFP

$4.6

$4.6

Subtotal

$4.6

$4.6

Subtotals by Program:
AIFP

$78.7

ASSP

0.4

AWCP

0.6

Total Expenditures

$10.9

$50.2

$1.5

Principal Repaid to
Treasury

($8.0)

($23.2)

($1.5)

Net Expenditures

$2.9

$27.0

$0.0

Total Loss on
Investment

$2.9

$17.2
($2.5)e
$14.7

$79.7
($35.2)
$44.5
$2.9

Notes: Numbers may not total due to rounding.
a
Total repayments including Treasury’s sale to Fiat of its equity ownership interest in New Chrysler and Treasury’s rights to receive
proceeds under an agreement with the United Auto Workers (“UAW”) retiree trust pertaining to the trust’s shares in New Chrysler for
$560 million on July 21, 2011.
b
Including GM’s debt payments of $50 million on March 31, 2011, $45 million on April 5, 2011, approximately $15.9 million on
May 3, 2011, approximately $0.1 million on December 16, 2011, approximately $18.9 million on December 23, 2011, and
approximately $6.7 million on January 11, 2012.
c
The final commitment and repayment amounts reflect the total funds expended under the ASSP loans. Treasury initially obligated $5
billion under ASSP. Treasury adjusted its obligation to $0.4 billion.
d
Total expenditures include $884 million loan to Old GM, which Old GM invested in GMAC in January 2009.
e
On March 2, 2011, Treasury entered into an underwriting offering of its Ally Financial TRUPS, which resulted in approximately $2.5
billion in principal repayment to Treasury.
Source: Treasury, Transactions Report, 6/27/2012.

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Automotive Industry Financing Program
Treasury provided $79.7 billion through AIFP to support automakers and
their financing arms in order to “avoid a disorderly bankruptcy of one or more
auto[motive] companies.”518 As of June 30, 2012, Treasury had received approximately $4.8 billion in dividends and interest from participating companies.519 Of
AIFP-related loan principal repayments and share sale proceeds, Treasury has
received approximately $22.5 billion related to its GM investment, $7.6 billion
related to its Chrysler investment, $2.5 billion related to its Ally Financial/GMAC
investment, and $1.5 billion related to its Chrysler Financial investment.520 As
discussed below, additional payments of $640.7 million and $413.1 million, respectively, were received under AWCP and ASSP.521
Taxpayers are still owed $27 billion for the TARP investment in GM and $14.7
billion for the TARP investment in Ally Financial.522 Taxpayers suffered a $2.9
billion loss on the TARP investment in Chrysler. Chrysler Financial fully repaid the
TARP investment.

GM
GM is still in TARP and taxpayers are owed $27 billion for the investment in GM.
In return for its investment, as of June 30, 2012, Treasury holds 32% of GM’s
common stock. Through June 30, 2012, Treasury had provided approximately
$49.5 billion to GM through AIFP. Of that amount, $19.4 billion was provided
before bankruptcy and $30.1 billion was provided as financing during bankruptcy.
During bankruptcy proceedings, Treasury’s loans were converted into common or
preferred stock in New GM or debt assumed by New GM. As a result of Old GM’s
bankruptcy, Treasury’s investment in Old GM was converted to a 60.8% common
equity stake in New GM, $2.1 billion in preferred stock in New GM, and a $7.1
billion loan to New GM ($6.7 billion through AIFP and $360.6 million through
AWCP). As part of a credit agreement with Treasury, $16.4 billion in TARP funds
were placed in an escrow account that GM could access only with Treasury’s
permission.523 In addition, Treasury has a claim in Old GM’s bankruptcy but does
not expect to recover any significant additional proceeds from this claim.524
Debt Repayments

As of June 30, 2012, the GM entities had made approximately $756.7 million in
dividend and interest payments to Treasury under AIFP.525 New GM repaid the
$6.7 billion loan provided through AIFP with interest, using a portion of the escrow
account that had been funded with TARP funds. What remained in escrow was
released to New GM with the final debt payment by New GM.526
Sale of GM Common Stock and GM’s Repurchase of Preferred Shares
From Treasury

In November and December 2010, New GM successfully completed an initial
public offering (“IPO”) in which New GM’s shareholders sold 549.7 million shares
of common stock and 100 million shares of Series B mandatorily convertible
preferred shares (“MCP”) for total gross proceeds of $23.1 billion.527 As part of the

quarterly report to congress I July 25, 2012

IPO, Treasury sold 412.3 million common shares for $13.5 billion in net proceeds
(after taking into account underwriting fees associated with the IPO), reducing its
number of common shares to 500.1 million and its ownership in New GM from
60.8% to 33.3%.528 On December 15, 2010, GM repurchased Treasury’s Series A
preferred stock (83.9 million shares) for total proceeds of $2.1 billion and a capital
gain to Treasury of approximately $41.9 million.529 On January 13, 2011, Treasury’s
ownership in GM was diluted from 33.3% to 32% as a result of GM contributing
61 million of its common shares to fund GM’s hourly and salaried pension plans.530
In order to recoup its total investment in GM, Treasury will need to recover an
additional $27 billion in proceeds. This translates to an average of $53.98 per share
on its remaining common shares in New GM, not taking into account dividend
and interest payments received from the GM entities.531 The break-even price
— $53.98 per share — is calculated by dividing the $27 billion (the amount that
remains outstanding to Treasury) by the 500.1 million remaining common shares
owned by Treasury. If the $756.7 million in dividends and interest received by
Treasury is included in this computation, then Treasury will need to recover $26.2
billion in proceeds, which translates into a break-even price of $52.39 per share,
not taking into account other fees or costs associated with selling the shares.

Chrysler
Chrysler is no longer in TARP and taxpayers suffered a $2.9 billion loss on the
TARP investment in Chrysler. Through October 3, 2010, Treasury made
approximately $12.5 billion available to Chrysler directly through AIFP in three
stages to three corporate entities: $4 billion before bankruptcy to CGI Holding
LLC — the parent company of Old Chrysler (the bankrupt entity) — and Chrysler
Financial; $1.9 billion in financing to Old Chrysler during bankruptcy; and $6.6
billion to New Chrysler.532 In consideration for its assistance to Chrysler, Treasury
received 9.9% of the common equity in New Chrysler.
On April 30, 2010, following the bankruptcy court’s approval of the plan of
liquidation for Old Chrysler, the $1.9 billion loan was extinguished without repayment. In return, Treasury retained the right to recover proceeds from the sale of
assets that were collateral for the loan from the liquidation of Old Chrysler
assets.533 According to Treasury, it is unlikely to fully recover its initial investment
of approximately $1.9 billion related to the loan.534 As of June 30, 2012, Treasury
had recovered approximately $57.4 million from asset sales by Old Chrysler.535 Of
the $4 billion lent to Old Chrysler’s parent company, CGI Holding LLC, before
bankruptcy, $500 million of the debt was assumed by New Chrysler while the
remaining $3.5 billion was held by CGI Holding LLC.536 Under the terms of this
loan agreement, as amended on July 23, 2009, Treasury was entitled to the greater
of approximately $1.4 billion or 40% of any proceeds that Chrysler Financial paid
to its parent company, CGI Holding LLC, after certain other distributions were
made.537 On May 14, 2010, Treasury accepted $1.9 billion in full satisfaction of its
$3.5 billion loan to CGI Holding LLC.538
On May 24, 2011, New Chrysler used the proceeds from a series of refinancing transactions and an equity call option exercised by Fiat to repay the loans from

For more on the results of GM’s
November 2010 IPO, see SIGTARP’s
January 2011 Quarterly Report,
page 163.

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special inspector general I troubled asset relief program

Treasury and the Canadian government.539 The repaid loans were made up of $6.6
billion in post-bankruptcy financing (of which $2.1 billion was never drawn down),
and the $500 million in debt assumed by New Chrysler.540 Treasury terminated
New Chrysler’s ability to draw the remaining $2.1 billion TARP loan.541
Over time, Fiat increased its ownership of New Chrysler. On July 21, 2011,
Treasury sold to Fiat for $500 million Treasury’s remaining equity ownership interest in New Chrysler. Treasury also sold to Fiat for $60 million Treasury’s rights to
receive proceeds under an agreement with the United Auto Workers retiree trust
pertaining to the trust’s shares in New Chrysler.542 Treasury also retains the right to
recover proceeds from Old Chrysler’s bankruptcy, but, according to Treasury, it is
unlikely to fully recover its $1.9 billion loan.
As of July 21, 2011, the Chrysler entities made approximately $1.2 billion in
interest payments to Treasury under AIFP.543

Automotive Financing Companies
Ally Financial, formerly known as GMAC

Ally Financial is still in TARP and taxpayers are owed $14.7 billion for the TARP
investment in Ally Financial. In return for its investment, as of June 30, 2012,
Treasury holds approximately 74% of Ally Financial’s common stock and $5.9
billion worth of mandatorily convertible preferred shares (“MCP”). On December
29, 2008, Treasury purchased $5 billion in senior preferred equity from GMAC
and received an additional $250 million in preferred shares through warrants that
Treasury exercised immediately at a cost of $2,500.544 In January 2009, Treasury
loaned Old GM $884 million, which it invested in GMAC.545 In May 2009,
Treasury exchanged this $884 million debt for a 35.4% common equity ownership
in GMAC.546
On May 21, 2009, Treasury made an additional investment in GMAC when it
purchased $7.5 billion of MCP and received warrants that Treasury immediately
exercised for an additional $375 million in MCP at an additional cost of approximately $75,000.547 On December 30, 2009, Treasury invested another $3.8
billion in GMAC, and Treasury received $2.5 billion in trust preferred securities
(“TRUPS”) and $1.3 billion in MCP. Treasury also received warrants, which were
immediately exercised, to purchase an additional $127 million in TRUPS and
$62.5 million in MCP at an additional cost of approximately $1,270 and $12,500,
respectively.548 Additionally, Treasury converted $3 billion of its MCP into GMAC
common stock, increasing its common equity ownership from 35.4% to 56.3%.549
On May 10, 2010, GMAC changed its name to Ally Financial Inc.550
On December 30, 2010, Treasury announced the conversion of $5.5 billion of
its MCP in Ally Financial to common equity, increasing Treasury’s ownership stake
in Ally Financial’s common equity from 56.3% to 73.8%.551 As a result, Treasury will
no longer receive the quarterly dividend payments that Ally Financial was required
to pay on the $5.5 billion of MCP. On March 7, 2011, Treasury sold its $2.7 billion
in TRUPS in Ally Financial in a public offering, resulting in $2.7 billion in total
proceeds to Treasury.552

quarterly report to congress I July 25, 2012

As a result of its conversion of MCP to common stock in Ally Financial, and
for as long as Treasury maintains common equity ownership at or above 70.8%,
Treasury has the right to appoint two additional directors, in addition to the four
Treasury has already appointed to Ally Financial’s board, increasing the size of the
board to 11 members.553 As of June 30, 2012, Treasury had not exercised its right
to fill its remaining two director positions.554 The conversion of $5.5 billion of
Treasury’s MCP diluted the shares of other existing shareholders in Ally Financial.
Following the conversion, the private equity firm Cerberus Capital Management,
L.P. (“Cerberus”) held 8.7%, third-party investors collectively held 7.6%, an independently managed trust owned by New GM held 5.9%, and New GM directly held
a 4% stake in Ally Financial’s common equity.555 New GM’s interests have been
consolidated in the trust. Figure 2.11 shows the breakdown of common equity
ownership in Ally Financial as of June 30, 2012.
Proposed Ally Financial IPO

On March 31, 2011, Ally Financial filed a Form S-1 Registration statement for
an IPO with the Securities and Exchange Commission (“SEC”).556 The document
includes a prospectus relating to the issuance of Ally Financial common stock.557
The prospectus also outlines certain aspects of Ally Financial’s business operations
and risks facing the company.558
Ally Financial stated that the proposed IPO would consist of “common stock
to be sold by the U.S. Department of the Treasury.”559 Ally Financial has disclosed
additional details about its proposed IPO in several amended Form S-1 Registration
statements filed over time with the SEC, the most recent on April 12, 2012.560
Concurrent with the proposed IPO, Treasury plans to convert $2.9 billion of its
existing $5.9 billion of MCP into common stock.561 Treasury will exchange the
remaining $3 billion of its MCP into so-called tangible equity units, a type of
preferred stock, and will offer a portion of these tangible equity units alongside
the proposed common equity offering.562 Treasury agreed to be named as a seller
but retained the right to decide whether to sell any of its 73.8% ownership of Ally
Financial’s common stock and in what amounts.563
As of June 30, 2012, taxpayers are owed $14.7 billion for the TARP investment
in Ally Financial. In return for the TARP investment Treasury holds 73.8% of Ally
Financial’s common stock and $5.9 billion in MCP.564 Treasury also exercised warrants at a cost of $90,015 to purchase securities with a par value of approximately
$688 million: $250 million in preferred shares (which were later converted to
MCP) and $438 million in additional MCP.565
As of June 30, 2012, Ally Financial had made approximately $2.9 billion in
dividend and interest payments to Treasury.566
Ally Financial Subsidiary Files for Chapter 11 Bankruptcy Relief

On May 14, 2012, Ally Financial announced that its mortgage subsidiary,
Residential Capital, LLC, and certain of its subsidiaries (“ResCap”) filed for
bankruptcy court relief under Chapter 11 of the U.S. Bankruptcy Code, and that it
was exploring strategic alternatives for its international operations, which include

149

Figure 2.11

OWNERSHIP IN ALLY FINANCIAL/GMAC
GM Trust
Third-Party
Investors

8%

Cerberus 9%

10%

74%

United States
Department
of the
Treasury

Notes: Numbers may be affected by rounding.
Note: Numbers may not total due to rounding.
Source: Ally Financial, Inc.: “Ownership Structure,” http://media.
ally.com/index.php?s=51,
7/9/2012.
Source:
: Ally Financial, Inc.:accessed
“Ownership
Structure,” media.ally.com/index.ph

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special inspector general I troubled asset relief program

auto finance, insurance, and banking and deposit operations in Canada, Mexico,
Europe, the U.K., and South America.567 Ally Financial also announced that as a
result of the Chapter 11 filing, ResCap will be deconsolidated from Ally Financial’s
financial statements and Ally Financial’s equity interest in ResCap will be written
down to zero.568
Chrysler Financial

Chrysler Financial is no longer in TARP, having fully repaid the TARP investment.
In January 2009, Treasury loaned Chrysler Financial $1.5 billion under AIFP to
support Chrysler Financial’s retail lending. On July 14, 2009, Chrysler Financial
fully repaid the loan in addition to approximately $7.4 million in interest
payments.569 In connection with the $3.5 billion pre-bankruptcy loan remaining
with CGI Holding LLC, the parent company of Old Chrysler (the bankrupt entity)
and Chrysler Financial, Treasury was entitled to the greater of approximately $1.4
billion or 40% of any proceeds that Chrysler Financial paid to its parent company,
CGI Holding LLC, after certain other distributions were made.570 On May 14,
2010, Treasury accepted $1.9 billion in full satisfaction of its $3.5 billion loan
to CGI Holding LLC, thereby relinquishing any interest in or claim on Chrysler
Financial.571 Seven months later, on December 21, 2010, TD Bank Group
announced it had agreed to purchase Chrysler Financial from Cerberus, the owner
of CGI Holding LLC, for approximately $6.3 billion.572 TD Bank Group completed
its acquisition of Chrysler Financial on April 1, 2011, and has rebranded Chrysler
Financial under the TD Auto Finance brand.573

Auto Supplier Support Program (“ASSP”)
On March 19, 2009, Treasury announced a commitment of $5 billion to ASSP
to “help stabilize the automotive supply base and restore credit flows in a
critical sector of the American economy.”574 Because of concerns about the auto
manufacturers’ ability to pay their invoices, suppliers had not been able to borrow
from banks by using their receivables as collateral. ASSP enabled automotive parts
suppliers to access Government-backed protection for money owed to them for
the products they shipped to manufacturers. Under the program, Treasury made
loans for GM ($290 million) and Chrysler ($123.1 million) that were fully repaid
in April 2010.575

Auto Warranty Commitment Program (“AWCP”)
AWCP was designed to bolster consumer confidence by guaranteeing Chrysler
and GM vehicle warranties during the companies’ restructuring in bankruptcy.576
Treasury obligated $640.7 million to this program — $360.6 million for GM
and $280.1 million for Chrysler.577 On July 10, 2009, the companies fully repaid
Treasury upon their exit from bankruptcy.578

Sect io n 3

AIG Remains in TARP
as the Largest TARP
Investment

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quarterly report to congress I July 25, 2012

Introduction

i

Treasury’s largest TARP investment is American International Group, Inc., (“AIG”)
with Treasury holding 61% of AIG’s common stock as of June 30, 2012. Once the
world’s largest insurance company, AIG became a central figure in the fixed-income
securities market beginning in the 1990s by underwriting the risk on a number
of structured products, including volatile residential mortgage-backed securities
(“RMBS”). In 2008, AIG suffered a severe liquidity crisis and credit downgrades
due to exposures on risky derivatives related to mortgage-backed securities in its
subsidiary, AIG Financial Products Corporation (“AIGFP”). The Government,
first through the Federal Reserve Bank of New York (“FRBNY”), and later through
TARP’s Systemically Significant Failing Institutions (“SSFI”) program, bailed
out AIG at a price tag of $161 billion.ii Taxpayers are still owed more than half
of the original TARP investment — a significant $36 billion of the $67.8 billion
TARP investment. According to Treasury’s TARP books and records, taxpayers
have realized losses on the TARP investment from an accounting standpoint of
$5.5 billion on Treasury’s sale of AIG stock. However, given the January 2011
restructuring of the FRBNY and Treasury investment, according to Treasury, the
Government overall has made a gain thus far on the stock sales. According to
Treasury, this leaves $30.4 billion in TARP funds outstanding.579 In return for that
investment, Treasury holds 1.06 billion shares of AIG common stock (61% of AIG’s
common stock).
Post-bailout, there have been several changes to AIG’s corporate governance,
sales of AIG’s subsidiaries and assets, and a reduction in AIG’s exposure to risky
derivatives. As controlling shareholder, Treasury has consented to or been consulted
on many of these changes. Largely as a result of assets sales, by the end of 2011,
assets had fallen from $1 trillion in 2007 to $552.4 billion.580 Revenue decreased
from $81.5 billion in 2007 to $64.3 billion in 2011.581 These are large numbers by
any measure. AIG remains one of the world’s largest insurance companies, and is
the third largest in the United States by assets.582 Although AIG has sold several
foreign life insurance subsidiaries, it still has 219 subsidiaries (compared with 245
in 2007) and continues to operate in more than 130 countries.583 AIGFP continues
to exist, but with far less exposure, due to efforts by FRBNY to remove exposure
and efforts by AIG to further reduce exposure.
AIG has operated in a changing regulatory environment. How it will be regulated in the future will not be known until Federal regulators designate which nonbank financial companies are systemically important financial institutions (“SIFI”)
as called for in the Dodd-Frank Wall Street Reform and Consumer Protection
Act (“Dodd-Frank Act”).584 There is no stated time when this designation will be
made. For more than two years, AIG has had no consolidated banking regulator of
its non-insurance financial business. AIG continues to operate its non-insurance
financial business today, albeit with far less exposure than in 2008, in part due
to Government action. Before it was abolished, the Office of Thrift Supervision
i

	This discussion is based on publicly available information. It is not an audit or evaluation under the Inspector General Act of 1978 as
amended.
	SSFI had only one participant, AIG.

ii

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special inspector general I troubled asset relief program

(“OTS”) was AIG’s consolidated regulator based on AIG’s ownership of a small
thrift. OTS officials admitted failures in their regulation of AIG. If AIG is designated a SIFI or recognized as a savings and loan holding company, the Federal Reserve
will become AIG’s primary regulator and heightened regulatory requirements will
apply. Regulatory oversight of AIG will be an enormous undertaking, presenting
challenges in examination, enforcement, and supervision, particularly as it relates
to risk, given AIG’s history. Effective, comprehensive, and rigorous regulation of
AIG is vital to ensure that history does not repeat itself.

Rise and Fall of AIG Prior to TARP
In the years before the Government bailout, AIG had a solid reputation, reliable
earnings, and was generally perceived to be one of the stronger companies in the
United States.585 Core insurance operations encompassed general insurance,
including property and casualty, commercial, industrial, and life insurance,
including annuities and retirement services. Insurance operations (including
general insurance, life insurance, and retirement services) accounted for nearly
90% of AIG’s revenue, which is still the case today. Approximately half of the
company’s revenue during this period came from outside the United States,
largely from Asia. For decades, the company’s AAA credit rating helped bolster its
insurance operations and allowed AIG to use its low cost of funds as leverage to
boost non-insurance lines, including aircraft leasing and consumer finance.
AIG’s credit rating also increased its attractiveness as a counterparty in capital markets, helping the company expand its product base. Over the years, AIG
expanded from insurance into other financial businesses. One of these was AIGFP,
a subsidiary created in 1987 to conduct sophisticated financial market trades, many
involving complex derivatives. Derivatives are financial instruments that can be
used to hedge risks or to bet on market price trends, and are typically derived from
underlying assets such as stocks, bonds, loans, currencies, or commodities. By the
1990s, AIGFP was a vital part of the fixed-income securities market as it related to
RMBS and commercial mortgage-backed securities (“CMBS”). RMBS are financial instruments backed by a pool of residential mortgage loans; CMBS are backed
by a pool of commercial mortgage loans. The loans are packaged into bundles of
loans sharing similar characteristics, and then sold to investors. This process, called
securitization, removes the loans from the balance sheets of banks and mortgage
lenders and gives them cash to issue new loans. The RMBS and CMBS were often
further pooled into bundles known as collateralized debt obligations (“CDOs”).
In 1998, AIGFP began to sell insurance-like contracts called credit default
swaps (“CDS”) that provided protection to investors against losses from RMBS
and CMBS that had been bundled into CDOs. The firm purchasing the CDS (the
“counterparty” to AIG), would pay AIG regular insurance-like premiums and in
return AIG would pay the counterparty if the CDO should default. Due to AIG’s
AAA rating, AIG was able to enter into these insurance-like contracts without

quarterly report to congress I July 25, 2012

posting any collateral, a benefit not available to lower-rated firms. Included in these
CDS contracts was a provision that, should AIG’s credit rating be downgraded, AIG
would be required to post collateral to ensure payment on these contracts. In addition, if the value of the securities that AIG was insuring fell, AIG was contractually
obligated to produce quickly the collateral to its counterparty to make up for the
difference in the drop in value of the security. That collateral could be either cash
or AAA-rated securities. AIGFP sold CDS to firms that bought or sold mortgages or
CDOs and to unrelated investors.
AIG had grown into a global giant with a top-tier AAA credit rating largely
under the direction of one man, Hank Greenberg, who was chief executive officer
from 1968 to 2005.586 Beginning in 2004, however, AIG became embroiled in a series of fraud investigations conducted by the Securities and Exchange Commission
(“SEC”), the Department of Justice, the New York State Insurance Department,
and the New York State Attorney General’s Office. Amid those investigations, AIG’s
board forced Greenberg to step down on March 14, 2005.
In early May 2005, AIG restated five years of its financial results, cutting $3.9
billion off reported profit over that period and reducing its book value by $2.7
billion.587 Credit rating agencies began questioning AIG’s creditworthiness, and
in March and June of 2005, Standard & Poor’s and Moody’s Investors Service
downgraded AIG’s AAA rating.588 An S&P executive testified to Congress that the
downgrade was due to “the company’s involvement in a number of questionable
financial transactions.”589
Starting in the third quarter of 2007 and continuing through 2008, AIG’s
financial condition deteriorated, causing a decline in market confidence that, in
turn, brought downgrades of AIG’s credit rating and nearly caused the company’s
collapse. The trigger and primary cause was AIGFP.
While AIGFP’s operating income grew from $131 million in 1994 to $949
million in 2006, closely tracking the boom in the CDS market and the overall
derivatives market, the risk involved in this business turned out to be dramatically
disproportionate to the income produced.590 As of June 2008, AIG provided more
than $400 billion of credit protection, primarily to banks, through AIGFP CDS.591
AIG was exposed to the underlying securities, which were composed largely of
subprime mortgages in CDOs that were initially rated AAA.
When the U.S. residential mortgage market deteriorated, the securities underlying AIGFP’s CDS contracts turned toxic as home prices tumbled and defaults skyrocketed. The value of the underlying securities plummeted, and the credit ratings
of those securities were downgraded. In the fourth quarter of 2007, counterparties
began making significant collateral calls to AIG, which only continued. With its
credit no longer rated AAA, AIG posted collateral in cash. According to AIG’s 2008
Form 10-K, “From July 1, 2008, to August 31, 2008, the continuing decline in
value of the super senior CDO securities protected by AIGFP’s super senior CDS
portfolio, together with rating downgrades of such CDO securities, resulted in
AIGFP posting additional collateral in an aggregate net amount of $5.9 billion. By
the beginning of September 2008, these collateral postings and securities lending
requirements were placing increasing stress on AIG parent’s liquidity.”592

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AIG was also taking risks with the assets of its life insurance subsidiaries
through its securities-lending program. AIG made short-term loans of securities it
owned and used the fees it earned on those loans to invest in RMBS. The value of
these and other AIG real estate-related investments also declined sharply, and contributed to further downgrades of AIG’s credit ratings in May 2008. The problems
in AIGFP exacerbated the problems in securities lending, and vice versa, as collateral demands from both sets of counterparties left the company struggling to find
cash. In September 2008, AIG’s credit ratings were downgraded again, triggering
additional collateral calls and cash requirements in excess of $20 billion.593 AIG,
facing an acute liquidity crisis, was on the brink of collapse, unable to access credit
in the private markets and bleeding cash.
The Congressional Oversight Panel (“COP”) found that AIG was brought down
by the company’s “insatiable appetite for risk and blindness to its own liabilities.”594
According to the Financial Crisis Inquiry Commission (“FCIC”), “AIG failed and
was rescued by the Government primarily because its enormous sales of credit
default swaps were made without putting up initial collateral, setting aside capital
reserves, or hedging its exposure — a profound failure in corporate governance,
particularly its risk management practices.”595
AIG sought and received Government support through a revolving credit facility
from FRBNY and later TARP funding from Treasury. Officials involved in the rescue maintained that if AIG went under, it would have taken down other financial
institutions and caused havoc around the world.596 Then-Treasury Secretary Henry
M. Paulson wrote in his memoir, “An AIG collapse would be much more devastating than the Lehman failure because of its size and the damage it would do to
millions of individuals whose retirement accounts it insured.”597

Changes at AIG After the Government
Bailout
Since the Government bailout, AIG has undergone some key changes.iii Some were
a direct result of the bailout, including a change in AIG’s capital structure such that
the Government took an ownership interest in AIG that was eventually converted
to common stock. AIG’s CEO, chairman of the board, and other management and
directors have changed, leaving only a few from pre-bailout times. FRBNY created
its Maiden Lane II and III investment vehicles to remove a large part of AIG’s
liquidity strain caused by its securities-lending portfolio and AIGFP’s exposure to
RMBS under its CDS contracts. AIG has sold a number of subsidiaries, primarily
foreign life insurance subsidiaries, using proceeds to pay down what was owed to
the Government.

	This discussion does not attempt to chronicle all of the changes at AIG while it has been in TARP.

iii

quarterly report to congress I July 25, 2012

Changes to Balance Sheet As a Result of the Bailout
The bailout and subsequent restructuring significantly altered AIG’s capital
structure. Prior to the bailout, AIG’s balance sheet consisted of $95.8 billion in
equity and $952.5 billion in total liabilities.598 For the year ended December 31,
2011, AIG’s balance sheet consisted of approximately $105 billion in equity and
$441.4 billion in total liabilities.599 In the bailout, the Government injected capital
into AIG and became AIG’s largest shareholder.
Changes to AIG’s Corporate Governance After the Government Bailout
There have been substantial changes to AIG’s corporate governance while the
Government has been AIG’s largest shareholder. Changes in management after
the Government bailout included a new CEO, Edward M. Liddy, a former Allstate
Corporation CEO, who was appointed in September 2008 after discussions
with Treasury. Less than a year after he became CEO, Liddy resigned. Liddy was
succeeded in August 2009 by Robert H. Benmosche, former CEO of MetLife,
Inc. As of June 30, 2012, out of AIG’s ten executives listed in its Form 10-K, only
four were executives with the company prior to TARP. They are William Dooley,
executive vice president of investments and financial services, who has been with
AIG since 1992; David Herzog, chief financial officer, who was hired in 2005;
Brian Schreiber, treasurer, who has been an AIG executive since 2002; and Jay
Wintrob, executive vice president of domestic life and retirement services, who has
been with AIG since 1999.600
There have been significant changes to AIG’s board while the company has
been in TARP. Although Greenberg had long been gone from AIG by the time of
the bailout, several board members appointed during Greenberg’s tenure remained.601 During the nearly four decades that Greenberg ran AIG, the company’s
board of directors played a minor role in governing the company, according to corporate governance expert Jennifer S. Taub, an associate law professor at Vermont
Law School.602 In the boardroom, there were as many as nine AIG executives
seated on the company’s 20-member board of directors in 2002.603 In 2008, the
year of the bailout, five AIG directors resigned. Two more followed in May 2009,
while two others did not seek re-election.604 Chairman Harvey Golub resigned in
July 2010 and was replaced by AIG director Steve Miller, a former chairman of
auto parts manufacturer Delphi Corp.605
AIG’s annual proxy mailing to shareholders ahead of its 2009 annual meeting
included a new set of corporate governance guidelines adopted by the board. The
guidelines trimmed the board size to between 8 and 12 directors and described that
a lead independent director would annually review the CEO’s performance.606
As of June 30, 2012, AIG’s 12-member board includes only two people who
have been directors since before TARP.607 George L. Miles, Jr., chairman of Chester
Engineers, Inc., joined the AIG board in 2005 and Suzanne Nora Johnson, former vice chairman of Goldman Sachs Group, became a director in July 2008.
Other current board members include fund managers in charge of Oak Street
Management Co. and Marblegate Asset Management; the former head of KPMG
LLP’s banking and finance practice; and the ex-CEO of Sears, Roebuck and Co.

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Two other board directors have significant aircraft industry experience: one is
the CEO of aircraft maker Hawker Beechcraft, Inc., and the other once headed
Northwest Airlines Corp.608
In April 2010, after AIG had missed five TARP dividend payments, Treasury
exercised its right to appoint two directors to the AIG board.609 Treasury named
Ronald Rittenmeyer, head of a private equity firm, and Donald Layton, a veteran of
JPMorgan Chase.610 Layton resigned from the AIG board in May 2012 to become
CEO of Freddie Mac.611 On July 11, 2012, a retired AIG director, Morris W. Offit,
was re-elected to the board.612

No Changes to AIG’s Outside Independent Auditor While in TARP
AIG has not changed its outside auditor while it has been in TARP.
PricewaterhouseCoopers has been AIG’s auditor for decades and continues to serve
in that role.
FRBNY Took Significant Mortgage-Backed Securities Off AIG’s Books
AIG held nearly $141 billion worth of RMBS, CMBS, derivatives, and assetbacked securities investments on its books at the end of 2007.613 The holdings
were slashed to $34.6 billion at the end of 2010, in part due to the actions taken
by FRBNY.614 The 2008 liquidity pressures on AIG were concentrated in two areas,
securities lending and CDS, insurance-like protection on CDOs (generally bundles
of RMBS). As part of the Federal bailout, most of the securities involved in those
areas were unloaded into two newly created special purpose vehicles: Maiden
Lane II (which held the RMBS associated with AIG’s securities-lending program)
and Maiden Lane III (which held the underlying CDO securities associated with
the CDS). Maiden Lane is the street behind the FRBNY building in the heart of
Manhattan’s financial district.
FRBNY made a $19.5 billion loan to Maiden Lane II which was used to
purchase subprime RMBS in AIG’s securities-lending portfolio that FRBNY put
into Maiden Lane II. FRBNY had sole control over Maiden Lane II and sales of
the RMBS in it.615 Last year, AIG offered to buy the entire portfolio for $15.7
billion. The FRBNY declined and instead held a series of auctions for the assets.616
Investment banks that won the auctions turned around and re-sold the securities
to clients, including AIG.
The FRBNY also created Maiden Lane III as a vehicle to buy from AIG’s
counterparties the CDOs that AIGFP had insured through CDS. The purchase
of the underlying CDOs terminated AIGFP’s obligations under the CDS contracts. SIGTARP previously reported in its audit, “Factors Affecting Efforts to
Limit Payments to AIG Counterparties,” issued in November 2009, that “FRBNY
decided to pay the counterparties the full market value of the CDOs, which, when
combined with the already posted collateral, meant that the counterparties were
effectively paid full face (or par) value of the credit default swaps, an amount far
above their market value at the time.”617 The face value amount of the securities
was $62.1 billion. AIG’s counterparties retained $35 billion in collateral posted by

quarterly report to congress I July 25, 2012

AIG and were paid an additional $26.8 billion.618 The FRBNY began auctioning
securities from Maiden Lane III in April 2012.
Maiden Lane III did not remove all of AIGFP’s exposure on CDS contracts. For
example, FRBNY did not purchase synthetic CDOs, which are CDOs backed by
CDS rather than real estate loans. AIGFP still had about $302 billion in exposure
to CDS on its books on December 31, 2008, after Maiden Lane III was created.619

AIG Sales of Certain Foreign Life Insurance Subsidiaries and
Other Assets
While in TARP, AIG has sold several of its foreign life insurance subsidiaries
including Nan Shan, AIG Star Life Insurance Co., ALICO, and AIA. These
transactions were with the consent of or in consultation with Treasury as AIG’s
controlling shareholder. Some of the transactions resulted in proceeds that went
to pay down amounts owed to the Government as part of a plan to recapitalize the
Government’s interest in AIG. At the end of 2011, about 14% of AIG’s consolidated
assets were located outside the United States and Canada, down from 37% in
2008.620 Figure 3.1 shows recent major foreign divestitures of $1 billion or more.
On the one hand, these transactions may be key steps in AIG’s restructuring
that have allowed AIG to meet working capital needs and to pay down the
Government. As Benmosche stated in March 2010, “Clearly, we will be a smaller
and more focused company than in the past. The only way we can repay taxpayers
is to divest parts of the organization, and we are.”621
However, AIG’s sales of ALICO and AIA, key pieces of AIG’s foreign life
insurance operations, meant losing what Benmosche described as some of “the
company’s crown jewels.”622 In 2010, AIG sold ALICO, one of the world’s largest
and most diversified international life insurance companies, to MetLife, Inc. The
sale included the company’s vast distribution network throughout four continents,
including agents, brokers and financial institutions; 12,500 employees across
more than 50 countries; and 20 million customers worldwide. The significance of
ALICO’s loss to AIG is best shown by the numbers. In 2008, ALICO generated
revenue of $32.3 billion, or approximately one-third of AIG’s revenue that year.623
The sale of AIA Group, Limited (“AIA”) entailed AIG parting ways with a leading
Pan-Asian life insurance organization that traces its roots in the Asia-Pacific region
back more than 90 years. The sale included all of the AIA companies operating
in 15 geographic markets across the Asia-Pacific region, including the company’s
international network of more than 320,000 agents and approximately 23,500
employees.624 AIA accounted for $9.3 billion of insurance premiums in 2010, about
12% of AIG’s revenue that year.625
In addition to these major transactions, AIG has sold its own Manhattan
headquarters building; a commodity index; a U.S. rail services leasing unit; its
U.S. personal auto insurance business; a German marine insurer; consumer
finance businesses in Mexico, Argentina, and Thailand; life insurance operations
in Canada, Japan, the Philippines, and Taiwan; and 80% of its consumer credit
provider, American General Finance.

Figure 3.1

AIG’S MAJOR RECENT FOREIGN
ASSET SALES
Nan Shan: On August 18, 2011, AIG sold
its 97.6% interest in Nan Shan Life Insurance
Company, Ltd., its Taiwanese life insurance unit,
to Taiwan-based Ruen Chen Investment Holding
Co., Ltd. for $2.2 billion. Established in 1963, Nan
Shan is the largest life insurer in Taiwan by total
book value and the third largest by total premiums.
Star and Edison: On February 1, 2011, AIG sold
its Japan-based life insurance subsidiaries, AIG
Star Life Insurance Co., Ltd., and AIG Edison Life
Insurance Company, to Prudential Financial, Inc.,
for a total of $4.8 billion, made up of $4.2 billion
in cash and $0.6 billion in the assumption of thirdparty debt. Star and Edison offer life, medical, and
annuity products to individuals and groups.
ALICO: On November 1, 2010, AIG sold ALICO,
a foreign life insurance company with operations
on four continents, to MetLife for approximately
$16.2 billion ($7.2 billion in cash and the remainder in securities of MetLife).
AIA: On October 29, 2010, AIG sold, in an initial
public offering, 8.08 billion shares (or 67%) of
Pan-Asian life insurer AIA for approximately $20.5
billion. On March 8, 2012, AIG sold 1.72 billion
shares of AIA to institutional investors for approximately $6 billion.
AIGFP Energy and Infrastructure Portfolio: On
August 11, 2009, AIG sold its remaining energy
and infrastructure investment assets, including
three Spanish solar power plants along with several U.S. assets, realizing aggregate net proceeds
in excess of $1.9 billion. This disposition effort
began during the fall of 2008.
AIG Otemachi Building in Tokyo: On May 28,
2009, AIG sold its prime real estate holding in
Tokyo, the AIG Otemachi Building and property, for
approximately $1.2 billion in cash to Nippon Life
Insurance Company.
Sources: AIG, Press Release, “AIG Reduces United States
Treasury Investment in AIG Subsidiary by Approximately $2
Billion,” 8/18/2011, www.aigcorporate.com/newsroom/
index.html, accessed 6/28/2012; AIG, Press Release, “AIG
Enters Into Agreement to Sell Nan Shan to Taiwan-Based
Consortium Led by the Roentex Group,” 1/12/2011,
www.aigcorporate.com/newsroom/index.html, accessed
6/29/2012; AIG, Press Release, “AIG Completes Sale
of Star and Edison Companies,” 2/1/2011, www.
aigcorporate.com/newsroom/index.html, accessed
6/28/2012; AIG, Press Release, “AIG Raises Nearly
$37 Billion in Two Transactions to Repay Government,”
11/1/2010, www.aigcorporate.com/newsroom/index.
html, accessed 6/28/2012; AIG, Press Release, “AIG
Announces Pricing of Sale of Ordinary Shares of AIA Group
Limited,” 3/5/2012, www.aigcorporate.com/newsroom/
index.html, accessed 6/28/2012; AIG, Press Release, “AIG
Financial Products Corp. Completes Disposition of Energy
and Infrastructure Investment Portfolio,” 8/11/2009,
www.aigcorporate.com/newsroom/index.html, accessed
6/28/2012; AIG, Press Release, “AIG Completes Sale of
Prime Tokyo Real Estate Asset to Nippon Life Insurance
Company,” 5/28/2009, www.aigcorporate.com/
newsroom/index.html, accessed 6/28/2012.

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AIG’s Current Businesses
For the year ending December 31, 2011, AIG reported the results of its businesses
through four segments: Chartis, which writes policies for foreign property/casualty,
commercial/industrial, and consumer insurance; SunAmerica Financial Group,
which focuses on U.S. life insurance, retirement services, and annuities; Aircraft
Leasing; and “Other Operations,” which includes the remaining derivatives
portfolio from AIGFP, other corporate investment operations, and AIG’s insurance
for residential mortgage lenders.626 Insurance continues to account for almost 90%
of the company’s revenue, as was generally the case historically. Aircraft leasing
accounts for 7% and other operations for 6%.627
In TARP, AIG has sold certain subsidiaries and other assets and added several
operations, although they are only a fraction of the size of those that it shed. Most
notably, through transactions in 2010 and 2011, AIG increased its ownership stake
in Japanese insurer Fuji Fire & Marine Insurance Company, Limited, from 41.7%
to 100%.628 Fuji is now part of Chartis, and largely because of that acquisition,
consumer insurance accounted for 38% of Chartis’s business in 2011, up from 30%
in 2009.629 The company has also acquired financial assets, including mortgage
securities.
Table 3.1. provides a snapshot of key AIG financial information from 2007 to
2011.
TABLE 3.1

AIG FINANCIAL HIGHLIGHTS
ON AVERAGE EQUITY)

($ BILLIONS EXCEPT FOR EARNINGS PER SHARE AND RETURN

2007

2008

2009

2010

2011

$1,048.4

$860.4

$847.6

$675.6

$552.4

Liabilities

952.5

807.7

748.6

568.4

441.4

Revenue

81.5

(6.8)

75.4

77.5

64.3

7.5

(100.4)

(12.3)

12.3

21.3

47.73

(756.85)

(90.48)

14.98

11.01

7.2%

-130.7%

-18.2%

11.8%

24%

Assets

Net income
Earnings per
share
Return on
average equity

Notes: Earnings per share is fully diluted, after extraordinary items. Return on average equity is net income as a percent of average
equity.
Source: SNL Financial; all data reflect company restatements of results as of April 20, 2012.

Chartis and SunAmerica
Chartis is AIG’s largest subsidiary. Chartis generated $40.7 billion in 2011 revenue
primarily through the sale of property and casualty insurance policies to companies
around the world for natural disasters and industrial accidents.iv Chartis has had
four consecutive years of underwriting losses, which in part reflect the severity of
	It also wrote policies to protect companies and wealthy individuals from specialized risks such as computer hackers, executive
kidnappings, yachting mishaps, crisis management, and shareholder lawsuits.

iv

quarterly report to congress I July 25, 2012

recent disasters.630 The U.S. property/casualty industry saw underwriting net losses
more than triple to $36.5 billion in 2011 from the previous year after a string of
costly catastrophes.631 Chartis had $3.2 billion in underwriting losses in 2011 from
catastrophes including Japan’s worst-ever earthquake, damages in the U.S. from
Hurricane Irene and tornadoes, and deadly flooding in Thailand.632
In its smaller consumer business, Chartis is using direct marketing to expand
sales of health, accident, and auto insurance in Brazil, Mexico, United Arab
Emirates, Turkey, Vietnam, Indonesia, India, and China. Revenue from consumer premiums rose to $3.6 billion in the 2012 first quarter, accounting for 41%
of Chartis’s sales. Part of the increase was due to Chartis’s 2010 acquisition of
Japanese insurer Fuji, which sells mainly to Asian consumers. Meanwhile, commercial premiums declined to $5.2 billion in the first quarter of 2012, down about
$500 million from a year ago.633
AIG subsidiary SunAmerica sells bread-and-butter life and health insurance
policies and retirement annuities to U.S. clients. SunAmerica also offers products such as brokerage services, financial planning, and retail mutual funds.
SunAmerica’s revenue of $15.3 billion in 2011 accounted for 24% of AIG’s total
sales.634

Investments by Chartis and SunAmerica
Like other insurers, Chartis and SunAmerica invest insurance premium payments
from customers to generate income for paying claims and benefits. Life insurers
such as SunAmerica have a relatively predictable business and can invest in
fixed maturity securities that match up with estimated payouts to customers.
SunAmerica also invests in private equity funds, hedge funds, and affordable
housing partnerships. Property insurers contend with unpredictable natural
disasters such as earthquakes and hurricanes. While according to AIG, Chartis
invests in relatively safe fixed-income securities such as municipal bonds, it also
needs strong investment income to offset insurance policy underwriting losses.
In recent years, it has lost money on underwriting, but attempted to make it up
on profits from investments.635 Average investments at Chartis and SunAmerica
have steadily increased from 2009 to 2011. In 2011, Chartis and SunAmerica
together held average investments of $286.3 billion, up 12% from 2010 holdings.636
However, pre-tax returns on those investments have fluctuated. Their combined
portfolio produced $14.2 billion in net investment income in 2011, a decline of
6% from the previous year.637
Aircraft Leasing
AIG’s International Lease Finance Corporation (“ILFC”) leases commercial jet
aircraft to foreign and domestic airlines. Revenue in the business has been steadily
decreasing since 2009 — it fell 4% from 2009 to 2010, and then another 6% from
2010 to 2011.638 The business’s loss deepened from $729 million in 2010 to $1
billion in 2011, which included write-downs in the value of older aircraft.639

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Mortgage-Backed Securities
According to AIG, to earn the higher returns needed to pay claims and benefits to
insurance customers, AIG has returned to investing in mortgage-backed securities,
although at a much smaller level than prior to TARP.640 From December 31, 2010,
to March 31, 2012, AIG had more than doubled its CMBS and non-agency RMBS
holdings to $28.4 billion.641 That did not include AIG’s April 2012 purchase of
$600 million worth of CDOs that had been in the Maiden Lane III portfolio.642
AIGFP and Other Securities Lending and CDS
AIG continues to maintain a portfolio of CDS and continues to engage in securities
lending, albeit much smaller than prior to TARP. AIGFP continues to exist and
was folded into the company’s Global Capital Markets business along with a
separate unit, AIG Markets Inc., which writes derivatives on behalf of other AIG
subsidiaries.643
AIGFP has sharply reduced its CDS portfolio to one-tenth its former size, from
about $2 trillion in net notional value in 2008 to about $168 billion in net notional
value at the end of its 2012 first quarter.644 Net notional value is the total risk exposure for a transaction, or the maximum amount of money that would be transferred
from the seller of protection to the buyer in the event of a credit default.645 This
reduction in exposure is due in part to FRBNY’s actions with Maiden Lane III. The
size of AIGFP’s trading book is greatly diminished, but it may come as a surprise
to some that any of AIGFP still exists at all. Former AIG CEO Edward M. Liddy
told Congress in 2009 he was weighing a number of options to quickly shut down
AIGFP and “break apart these trading books.”646 His successor and current CEO,
Robert H. Benmosche, has been winding down some of AIGFP’s trading books
over time.647 Benmosche hired Peter Hancock, the founder of JPMorgan’s global
derivatives group and now the head of AIG’s Chartis unit, to manage what AIG has
described as the “de-risking” of AIGFP.648
AIG’s 2008 Form 10-K stated that the orderly wind-down of AIGFP would
take a substantial period of time. An AIG presentation about its first quarter 2012
results noted that AIGFP may be around for at least seven more years until its
final contracts expire.649 The company says it manages the AIGFP portfolio “for
maximum profit contribution and limited risk.”650 According to AIG, active trading
wound down in mid-2011, and AIGFP now enters into new derivative transactions
only to hedge its portfolio, which according to AIG means to protect that portfolio
by making an offsetting investment in a related security.651 Its non-AIGFP divisions
also use derivatives to hedge against risk. According to AIG, “Although the remaining AIGFP derivatives portfolio may experience periodic fair value volatility, the
portfolio consists predominantly of transactions AIG believes are of low complexity, low risk, supportive of AIG’s risk management objectives, or not economically
appropriate to unwind based on a cost versus benefit analysis.”652 Table 3.2 shows
how AIGFP’s portfolio of investments has changed since 2008.

quarterly report to congress I July 25, 2012

TABLE 3.2

AIGFP’s Portfolio 2008-2012

($ BILLIONS)

12/31/2008

12/31/2009

12/31/2010

12/31/2011

3/31/2012

~$1,450

Not reported

Not reported

$131

$126

Stable value
wraps

~40

Not reported

Not reported

20

19

Corporate
debt CDS

~52

22

12

12

12

Regulatory
capital CDS

~245

150

38

7

6

Multi-sector
CDS

~13

8

7

6

5

~$1,800

$940

$352.8

$176

$168

Market
derivatives

Total

Notes: Net notional value in billions of dollars.
Sources: AIG, conference call presentations, May 4, 2012, February 24, 2012, and February 25, 2011, www.aigcorporate.
com/investors/financial_reports.html, accessed 7/21/2012; AIG 10-K for 2010, 2/24/2011, www.sec.gov/Archives/edgar/
data/5272/000104746911001283/0001047469-11-001283-index.htm, accessed 6/28/2012.

AIGFP’s remaining portfolio includes these components:
• The largest group of securities is $126 billion in what the company describes
as “market derivatives” that are fully hedged. Managed by AIG’s Global Capital
Markets Group, about three-fourths of these instruments are intended to
protect AIG affiliate companies’ own assets, while the others are “legacy” thirdparty client trades left from before the bailout.653
• Next in size is $19 billion in AIGFP securities meant to smooth out interest
rate volatility in stable value funds, which are similar to money market funds
but offer higher returns. AIGFP’s instruments, known as stable value wraps,
help fixed-income investments in stable value funds maintain book value even if
market value drops.654 On May 4, 2012, AIG said it expected to move the stable
value wraps to one of its insurance entities this year.655
• Another component of the AIGFP portfolio is $12 billion in CDS contracts
written for bundles of corporate debt.656
• A dwindling number of CDS contracts that AIGFP tailored specifically for
European banks also remain. Banks bought these regulatory capital swaps as
protection from potential losses on mortgages and corporate loans so they could
hold less capital and still comply with regulatory requirements.657
• AIGFP’s portfolio includes $5 billion in synthetic CDOs not placed into Maiden
Lane III.658 AIG said this set of securities “managed to retain significant future
upside” for additional profits.
According to AIG’s 2011 Form 10-K, “The senior management of AIGFP
reports the results of its operations to and reviews future strategies with AIG’s
senior management.”659 The Form 10-K provided details about some components

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of the AIGFP portfolio such as a breakdown of credit ratings, origination years of
RMBS, and risk sensitivity of remaining swaps.
AIG began edging back into securities lending in 2011, when Chartis began
lending municipal bonds and requiring counterparties to put up 102% collateral.660
SunAmerica began securities lending in early 2012.661 As of March 31, 2012, AIG
had securities valued at $8.9 billion pledged in securities-lending programs.662 That
compares with about $76 billion at the end of 2007 prior to the TARP injection.663

AIG’s Changing Regulatory Environment
In the years leading up to its near collapse, AIG’s massive size, interconnectedness,
geographic reach, and product breadth of operations were not matched by a
coherent U.S. regulatory structure to oversee its business. A combination of state,
international, and Federal authorities regulate AIG and its subsidiaries. There is
currently no Federal banking regulator with responsibility for overseeing AIG’s noninsurance financial businesses.
AIG’s domestic, life, and property/casualty insurance subsidiaries are regulated
by the state insurance regulators or foreign regulators where these companies are
domiciled or operate.v The state insurance regulators examine the parent company
only to the extent that it relates to the insurance subsidiaries.vi Foreign insurance
regulators, operating under their own countries’ laws, have jurisdiction over AIG’s
overseas insurance subsidiaries.
From 1999 to March 2010, OTS was the supervisor of AIG’s non-insurance
financial business because AIG was permitted to be considered a savings and loan
holding company due to its ownership of a small Wilmington, Delaware, thrift, AIG
Federal Savings Bank, which accounted for a tiny piece of its operations. This was
significant because the European Union required foreign companies doing business in Europe to have the equivalent of a “consolidated supervisor” in their home
country. Starting in 2004, OTS had worked to successfully persuade the European
Union that it was capable of performing this role.664 AIG was subject to OTS
regulation, examination, supervision, and reporting requirements. OTS also had
enforcement authority over AIG and its subsidiaries and could restrict or prohibit
activities that were a serious risk to the financial safety, soundness, or stability of
AIG Federal Savings Bank. The Office of the Comptroller of the Currency is now
responsible for regulating AIG Federal Savings Bank, but not the rest of the company. Since 2010, AIG has been in discussions with European regulators concerning consolidated regulation.665

	The primary state insurance regulators include New York, Pennsylvania, and Texas.
	Though examinations of the AIG parent were limited to how it related to the subsidiaries, the regulators typically obtained additional
information about the parent through informal channels, such as regular communications with parent company management and review
of public filings. (Congressional Oversight Panel, “June Oversight Report: The AIG Rescue, Its Impact on Markets, and the Government’s
Exit Strategy,” 6/10/2010, p. 23, http://cybercemetery.unt.edu/archive/cop/20110401232818/http://cop.senate.gov/reports/
library/report-061010-cop.cfm, accessed 6/28/2012.)

v

vi

quarterly report to congress I July 25, 2012

The Federal Reserve has not regulated AIG either before or after the bailout. Its
involvement with the company was instead through the Federal Reserve’s responsibility to maintain financial system stability and contain systemic risk that may arise
in financial markets.
The significant interconnectedness and complexity of AIG’s businesses, and the
lack of effective regulatory oversight of AIG’s financial business, were factors in
AIG’s near collapse and subsequent bailout. Despite what turned out to be AIG’s
key role as a financial institution, its only U.S. Federal banking regulator was OTS.
AIGFP fell outside the scope of the state insurance regulators, even though its
CDS had a function similar to insurance, and AIGFP’s CDS trades fell outside
OTS’s regulatory authority. This regulatory structure meant there was no comprehensive examination and regulation of CDS activity within AIGFP. Certain other
financial operations inside AIG — including capital markets, consumer finance,
and aircraft leasing — were regulated on a piecemeal basis or escaped regulation
entirely.
As the FCIC and COP concluded in separate reports to Congress, OTS failed
in its role as AIG’s consolidated supervisor; it neither understood its responsibility
nor had the tools to oversee the entire company’s complex financial services,
including AIGFP. As AIG’s holding company regulator, OTS was charged with overseeing the parent and had the power and the duty to spot and require the company
to curtail its risk, but according to COP, it “failed to do so.”666 At a March 2009
congressional hearing, then-Acting OTS Director Scott Polakoff acknowledged that
his agency failed to recognize the extent of the liquidity risk in AIGFP’s CDS portfolio. In addition, John Reich, a former OTS director, told the FCIC that as late as
September 2008, he had “no clue — no idea — what [AIG’s] CDS liability was.”667
He further told the FCIC, “At the simplest level, . . . an organization like OTS cannot supervise AIG, GE, Merrill Lynch, and entities that have worldwide offices. . .
it’s like a gnat on an elephant — there’s no way.”668
The Dodd-Frank Act may subject AIG to substantial additional Federal regulation. The law abolished OTS and moved supervision of savings and loan institutions to the OCC and supervision of their holding companies to the Federal
Reserve. The Federal Reserve could take over regulating AIG if it recognizes
AIG as a savings and loan holding company under the Home Owners’ Loan Act.
However, AIG anticipates that it will not be a savings and loan holding company
until Treasury holds less than 50% ownership interest.669 The Dodd-Frank Act also
set up a new framework for supervising nonbank financial companies designated
as systemically important financial institutions because of the role they play in the
financial system. SIFIs face more stringent capital and liquidity requirements and
annual stress tests, among other things. They also will be required to follow heightened corporate governance requirements and to prepare “living wills” — plans on
how they could be unwound if they fail.
Nonbank SIFI designations have not yet been made and there is no stated
time frame to do so. On April 3, 2012, the Financial Stability Oversight Council
(“FSOC”), a collection of regulators responsible for rule-making in this area,
issued a final rule effective May 11, 2012, with the criteria and process it will

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use to decide which large U.S. nonbank financial firms are designated as SIFIs.
A nonbank financial institution may be designated a SIFI if it is predominantly
engaged in financial activities. FSOC currently is analyzing the potential systemic
importance of individual companies. However, before any SIFI determination can
be made, the Federal Reserve Board must define what it means for a company to
be “predominantly engaged in financial activities.”
If FSOC designates AIG as a nonbank SIFI, AIG would be subject to Federal
Reserve examination, enforcement, and supervision. AIG’s senior managers expect
AIG to be named a SIFI, and they say that AIG has begun preparing for this designation. “People say, ‘Are you worried about being a SIFI? Are you worried about the
Federal Reserve?’ No. I welcome it,” Benmosche said at an insurance conference
earlier this year.670 Peter Hancock, the head of AIG’s Chartis insurance unit, told a
conference last December, “We’ve done more to de-lever our balance sheet and become Fed-ready, because we expect to be regulated by the Fed, than I think almost
any other large insurance company.”671
While the Dodd-Frank Act’s nonbank SIFI designation process was intended to
give regulators better oversight of nonbank financial players that have crucial roles
in the nation’s financial system and subject those designated entities to prudential
standards promulgated by the Federal Reserve, the designation of a company as a
SIFI is only the first step in a host of challenges Federal regulators face in implementing financial reform. If AIG is designated as a SIFI or recognized as a savings
and loan holding company, the Federal Reserve, as its primary supervisor, will face
enormous examination, enforcement, supervision, and logistical challenges in its
responsibility to provide comprehensive and effective oversight. This is particularly
true as it relates to risk, given AIG’s history.
Although AIG has made changes while in TARP, it remains one of the world’s
largest companies, with hundreds of subsidiaries in more than 130 countries.
Comprehensive and effective oversight of AIG would require the Federal Reserve
to have extensive expertise with and knowledge of a wide array of nonbanking
businesses and their risks, including AIG’s insurance operations, aircraft leasing
business, its mortgage guaranty, securities lending, and other derivatives trading
business.
One vital concern for AIG (and any future regulator of AIG) is determining
the proper level of risk to make a profit while minimizing the chance of failure.
Although this is a continuing challenge for all companies, given its history, risk is
of particular concern for AIG. In its 2011 annual report, AIG said, “Risk management is a key element of AIG’s approach to corporate governance.”672 This statement is not much different from statements made before the company crashed. In
its 2007 annual report, the company said, “AIG believes that strong risk management practices and a sound internal control environment are fundamental to its
continued success and profitable growth.”673 And until shortly before the company
imploded, AIG executives denied there was much, if any, risk from its derivatives
portfolio. Even during an August 2007 investor presentation in which AIG revealed
that AIGFP had $79 billion in exposure to super-senior multi-sector CDOs (largely
U.S. subprime mortgages), and that the AIG securities lending portfolio included

quarterly report to congress I July 25, 2012

$28.7 billion in sub-prime RMBS, accompanying slides emphasized that risk was
“extremely remote.”674 On a telephone call with analysts that day, Joseph Cassano,
then the head of AIGFP, said, “It is hard for us, without being flippant, to even see
a scenario within any kind of realm or reason that would see us losing $1 in any of
those transactions.”675 Within a year, the bottom dropped out.
The decisions regulators make today about AIG will be crucial to protecting taxpayers in the future. Proper and effective supervision of AIG is just one of
the many challenges regulators will likely face in the months and years to come.
Effective, comprehensive, and rigorous regulation of AIG is vital to ensure that history does not repeat itself and that taxpayers are protected.

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Sect ion 4

TARP Operations and
Administration

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special inspector general I troubled asset relief program

quarterly report to congress I July 25, 2012

Under the Emergency Economic Stabilization Act of 2008 (“EESA”), Congress
authorized the Secretary of the Treasury (“Treasury Secretary”) to create the
operational and administrative mechanisms to carry out the Troubled Asset Relief
Program (“TARP”). EESA established the Office of Financial Stability (“OFS”)
within the U.S. Department of the Treasury (“Treasury”). OFS is responsible for
administering TARP.676 Treasury has authority to establish program vehicles, issue
regulations, directly hire or appoint employees, enter into contracts, and designate
financial institutions as financial agents of the Government.677 In addition to using
permanent and interim staff, OFS relies on contractors and financial agents for
legal services, investment consulting, accounting, and other key services.

TARP Administrative and Program
Expenditures
As of June 30, 2012, Treasury has obligated $314.2 million for TARP
administrative costs and $797.3 million in programmatic expenditures for a total
of $1.1 billion. According to Treasury, as of June 30, 2012, it had spent $265.5
million on TARP administrative costs and $697.0 million on programmatic
expenditures, for a total of $962.5 million.678 Treasury reported that it employs 74
career civil servants, 97 term appointees, and 22 reimbursable detailees, for a total
of 193 full-time employees.679 Table 4.1 provides a summary of the expenditures
and obligations for TARP administrative costs through June 30, 2012. These costs
are categorized as “personnel services” and “non-personnel services.”

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TABLE 4.1

TARP ADMINISTRATIVE EXPENDITURES AND OBLIGATIONS
Budget Object Class Title

Obligations for Period Expenditures for Period
Ending 6/30/2012
Ending 6/30/2012

Personnel Services
Personnel Compensation & Benefits
Total Personnel Services

$94,533,456

$94,364,796

$94,533,456

$94,364,796

$1,908,580

$1,854,247

11,960

11,960

764,636

689,873

402

402

215,389,359

166,974,667

1,364,438

1,356,533

253,286

243,907

—

—

Non-Personnel Services
Travel & Transportation of Persons
Transportation of Things
Rents, Communications, Utilities & Misc.
Charges
Printing & Reproduction
Other Services
Supplies & Materials
Equipment
Land & Structures

634

634

Total Non-Personnel Services

Dividends and Interest

$219,693,295

$171,132,223

Grand Total

$314,226,751

$265,497,019

Notes: Numbers affected by rounding. The cost associated with “Other Services” under TARP Administrative Expenditures and
Obligations are composed of administrative services including financial, administrative, IT, and legal (non-programmatic) support.
Source: Treasury, response to SIGTARP data call, 7/9/2012.

Current Contractors and Financial
Agents
As of June 30, 2012, Treasury had retained 139 private vendors: 18 financial agents
and 121 contractors, to help administer TARP.680 Table 4.2 provides a summary of
the programmatic expenditures, which include costs to hire financial agents and
contractors, and obligations through June 30, 2012, excluding costs and obligations
related to personnel services and travel and transportation. Although Treasury has
informed SIGTARP that it “does not track” the number of individuals who provide
services under its agreements, the number likely dwarfs the 193 that Treasury
has identified as working for OFS.681 For example, on October 14, 2010, the
Congressional Oversight Panel (“COP”) reported that “Fannie Mae alone currently
has 600 employees working to fulfill its TARP commitments.”682

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quarterly report to congress I July 25, 2012

TABLE 4.2

OFS SERVICE CONTRACTS
Type of
Transaction

Obligated
Value

Expended
Value

Legal services for the implementation of
TARP

Contract

$931,090

$931,090

Ennis Knupp & Associates Inc.1

Investment and Advisory Services

Contract

2,635,827

2,635,827

10/14/2008

The Bank of New York Mellon
Corporation

Custodian

Financial Agent

48,098,612

45,712,347

10/16/2008

PricewaterhouseCoopers

Internal control services

Contract

34,921,161

32,352,065

9,000

—

Date

Vendor

Purpose

10/10/2008

Simpson Thacher & Bartlett MNP LLP

10/11/2008

10/17/2008

Turner Consulting Group, Inc.2

For process mapping consultant services

Interagency
Agreement

10/18/2008

Ernst & Young LLP

Accounting Services

Contract

14,550,519

13,640,626

10/29/2008

Hughes Hubbard & Reed LLP

Legal services for the Capital
Purchase Program

Contract

3,060,921

2,835,357

10/29/2008

Squire, Sanders & Dempsey LLP

Legal services for the Capital
Purchase Program

Contract

2,687,999

2,687,999

10/31/2008

Lindholm & Associates, Inc.

Human resources services

Contract

614,963

614,963

11/7/2008

Sonnenschein Nath & Rosenthal LLP4

Legal services related to auto industry
loans

Contract

2,702,441

2,702,441

11/9/2008

Internal Revenue Service

Detailees

Interagency
Agreement

97,239

97,239

11/17/2008

Internal Revenue Service

CSC Systems & Solutions LLC2

Interagency
Agreement

8,095

8,095

11/25/2008

Department of the Treasury —
Departmental Offices

Administrative Support

Interagency
Agreement

16,512,820

16,131,121

12/3/2008

Alcohol and Tobacco Tax and
Trade Bureau

IAA — TTB Development, Mgmt &
Operation of SharePoint

Interagency
Agreement

67,489

67,489

12/5/2008

Washington Post3

Subscription

Interagency
Agreement

395

—

12/10/2008

Sonnenschein Nath & Rosenthal LLP4

Legal services for the purchase of
assets-backed securities

Contract

102,769

102,769

12/10/2008

Thacher Proffitt & Wood4

Admin action to correct system issue

Contract

—

—

12/15/2008

Office of Thrift Supervision

Detailees

Interagency
Agreement

225,547

164,823

12/16/2008

Department of Housing and
Urban Development

Detailees

Interagency
Agreement

—

—

12/22/2008

Office of Thrift Supervision

Detailees

Interagency
Agreement

103,871

—

12/24/2008

Cushman and Wakefield of VA Inc.

Painting Services for TARP Offices

Contract

8,750

8,750

1/6/2009

Securities and Exchange Commission Detailees

Interagency
Agreement

30,416

30,416

1/7/2009

Colonial Parking Inc.

Lease of parking spaces

Contract

338,050

224,033

1/27/2009

Cadwalader Wickersham & Taft LLP

Bankruptcy Legal Services

Contract

409,955

409,955

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OFS SERVICE CONTRACTS

(Continued)

Date

Vendor

Purpose

Type of
Transaction

Obligated
Value

Expended
Value

1/27/2009

Whitaker Brothers Bus Machines Inc.

Paper Shredder

Contract

$3,213

$3,213

1/30/2009

Comptroller of the Currency

Detailees

Interagency
Agreement

501,118

501,118

2/2/2009

US Government Accountability Office

IAA — GAO required by P.L. 110-343 to
conduct certain activities related to
TARP IAA

Interagency
Agreement

7,459,049

7,459,049

2/3/2009

Internal Revenue Service

Detailees

Interagency
Agreement

242,499

242,499

2/9/2009

Pat Taylor & Associates, Inc.

Temporary Services for Document
Production, FOIA assistance, and
Program Support

Contract

692,108

692,108

2/12/2009

Locke Lord Bissell & Liddell LLP

Initiate Interim Legal Services in support of
Contract
Treasury Investments under EESA

272,243

272,243

2/18/2009

Fannie Mae

Homeownership Preservation Program

Financial Agent

318,054,368

283,824,329

2/18/2009

Freddie Mac

Homeownership Preservation Program

Financial Agent

209,158,529

181,217,492

2/20/2009

Financial Clerk U.S. Senate

Congressional Oversight Panel

Interagency
Agreement

3,394,348

3,394,348

2/20/2009

Office of Thrift Supervision

Detailees

Interagency
Agreement

203,390

189,533

2/20/2009

Simpson Thacher & Bartlett MNP LLP Capital Assistance Program (I)

Contract

1,530,023

1,530,023

2/20/2009

Venable LLP

Capital Assistance Program (II)
Legal Services

Contract

1,394,724

1,394,724

2/26/2009

Securities and Exchange Commission Detailees

Interagency
Agreement

18,531

18,531

2/27/2009

Pension Benefit Guaranty Corporation Rothschild, Inc.

Interagency
Agreement

7,750,000

7,750,000

3/6/2009

The Boston Consulting Group

Management Consulting relating to the
Auto industry

Contract

991,169

991,169

3/16/2009

Earnest Partners

Small Business Assistance Program

Financial Agent

2,947,780

2,947,780

3/30/2009

Bingham McCutchen LLP5

SBA Initiative Legal Services — Contract
Novated from TOFS-09-D-0005 with
McKee Nelson

Contract

273,006

143,893

3/30/2009

Cadwalader Wickersham & Taft LLP

Auto Investment Legal Services

Contract

17,392,786

17,392,786

3/30/2009

Haynes and Boone, LLP

Auto Investment Legal Services

Contract

345,746

345,746

3/30/2009

McKee Nelson5

SBA Initiative Legal Services — Contract
Novated to TOFS-10-D-0001 with Bingham Contract
McCutchen LLP

149,349

126,631

3/30/2009

Sonnenschein Nath & Rosenthal LLP4 Auto Investment Legal Services

Contract

1,834,193

1,834,193

3/31/2009

FI Consulting Inc.

Credit Reform Modeling and Analysis

Contract

4,124,750

3,041,748

35,187

25,808

4,100,195

4,099,923

4/3/2009

American Furniture Rentals Inc.3

Furniture Rental 1801

Interagency
Agreement

4/3/2009

The Boston Consulting Group

Management Consulting relating to the
Auto industry

Contract

4/17/2009

Bureau of Engraving and Printing

Detailees

Interagency
Agreement

45,822

45,822

4/17/2009

Herman Miller, Inc.

Aeron Chairs

Contract

53,799

53,799

4/21/2009

AllianceBernstein LP

Asset Management Services

Financial Agent

43,372,479

39,575,340

4/21/2009

FSI Group, LLC

Asset Management Services

Financial Agent

23,633,383

22,052,953

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OFS SERVICE CONTRACTS

(Continued)

Date

Vendor

Purpose

Type of
Transaction

Obligated
Value

Expended
Value

4/21/2009

Piedmont Investment Advisors, LLC

Asset Management Services

Financial Agent

$11,561,031

$10,588,154

4/30/2009

Department of State

Detailees

Interagency
Agreement

—

—

5/5/2009

Federal Reserve Board

Detailees

Interagency
Agreement

48,422

48,422

5/13/2009

Department of the Treasury —
U.S. Mint

“Making Home Affordable” Logo search

Interagency
Agreement

325

325

5/14/2009

Knowledgebank Inc.2

Executive Search and recruiting Services
— Chief Homeownership Officer

Contract

124,340

124,340

5/15/2009

Phacil, Inc.

Freedom of Information Act (FOIA) Analysts
to support the Disclosure Services, Privacy Contract
and Treasury Records

90,301

90,301

5/20/2009

Securities and Exchange Commission Detailees

Interagency
Agreement

430,000

430,000

5/22/2009

Department of Justice — ATF

Detailees

Interagency
Agreement

243,778

243,778

5/26/2009

Anderson, McCoy & Orta

Legal services for work under Treasury’s
Public Private Investment Funds (PPIF)
program

Contract

2,286,996

2,286,996

5/26/2009

Legal services for work under Treasury’s
Simpson Thacher & Bartlett MNP LLP Public Private Investment Funds (PPIF)
program

Contract

7,849,026

3,526,454

6/9/2009

Financial Management Services

Gartner, Inc.

Interagency
Agreement

89,436

89,436

6/29/2009

Department of the Interior

Federal Consulting Group (Foresee)

Interagency
Agreement

49,000

49,000

7/17/2009

Korn/Ferry International

Executive search services for the OFS
Chief Investment Officer position

Contract

74,023

74,023

7/30/2009

Cadwalader Wickersham & Taft LLP

Restructuring Legal Services

Contract

1,278,696

1,278,696

7/30/2009

Debevoise & Plimpton LLP

Restructuring Legal Services

Contract

1,650

1,650

7/30/2009

Fox, Hefter, Swibel, Levin &
Carol, LLP

Restructuring Legal Services

Contract

26,493

26,493

8/10/2009

Department of Justice — ATF

Detailees

Interagency
Agreement

63,109

63,109

8/10/2009

National Aeronautics and Space
Administration (NASA)

Detailees

Interagency
Agreement

140,889

140,889

8/18/2009

Mercer (US) Inc.

Executive Compensation Data Subscription Contract

3,000

3,000

63,248

63,248

5,000

5,000

8/25/2009

Department of Justice — ATF

Detailees

Interagency
Agreement

9/2/2009

Knowledge Mosaic Inc.

SEC filings subscription service

Contract

9/10/2009

Equilar, Inc.

Executive Compensation Data Subscription Contract

9/11/2009

PricewaterhouseCoopers

PPIP compliance

Contract

59,990

59,990

3,065,705

2,976,502

9/18/2009

Treasury Franchise Fund

BPD

Interagency
Agreement

436,054

436,054

9/30/2009

Immixtechnology Inc.3

EnCase eDiscovery ProSuite

Interagency
Agreement

210,184

—

9/30/2009

Immixtechnology Inc.3

Guidance Inc.

Interagency
Agreement

108,000

—

Continued on next page

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OFS SERVICE CONTRACTS

(Continued)

Date

Vendor

Purpose

Type of
Transaction

Obligated
Value

Expended
Value

9/30/2009

NNA INC.

Newspaper delivery

Contract

$8,479

$8,220

9/30/2009

SNL Financial LC

SNL Unlimited, a web-based
financial analytics service

Contract

460,000

460,000

11/9/2009

Department of the Treasury —
Departmental Offices

Administrative Support

Interagency
Agreement

23,682,061

18,056,064

12/16/2009

Internal Revenue Service

Detailees

Interagency
Agreement

—

—

12/22/2009

Avondale Investments LLC

Asset Management Services

Financial Agent

772,657

772,657

12/22/2009

Bell Rock Capital, LLC

Asset Management Services

Financial Agent

2,175,615

1,868,409

12/22/2009

Howe Barnes Hoefer & Arnett, Inc.

Asset Management Services

Financial Agent

3,284,195

2,947,231

12/22/2009

Hughes Hubbard & Reed LLP

Document Production services and
Litigation Support

Contract

1,456,803

855,396

12/22/2009

KBW Asset Management, Inc.

Asset Management Services

Financial Agent

4,937,433

4,937,433

12/22/2009

Lombardia Capital Partners, LLC

Asset Management Services

Financial Agent

3,242,419

2,810,840

12/22/2009

Paradigm Asset Management
Co., LLC

Asset Management Services

Financial Agent

3,298,978

2,968,731

1/14/2010

US Government Accountability Office

IAA — GAO required by P.L.110-343 to
conduct certain activities related to TARP

Interagency
Agreement

7,304,722

7,304,722

1/15/2010

Association of Government
Accountants

CEAR Program Application

Contract

5,000

5,000

2/16/2010

Internal Revenue Service

Detailees

Interagency
Agreement

52,742

52,742

2/16/2010

The MITRE Corporation

FNMA IR2 assessment — OFS task order
on Treasury MITRE Contract

Contract

730,192

730,192

2/18/2010

Treasury Franchise Fund

BPD

Interagency
Agreement

1,221,140

1,221,140

3/8/2010

Qualx Corporation

FOIA Support Services

Contract

549,518

549,518

3/12/2010

Department of the Treasury —
Departmental Offices

Administrative Support

Interagency
Agreement

671,731

671,731

3/22/2010

Gartner, Inc.

Financial Management Services

Interagency
Agreement

73,750

73,750

3/26/2010

Federal Maritime Commission

Detailees

Interagency
Agreement

158,600

158,600

3/29/2010

Morgan Stanley

Disposition Agent Services

Financial Agent

16,685,290

16,685,290

4,797,556

4,797,556

4/2/2010

Financial Clerk U.S. Senate

Congressional Oversight Panel

Interagency
Agreement

4/8/2010

Squire, Sanders & Dempsey LLP

Housing Legal Services

Contract

1,229,350

918,224

4/12/2010

Hewitt EnnisKnupp, Inc.

Investment Consulting Services

Contract

4,499,750

2,661,486

4/22/2010

Digital Management Inc.

Data and Document Management
Consulting Services

Contract

—

—

4/22/2010

MicroLink, LLC

Data and Document Management
Consulting Services

Contract

11,442,511

8,425,393

4/23/2010

RDA Corporation

Data and Document Management
Consulting Services

Contract

6,626,280

4,309,463

5/4/2010

Internal Revenue Service

Training — Bulux CON 120

Interagency
Agreement

1,320

1,320

1

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quarterly report to congress I July 25, 2012

OFS SERVICE CONTRACTS

(Continued)

Date

Vendor

Purpose

Type of
Transaction

Obligated
Value

Expended
Value

5/17/2010

Lazard Fréres & Co. LLC

Transaction Structuring Services

Financial Agent

$15,032,527

$11,518,280

6/24/2010

Reed Elsevier Inc (dba LexisNexis)

Accurint subscription service for
one year — 4 users

Contract

8,208

8,208

6/30/2010

The George Washington University

Financial Institution Management &
Modeling — Training course (J.Talley)

Contract

5,000

5,000

7/21/2010

Navigant Consulting

Program Compliance Support Services

Contract

1,766,984

313,234

7/21/2010

Regis and Associates PC

Program Compliance Support Services

Contract

1,161,816

296,521

7/22/2010

Ernst & Young LLP

Program Compliance Support Services

Contract

3,323,286

2,042,110

7/22/2010

PricewaterhouseCoopers

Program Compliance Support Services

Contract

—

—

7/22/2010

Schiff Hardin LLP

Housing Legal Services

Contract

97,526

97,526

7/27/2010

West Publishing Corporation

Subscription Service for 4 users

Contract

6,722

6,664

8/6/2010

Alston & Bird LLP

Omnibus procurement for legal services

Contract

1,339,366

213,527

8/6/2010

Cadwalader Wickersham & Taft LLP

Omnibus procurement for legal services

Contract

5,949,077

2,789,647

8/6/2010

Fox, Hefter, Swibel, Levin &
Carol, LLP

Omnibus procurement for legal services

Contract

199,200

152,947

8/6/2010

Haynes and Boone, LLP

Omnibus procurement for legal services

Contract

—

—

8/6/2010

Hughes Hubbard & Reed LLP

Omnibus procurement for legal services

Contract

1,877,048

796,190

8/6/2010

Love & Long LLP

Omnibus procurement for legal services

Contract

—

—

8/6/2010

Orrick Herrington Sutcliffe LLP

Omnibus procurement for legal services

Contract

—

—

8/6/2010

Paul, Weiss, Rifkind, Wharton &
Garrison LLP

Omnibus procurement for legal services

Contract

6,475,491

2,911,462

8/6/2010

Perkins Coie LLP

Omnibus procurement for legal services

Contract

—

—

8/6/2010

Seyfarth Shaw LLP

Omnibus procurement for legal services

Contract

—

—

8/6/2010

Shulman, Rogers, Gandal, Pordy &
Ecker, PA

Omnibus procurement for legal services

Contract

313,725

202,303

8/6/2010

Sullivan Cove Reign Enterprises JV

Omnibus procurement for legal services

Contract

—

—

8/6/2010

Venable LLP

Omnibus procurement for legal services

Contract

498,100

960

8/12/2010

Knowledge Mosaic Inc.

SEC filings subscription service

Contract

5,000

5,000

8/30/2010

Department of Housing and
Urban Development

Detailees

Interagency
Agreement

29,915

29,915

9/1/2010

CQ-Roll Call Inc.

One-year subscription (3 users) to the CQ
Today Breaking News & Schedules, CQ
Contract
Congressional & Financial Transcripts, CQ
Custom Email Alerts

7,500

7,500

9/17/2010

Bingham McCutchen LLP5

SBA 7(a) Security Purchase Program

Contract

19,975

11,177

Davis Audrey Robinette

Program Operations Support Services to
include project management, scanning
and document management and
correspondence

Contract

2,328,450

1,852,662

9/30/2010

CCH Incorporated

GSA Task Order for procurement
books — FAR, T&M, Government
Contracts Reference, World Class
Contracting

Contract

2,430

2,430

10/1/2010

Financial Clerk U.S. Senate

Congressional Oversight Panel

Interagency
Agreement

5,200,000

2,777,752

10/8/2010

Management Concepts Inc.

Training Course — CON 217

Contract

1,025

1,025

9/27/2010

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OFS SERVICE CONTRACTS

(Continued)

Date

Vendor

Purpose

Type of
Transaction

Obligated
Value

Expended
Value

10/8/2010

Management Concepts Inc.

Training Course — CON 216

Contract

$1,025

$1,025

10/8/2010

Management Concepts Inc.

Training Course — CON 218

Contract

2,214

2,214

10/8/2010

Management Concepts Inc.

Training Course — 11107705

Contract

995

995

10/8/2010

Management Concepts Inc.

Training Course — Analytic Boot

Contract

1,500

1,500

10/8/2010

Management Concepts Inc.

Training Course — CON 218

Contract

2,214

2,214

10/8/2010

Management Concepts Inc.

Training Course — CON 217

Contract

1,025

1,025

10/8/2010

Management Concepts Inc.

Training Course — CON 218

Contract

2,214

2,214

10/14/2010

Hispanic Association of Colleges &
Universities

Detailees

Contract

12,975

12,975

10/26/2010

US Government Accountability Office

IAA — GAO required by P.L. 110-343 to
conduct certain activities related to TARP

Interagency
Agreement

5,600,000

3,738,195

11/8/2010

The MITRE Corporation

FNMA IR2 assessment — OFS task order
on Treasury MITRE Contract for cost and Contract
data validation services related to HAMP FA

2,288,166

1,501,419

11/18/2010

Greenhill & Co., Inc.

Structuring and Disposition Services

6,139,167

6,139,167

12/2/2010

Addx Corporation

Acquisition Support Services — PSD TARP
Contract
(action is an order against BPA)

1,311,314

1,148,690

12/29/2010

Reed Elsevier Inc. (dba LexisNexis)

Accurint subscription services one user

Contract

1,026

684

1/5/2011

Canon U.S.A. Inc.

Administrative Support

Interagency
Agreement

12,937

12,013

1/18/2011

Perella Weinberg Partners & Co.

Structuring and Disposition Services

Financial Agent

5,542,473

5,542,473

1,092,962

1,090,860

Financial Agent

1/24/2011

Treasury Franchise Fund

BPD

Interagency
Agreement

1/26/2011

Association of Government
Accountants

CEAR Program Application

Contract

5,000

5,000

2/24/2011

ESI International Inc.

Mentor Program Training
(call against IRS BPA)

Contract

20,758

20,758

2/28/2011

Department of the Treasury —
Departmental Offices

Administrative Support

Interagency
Agreement

17,805,529

13,299,171

3/3/2011

Equilar, Inc.

Executive Compensation Data Subscription Contract

59,995

59,995

3/10/2011

Mercer (US) Inc.

Executive Compensation Data Subscription Contract

7,425

3,600

3/22/2011

Harrison Scott Publications, Inc.

Subscription Service

Contract

5,894

5,894

3/28/2011

Fox News Network LLC6

Litigation Settlement

Interagency
Agreement

121,000

121,000

4/20/2011

Federal Reserve Bank of New York
(FRBNY) HR

Oversight Services

Interagency
Agreement

1,300,000

875,415

4/26/2011

PricewaterhouseCoopers LLP

Financial Services Omnibus

Contract

2,509,632

1,442,695

4/27/2011

ASR Analytics, LLC

Financial Services Omnibus

Contract

—

—

4/27/2011

Ernst & Young, LLP

Financial Services Omnibus

Contract

1,414,262

283,378

4/27/2011

FI Consulting, Inc.

Financial Services Omnibus

Contract

1,703,711

1,105,778

4/27/2011

Lani Eko & Company CPAs LLC

Financial Services Omnibus

Contract

50,000

—

4/27/2011

MorganFranklin, Corporation

Financial Services Omnibus

Contract

50,000

—

4/27/2011

Oculus Group, Inc.

Financial Services Omnibus

Contract

2,284,646

608,490

4/28/2011

Booz Allen Hamilton, Inc.

Financial Services Omnibus

Contract

50,000

—

4/28/2011

KPMG, LLP

Financial Services Omnibus

Contract

50,000

—

Continued on next page

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quarterly report to congress I July 25, 2012

OFS SERVICE CONTRACTS

(Continued)

Type of
Transaction

Obligated
Value

Expended
Value

$21,300

$—

Contract

10,260

6,840

Contract

7,515

7,515

CQ-Roll Call Inc.

One year subscription to the CQ Today
Breaking News & Schedules, CQ
Contract
Congressional & Financial Transcripts, CQ
Custom Email Alerts

7,750

7,750

6/17/2011

Winvale Group LLC

Anti-Fraud Protection and Monitoring
Subscription Services

504,232

242,507

7/28/2011

Internal Revenue Service-Procurement Detailee

Interagency
Agreement

84,234

84,234

9/9/2011

Financial Management Service

FMS – NAFEO

Interagency
Agreement

22,755

—

9/12/2011

ADC LTD NM

MHA Felony Certification Background
Checks (BPA)

Contract

447,799

227,950

9/15/2011

ABMI – All Business Machines, Inc

4 Level 4 Security Shredders and Supplies Contract

4,392

4,392

9/29/2011

Department of Interior

National Business Center, Federal
Consulting Group

Interagency
Agreement

25,000

25,000

9/29/2011

Knowledge Mosaic Inc.

Renewing TD010-F-249 SEC filings
Subscription Service

Contract

4,200

4,200

10/4/2011

Internal Revenue Service

IRS

Interagency
Agreement

168,578

63,216

10/20/2011

ABMI – All Business Machines, Inc.

4 Level 4 Security Shredders and Supplies Contract

4,827

4,827

Date

Vendor

Purpose

4/28/2011

Office of Personnel Management
(OPM) — Western Management
Development Center

Leadership Training

Interagency
Agreement

5/31/2011

Reed Elsevier Inc (dba LexisNexis)

Accurint subscriptions by LexisNexis for
5 users

5/31/2011

West Publishing Corporation

Five (5) user subscriptions to CLEAR by
West Government Solutions

6/9/2011

Contract

11/18/2011

Qualx Corporation

FOIA Support Services

Contract

11/29/2011

Houlihan Lokey, Inc.

Transaction Structuring Services

Financial Agent

68,006

68,006

4,500,000

2,661,290

12/20/2011

Allison Group LLC

Pre-Program and Discovery Process Team
Contract
Building

19,980

19,065

12/30/2011

Department of the Treasury —
Departmental Offices

Department of Treasury — DO

Interagency
Agreement

15,098,746

4,698,183

12/30/2011

Treasury Franchise Fund

ARC

Interagency
Agreement

901,433

674,451

1/4/2012

Government Accountability Office

Government Accountability Office

Interagency
Agreement

3,510,818

1,853,391

1/5/2012

Office of Personnel Management
(OPM) — Western Management
Development Center

Office of Personnel Management (OPM) — Interagency
Western Management Development Center Agreement

31,088

—

2/2/2012

Moody’s Analytics Inc.

ABS/MBS Data Subscription Services

Contract

1,804,000

1,043,333

1,050,000

706,034

5,000

5,000

2/7/2012

Greenhill & Co., LLC

Structuring and Disposition Services

FAA Listing

2/14/2012

Association of Govt Accountants

CEAR Program Application

Contract

2/27/2012

Diversified Search LLC

CPP Board Placement Services

Contract

50,000

135,175

3/6/2012

Integrated Federal Solutions, Inc.

TARP Acquisition Support (BPA)

Contract

99,750

87,282

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OFS SERVICE CONTRACTS

(Continued)

Date

Vendor

Purpose

Type of
Transaction

Obligated
Value

Expended
Value

3/14/2012

Department of Interior

National Business Center, Federal
Consulting Group

Interagency
Agreement

$26,000

$26,000

3/15/2012

Integrated Federal Solutions, Inc.

TARP Acquisition Support (BPA)

Contract

668,548

96,817

3/30/2012

Department of the Treasury —
Departmental Offices WCF

Departmental Offices

Interagency
Agreement

1,136,980

—

3/30/2012

E-Launch Multimedia, Inc.

Subscription Service

Contract

13,100

—

5/2/2012

Cartridge Technology, Inc.

Maintenance Agreement for Canon
ImageRunner

Contract

7,846

654

5/10/2012

Equilar Inc.

Executive Compensation Data Subscription Contract

44,995

44,995

6/12/2012

Department of Justice

Department of Justice

Interagency
Agreement

1,737,884

—

6/15/2012

Qualx Corporation

FOIA Support Services

Contract

50,000

—

West Publishing Corporation

Subscription for Anti Fraud Unit to Perform
Contract
Background Research

8,660

—

Department of the Treasury —
Departmental Offices

Administrative Support

Interagency
Agreement

660,601

660,601

Judicial Watch7

Litigation related

Other Listing

1,500

1,500

Judicial Watch

Litigation related

Other Listing

2,146

2,146

6/30/2012

7

Total

$1,035,016,005 $886,035,122

Notes: Numbers may not total due to rounding. At year-end, OFS validated the matrix against source documents resulting in modification of award date. At year-end, a matrix entry that included several
Interagency Agreements bundled together was split up to show the individual IAAs. For IDIQ contracts, $0 is obligated if no task orders have been awarded. Table 4.2 includes all vendor contracts
administered under Federal Acquisition Regulations, inter-agency agreements and financial agency agreements entered into support of OFS since the beginning of the program. The table does not include
salary, benefits, travel, and other non-contract related expenses.
1
	EnnisKnupp Contract TOFS-10-D-0004, was novated to Hewitt EnnisKnupp (TOFS-10-D-0004).
2
Awarded by other agencies on behalf of OFS and are not administered by PSD.
3
Awarded by other branches within the PSD pursuant to a common Treasury service level and subject to a reimbursable agreement with OFS.
4
Thacher Proffitt & Wood, Contract TOS09-014B, was novated to Sonnenschein Nath & Rosenthal (TOS09-014C).
5
	McKee Nelson Contract, TOFS-09-D-0005, was novated to Bingham McCutchen.
6
Fox News Network LLC is a payment in response to a litigation claim. No contract or agreement was issued to Fox News Network LLC.
7
Judicial Watch is a payment in response to a litigation claim. No contract or agreement was issued to Judicial Watch.
Source: Treasury, response to SIGTARP data call, 7/11/2012.

S ect i o n 5

SIGTARP Recommendations

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special inspector general I troubled asset relief program

quarterly report to congress I July 25, 2012

One of the critical responsibilities of the Office of the Special Inspector General
for the Troubled Asset Relief Program (“SIGTARP”) is to provide recommendations
to the U.S. Department of the Treasury (“Treasury”) and other Federal agencies
related to the Troubled Asset Relief Program (“TARP”) to facilitate transparency
and effective oversight and to prevent fraud, waste, and abuse. SIGTARP has made
105 recommendations in its quarterly reports to Congress and in many of its audit
reports. This section discusses developments with respect to SIGTARP’s prior
recommendations, including recommendations made since SIGTARP’s Quarterly
Report to Congress dated April 25, 2012 (the “April 2012 Quarterly Report”), and,
in the table at the end of this section, summarizes SIGTARP’s recommendations
from past quarters and notes the extent of implementation.

Recommendations from SIGTARP’s Audit of
the Hardest Hit Fund
In its audit report “Factors Affecting Implementation of the Hardest Hit Fund
Program,” released April 12, 2012, SIGTARP reviewed Treasury’s administration
of the Housing Finance Agency Innovation Fund for the Hardest Hit Housing
Markets (“HHF”). Under HHF, TARP dollars are meant to fund “innovative
measures” developed by 19 state housing finance agencies (“HFAs”). SIGTARP
found that after two years, HHF has experienced significant delay in providing
help to homeowners due to several factors, including a lack of comprehensive
planning by Treasury and a delay and limitation in participation in the program
by large servicers, and the GSEs Fannie Mae and Freddie Mac. In its audit,
SIGTARP reported that as of December 31, 2011, the latest data then available,
HHF had spent only $217.4 million to provide assistance to 30,640 homeowners
— approximately 3% of the TARP funds allocated to HHF and approximately 7% of
the minimum number of homeowners the state HFAs estimate helping over the life
of the program. The report included five recommendations to Treasury.
Treasury should set meaningful and measurable performance goals for
the Hardest Hit Fund program including, at a minimum, the number of
homeowners Treasury estimates will be helped by the program, and measure
the program’s progress against those goals.
Treasury has not set measurable goals and metrics that would allow Treasury,
the public, and Congress to measure the progress and success of HHF. Treasury set
a single goal for HHF: help prevent foreclosures and help preserve homeownership.
Treasury deferred to individual states to set goals but did not require those states to
set measurable goals. Most states’ goals are high-level expectations with no measurable target, such as Florida’s “preserving homeownership” and “protecting home
values.”
Rather than acknowledge that after more than two years, HHF is not reaching
enough homeowners and make changes suggested by SIGTARP that are designed

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to measure progress and ultimately reach those homeowners, Treasury is not
adopting SIGTARP’s recommendation. Rather than set meaningful goals for HHF
and measure progress against those goals, Treasury chooses instead to rely on its
requirement that each state estimate the number of households to be assisted. This
number has limited usefulness. First, states have been reporting this number for
more than two years and Treasury has not used this number effectively to change
the program to help a significant number of homeowners. Second, states can, and
have, changed estimates, creating a shifting baseline that makes it difficult to measure performance against expectations. The states’ estimated number of homeowners to be assisted by the Hardest Hit Fund has steadily decreased over the last year.
Treasury has not adopted this estimate or even reported it.
It is not too late for Treasury to set measurable goals, including at a minimum,
adopting the HFAs’ collective estimate or developing its own goal of how many
homeowners Treasury expects HHF to help. Treasury must set meaningful goals
and metrics to identify program successes and set-backs, and change the program
as needed. Treasury has stated that establishing static numeric targets is not suited
to the dynamic nature of HHF. Taxpayers that fund this program have an absolute
right to know what the Government’s expectations and goals are for using $7.6
billion in TARP funds. By refusing to set any goals for the programs, Treasury is
subject to criticism that it is attempting to avoid accountability.
Treasury should instruct state housing finance agencies in the Hardest Hit
Fund to set meaningful and measurable overarching and interim performance
goals with appropriate metrics to measure progress for their individual state
programs.
Treasury is not adopting this recommendation. Most states’ goals are high-level
expectations with no measurable targets. Although states estimate the number of
households to be assisted, these estimates are of limited value for performance
measurement because the states can, and have, changed that number. The states’
collective estimate of the number of households to be assisted is a moving target,
and has been steadily decreasing. If the estimate of the number of households to be
assisted changes, consistent performance measurement over the life of the program
is not possible, progress is no longer measured based on a goal established at the
outset, and opportunities for accountability to the public are diminished.
Treasury should set milestones at which the state housing finance agencies in
the Hardest Hit Fund must review the progress of individual state programs
and make program adjustments from this review.
Treasury has not agreed to implement this recommendation, although it would
be easy to do so. For example, Treasury could at a minimum adopt the HFAs’ estimates of homeowners to be assisted through 2017, and then set interim goals, such
as the number of homeowners that each state HFA should reach each year. States
continue to need Treasury’s help and support to increase the number of homeowners helped, and Treasury should do everything it can to ensure the program’s

quarterly report to congress I July 25, 2012

success. Without regular periodic milestones and program adjustments, opportunities to reach struggling homeowners may be lost.
Treasury should publish on its website and in the Housing Scorecard on a
quarterly basis the total number of homeowners assisted, funds drawn down
by states, and dollars expended for assistance to homeowners, assistance
committed to homeowners, and cash on hand, aggregated by all state Hardest
Hit Fund programs.
Treasury has rejected this basic recommendation for greater transparency.
While the 19 HFAs have provided a significant amount of transparency on their
HHF programs on each of their websites, Treasury itself can do more to improve
transparency. Tracking performance of all HHF programs would require a taxpayer to gather information from 19 websites. Treasury aggregates the number of
homeowners assisted and dollars expended, but SIGTARP, not Treasury, publishes
this information. Treasury should publish this information, along with other useful
information on HHF’s performance, on its website and in the monthly Housing
Scorecard that reports on the Administration’s efforts in housing programs. A
Treasury official told SIGTARP during its audit that it is appropriate to leave reporting of the data to the states, stating, “This is not our program. These are their programs.” However, HHF is a TARP program, the source of the funds is TARP, and
Treasury is the steward over TARP. Congress and the public are rightfully entitled
to increased transparency and accountability of how TARP funds are used.
Treasury should develop an action plan for the Hardest Hit Fund that
includes steps to increase the numbers of homeowners assisted and to gain
industry support for Treasury-approved HHF programs. Treasury should set
interim metrics for how many homeowners it intends to assist in a Treasurydefined time period in each particular program (such as principal reduction,
second lien reduction, or reinstatement). If Treasury cannot achieve the
desired level of homeowners assisted in any one program area in the defined
time period, Treasury should put the funds to better use toward programs that
are reaching homeowners.
Treasury is rejecting this recommendation. Treasury must change the status
quo and fulfill its role as steward over TARP programs and make determinations
of which programs are successful and which programs are not working. In particular, Treasury needs to develop an action plan that includes steps that Treasury
intends to take to increase dramatically the numbers of homeowners assisted in all
the HHF programs, including the two known areas Treasury supports but that are
lacking broad industry support — principal reduction and second-lien reduction. If
Treasury is unable to help struggling homeowners with one type of assistance, for
example principal reduction, then it must take leadership to put the funds to better
use. This may include putting the funds toward programs that are more successful
at reaching homeowners. Treasury has an obligation to ensure that HHF funds are
reaching homeowners, and it is unacceptable to delegate all of this responsibility to
the states.

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Recommendations from SIGTARP’s Audit of
the Net Present Value Test’s Impact on the
Home Affordable Modification Program
In its audit report “The Net Present Value Test’s Impact on the Home Affordable
Modification Program,” released June 18, 2012, SIGTARP assessed the issues
surrounding the Net Present Value (“NPV”) test that have posed challenges to
HAMP’s success. SIGTARP’s report identified concerns with the NPV test that
may stand as barriers to homeowners getting much-needed help from HAMP. The
report included four recommendations to Treasury.
Treasury should stop allowing servicers to add a risk premium to Freddie
Mac’s discount rate in HAMP’s net present value test.
SIGTARP found in its sample that the discretion that Treasury gave to servicers
to override the baseline discount rate in the NPV test by adding a risk premium (of
up to 2.5%) reduces the number of otherwise qualified homeowners Treasury helps
through HAMP. Treasury responded that it would discuss this recommendation
with SIGTARP, but that use of a risk premium is traditional in expected cash flow
modeling. HAMP is not a traditional program and the risk premium is not traditionally used by servicers in HAMP. Only four servicers add a risk premium, including Bank of America, N.A., and Wells Fargo Bank, N.A. More than 100 servicers do
not add a risk premium. There is a simple fix for Treasury to remove this obstacle to
homeowners getting into HAMP — tell servicers that risk premiums are no longer
allowed.
Treasury should ensure that servicers use accurate information when
evaluating net present value test results for homeowners applying to HAMP
and should ensure that servicers maintain documentation of all net present
value test inputs. To the extent that a servicer does not follow Treasury’s
guidelines on input accuracy and documentation maintenance, Treasury
should permanently withhold incentives from that servicer.
Any model will be only as good as its inputs. SIGTARP found in its sample that
servicers made errors using NPV inputs and did not properly maintain records of all
NPV inputs during the period of our review. Within SIGTARP’s judgmental sample
of 149 HAMP applications, SIGTARP found that the servicers could provide both
accurate inputs and documentation for only two HAMP applications. SIGTARP
found that servicers failed to comply with HAMP guidelines on maintaining
records on NPV inputs, which is crucial for compliance and to protect homeowners’ rights to challenge servicer error. Treasury responded that it would discuss this
recommendation with SIGTARP.
Treasury should require servicers to improve their communication with
homeowners regarding denial of a HAMP modification so that homeowners
can move forward with other foreclosure alternatives in a timely and fully

quarterly report to congress I July 25, 2012

informed manner. To the extent that a servicer does not follow Treasury’s
guidelines on these communications, Treasury should permanently withhold
incentives from that servicer.
In its sample, SIGTARP found that servicers had poor communication with
homeowners on the denial of a HAMP modification due to the NPV test. HAMP
guidelines require that servicers communicate a denial to the homeowner within
10 days of the decision. Servicers’ failure to communicate denial in a timely manner can have serious consequences because a delay may prevent homeowners from
finding other foreclosure alternatives sooner. In addition, HAMP guidelines require
that the servicer list certain NPV inputs and provide vital information on foreclosure alternatives in the denial letter. Treasury said it would discuss this recommendation with SIGTARP, and that it made improvements in this area according to a
sample that Treasury compliance agent Freddie Mac recently conducted on four
large servicers.
Treasury should ensure that more detail is captured by the Making Home
Affordable Compliance Committee meeting minutes regarding the substance
of discussions related to compliance efforts on servicers in HAMP. Treasury
should make sure that minutes clearly outline the specific problems
encountered by servicers, remedial options discussed, and any requisite
actions taken to remedy the situation.
SIGTARP found a lack of detail in Treasury’s meeting minutes related to
Treasury’s oversight of servicers and servicer remediation efforts. Because Treasury
failed to document its oversight, SIGTARP was unable to verify Treasury’s role in
the oversight of servicers or its compliance agent Freddie Mac. Treasury said it
would discuss this recommendation with SIGTARP.

Update on Recommendation Regarding
Hardest Hit Fund Information Security
As part of its ongoing efforts to reduce TARP’s vulnerabilities to fraud, waste, and
abuse, SIGTARP notified Treasury, in a letter dated November 23, 2011, of an area
of potential vulnerability related to the handling of sensitive borrower information
by the state HFAs that participate in HHF, and made recommendations on how to
reduce that vulnerability.
SIGTARP recommended:
Treasury should protect borrower personally identifiable information (“PII”)
and other sensitive borrower information compiled for the Hardest Hit
Fund (“HHF”) by: (1) requiring that within 90 days, all Housing Finance
Agencies (and their contractors) (“HFAs”) participating in HHF develop and
implement effective policies and procedures to ensure protection against
unauthorized access, use, and disposition of PII and other sensitive borrower

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information; (2) Treasury reviewing each HFA’s policies and procedures
to determine if they are effective, and taking such action as is required to
ensure effectiveness; (3) requiring that all parties granted access to borrower
information should be made aware of restrictions on copying and disclosing
this information; (4) requiring annual certification by HFAs to Treasury that
that they are in compliance with all applicable laws, policies and procedures
pertaining to borrower information; and (5) requiring that HFAs promptly
notify Treasury and SIGTARP within 24 hours, when a breach of security has
occurred involving borrower information.
Treasury told SIGTARP that it obtained all 19 HFAs’ policies and procedures
regarding the protection of PII, is in the process of discussing these policies with
the HFAs, and sent a survey to each of the HFAs. Treasury told SIGTARP that the
three current certifications per year, as required by the contract between Treasury
and the HFAs, cover all federal and state laws regarding PII, and extend to a
contractor’s handling of PII. Treasury told SIGTARP that it informed all participating HFAs by email that it considers PII breaches to be included in contractual
notification requirements. However, Treasury did not require notification within 24
hours or notification to SIGTARP. It is important that the reporting of any breach
of homeowner PII occur as expeditiously as possible to SIGTARP and Treasury
to protect against or lessen the damage that could be done with this information.
SIGTARP will continue to monitor Treasury’s efforts to implement SIGTARP’s
recommendation.

*

*

*

*

*

*

*

*

2

3

4

5

6

7

8

9

Treasury should give careful consideration before agreeing
to the expansion of TALF to include MBS without a full review
of risks that may be involved and without considering certain
minimum fraud protections.

Agreements with TALF participants should include an
acknowledgment that: (1) they are subject to the oversight
of OFS-Compliance and SIGTARP, (2) with respect to any
condition imposed as part of TALF, that the party on which
the condition is imposed is required to establish internal
controls with respect to each condition, report periodically
on such compliance, and provide a certification with respect
to such compliance.

In formulating the structure of TALF, Treasury should
consider requiring, before committing TARP funds to the
program, that certain minimum underwriting standards and/
or other fraud prevention mechanisms be put in place with
respect to the ABS and/or the assets underlying the ABS
used for collateral.

Treasury begins to develop an overall investment strategy to
address its portfolio of stocks and decide whether it intends
to exercise warrants of common stock.

Treasury quickly determines its going-forward valuation
methodology.

Treasury should require all TARP recipients to report on the
actual use of TARP funds.

All existing TARP agreements, as well as those governing
new transactions, should be posted on the Treasury website
as soon as possible.

Treasury should include language in new TARP agreements
to facilitate compliance and oversight. Specifically, SIGTARP
recommends that each program participant should (1)
acknowledge explicitly the jurisdiction and authority of
SIGTARP and other oversight bodies, as relevant, to oversee
compliance of the conditions contained in the agreement
in question, (2) establish internal controls with respect to
that condition, (3) report periodically to the Compliance
department of the Office of Financial Stability (“OFSCompliance”) regarding the implementation of those controls
and its compliance with the condition, and (4) provide a
signed certification from an appropriate senior official to
OFS-Compliance that such report is accurate.

Treasury should include language in the automobile industry
transaction term sheet acknowledging SIGTARP’s oversight
role and expressly giving SIGTARP access to relevant
documents and personnel.

X

X

X

X

X

X

X

Implemented

X

Partially
Implemented

Note: * Indicates that Treasury considers the recommendation closed and will take no further action.

*

1

Recommendation

SIGTARP Recommendations Table
In Process

X

Not
Implemented
TBD/NA

Continued on next page

This recommendation was implemented
with respect to CMBS, and the Federal
Reserve did not expand TALF to RMBS.

The Federal Reserve adopted
mechanisms that address this
recommendation.

Although Treasury has made
substantial efforts to comply with
this recommendation in many of its
agreements, there have been exceptions,
including in its agreements with servicers
in MHA.

Comments

quarterly report to congress I July 25, 2012

189

*

*

*

*

*

*

*

13

14

15

16

17

18

19

X

X

X

X

X

X

X

Implemented

Partially
Implemented

Note: * Indicates that Treasury considers the recommendation closed and will take no further action.

Treasury should address the confusion and uncertainty on
executive compensation by immediately issuing the required
regulations.

All TALF modeling and decisions, whether on haircuts or any
other credit or fraud loss mechanisms, should account for
potential losses to Government interests broadly, including
TARP funds, and not just potential losses to the Federal
Reserve.

Treasury should not allow Legacy Securities PPIFs to invest
in TALF unless significant mitigating measures are included
to address these dangers.

Treasury should design a robust compliance protocol with
complete access rights to all TALF transaction participants
for itself, SIGTARP, and other relevant oversight bodies.

Treasury should require additional anti-fraud and credit
protection provisions, specific to all MBS, before
participating in an expanded TALF, including minimum
underwriting standards and other fraud prevention
measures.

In TALF, Treasury should require significantly higher haircuts
for all MBS, with particularly high haircuts for legacy RMBS,
or other equally effective mitigation efforts.

In TALF, Treasury should dispense with rating agency
determinations and require a security-by-security screening
for each legacy RMBS. Treasury should refuse to participate
if the program is not designed so that RMBS, whether new
or legacy, will be rejected as collateral if the loans backing
particular RMBS do not meet certain baseline underwriting
criteria or are in categories that have been proven to be
riddled with fraud, including certain undocumented subprime
residential mortgages.

Treasury and the Federal Reserve should provide to
SIGTARP, for public disclosure, the identity of the borrowers
who surrender collateral in TALF.

*

12

Treasury should oppose any expansion of TALF to legacy
MBS without significant modifications to the program to
ensure a full assessment of risks associated with such an
expansion.

Treasury should formalize its valuation strategy and begin
providing values of the TARP investments to the public.

*

(Continued)

11

10

Recommendation

SIGTARP Recommendations Table
In Process

X

Not
Implemented

X

X

TBD/NA

Continued on next page

The Federal Reserve adopted
mechanisms that address this
recommendation with respect to CMBS,
and did not expand TALF to RMBS.

This recommendation was implemented
with respect to CMBS, and the Federal
Reserve did not expand TALF to RMBS.

The Federal Reserve announced that
RMBS were ineligible for TALF loans,
rendering this recommendation moot.

On December 1, 2010, the Federal
Reserve publicly disclosed the identities
of all TALF borrowers and that there had
been no surrender of collateral. SIGTARP
will continue to monitor disclosures if a
collateral surrender takes place.

Treasury has formalized its valuation
strategy and regularly publishes its
estimates.

This recommendation was implemented
with respect to CMBS, and the Federal
Reserve did not expand TALF to RMBS.

Comments

190
special inspector general I troubled asset relief program

*

*

*

*

21

22

23

24

Treasury should require servicers in MHA to submit thirdparty verified evidence that the applicant is residing in the
subject property before funding a mortgage modification.

Treasury should require PPIP managers to provide most
favored nation clauses to PPIF equity stakeholders, to
acknowledge that they owe Treasury a fiduciary duty, and to
adopt a robust ethics policy and compliance apparatus.

Treasury should require that all PPIF fund managers (1)
have stringent investor-screening procedures, including
comprehensive “Know Your Customer” requirements at least
as rigorous as that of a commercial bank or retail brokerage
operation to prevent money laundering and the participation
of actors prone to abusing the system, and (2) be required
to provide Treasury with the identities of all the beneficial
owners of the private interests in the fund so that Treasury
can do appropriate diligence to ensure that investors in the
funds are legitimate.

Treasury should impose strict conflict-of-interest rules upon
PPIF managers across all programs that specifically address
whether and to what extent the managers can (1) invest
PPIF funds in legacy assets that they hold or manage on
behalf of themselves or their clients or (2) conduct PPIF
transactions with entities in which they have invested on
behalf of themselves or others.

Treasury should require CAP participants to (1) establish an
internal control to monitor their actual use of TARP funds, (2)
provide periodic reporting on their actual use of TARP funds,
(3) certify to OFS-Compliance, under the penalty of criminal
sanction, that the report is accurate, that the same criteria
of internal controls and regular certified reports should be
applied to all conditions imposed on CAP participants, and
(4) acknowledge explicitly the jurisdiction and authority of
SIGTARP and other oversight bodies, as appropriate, to
oversee conditions contained in the agreement.

Treasury should significantly increase the staffing levels of
OFS-Compliance and ensure the timely development and
implementation of an integrated risk management and
compliance program.

(Continued)

X

Implemented

X

X

X

Partially
Implemented

Note: * Indicates that Treasury considers the recommendation closed and will take no further action.

25

*

20

Recommendation

SIGTARP Recommendations Table

X

In Process

Not
Implemented

X

TBD/NA

Continued on next page

Treasury has decided to adopt this
important SIGTARP recommendation.
SIGTARP will monitor Treasury’s
implementation of the recommendation.

Treasury’s agreements with PPIF
managers include investor-screening
procedures such as “Know Your
Customer” requirements. Treasury
has agreed that it will have access to
any information in a fund manager’s
possession relating to beneficial owners.
However, Treasury did not impose an
affirmative requirement that managers
obtain and maintain beneficial owner
information.

Treasury has adopted some significant
conflict-of-interest rules related to this
recommendation, but has failed to
impose other significant safeguards.

Treasury closed the program with no
investments having been made, rendering
this recommendation moot.

According to Treasury, OFS-Compliance
has increased its staffing level and has
contracted with four private firms to
provide additional assistance to OFSCompliance.

Comments

quarterly report to congress I July 25, 2012

191

*

*

*

29

30

31
X

X

Implemented

X

Partially
Implemented

Note: * Indicates that Treasury considers the recommendation closed and will take no further action.

In MHA, Treasury should proactively educate homeowners
about the nature of the program, warn them about
modification rescue fraudsters, and publicize that no fee is
necessary to participate in the program.

In MHA, Treasury should defer payment of the $1,000
incentive to the servicer until after the homeowner has
verifiably made a minimum number of payments under the
mortgage modification program.

In MHA, Treasury should require that verifiable, third-party
information be obtained to confirm an applicant’s income
before any modification payments are made.

In MHA, Treasury should require the servicer to compare
the income reported on a mortgage modification application
with the income reported on the original loan applications.

*

28

In MHA, Treasury should require a closing-like procedure
be conducted that would include (1) a closing warning
sheet that would warn the applicant of the consequences
of fraud; (2) the notarized signature and thumbprint of each
participant; (3) mandatory collection, copying, and retention
of copies of identification documents of all participants in
the transaction; (4) verbal and written warnings regarding
hidden fees and payments so that applicants are made fully
aware of them; (5) the benefits to which they are entitled
under the program (to prevent a corrupt servicer from
collecting payments from the Government and not passing
the full amount of the subsidies to the homeowners); and (6)
the fact that no fee should be charged for the modification.

Additional anti-fraud protections should be adopted in MHA
to verify the identity of the participants in the transaction
and to address the potential for servicers to steal from
individuals receiving Government subsidies without applying
them for the benefit of the homeowner.

*

(Continued)

27

26

Recommendation

SIGTARP Recommendations Table

X

In Process

X

X

Not
Implemented
TBD/NA

Continued on next page

Rather than deferring payment of the
incentive until after the homeowner has
verifiably made a minimum number of
payments on its permanent modification,
Treasury will pay the incentive after the
servicer represents that the homeowner
has made three payments during the trial
period.

Treasury has rejected SIGTARP’s
recommendation and does not require
income reported on the modification
application to be compared to income
reported on the original loan application.

Treasury has said it will adopt this
recommendation. SIGTARP will monitor
Treasury’s implementation of the
recommendation.

Treasury rejected SIGTARP’s
recommendation for a closing-like
procedure. However, since this
recommendation was issued, Treasury
has taken several actions to prevent
fraud on the part of either MHA servicers
or applicants.

Comments

192
special inspector general I troubled asset relief program

*

37
X

Implemented

X

X

Partially
Implemented

Note: * Indicates that Treasury considers the recommendation closed and will take no further action.

Treasury should require PPIF managers to disclose to
Treasury, as part of the Watch List process, not only
information about holdings in eligible assets but also
holdings in related assets or exposures to related liabilities.

The conditions that give Treasury “cause” to remove a
PPIF manager should be expanded to include a manager’s
performance below a certain standard benchmark, or if
Treasury concludes that the manager has materially violated
compliance or ethical rules.

*

Treasury should periodically disclose PPIF trading activity
and require PPIF managers to disclose to SIGTARP, within
seven days of the close of the quarter, all trading activity,
holdings, and valuations so that SIGTARP may disclose
such information, subject to reasonable protections, in its
quarterly reports.

36

*

34

Treasury should require the imposition of strict information
barriers or “walls” between the PPIF managers making
investment decisions on behalf of the PPIF and those
employees of the fund management company who manage
non-PPIF funds.

Treasury should define appropriate metrics and an
evaluation system should be put in place to monitor the
effectiveness of the PPIF managers, both to ensure they
are fulfilling the terms of their agreements and to measure
performance.

*

33

In MHA, Treasury should require its agents to keep track of
the names and identifying information for each participant in
each mortgage modification transaction and to maintain a
database of such information.

(Continued)

35

*

32

Recommendation

SIGTARP Recommendations Table
In Process

X

X

X

Not
Implemented
TBD/NA

Continued on next page

Treasury has refused to adopt this
recommendation, relying solely on
Treasury’s right to end the investment
period after 12 months. That timeframe
has already expired. Treasury’s failure to
adopt this recommendation potentially
puts significant Government funds at risk.

After more than two years, Treasury
now states that it has developed risk
and performance metrics. However, it
is still not clear how Treasury will use
these metrics to evaluate the PPIP
managers and take appropriate action as
recommended by SIGTARP.

Treasury has committed to publish
on a quarterly basis certain high-level
information about aggregated purchases
by the PPIFs, but not within seven days of
the close of the quarter. Treasury has not
committed to providing full transparency
to show where public dollars are invested
by requiring periodic disclosure of every
trade in the PPIFs.

Treasury has refused to adopt this
significant anti-fraud measure designed
to prevent conflicts of interest. This
represents a material deficiency in the
program.

While Treasury’s program administrator,
Fannie Mae, has developed a HAMP
system of record that maintains the
servicers’ and investors’ names and
participating borrowers’ personally
identifiable information, such as names
and addresses, the database is not
constructed to maintain other information
that may assist in detecting insiders who
are committing large-scale fraud.

Comments

quarterly report to congress I July 25, 2012

193

Treasury and FRBNY should (1) examine Moody’s assertions
that some credit rating agencies are using lower standards
to give a potential TALF security the necessary AAA rating
and (2) develop mechanisms to ensure that acceptance of
collateral in TALF is not unduly influenced by the improper
incentives to overrate that exist among the credit agencies.

*

*

*

*

*

*

39

40

41

42

43

44

X

X

X

X

Implemented

X

Partially
Implemented

Note: * Indicates that Treasury considers the recommendation closed and will take no further action.

Treasury should establish policies to guide decision making
in determining whether it is appropriate to defer to another
agency when making TARP programming decisions where
more than one Federal agency is involved.

Treasury should establish policies to guide any similar
future decisions to take a substantial ownership position in
financial institutions that would require an advance review
so that Treasury can be reasonably aware of the obligations
and challenges facing such institutions.

The Secretary of the Treasury should direct the Special
Master to work with FRBNY officials in understanding AIG
compensation programs and retention challenges before
developing future compensation decisions that may affect
both institutions’ ability to get repaid by AIG for Federal
assistance provided.

Treasury should improve existing control systems to
document the occurrence and nature of external phone calls
and in-person meetings about actual and potential recipients
of funding under the CPP and other similar TARP-assistance
programs to which they may be part of the decision making.

Treasury should more explicitly document the vote of each
Investment Committee member for all decisions related to
the investment of TARP funds.

Treasury should require PPIF managers to obtain and
maintain information about the beneficial ownership of all of
the private equity interests, and Treasury should have the
unilateral ability to prohibit participation of private equity
investors.

(Continued)

38

Recommendation

SIGTARP Recommendations Table
In Process

X

Not
Implemented

X

TBD/NA

Continued on next page

Treasury has agreed to work closely with
other Federal agencies that are involved
in TARP.

Treasury stated that it does not
anticipate taking a substantial percentage
ownership position in any other financial
institution pursuant to EESA.

Treasury and the Federal Reserve have
discussed concerns about potential
overrating or rating shopping with the
rating agencies, and have agreed to
continue to develop and enhance risk
management tools and processes, where
appropriate.

Treasury has agreed that it can have
access to any information in a fund
manager’s possession relating to
beneficial owners. However, Treasury is
not making an affirmative requirement
that managers obtain and maintain
beneficial owner information. Treasury will
not adopt the recommendation to give
itself unilateral ability to deny access to
or remove an investor, stating that such a
right would deter participation.

Comments

194
special inspector general I troubled asset relief program

Treasury should develop other performance metrics
and publicly report against them to measure over time
the implementation and success of HAMP. For example,
Treasury could set goals and publicly report against those
goals for servicer processing times, modifications as a
proportion of a servicer’s loans in default, modifications
as a proportion of foreclosures generally, rates of how
many borrowers fall out of the program prior to permanent
modification, and re-default rates.

Treasury should undertake a sustained public service
campaign as soon as possible, both to reach additional
borrowers who could benefit from the program and to arm
the public with complete, accurate information — this will
help to avoid confusion and delay, and prevent fraud and
abuse.

Treasury should reconsider its position that allows servicers
to substitute alternative forms of income verification based
on subjective determinations by the servicer.

Treasury should re-examine HAMP’s structure to ensure that
it is adequately minimizing the risk of re-default stemming
from non-mortgage debt, second liens, partial interest rate
resets after the five-year modifications end, and from many
borrowers being underwater.

Treasury should institute careful screening before putting
additional capital through CDCI into an institution with
insufficient capital to ensure that the TARP matching funds
are not flowing into an institution that is on the verge of
failure.

Treasury should develop a robust procedure to audit and
verify the bona fides of any purported capital raise in CDCI
and to establish adequate controls to verify the source,
amount and closing of all claimed private investments.

Treasury should revise CDCI terms to clarify that Treasury
inspection and copy rights continue until the entire CDCI
investment is terminated. Additionally, consistent with
recommendations made in connection with other TARP
programs, the terms should be revised to provide expressly
that SIGTARP shall have access to the CDFI’s records equal
to that of Treasury.

46

47

48

49

50

51

52

X

X

X

X

Implemented

X

X

Partially
Implemented

Note: * Indicates that Treasury considers the recommendation closed and will take no further action.

Treasury should rectify the confusion that its own
statements have caused for HAMP by prominently disclosing
its goals and estimates (updated over time, as necessary)
of how many homeowners the program will help through
permanent modifications and report monthly on its progress
toward meeting that goal.

(Continued)

45

Recommendation

SIGTARP Recommendations Table
In Process

X

X

Not
Implemented
TBD/NA

Continued on next page

Treasury has adopted some programs to
assist underwater mortgages to address
concerns of negative equity but has not
addressed other factors contained in this
recommendation.

Although Treasury has increased its
reporting of servicer performance, it has
not identified goals for each metric and
measured performance against those
goals.

Despite SIGTARP’s repeated highlighting
of this essential transparency and
effectiveness measure, Treasury has
refused to disclose clear and relevant
goals and estimates for the program.

Comments

quarterly report to congress I July 25, 2012

195

Treasury should ensure that more detail is captured by
the Warrant Committee meeting minutes. At a minimum,
the minutes should include the members’ qualitative
considerations regarding the reasons bids were accepted or
rejected within fair market value ranges.

Treasury should document in detail the substance of
all communications with recipients concerning warrant
repurchases.

Treasury should develop and follow guidelines and internal
controls concerning how warrant repurchase negotiations
will be pursued, including the degree and nature of
information to be shared with repurchasing institutions
concerning Treasury’s valuation of the warrants.

*

*

*

54

55

56

57

58

X

X

Not
Implemented
TBD/NA

Although Treasury largely continues
to rely on self-reporting, stating that
it only plans to conduct testing where
they have particular concerns as to a
TARP recipient’s compliance procedures
or testing results, it has conducted
independent testing of compliance
obligations during some compliance
reviews.

Treasury has adopted procedures
designed to address this
recommendation, including a policy to
discuss only warrant valuation inputs and
methodologies prior to receiving a bid,
generally to limit discussion to valuation
ranges after receiving approval from
the Warrant Committee, and to note
the provision of any added information
in the Committee minutes. However,
Treasury believes that its existing internal
controls are sufficient to ensure adequate
consistency in the negotiation process.

Treasury has agreed to document the
dates, participants, and subject line of
calls. It has refused to document the
substance of such conversations.

Treasury has indicated that it has
implemented this recommendation.
Although the detail of the minutes has
improved, Treasury is still not identifying
how each member of the committee
casts his or her vote.

Comments

Continued on next page

In Process

Note: * Indicates that Treasury considers the recommendation closed and will take no further action.

X

X

Partially
Implemented

X

X

Implemented

Treasury states that it has developed
guidance and provided that guidance to
the exceptional assistance participants
that were remaining in TARP as of
June 30, 2011. Treasury has not
addressed other factors contained in this
recommendation, citing its belief that
materiality should be subject to a fact
and circumstances review.

Treasury should develop guidelines that apply consistently
across TARP participants for when a violation is sufficiently
material to merit reporting, or in the alternative require that
all violations be reported.

Treasury should promptly take steps to verify TARP
participants’ conformance to their obligations, not only by
ensuring that they have adequate compliance procedures
but also by independently testing participants’ compliance.

Treasury should consider more frequent surveys of a CDCI
participant’s use of TARP funds than annually as currently
contemplated. Quarterly surveys would more effectively
emphasize the purpose of CDCI.

(Continued)

53

Recommendation

SIGTARP Recommendations Table

196
special inspector general I troubled asset relief program

When Treasury considers whether to accept an existing CPP
participant into SBLF, because conditions for many of the
relevant institutions have changed dramatically since they
were approved for CPP, Treasury and the bank regulators
should conduct a new analysis of whether the applying
institution is sufficiently healthy and viable to warrant
participation in SBLF.

When Treasury conducts the new analysis of an institution’s
health and viability, the existing CPP preferred shares should
not be counted as part of the institution’s capital base.

64

65

X

X

X

Implemented

X

Partially
Implemented

Note: * Indicates that Treasury considers the recommendation closed and will take no further action.

Treasury should launch a broad-based information
campaign, including public service announcements in target
markets that focus on warnings about potential fraud, and
include conspicuous fraud warnings whenever it makes
broad public announcements about the HAMP program.

63

Treasury should reconsider the length of the minimum term
of HAMP’s unemployment forbearance program.

62

*

Treasury should adopt a uniform appraisal process across
all HAMP and HAMP-related short-sale and principal
reduction programs consistent with FHA’s procedures.

61

Treasury should re-evaluate the voluntary nature of its
principal reduction program and, irrespective of whether it
is discretionary or mandatory, consider changes to better
maximize its effectiveness, ensure to the greatest extent
possible the consistent treatment of similarly situated
borrowers, and address potential conflict of interest issues.

60

*

For each HAMP-related program and subprogram, Treasury
should publish the anticipated costs and expected
participation in each and that, after each program is
launched, it report monthly as to the program’s performance
against these expectations.

(Continued)

59

Recommendation

SIGTARP Recommendations Table
In Process

X

X

Not
Implemented

X

TBD/NA

Continued on next page

Treasury refused to adopt this
recommendation, citing its belief that
current CPP participants may be unfairly
disadvantaged in their SBLF applications
if their existing CPP investments are
not counted as part of their capital
base, and that SBLF “already provides
substantial hurdles that CPP recipients
must overcome” that don’t apply to other
applicants.

For more than a year, Treasury refused to
adopt this recommendation, even though
average U.S. terms of unemployment
were lengthening. However, in July 2011,
the Administration announced a policy
change, and Treasury has extended the
minimum term of the unemployment
program from three months to 12
months, effective October 1, 2011.

Treasury plans to maintain the voluntary
nature of the program, providing an
explanation that on its face seems
unpersuasive to SIGTARP. SIGTARP will
continue to monitor performance.

Treasury has provided anticipated costs,
but not expected participation.

Comments

quarterly report to congress I July 25, 2012

197

Treasury, as part of its due diligence concerning any
proposed restructuring, recapitalization, or sale of its CPP
investment to a third party, should provide to SIGTARP the
identity of the CPP institution and the details of the proposed
transaction.

*

*

*

*

*

67

68

69

70

71

X

X

X

X

Implemented

Partially
Implemented

Note: * Indicates that Treasury considers the recommendation closed and will take no further action.

OFS should adopt the legal fee bill review standards
and procedures contained in the FDIC’s Outside Counsel
Deskbook, or establish similarly specific instructions and
guidance for OFS COTRs to use when reviewing legal fee
bills, and incorporate those instructions and guidance into
OFS written policies.

OFS should include in its open legal service contracts
detailed requirements for law firms on the preparation and
submission of legal fee bills, or separately provide the
instructions to law firms and modify its open contracts,
making application of the instructions mandatory.

OFS should adopt the legal fee bill submission standards
contained in the FDIC’s Outside Counsel Deskbook, or
establish similarly detailed requirements for how law
firms should prepare legal fee bills and describe specific
work performed in the bills, and which costs and fees are
allowable and unallowable.

When a CPP participant refinances into SBLF and seeks
additional taxpayer funds, Treasury should provide to
SIGTARP the identity of the institution and details of the
proposed additional SBLF investment.

Treasury should take steps to prevent institutions that are
refinancing into the SBLF from CPP from securing windfall
dividend reductions without any relevant increase in lending.

(Continued)

66

Recommendation

SIGTARP Recommendations Table

X

In Process

X

Not
Implemented
TBD/NA

Continued on next page

Treasury told SIGTARP that OFS has held
training on its newly adopted guidance
prescribing how legal fee bills should
be prepared with OFS COTRs and other
staff involved in the review of legal fee
bills, and that the OFS COTRs will begin
reviewing invoices in accordance with
its new guidance for periods starting
with March 2011. OFS also stated that
it incorporated relevant portions of its
training on the new legal fee bill review
standards into written procedures.

Treasury told SIGTARP that OFS has
distributed its new guidance to all
law firms currently under contract to
OFS. Treasury further stated that OFS
will work with Treasury’s Procurement
Services Division to begin modifying
base contracts for OFS legal services to
include those standards as well.

Treasury told SIGTARP that OFS has
created new guidance using the FDIC’s
Outside Counsel Deskbook and other
resources.

Treasury refused to adopt this
recommendation, suggesting that
its adoption would subvert the will
of Congress and that SIGTARP’s
recommendation “may not be helpful”
because “it is unclear that using this
statutorily mandated baseline will lead to
anomalies.”

Comments

198
special inspector general I troubled asset relief program

*

*

*

*

73

74

75

76

Treasury should establish benchmarks and goals for
acceptable program performance for all MHA servicers,
including the length of time it takes for trial modifications to
be converted into permanent modifications, the conversion
rate for trial modifications into permanent modifications,
the length of time it takes to resolve escalated homeowner
complaints, and the percentage of required modification
status reports that are missing.

Treasury should require that MHA servicer communications
with homeowners relating to changes in the status or
terms of a homeowner’s modification application, trial or
permanent modification, HAFA agreement, or any other
significant change affecting the homeowner’s participation in
the MHA program, be in writing.

Treasury should ensure that more detail is captured by
the MHA Compliance Committee meeting minutes. At a
minimum, the minutes should include MHA-C’s proposed
rating for each servicer, the committee members’ qualitative
and quantitative considerations regarding each servicer’s
ratings, the votes of each committee member, the final
rating for each servicer, justification for any difference in
that rating with MHA-C’s proposed rating, and any followup including escalation to Treasury’s Office of General
Counsel or the Assistant Secretary and the outcomes of that
escalation.

Treasury should establish detailed guidance and internal
controls governing how the MHA Servicer Compliance
Assessment will be conducted and how each compliance
area will be weighted.

OFS should review previously paid legal fee bills to
identify unreasonable or unallowable charges, and seek
reimbursement for those charges, as appropriate.

(Continued)

Implemented

X

X

Partially
Implemented

Note: * Indicates that Treasury considers the recommendation closed and will take no further action.

*

72

Recommendation

SIGTARP Recommendations Table

X

In Process

X

X

Not
Implemented
TBD/NA

Continued on next page

Treasury told SIGTARP that it already
established benchmarks in this area,
including that trial periods should last
three to four months, and escalated
cases should be resolved in 30 days. If
these are the benchmarks for acceptable
performance, many servicers have
missed the mark. Also, Treasury has yet
to establish a benchmark for conversion
rates from trial modifications to
permanent modifications.

Treasury has refused to adopt this
recommendation, saying it already
requires a loan servicer to communicate
in writing with a borrower an average
of 10 times. However, most written
requirements apply to a HAMP
application and Treasury’s response fails
to address homeowners who receive
miscommunication from servicers on
important milestones or changes.

Minutes of recent MHA Compliance
Committee meetings contain brief
explanations of servicer assessment
rating decisions. However, these
minutes do not explain the Committee’s
deliberations in detail, do not indicate
how members voted beyond a tally of
the votes, and do not discuss followup actions or escalation. SIGTARP
will continue to monitor Treasury’s
implementation of the recommendation.

Treasury made important changes to
its servicer assessments by including
metrics for the ratings, including several
quantitative metrics. However, qualitative
metrics to assess the servicer’s internal
controls in the three ratings categories
remain, and guidelines or criteria for
rating the effectiveness of internal
controls are still necessary. SIGTARP
will continue to monitor Treasury’s
implementation of this recommendation.

Treasury told SIGTARP that Treasury
procurement is trying to determine what
action, if any, is appropriate with other
legal service contracts.

Comments

quarterly report to congress I July 25, 2012

199

The Treasury contracting officer should disallow and seek
recovery from Simpson Thacher & Bartlett LLP for $96,482
in questioned, ineligible fees and expenses paid that were
not allowed under the OFS contract. Specifically, those are
$68,936 for labor hours billed at rates in excess of the
allowable maximums set in contract TOFS-09-0001, task
order 1, and $22,546 in other direct costs not allowed
under contract TOFS-09-007, task order 1.

Treasury should promptly review all previously paid legal fee
bills from all law firms with which it has a closed or open
contract to identify unreasonable or unallowable charges
and seek reimbursement for those charges, as appropriate.

Treasury should require in any future solicitation for legal
services multiple rate categories within the various partner,
counsel, and associate labor categories. The additional
labor rate categories should be based on the number of
years the attorneys have practiced law.

Treasury should pre-approve specified labor categories and
rates of all contracted legal staff before they are allowed to
work on and charge time to OFS projects.

80

81

82

83

Implemented

Partially
Implemented

Note: * Indicates that Treasury considers the recommendation closed and will take no further action.

Treasury should specifically determine the allowability of
$7,980,215 in questioned, unsupported legal fees and
expenses paid to the following law firms: Simpson Thacher
& Bartlett LLP ($5,791,724); Cadwalader Wickersham &
Taft LLP ($1,983,685); Locke Lord Bissell & Liddell LLP
($146,867); and Bingham McCutchen LLP (novated from
McKee Nelson LLP, $57,939).

79

Treasury must ensure that all servicers participating in MHA
comply with program requirements by vigorously enforcing
the terms of the servicer participation agreements, including
using all financial remedies such as withholding, permanently
reducing, and clawing back incentives for servicers who
fail to perform at an acceptable level. Treasury should be
transparent and make public all remedial actions taken
against any servicer.

78

*

Treasury should publicly assess the top 10 MHA servicers’
program performance against acceptable performance
benchmarks in the areas of: the length of time it takes
for trial modifications to be converted into permanent
modifications, the conversion rate for trial modifications
into permanent modifications, the length of time it takes
to resolve escalated homeowner complaints, and the
percentage of required modification status reports that are
missing.

(Continued)

77

Recommendation

SIGTARP Recommendations Table
In Process

X

X

X

X

X

X

X

Not
Implemented
TBD/NA

Continued on next page

Treasury neither agreed nor disagreed
with the recommendation.

Treasury neither agreed nor disagreed
with the recommendation.

Treasury neither agreed nor disagreed
with the recommendation.

Treasury neither agreed nor disagreed
with the recommendation.

Treasury neither agreed nor disagreed
with the recommendation.

Treasury has rejected this important
recommendation, stating that it “believes
that the remedies enacted have been
appropriate and that appropriate
transparency exists.”

Treasury has rejected this important
recommendation, stating that it “believes
that the remedies enacted have been
appropriate, and that appropriate
transparency exists.”

Comments

200
special inspector general I troubled asset relief program

*

88

X

Implemented

Partially
Implemented

Note: * Indicates that Treasury considers the recommendation closed and will take no further action.

The Office of the Special Master should better document
its use of market data in its calculations. At a minimum, the
Office of the Special Master should prospectively document
which companies and employees are used as comparisons
in its analysis of the 50th percentile of the market, and
it should also maintain records and data so that the
relationship between its determinations and benchmarks are
clearly understood.

To ensure that the Office of the Special Master consistently
grants exceptions to the $500,000 cash salary cap, the
Office of the Special Master should substantiate each
exception requested and whether the requests demonstrate
or fail to demonstrate “good cause.”

*

87

Treasury should assess whether it should renegotiate the
terms of its Capital Purchase Program contracts for those
community banks that will not be able to exit TARP prior
to the dividend rate increase in order to help preserve the
value of taxpayers’ investments.

Treasury should protect borrower personally identifiable
information (“PII”) and other sensitive borrower information
compiled for the Hardest Hit Fund (“HHF”) by: (1) requiring
that within 90 days, all Housing Finance Agencies (and
their contractors) (“HFAs”) participating in HHF develop
and implement effective policies and procedures to ensure
protection against unauthorized access, use, and disposition
of PII and other sensitive borrower information; (2) Treasury
reviewing each HFA’s policies and procedures to determine
if they are effective, and taking such action as is required to
ensure effectiveness; (3) requiring that all parties granted
access to borrower information should be made aware
of restrictions on copying and disclosing this information;
(4) requiring annual certification by HFAs to Treasury that
they are in compliance with all applicable laws, policies
and procedures pertaining to borrower information; and (5)
requiring that HFAs promptly notify Treasury and SIGTARP
within 24 hours, when a breach of security has occurred
involving borrower information.

*

85

Treasury, in consultation with Federal banking regulators,
should develop a clear TARP exit path to ensure that
as many community banks as possible repay the TARP
investment and prepare to deal with the banks that cannot.
Treasury should develop criteria pertaining to restructurings,
exchanges, and sales of its TARP investments (including any
discount of the TARP investment, the treatment of unpaid
TARP dividend and interest payments, and warrants).

(Continued)

86

*

84

Recommendation

SIGTARP Recommendations Table

X

X

X

In Process

X

Not
Implemented
TBD/NA

Continued on next page

OSM began memorializing in its records
justifications for exceptions. SIGTARP
will continue to monitor whether those
records substantiate each exception
requested and whether the requests
demonstrate or fail to demonstrate “good
cause.”

See discussion in this section

Treasury rejected this recommendation
without ever addressing why.

Treasury responded to this
recommendation by saying that it
continues its efforts to wind down CPP
through repayments, restructuring, and
sales, all of which it was doing prior to
this recommendation. Treasury intends
to auction off a pool of TARP securities.
Treasury has not addressed the criteria
for these divestment strategies.

Comments

quarterly report to congress I July 25, 2012

201

In order to allow for effective compliance and enforcement
in HAMP Tier 2, Treasury should require that the borrower
prove that the property has been rented and is occupied
by a tenant at the time the borrower applies for a loan
modification, as opposed to requiring only a certification
that the borrower intends to rent the property. As part of
the Request for Mortgage Assistance (“RMA”) application
for HAMP Tier 2, the borrower should provide the servicer
with a signed lease and third-party verified evidence of
occupancy in the form of documents showing that a renter
lives at the property address, such as a utility bill, driver’s
license, or proof of renter’s insurance. In the case of
multiple-unit properties under one mortgage,Treasury should
require that the borrower provide the servicer with evidence
that at least one unit is occupied by a tenant as part of the
RMA.

To continue to allow for effective compliance and
enforcement in HAMP Tier 2 after the trial modification has
started, Treasury should require that, prior to conversion
of a trial modification to a permanent modification, the
borrower certify under penalty of perjury that none of the
occupancy circumstances stated in the RMA have changed.

90

91

Implemented

Partially
Implemented

Note: * Indicates that Treasury considers the recommendation closed and will take no further action.

The Office of the Special Master should develop more
robust policies, procedures, or guidelines to help ensure
that its pay determination process and its decisions are
evenhanded. These measures will improve transparency
and help the Office of the Special Master consistently apply
the Interim Final Rule principles of “appropriate allocation,”
“performance-based compensation,” and “comparable
structures and payments.

(Continued)

89

Recommendation

SIGTARP Recommendations Table
In Process

X

X

X

Not
Implemented
TBD/NA

Continued on next page

Treasury responded to this
recommendation by requiring that
borrowers certify that they intend to rent
the property for at least five years and
that they will make reasonable efforts
to rent. This does not go far enough.
Requiring only a self-certification, without
a strong compliance and enforcement
regime to ensure that the intent is
carried out and the property is actually
rented, leaves the program vulnerable to
risks that TARP funds will pay investors
for modifications for mortgages on
vacation homes that are not rented,
and may delay, as opposed to prevent,
foreclosures and increase HAMP redefault
rates.

Treasury responded to this
recommendation by requiring that
borrowers certify that they intend to rent
the property for at least five years and
that they will make reasonable efforts
to rent. This does not go far enough.
Requiring only a self-certification, without
a strong compliance and enforcement
regime to ensure that the intent is
carried out and the property is actually
rented, leaves the program vulnerable to
risks that TARP funds will pay investors
for modifications for mortgages on
vacation homes that are not rented,
and may delay, as opposed to prevent,
foreclosures and increase HAMP redefault
rates.

OSM defended the adequacy of its
policies and procedures. OSM stated it
will carefully focus on how it can further
develop and articulate its policies,
procedures, and guidelines.

Comments

202
special inspector general I troubled asset relief program

Given the expected increase in the volume of HAMP
applications due to the implementation of HAMP Tier 2,
Treasury should convene a summit of key stakeholders to
discuss program implementation and servicer ramp-up and
performance requirements so that the program roll-out is
efficient and effective.

(b) Treasury should undertake a sustained public service
campaign as soon as possible both to reach additional
borrowers who could potentially be helped by HAMP Tier 2
and to arm the public with complete, accurate information
about the program to avoid confusion and delay, and to
prevent fraud and abuse.

(a) Treasury should require that servicers provide the
SIGTARP/CFPB/Treasury Joint Task Force Consumer Fraud
Alert to all HAMP-eligible borrowers as part of their monthly
mortgage statement until the expiration of the application
period for HAMP Tier 1 and 2.

In order to protect against the possibility that the extension
and expansion of HAMP will lead to an increase in mortgage
modification fraud,

(c) Treasury should bar payment of TARP-funded incentives
to any participant for a loan modification on a property that
has been reported vacant for more than three months, until
such time as the property has been re-occupied by a tenant
and the borrower has provided third-party verification of
occupancy.

(b) Treasury should require servicers to provide monthly
reports to Treasury of any properties that have remained
vacant for more than three months.

(a) Treasury should require that borrowers immediately notify
their servicer if the property has remained vacant for more
than three months.

To prevent a property that has received a HAMP Tier 2
modification from remaining vacant for an extended period
of time after a lease expires or a tenant vacates,

(Continued)

Implemented

Partially
Implemented

Note: * Indicates that Treasury considers the recommendation closed and will take no further action.

94

93

92

Recommendation

SIGTARP Recommendations Table
In Process

X

X

X

Not
Implemented
TBD/NA

Continued on next page

Treasury has not implemented this
recommendation. Treasury has not held
a summit of all key stakeholders to
make the program roll-out efficient and
effective. On the program roll-out date of
June 1, 2012, only three of the top 10
largest servicers had fully implemented
HAMP Tier 2.

Treasury has not implemented this
recommendation. It is important that
Treasury educate as many homeowners
as possible with accurate information
about HAMP in an effort to prevent
mortgage modification fraud.

Treasury responded to this
recommendation by requiring that
borrowers certify that they intend to rent
the property for at least five years and
that they will make reasonable efforts to
rent the property on a year-round basis
if it becomes vacant. Treasury’s actions
did not go far enough to protect the
program. With no compliance regime to
determine that a renter is in place, the
program remains vulnerable to TARP
funds being paid to modify mortgages
that do not fit within the intended
expansion of the program.

Comments

quarterly report to congress I July 25, 2012

203

Treasury should set meaningful and measurable
performance goals for the Hardest Hit Fund program
including, at a minimum, the number of homeowners
Treasury estimates will be helped by the program, and
measure the program’s progress against those goals.

Treasury should instruct state housing finance agencies
in the Hardest Hit Fund to set meaningful and measurable
overarching and interim performance goals with appropriate
metrics to measure progress for their individual state
programs.

Treasury should set milestones at which the state housing
finance agencies in the Hardest Hit Fund must review the
progress of individual state programs and make program
adjustments from this review.

Treasury should publish on its website and in the Housing
Scorecard on a quarterly basis the total number of
homeowners assisted, funds drawn down by states, and
dollars expended for assistance to homeowners, assistance
committed to homeowners, and cash on hand, aggregated
by all state Hardest Hit Fund programs.

97

98

99

100

Implemented

Partially
Implemented

Note: * Indicates that Treasury considers the recommendation closed and will take no further action.

To allow for assessment of the progress and success
of HAMP Tier 2, Treasury should set meaningful and
measurable goals, including at a minimum the number of
borrowers Treasury estimates will be helped by HAMP Tier
2. Treasury should unambiguously and prominently disclose
its goals and report monthly on its progress in meeting
these goals.

(b) Treasury should develop and publish separate metrics
related to HAMP Tier 2 in the compliance results and
program results sections of the quarterly Making Home
Affordable (“MHA”) servicer assessments of the Top 10 MHA
servicers.

(a) Treasury should include additional criteria in its servicer
compliance assessments that measure compliance with the
program guidelines and requirements of HAMP Tier 2.

To ensure servicer compliance with HAMP Tier 2 guidelines
and assess servicer performance,

(Continued)

96

95

Recommendation

SIGTARP Recommendations Table

X

In Process

X

X

X

X

X

Not
Implemented
TBD/NA

Continued on next page

See discussion in this section

See discussion in this section

See discussion in this section

See discussion in this section

Treasury has rejected this
recommendation. Treasury’s refusal to
provide meaningful and measurable goals
leaves it vulnerable to accusations that it
is trying to avoid accountability.

Treasury said that it will include metrics
in the future. SIGTARP will continue to
monitor Treasury’s implementation of this
recommendation.

Comments

204
special inspector general I troubled asset relief program

Treasury should stop allowing servicers to add a risk
premium to Freddie Mac’s discount rate in HAMP’s net
present value test.

Treasury should ensure that servicers use accurate
information when evaluating net present value test results
for homeowners applying to HAMP and should ensure that
servicers maintain documentation of all net present value
test inputs. To the extent that a servicer does not follow
Treasury’s guidelines on input accuracy and documentation
maintenance, Treasury should permanently withhold
incentives from that servicer.

Treasury should require servicers to improve their
communication with homeowners regarding denial of a
HAMP modification so that homeowners can move forward
with other foreclosure alternatives in a timely and fully
informed manner. To the extent that a servicer does not
follow Treasury’s guidelines on these communications,
Treasury should permanently withhold incentives from that
servicer.

Treasury should ensure that more detail is captured by the
Making Home Affordable Compliance Committee meeting
minutes regarding the substance of discussions related to
compliance efforts on servicers in HAMP. Treasury should
make sure that minutes clearly outline the specific problems
encountered by servicers, remedial options discussed, and
any requisite actions taken to remedy the situation.

102

103

104

105

Implemented

Partially
Implemented

Note: * Indicates that Treasury considers the recommendation closed and will take no further action.

Treasury should develop an action plan for the Hardest
Hit Fund that includes steps to increase the numbers of
homeowners assisted and to gain industry support for
Treasury-approved HHF programs. Treasury should set
interim metrics for how many homeowners it intends to
assist in a Treasury-defined time period in each particular
program (such as principal reduction, second lien reduction,
or reinstatement). If Treasury cannot achieve the desired
level of homeowners assisted in any one program area in
the defined time period, Treasury should put the funds to
better use toward programs that are reaching homeowners.

(Continued)

101

Recommendation

SIGTARP Recommendations Table

X

In Process

X

X

X

X

Not
Implemented
TBD/NA

See discussion in this section

See discussion in this section

See discussion in this section

See discussion in this section

See discussion in this section

Comments

quarterly report to congress I July 25, 2012

205

Endnotes
206

special inspector general I troubled asset relief program

1.
2.
3.
4.
5.
6.
7.
8.

9.

10.
11.
12.
13.
14.
15.
16.

17.

18.
19.
20.
21.

22.
23.
24.
25.
26.
27.
28.
29.
30.
31.
32.
33.
34.
35.
36.

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HUD, response to SIGTARP draft report, 1/10/2011.
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Treasury, response to SIGTARP data call, 7/2/2012.

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Treasury, response to SIGTARP data call, 7/9/2012.
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Treasury conference call, 3/19/2009.
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Small Business Jobs Act, P.L. 111-240, 9/27/2010, p. 2.
Treasury, response to SIGTARP data call, 10/5/2011.
Treasury, response to SIGTARP data call, 10/5/2011.
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Appendix a I glossary I July 25, 2012

Glossary
This appendix provides a glossary of terms that are used in the context of this report.
7(a) Loan Program: SBA loan program guaranteeing
a percentage of loans for small businesses that cannot
otherwise obtain conventional loans at reasonable terms.
Accredited Investors: Individuals or institutions that
by law are considered financially sophisticated enough
so that they can invest in ventures that are exempt from
investor protection laws. Under U.S. securities laws, these
include many financial companies, pension plans, wealthy
individuals, and top executives or directors of the issuing
companies.
Asset-Backed Securities (“ABS”): Bonds backed by a
portfolio of consumer or corporate loans, e.g., credit card,
auto, or small-business loans. Financial companies typically
issue ABS backed by existing loans in order to fund new loans
for their customers.
Auction Agent: Firm (such as an investment bank) that buys
a series of securities from an institution for resale.
Collateral: Asset pledged by a borrower to a lender until a
loan is repaid. Generally, if the borrower defaults on the loan,
the lender gains ownership of the pledged asset and may sell
it to satisfy the debt. In TALF, the ABS or CMBS purchased
with the TALF loan is the collateral that is posted with
FRBNY.
Collateralized Debt Obligation (“CDO”): A security that
entitles the purchaser to some part of the cash flows from a
portfolio of assets such as mortgage-backed securities, bonds,
loans, or other CDOs.

Credit Default Swap (“CDS”): A contract where the seller
receives payments from the buyer in return for agreeing to
pay the buyer when a particular credit event occurs, such
as when the credit rating on a bond is downgraded or a
loan goes into default. The buyer does not need to own the
asset covered by the contract, meaning the swap can serve
essentially as a bet against the underlying bond or loan.
Cumulative Preferred Stock: Stock requiring a defined
dividend payment. If the company does not pay the dividend
on schedule, it still owes the missed dividend to the stock’s
owner.
CUSIP number (“CUSIP”): Unique identifying number
assigned to all registered securities in the United States
and Canada; the name originated with the Committee on
Uniform Securities Identification Procedures.
Custodian Bank: Bank holding the collateral and managing
accounts for FRBNY; for TALF the custodian is Bank of New
York Mellon.
Debt: Investment in a business that is required to be paid
back to the investor, usually with interest.
Deed-in-Lieu of Foreclosure: Instead of going through
foreclosure, the borrower voluntarily surrenders the deed to
the home to the home lender, as satisfaction of the unpaid
mortgage balance.

Commercial Mortgage-Backed Securities (“CMBS”):
Bonds backed by one or more mortgages on commercial real
estate (e.g., office buildings, rental apartments, hotels).

Deficiency Judgment: Court order authorizing a lender to
collect all or part of an unpaid and outstanding debt resulting
from the borrower’s default on the mortgage note securing a
debt. A deficiency judgment is rendered after the foreclosed
or repossessed property is sold when the proceeds are
insufficient to repay the full mortgage debt.

Common Stock: Equity ownership entitling an individual to
share in corporate earnings and voting rights.

Deobligations: An agency’s cancellation or downward
adjustment of previously incurred obligations.

Community Development Financial Institutions
(“CDFIs”): Financial institutions eligible for Treasury
funding to serve urban and rural low-income communities
through the CDFI Fund. CDFIs were created in 1994
by the Riegle Community Development and Regulatory
Improvement Act. These entities must be certified by
Treasury; certification confirms that they target at least 60%
of their lending and other economic development activities to
areas underserved by traditional financial institutions.

Due Diligence: Appropriate level of attention or care a
reasonable person should take before entering into an
agreement or a transaction with another party. In finance, it
often refers to the process of conducting an audit or review of
the institution before initiating a transaction.
Dutch Auction: A type of auction in which multiple bidders
bid for different quantities of the asset; the price the seller
accepts is set at the lowest bid of the group of high bidders
whose collective bids fulfill the amount of shares offered. As

glossary I Appendix A I July 25, 2012

an example, three investors place bids to own a portion of
100 shares offered by the issuer:
• Bidder A wants 50 shares at $4/share.
• Bidder B wants 50 shares at $3/share.
• Bidder C wants 50 shares at $2/share.
The seller selects Bidders A and B as the two highest bidders,
and their collective bids consume the 100 shares offered. The
winning price is $3, which is what both bidders pay per share.
Bidder C’s bid is not filled. Treasury uses a modified version
of a Dutch Auction in the dispensation of its warrants.
Equity: Investment that represents an ownership interest in a
business.
Equity Capital Facility: Commitment to invest equity
capital in a firm under certain future conditions. An equity
facility when drawn down is an investment that increases
the provider’s ownership stake in the company. The investor
may be able to recover the amount invested by selling its
ownership stake to other investors at a later date.
Excess Spread: Funds left over after required payments and
other contractual obligations have been met. In TALF it is
the difference between the periodic amount of interest paid
out by the collateral and the amount of interest charged by
FRBNY on the nonrecourse loan provided to the borrower to
purchase the collateral.
Exercise Price: Preset price at which a warrant holder
may purchase each share. For warrants in publicly traded
institutions issued through CPP, this was based on the
average stock price during the 20 days before the date that
Treasury granted preliminary CPP participation approval.
Government-Sponsored Enterprises (GSEs): Private
corporations created and chartered by the Government to
reduce borrowing costs and provide liquidity in the market,
the liabilities of which are not officially considered direct
taxpayer obligations. On September 7, 2008, the two largest
GSEs, the Federal National Mortgage Association (“Fannie
Mae”) and the Federal Home Loan Mortgage Corporation
(“Freddie Mac”), were placed into Federal conservatorship.
They are currently being financially supported by the
Government.
Haircut: Difference between the value of the collateral and
the value of the loan (the loan value is less than the collateral
value).

Illiquid Assets: Assets that cannot be quickly converted to
cash.
Investors: Owners of mortgage loans or bonds backed by
mortgage loans who receive interest and principal payments
from monthly mortgage payments. Servicers manage the cash
flow from borrowers’ monthly payments and distribute them
to investors according to Pooling and Servicing Agreements
(“PSAs”).
Legacy Securities: Real estate-related securities originally
issued before 2009 that remained on the balance sheets
of financial institutions because of pricing difficulties that
resulted from market disruption.
Limited Partnership: Partnership in which there is at least
one partner whose liability is limited to the amount invested
(limited partner) and at least one partner whose liability
extends beyond monetary investment (general partner).
Loan Servicers: Companies that perform administrative
tasks on monthly mortgage payments until the loan is
repaid. These tasks include billing, tracking, and collecting
monthly payments; maintaining records of payments and
balances; allocating and distributing payment collections to
investors in accordance with each mortgage loan’s governing
documentation; following up on delinquencies; and initiating
foreclosures.
Loan-to-Value (“LTV”) Ratio: Lending risk assessment ratio
that mortgage lenders examine before approving a mortgage;
calculated by dividing the outstanding amount of the loan
by the value of the collateral backing the loan. Loans with
high LTV ratios are generally seen as higher risk because the
borrower has less of an equity stake in the property.
Mandatorily Convertible Preferred Stock (“MCP”): A type
of preferred share (ownership in a company that generally
entitles the owner of the shares to collect dividend payments)
that can be converted to common stock under certain
parameters at the discretion of the company and must be
converted to common stock by a certain time.
Nationally Recognized Statistical Rating Organization
(“NRSRO”): Credit rating agency registered with the
SEC. Credit rating agencies provide their opinion of the
creditworthiness of companies and the financial obligations
issued by companies. The ratings distinguish between
investment grade and non-investment grade equity and debt
obligations.

229

230

Appendix a I glossary I July 25, 2012

Net Present Value (“NPV”) Test: Compares the money
generated by modifying the terms of the mortgage with the
amount an investor can reasonably expect to recover in a
foreclosure sale.
Non-Agency Residential Mortgage-Backed Securities
(“non-agency RMBS”): Financial instrument backed by
a group of residential real estate mortgages (i.e., home
mortgages for residences with up to four dwelling units) not
guaranteed or owned by a Government-sponsored enterprise
(“GSE”) (Fannie Mae or Freddie Mac) or a Government
Agency.
Non-Cumulative Preferred Stock: Preferred stock with
a defined dividend, without the obligation to pay missed
dividends.
Non-Recourse Loan: Secured loan in which the borrower is
relieved of the obligation to repay the loan upon surrendering
the collateral.
Obligations: Definite commitments that create a legal
liability for the Government to pay funds.
Pool Assemblers: Firms authorized to create and market
pools of SBA-guaranteed loans.
Preferred Stock: Equity ownership that usually pays a fixed
dividend before distributions for common stock owners but
only after payments due to debt holders. It typically confers
no voting rights. Preferred stock also has priority over
common stock in the distribution of assets when a bankrupt
company is liquidated.
Pro Rata: Refers to dividing something among a group of
participants according to the proportionate share that each
participant holds as a part of the whole.
Qualifying Financial Institutions (“QFIs”): Private and
public U.S.-controlled banks, savings associations, bank
holding companies, certain savings and loan holding
companies, and mutual organizations.
Qualified Institutional Buyers (“QIB”): Institutions that
under U.S. securities law are permitted to buy securities that
are exempt from registration under investor protection laws
and to resell those securities to other QIBs. Generally, these
institutions own and invest at least $100 million in securities,
or are registered broker-dealers that own or invest at least $10
million in securities.
Revolving Credit Facility: Line of credit for which borrowers
pay a commitment fee, allowing them to repeatedly draw

down funds up to a guaranteed maximum amount. The
amount of available credit decreases and increases as funds
are borrowed and then repaid.
Risk-Weighted Assets: Risk-based measure of total assets
held by a financial institution. Assets are assigned broad
risk categories. The amount in each risk category is then
multiplied by a risk factor associated with that category. The
sum of the resulting weighted values from each of the risk
categories is the bank’s total risk-weighted assets.
SBA Pool Certificates: Ownership interest in a bond backed
by SBA-guaranteed loans.
Senior Preferred Stock: Shares that give the stockholder
priority dividend and liquidation claims over junior preferred
and common stockholders.
Senior Subordinated Debentures: Debt instrument ranking
below senior debt but above equity with regard to investors’
claims on company assets or earnings.
Servicing Advances: If borrowers’ payments are not made
promptly and in full, servicers are contractually obligated to
advance the required monthly payment amount in full to the
investor. Once a borrower becomes current or the property is
sold or acquired through foreclosure, the servicer is repaid all
advanced funds.
Short Sale: Sale of a home for less than the unpaid mortgage
balance. A borrower sells the home and the lender accepts
the proceeds as full or partial satisfaction of the unpaid
mortgage balance, thus avoiding the foreclosure process.
Skin in the Game: Equity stake in an investment; down
payment; the amount an investor can lose.
Special Purpose Vehicle (“SPV”): A legal entity, often offbalance-sheet, that holds transferred assets presumptively
beyond the reach of the entities providing the assets, and that
is legally isolated from its sponsor or parent company.
Subchapter S Corporations (“S corporations”): Corporate
form that passes corporate income, losses, deductions, and
credit through to shareholders for Federal tax purposes.
Shareholders of S corporations report the flow-through of
income and losses on their personal tax returns and are taxed
at their individual income tax rates.
Subordinated Debentures: Form of debt security that ranks
below other loans or securities with regard to claims on assets
or earnings.

glossary I Appendix A I July 25, 2012

Systemically Significant Institutions: Term referring to any
financial institution whose failure would impose significant
losses on creditors and counterparties, call into question the
financial strength of similar institutions, disrupt financial
markets, raise borrowing costs for households and businesses,
and reduce household wealth.

Sources:
Board of Governors of the Federal Reserve System, “Bank Holding Companies,” no date, www.
fedpartnership.gov/bank-life-cycle/manage-transition/bank-holding-companies.cfm, accessed
7/5/2012.

TALF Agent: Financial institution that is party to the TALF
Master Loan and Security Agreement and that occasionally
acts as an agent for the borrower. TALF agents include
primary and nonprimary broker-dealers.

FDIC, “FDIC Law, Regulations, Related Acts,” no date, www.fdic.gov/regulations/laws/
rules/2000-4600.html, accessed 7/5/2012.

Trial Modification: Under HAMP, a period of at least three
months in which a borrower is given a chance to establish
that he or she can make lower monthly mortgage payments
and qualify for a permanent modification.

GAO, “Principles of Federal Appropriations Law, Third Edition, Volume II,” 1/2004, www.gao.gov/
special.pubs/d06382sp.pdf, p. 7-3, accessed 7/5/2012.

Trust Preferred Securities (“TRUPS”): Securities that have
both equity and debt characteristics created by establishing a
trust and issuing debt to it.
Undercapitalized: Condition in which a financial institution
does not meet its regulator’s requirements for sufficient
capital to operate under a defined level of adverse conditions.
Underwater Mortgage: Mortgage loan on which a
homeowner owes more than the home is worth, typically as a
result of a decline in the home’s value. Underwater mortgages
are also referred to as having negative equity.

Federal Reserve Board, Federal Reserve Banks Operating Circular No. 8: Collateral, www.frbservices.
org/files/regulations/pdf/operating_circular_8.pdf, accessed 7/11/2012.
FCIC, glossary, no date, www.fcic.gov/resource/glossary, accessed 7/5/2012.
FDIC, “Credit Card Securitization Manual,” no date, www.fdic.gov/regulations/examinations/credit_
card_securitization/glossary.html, accessed 7/5/2012.

FRBNY, “TALF FAQ’s,” 7/21/2010, www.newyorkfed.org/markets/talf_faq.html, accessed 7/5/2012.
SIGTARP, “Factors Affecting Implementation of the Home Affordable Modification Program,”
3/25/2010, www.sigtarp.gov/Audit%20Reports/Factors_Affecting_Implementation_of_the_Home_
Affordable_Modification_Program.pdf, accessed 7/11/2012.

GAO, “Troubled Asset Relief Program Treasury Needs to Strengthen Its Decision-Making Process
on the Term Asset-Backed Securities Loan Facility,” 2/2010, www.gao.gov/new.items/d1025.
pdf, accessed 7/5/2012.GAO, “Troubled Asset Relief Program: Third Quarter 2010 Update of
Government Assistance Provided to AIG and Description of Recent Execution of Recapitalization
Plan,” 1/20/2011, www.gao.gov/new.items/d1146.pdf, accessed 7/5/2012.
IRS, “Glossary of Offshore Terms,” no date, www.irs.gov/businesses/small/article/0,,id=106572,00.
html, accessed 7/5/2012.
Making Home Affordable base NPV model documentation v4.0, updated 10/1/2010. www.
hmpadmin.com/portal/programs/docs/hamp_servicer/npvmodeldocumentationv4.pdf, pp. 23-24,
accessed 7/5/2012.
SBA, “Notice of Changes to SBA Secondary Market Program,” 9/21/2004, archive.sba.gov/idc/
groups/public/documents/sba_program_office/bank_notice_of_changes.htm, accessed 7/5/2012.
SEC, “NRSRO,” no date, www.sec.gov/answers/nrsro.htm, accessed 7/5/2012.
Treasury, “Decoder,” www.treasury.gov/initiatives/financial-stability/Pages/Glossary.aspx, accessed
7/5/2012.
Treasury, “Fact Sheet: Unlocking Credit for Small Businesses,” 3/16/2009, http://www.treasury.gov/
press-center/press-releases/Pages/tg58.aspx, accessed 7/5/2012.
Treasury, “Special Master Feinberg Testimony before the House Committee on Oversight and
Government Reform,” 10/28/2009, www.treasury.gov/press-center/press-releases/Pages/tg334.
aspx, accessed 7/5/2012.
Treasury, “Supplemental Directive 10-14: Making Home Affordable Program - Principal Reduction
Alternative Update,” 10/15/2010, www.hmpadmin.com/portal/programs/docs/hamp_servicer/
sd1014.pdf, accessed 7/5/2012.
Treasury, “TARP Standards for Compensation and Corporate Governance,” 6/10/2009, www.
treasury.gov/press-center/press-releases/Pages/tg165.aspx, accessed 7/5/2012.
U.S. Census Bureau, “Residential Finance Survey, Glossary Of RFS Terms And Definitions,” no date,
www.census.gov/hhes/www/rfs/glossary.html#l, accessed 7/5/2012.
U.S. Department of Housing and Urban Development, “Glossary,” no date, www.hud.gov/offices/hsg/
sfh/buying/glossary.cfm, accessed 7/5/2012.

231

232

Appendix B I Acronyms and abbreviations I July 25, 2012

Acronyms and Abbreviations
2MP Second Lien Modification Program
ABS

asset-backed securities

AGP Asset Guarantee Program
AHR American Home Recovery
AIA

American International Assurance Co., Ltd.;
AIA Group Limited

AIA SPV AIA Aurora LLC
AIFP Automotive Industry Financing Program
AIG American International Group, Inc.
AIGFP AIG Financial Products Corporation
AIG Trust AIG Credit Facility Trust
ALICO
ALICO SPV

American Life Insurance Company
ALICO Holdings LLC

Ally Financial Ally Financial Inc.
Ameris Ameris Bancorp, Moultrie, Georgia
ASSP Auto Supplier Support Program
AWCP Auto Warranty Commitment Program
Bank of
Bank of America Corporation
America
BOC

Bank of the Commonwealth

Bridgeview Bridgeview Bancorp, Inc., Bridgeview, Illinois
CAP Capital Assistance Program
CBO

Congressional Budget Office

CDCI

Community Development Capital Initiative

CDFI

Community Development Financial Institution

CDOs
CDS

collateralized debt obligations
Credit Default Swap

Centrue Centrue Financial Corporation, St. Louis, Missouri
CEO

chief executive officer

Cerberus Cerberus Capital Management, L.P.
CFPB Consumer Financial Protection Bureau
Chrysler

Chrysler Holding LLC

Chrysler
Chrysler Financial Services Americas LLC
Financial
CIC

CIC Bancshares, Inc.

Citigroup Citigroup, Inc.
CLTV
CMBS

Combined Loan-to-Value
commercial mortgage-backed securities

Coastal
Securities
Colonial
COP

Coastal Securities, Inc.
Colonial Bank
Congressional Oversight Panel

CPP Capital Purchase Program
CUSIPs
Dodd-Frank Act
DTI

CUSIP numbers; from Committee on Uniform
Securities Identification Procedures
Dodd-Frank Wall Street Reform and Consumer
Protection Act
debt-to-income ratio

Edison AIG Edison Life Insurance Company
EESA
Eligible assets

Emergency Economic Stabilization Act of 2008
securities eligible for purchase by PPIFs

Fannie Mae Federal National Mortgage Association
Farmers Capital
FBI

Farmers Capital Bank Corporation,
Frankfort, Kentucky
Federal Bureau of Investigation

FCIC

Financial Crisis Inquiry Commission

FDIC

Federal Deposit Insurance Corporation

FDIC OIG

Federal Deposit Insurance Corporation Office of
Inspector General

Federal
Federal Reserve System
Reserve
FHA

Federal Housing Administration

FHA2LP Treasury/FHA Second-Lien Program
FHFA
FHFA OIG
Fiat

Federal Housing Finance Agency
Federal Housing Finance Agency Office of the
Inspector General
Fiat North America LLC

Fidelity
Fidelity Southern Corporation, Atlanta, Georgia
Southern
First Capital
First Capital Bancorp, Inc., Glen Allen, Virginia
Bancorp
Firstbank Firstbank Corporation, Alma, Michigan
First Citizens
First Citizens Banc Corp, Sandusky, Ohio
Banc
FirstCity

FirstCity Bank

First
Community First Community Bank of Hammond, Louisiana
Bank
First Defiance First Defiance Financial Corp., Defiance, Ohio

Acronyms and abbreviations I Appendix B I July 25, 2012

First Security
First Security Group, Inc.
Group
First Trust First Trust Corporation, New Orleans, Louisiana
FLC

Flahive Law Corporation

FNB United FNB United Corp., Asheboro, North Carolina
Fort Lee
FRB

Fort Lee Federal Savings Bank, Fort Lee, New Jersey
Federal Reserve Board of Governors

FRBNY Federal Reserve Bank of New York
Federal Reserve Board Office of the
FRB OIG
Inspector General
Freddie Mac Federal Home Loan Mortgage Corporation
FSOC
GAO

Financial Stability Oversight Council
Government Accountability Office

Genesis Genesis Staffing, Inc.
Ginnie Mae Government National Mortgage Association
GM General Motors Company
GMAC GMAC Inc.
Greater Kinston
GSE
HAFA
HAMP

Greater Kinston Credit Union, Kinston, North Carolina
Government-sponsored enterprise
Home Affordable Foreclosure Alternatives program
Home Affordable Modification Program

HFA Housing Finance Agency
HHF
HPDP

International Lease Finance Corporation

Intervest Intervest Bancshares Corporation

Jobs Act

Invesco Legacy Securities Master Fund, L.P.
initial public offering
Internal Revenue Service Criminal
Investigation Division
Jobs Act of 2010

JPMorgan JPMorgan Chase & Co.
Legacy Home
Legacy Home Loans and Real Estate
Loans
Litton Litton Loan Servicing, LP
LNB
LTV
M&T

LNB Bancorp, Inc., Lorain, Ohio
loan-to-value ratio
M&T Bank Corporation

MainSource MainSource Financial Group
MBS

mortgage-backed securities

MCP mandatorily convertible preferred shares
MetroCorp
MHA

New Chrysler Chrysler Group LLC
New Point New Point Financial Services, Inc.
Non-Agency
RMBS
NPV
NRSRO

Non-Agency Residential Mortgage-Backed Securities
net present value
nationally recognized statistical rating organization

Oaktree Oaktree PPIP Fund, L.P.
OCC
Ocala

Office of the Comptroller of the Currency
Ocala Funding

Old Chrysler Chrysler Group LLC
Old GM
OFS
OMB

General Motors Corp.
Office of Financial Stability
Office of Management and Budget

Option ARM Option Adjustable Rate Mortgage
Orion Bank Orion Bank
OTS

Office of Thrift Supervision

Oxford Oxford Collection Agency, Inc.
Peoples Peoples Bancorp of North Carolina, Inc., Newton,
Bancorp of NC North Carolina
PII personally identifiable information
PPIF Public-Private Investment Fund

HUD OIG

IRS-CI

Nan Shan Life Insurance Company Ltd.

PPIP Public-Private Investment Program

Department of Housing and Urban Development
Office of the Inspector General

IPO

Millennium Bancorp, Inc., Edwards, Colorado

Home Price Decline Protection program
Department of Housing and Urban Development

Invesco

Nan Shan

Hardest Hit Fund

HUD

ILFC

Millennium

MetroCorp Bancshares, Inc., Houston, Texas
Making Home Affordable program

PRA

Principal Reduction Alternative program

Premier
Premier Bancorp, Inc., Wilmette, Illinois
Bancorp
PremierWest PremierWest Bancorp, Medford, Oregon
PSA

Pooling and Servicing Agreement

QFI qualifying financial institution
Pulaski

Pulaski Financial Corp, Creve Coeur, Missouri

QIB Qualified Institutional Buyers
RD

Department of Agriculture’s Office of
Rural Development

RD-HAMP

Rural Development Home Affordable
Modification Program

ResCap Residential Capital, LLC
RMBS

residential mortgage-backed securities

Rogers
Rogers Bancshares, Inc.
Bancshares
S corporations IRS subchapter S corporations
SBA

Small Business Administration

SBLF

Small Business Lending Fund

SCB Bank
SEC

SCB Bank, Shelbyville, Indiana
Securities and Exchange Commission

Secret Service Secret Service

233

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Appendix B I Acronyms and abbreviations I July 25, 2012

Servicers

loan servicers

Shay Financial Shay Financial Services, Inc.
SIFI
SIGTARP Act
SNL
Southern First
SPA

Systemically Important Financial Institutions
Special Inspector General for the Troubled Asset
Relief Program Act of 2009
SNL Financial, LLC
Southern First Bancshares, Inc., Greenville, South
Carolina
Servicer Participation Agreement

SPV special purpose vehicle
SSFI Systemically Significant Failing Institutions program
Star

AIG Star Life Insurance Co., Ltd.

TALF

Term Asset-Backed Securities Loan Facility

TARP

Troubled Asset Relief Program

Task Force joint task force
Taylor Capital Taylor Capital Group, Rosemont, Illinois
TBW

Taylor, Bean and Whitaker Mortgage Corporation

TCW

The TCW Group, Inc.

Tennessee
Tennessee Commerce Bancorp, Inc.
Commerce
TIP

Targeted Investment Program

Tivest Tivest Development and Construction LLC

TPP trial period plan
Treasury Department of the Treasury
Treasury/FMA
HAMP

HAMP Loan Modification Option for
FHA-insured Mortgages

Treasury
Secretary of the Treasury
Secretary
TRUPS

trust preferred securities

TSG

The Shmuckler Group, LLC

UAW

United Auto Workers

UCB

United Commercial Bank

UCBH

UCBH Holdings, Inc.

UCSB

Unlocking Credit for Small Businesses

United Bancorp United Bancorp, Inc., Tecumseh, Michigan
UP
USPIS
VA
Valley National
Wellington
Wells Fargo
WSFS

Home Affordable Unemployment Program
U.S. Postal Inspection Service
Department of Veterans Affairs
Valley National Bancorp, Wayne, New Jersey
Wellington Management Legacy Securities PPIF
Master Fund, LP
Wells Fargo & Company
WSFS Financial Corporation

Reporting Requirements I Appendix C I July 25, 2012

Reporting Requirements

This appendix provides Treasury’s responses to data call questions regarding the reporting requirements of the Special
Inspector General for the Troubled Asset Relief Program outlined in EESA Section 121, as well as a cross-reference to related
data presented in this report and prior reports. Italic style indicates narrative taken verbatim from source documents.

#
1

EESA
Section

EESA Reporting
Requirement

Section
121(c)(A)

A description of
the categories of
troubled assets
purchased or
otherwise procured
by the Treasury
Secretary.

Treasury Response to SIGTARP Data Call

SIGTARP
Report Section

Treasury’s authority to make new financial commitments under TARP ended on
October 3, 2010

Section 2:
“TARP Overview”

Below are program descriptions from Treasury’s www.treasury.gov/initiatives/financialstability/Pages/default.aspx website, as of 6/30/2012:

Appendix D:
“Transaction
Detail”

CPP: Treasury created the Capital Purchase Program (CPP) in October 2008 to stabilize
the financial system by providing capital to viable financial institutions of all sizes
throughout the nation. With a strengthened capital base, financial institutions have an
increased capacity to lend to U.S. businesses and consumers and to support the U.S.
economy.
AIG: In September of 2008, panic in the financial system was deep and widespread
Amidst these events, on Friday, September 12, American International Group (AIG) officials informed the Federal Reserve and Treasury that the company was facing potentially
fatal liquidity problems. At the time, AIG was the largest provider of conventional insurance
in the world, with approximately 75 million individual and corporate customers in over 130
countries.a
AGP: Under the Asset Guarantee Program (AGP), Treasury acted to support the value of
certain assets held by qualifying financial institutions, by agreeing to absorb unexpectedly
large losses on certain assets. The program was designed for financial institutions whose
failure could harm the financial system and was used in conjunction with other forms of
exceptional assistance.
TIP: Under the Targeted Investment Program (TIP), Treasury provided exceptional
assistance on a case-by-case basis in order to stabilize institutions that were considered
systemically significant to prevent broader disruption of financial markets. Treasury
provided this assistance by purchasing preferred stock, and also received warrants to
purchase common stock, in the institutions.
TALF: This joint initiative with the Federal Reserve builds off, broadens and expands the
resources available to support the consumer and business credit markets by providing
the financing to private investors to help unfreeze and lower interest rates for auto,
student loan, small business, credit card and other consumer and business credit. The
U.S. Treasury originally committed $20 billion to provide credit protection for $200 billion
of lending from the Federal Reserve. This commitment was later reduced to $4.3 billion
after the program closed to new lending on June 30, 2010, with $43 billion in loans
outstanding.
PPIP: On March 23, 2009, the U.S. Department of the Treasury (“Treasury”), announced
the Legacy Securities Public-Private Investment Program (“PPIP”) as a key component of
President Obama’s Financial Stability Plan. The Financial Stability Plan outlines a broad
framework to bring capital into the financial system and address the problem of legacy
real estate assets.
CDCI: As part of the Administration’s ongoing commitment to improving access to credit
for small businesses, Treasury announced on February 3 final terms for the Community
Development Capital Initiative (CDCI). This TARP program invested lower-cost capital in
Community Development Financial Institutions (CDFIs) that lend to small businesses in the
country’s hardest-hit communities.
Continued on next page

235

236

Appendix C I Reporting Requirements I July 25, 2012

#

EESA
Section

EESA Reporting
Requirement

SIGTARP
Report Section

Treasury Response to SIGTARP Data Call
SBLF: Enacted into law as part of the Small Business Jobs Act of 2010 (the Jobs Act), the
Small Business Lending Fund (SBLF) is a $30 billion fund that encourages lending to small
businesses by providing capital to qualified community banks with assets of less than $10
billion. Through the Small Business Lending Fund, Main Street banks and small businesses
can work together to help create jobs and promote economic growth in local communities
across the nation.
UCSB: The Treasury Department will begin making direct purchases of securities backed
by SBA loans to get the credit market moving again, and it will stand ready to purchase
new securities to ensure that community banks and credit unions feel confident in
extending new loans to local businesses.
AIFP: The objective of the Automotive Industry Financing Program (AIFP) is to prevent a
significant disruption of the American automotive industry, which would pose a systemic
risk to financial market stability and have a negative effect on the economy of the United
States.
ASSP: [ASSP was created to] provide up to $5 billion in financing, giving suppliers the
confidence they need to continue shipping parts, pay their employees and continue their
operations.b
AWCP: The Treasury Department announced an innovative new program to give
consumers who are considering new car purchases the confidence that even while
Chrysler and GM were restructuring in bankruptcy, their warrantees will be honored. This
program is part of the Administration’s broader program to stabilize the auto industry and
stand behind a restructuring effort that will result in stronger, more competitive and viable
American car companies.b
HAMP (a program under MHA): The Home Affordable Modification Program has a
simple goal: reduce the amount homeowners owe per month to sustainable levels to
stabilize communities. This program will bring together lenders, investors, servicers,
borrowers and the Government, so that all stakeholders share in the cost of ensuring that
responsible homeowners can afford their monthly mortgage payments -- helping to reach
up to 3 to 4 million at-risk borrowers in all segments of the mortgage market, reducing
foreclosures, and helping to avoid further downward pressures on overall home prices.

2

3

4

Section
121(c)(B)

Section
121(c)(C)

Section
121(c)(D)

A listing of the
troubled assets
purchased in each
such category
described under
Section 121(c)(A)

Treasury’s authority to make new financial commitments under TARP ended on
October 3, 2010.

An explanation
of the reasons
the Treasury
Secretary deemed
it necessary to
purchase each such
troubled asset.

Treasury’s authority to make new financial commitments under TARP ended on
October 3, 2010.

A listing of each
financial institution
from which such
troubled assets
were purchased

See #2.

Information on all transactions as well as additional information about these programs
and related purchases is available in the transaction reports and monthly 105(a) reports
posted at www.treasury.gov/initiatives/financial-stability/briefing-room/reports/Pages/
Home.aspx. Information regarding all transactions through the end of June 2012 is
available at the aforementioned link in a transaction report dated 6/27/2012.

Appendix D:
“Transaction
Detail”

Section 2: “TARP
Overview”
Appendix C:
“Reporting
Requirements”
of prior SIGTARP
Quarterly Reports
to Congress
See #2.

Continued on next page

Reporting Requirements I Appendix C I July 25, 2012

#
5

6

7

8

EESA
Section

EESA Reporting
Requirement

Section
121(c)(E)

A listing of
and detailed
biographical
information on each
person or entity
hired to manage
such troubled
assets.

There have been no new PPIP fund managers hired between March 31, 2012, and
June 30, 2012.

A current estimate
of the total amount
of troubled assets
purchased pursuant
to any program
established under
Section 101, the
amount of troubled
assets on the
books of Treasury,
the amount of
troubled assets
sold, and the profit
and loss incurred
on each sale or
disposition of each
such troubled
assets.

The transaction reports capture detailed information about troubled asset purchases,
price paid, and the amount of troubled assets currently on Treasury’s books. The latest
transaction reports are available on Treasury’s website at www.treasury.gov/initiatives/
financial-stability/briefing-room/reports/Pages/Home.aspx. Information regarding all
transactions through the end of June 2012 is available at the aforementioned link in a
transaction report dated 6/27/2012.

A listing of the
insurance contracts
issued under
Section 102.

Treasury’s authority to make new financial commitments under TARP ended on October 3,
2010. As such, Treasury cannot issue any new insurance contracts after this date.

A detailed statement
of all purchases,
obligations,
expenditures, and
revenues associated
with any program
established by the
Secretary of the
Treasury under
Sections 101 and
102.

Treasury’s authority to make new financial commitments under TARP ended on
October 3, 2010.

Section
121(c)(F)

Section
121(c)(G)

Section
121(f)

Treasury Response to SIGTARP Data Call

On February 7, 2012, the Treasury executed a new Financial Agency Agreement with
Greenhill & Co. LLC (Greenhill) to provide certain services relating to the management
and disposition of American International Group, Inc. (AIG) investments acquired
pursuant to the Emergency Economic Stability Act of 2008 (EESA). Greenhill is a global
financial services firm providing investment banking, advice on mergers, acquisitions,
restructurings, financings and capital raisings to corporations, partnerships, institutions
and governments.

Treasury published its most recent valuation of TARP investments as of June 30, 2012,
on 7/10/2012, in its July 2012 105(a) report that is available at the following link: www.
treasury.gov/initiatives/financial-stability/briefing-room/reports/105/Pages/default.aspx

SIGTARP
Report Section
Section 2:
“Public-Private
Investment
Program”
Appendix C:
“Reporting
Requirements”
of prior SIGTARP
Quarterly Reports
to Congress
Table C.1;
Section 2: “TARP
Overview”
Appendix D:
“Transaction
Detail”

Information on the repayments of Treasury’s investments under the CPP and proceeds
from the sale of warrants are available within Treasury’s press releases, transactions
reports and Section 105(a) Monthly Congressional Reports at the following links:
www.treasury.gov/initiatives/financial-stability/briefing-room/Pages/press-releases.aspx
www.treasury.gov/initiatives/financial-stability/briefing-room/reports/Pages/Home.aspx

Section 2:
“TARP Overview”
Section 2:
“Targeted
Investment
Program and
Asset Guarantee
Program”
Table C.1;
Section 2:
“TARP Overview”

Treasury provides information about TARP obligations, expenditures and revenues in
separate transaction reports available on Treasury’s public website at www.treasury.gov/
Section 3:
initiatives/financial-stability/briefing-room/reports/Pages/Home.aspx. Information regarding “TARP Operations
all transactions through the end of June 2012 is available at the aforementioned link in a
and Administration”
transaction report dated 6/27/2012.
Appendix D:
Information on obligations and expenditures is also available in the Daily TARP Update
“Transaction Detail”
reports available on Treasury’s public website at: www.treasury.gov/initiatives/financialstability/briefing-room/reports/tarp-daily-summary-report/pages/default.aspx, accessed
7/5/2012.

Notes:
a
Otherwise known as Systemically Significant Failing Institution (“SSFI”).
b
Description is of 3/31/2011.
Sources: Treasury, response to SIGTARP data call, 7/5/2012; Program Descriptions: Treasury, “Programs,” www.treasury.gov/initiatives/financial-stability/programs/Pages/default.aspx accessed
7/5/2012; ASSP: “Treasury Announces Auto Suppliers Support Program,” 3/19/2009, www.treasury.gov/press-center/press-releases/Pages/tg64.aspx, accessed 7/5/2012; AWCP: “Obama
Administration’s New Warrantee Commitment Program,” no date, www.whitehouse.gov/assets/documents/Warrantee_Commitment_Program.pdf, accessed 7/5/2012; TALF: Federal Reserve, “Term
Asset-Backed Securities Loan Facility (TALF) Frequently Asked Questions,” no date, www.federalreserve.gov/newsevents/press/monetary/monetary20090303a2.pdf, accessed 7/5/2012; SBLF: Small
Business Lending Act, P.L. 111-240, 9/27/2010; MHA “Making Home Affordable Updated Detailed Description Update,” 3/26/2010, www.treasury.gov/initiatives/financial-stability/programs/housingprograms/mha/Pages/default.aspx, accessed 7/5/2012.

237

238

Appendix C I Reporting Requirements I July 25, 2012

Table C.1

TOTAL AMOUNT OF TROUBLED ASSETS PURCHASED AND HELD ON TREASURY’S BOOKs

($ BILLIONS)

Obligations After
Dodd-Frank
(As of 10/3/2010)

Current Obligations
(As of 6/30/2012)

Expended

On Treasury’s
Booksa

Housing Support Programs

$45.6

$45.6

$4.5

$—

Capital Purchase Program (“CPP”)

204.9

204.9

204.9

13.8

Community Development Capital Initiative (“CDCI”)

0.6

0.6

0.2

0.6

Systemically Significant Failing Institutions (“SSFI”)

69.8

67.8c

67.8

36.0

Targeted Investment Program (“TIP”)

40.0

40.0

40.0

0.0

Asset Guarantee Program (“AGP”)

5.0

5.0

0.0

0.0

Term Asset-Backed Securities Loan Facility (“TALF”)

4.3

1.4

0.1

0.1

22.4

21.9

18.5

14.1

Unlocking Credit for Small Businesses (“UCSB”)

0.4

0.4

0.4

0.0

Automotive Industry Support Programs (“AIFP”)b

81.8

79.7d

79.7

44.5

$474.8

$467.2

$416.1

$109.1

Public-Private Investment Program (“PPIP”)

Total

Notes: Numbers may not total due to rounding.
a
“On Treasury’s Books” calculated as the amount of TARP funds remaining outstanding, including realized losses and write-offs.
b
Includes amounts for AIFP, ASSP, and AWCP.
c
Treasury deobligated $2 billion in equity facility for AIG that was never drawn down.
d
Includes $80.7 billion for Automotive Industry Financing Program, $0.6 billion for Auto Warranty Commitment Program, and $0.4 billion for Auto Supplier Support Program.
Sources: Repayments data: Treasury, Transactions Report, 6/27/2012; Treasury, Daily TARP Update, 7/2/2012.

Preferred Stock w/ Warrants
Preferred Stock w/ Exercised Warrants

Bank of America Corporation, Charlotte, NC1b

Bank of America Corporation, Charlotte, NC1a,1b

Bank of Commerce, Charlotte, NC2

Bank of Commerce Holdings, Redding, CA49

Bank of George, Las Vegas, NV2

Bank of Marin Bancorp, Novato, CA

Bank of the Carolinas Corporation, Mocksville, NC

Bank of the Ozarks, Inc., Little Rock, AR

Bankers’ Bank of the West Bancorp, Inc.,
Denver, CO2

10/28/2008

1/9/2009

1/16/2009

11/14/2008

3/13/2009

12/5/2008

4/17/2009

12/12/2008

1/30/2009

2,10

$8,600,000

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Exercised Warrants

$12,639,000

$75,000,000

$13,179,000

$28,000,000

$2,672,000

$17,000,000

$3,000,000

$10,000,000,000

$15,000,000,000

$1,004,000

$50,000,000

$48,000,000

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

$30,000,000

$13,669,000

Preferred Stock w/ Warrants

Preferred Stock w/ Exercised Warrants

$21,100,000

$7,400,000

Preferred Stock w/ Exercised Warrants

$2,000,000

Preferred Stock w/ Exercised Warrants

$525,000,000

$8,152,000

$110,000,000

$5,000,000

$21,000,000

$52,000,000

$6,000,000

$1,800,000

$3,388,890,000

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Warrants

Subordinated Debentures w/ Exercised
Warrants

Preferred Stock w/ Warrants

Bank Financial Services, Inc., Eden Prairie, MN2

AmFirst Financial Services, Inc., McCook, NE8

8/21/2009

8/14/2009

AmeriServ Financial, Inc, Johnstown, PA50

12/19/2008

Preferred Stock w/ Warrants

BancTrust Financial Group, Inc., Mobile, AL

Ameris Bancorp, Moultrie, GA85

11/21/2008

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants

BancStar, Inc., Festus, MO2

American State Bancshares, Inc., Great Bend, KS2

1/9/2009

12/19/2008

American Premier Bancorp, Arcadia, CA2

5/29/2009

Preferred Stock w/ Warrants

$2,492,000

Preferred Stock w/ Exercised Warrants

4/3/2009

American Express Company, New York, NY

1/9/2009

$3,674,000

Preferred Stock w/ Exercised Warrants

BancPlus Corporation, Ridgeland, MS2,30

AmeriBank Holding Company, Collinsville, OK2,49

3/6/2009

2/20/2009

AMB Financial Corp., Munster, IN2,50

1/30/2009

$70,000,000

Preferred Stock w/ Exercised Warrants

Bancorp Rhode Island, Inc., Providence, RI

Alpine Banks of Colorado, Glenwood Springs, CO2

3/27/2009

$3,652,000

Preferred Stock w/ Exercised Warrants

12/19/2008

Allied First Bancorp, Inc., Oswego, IL2

4/24/2009

$12,000,000

Subordinated Debentures
w/ Exercised Warrants

Bancorp Financial, Inc., Oak Brook, IL2,10,49

Alliance Financial Services Inc., Saint Paul, MN8

6/26/2009

$26,918,000

$2,986,000

$4,781,000

$6,514,000

$12,720,000

$3,500,000

$10,000,000

$111,000,000

$16,369,000

$6,000,000

$4,400,000

$12,000,000

Investment Amount

Preferred Stock w/ Warrants

BancIndependent, Inc., Sheffield, AL2,49

Alliance Financial Corporation, Syracuse, NY

12/19/2008

Preferred Stock w/ Exercised Warrants

7/10/2009

Alliance Bancshares, Inc., Dalton, GA2

6/26/2009

Preferred Stock w/ Exercised Warrants
Preferred Stock w/ Warrants

3/13/2009

Alaska Pacific Bancshares, Inc., Juneau, AK

2/6/2009

Avenue Financial Holdings, Inc., Nashville, TN2,49

Alarion Financial Services, Inc., Ocala, FL2

1/23/2009

Preferred Stock w/ Exercised Warrants

Atlantic Bancshares, Inc., Bluffton, SC

Adbanc, Inc, Ogallala, NE2,49

1/30/2009

Preferred Stock w/ Exercised Warrants
Preferred Stock w/ Warrants

2/27/2009

AB&T Financial Corporation, Gastonia, NC

1/23/2009

12/29/2009

1st United Bancorp, Inc., Boca Raton, FL2

3/13/2009

Preferred Stock w/ Warrants

Associated Banc-Corp, Green Bay, WI

1st Source Corporation, South Bend, IN

1/23/2009

Preferred Stock
Preferred Stock w/ Warrants

11/21/2008

1st FS Corporation, Hendersonville, NC

11/14/2008

Anchor BanCorp Wisconsin Inc., Madison, WI

1st Enterprise Bank, Los Angeles, CA2,10a,49

12/11/2009

Preferred Stock w/ Warrants
Preferred Stock w/ Exercised Warrants

Annapolis Bancorp, Inc., Annapolis, MD

1st Enterprise Bank, Los Angeles, CA2,49

2/13/2009

1/30/2009

1st Constitution Bancorp, Cranbury, NJ

12/23/2008

Investment Description

1/30/2009

Institution

Purchase
Date

CPP TRANSACTION DETAIL, AS OF 6/30/2012

Table D.1

Transaction Detail

11/4/2009

3/31/2009

9/27/2011

12/9/2009

12/9/2009

9/29/2010

8/5/2009

8/18/2011

7/14/2011

$75,000,000

$28,000,000

$17,000,000

$10,000,000,000

$15,000,000,000

$48,000,000

$30,000,000

$13,669,000

$21,100,000

$7,400,000

$262,500,000

9/14/2011

9/15/2011

$262,500,000

$4,076,000

$21,000,000

$47,665,332

$6,000,000

$1,800,000

$3,388,890,000

$2,492,000

$3,674,000

$26,918,000

$12,720,000

$10,000,000

$111,000,000

$6,000,000

$4,400,000

$12,000,000

Capital Repayment
Amount (Loss)6

4/6/2011

4/18/2012

8/11/2011

6/13/2012

11/2/2011

1/26/2011

6/17/2009

9/15/2011

9/22/2011

5/13/2009

7/21/2011

11/18/2009

12/29/2010

9/1/2011

9/1/2011

10/27/2010

Capital
Repayment
Date

$—

$—

$—

$—

$—

$—

$—

$—

$—

$—

$—

$262,500,000

$4,076,000

$—

$—

$—

$—

$—

$—

$—

$—

$—

$—

$—

$—

$—

$—

Remaining
Capital Amount

11/24/2009

11/18/2011

10/26/2011

3/3/2010

3/3/2010

9/29/2010

9/30/2009

8/18/2011

7/14/2011

9/15/2011

11/30/2011

11/2/2011

11/2/2011

1/26/2011

7/29/2009

9/15/2011

9/22/2011

6/17/2009

7/21/2011

11/18/2009

3/9/2011

N/A

9/1/2011

11/18/2011

Final
Disposition
Date

R

P

R

A

A

R

R

R

R

R

A

R

R

R

R

R

R

R

R

R

R

R

P

Note15

$2,650,000

$1,703,984

$125,000

$122,365,216

$183,547,824

$2,400,000

$1,400,000

$410,000

$1,055,000

$370,000

$3,435,006

$825,000

$300,000

$90,000

$340,000,000

$125,000

$184,000

$900,000

$636,000

$500,000

$3,750,000

N/A

$220,000

$326,576

Final Disposition
Proceeds

$30.08

$0.23

$37.01

$2.80

$8.18

$2.99

$0.70

$13.19

$6.80

$0.45

$2.82

$12.60

$58.21

$6.85

$0.27

$34.34

$8.20

$0.90

$6.21

$22.60

$13.00

$9.41

Stock
Price as of
6/29/2012

$1,061,947

$3,354,167

$1,039,677

$451,111

$279,991

$2,439,028

$421,921

$458,333,333

$835,416,667

$150,577

$7,888,889

$1,460,782

$4,207,399

$941,667

$1,516,737

$2,686,411

$1,028,415

$122,725

$68,104,167

$1,326,398

$1,146,635

$2,776,667

$9,302,107

$920,142

$162,682

$74,367,308

$343,021

$529,576

$12,082,539

$409,753

$388,742

$538,360

$469,599

$784,605

$998,057

$1,715,769

$360,694

$370,903

$10,730,000

$1,229,949

$1,128,156

$1,106,667

Dividends/
Interest Paid to
Treasury

Continued on next page

475,204

730,994

299,706

7,399,103

698,554

Current
Outstanding
Warrants

Transaction detail I Appendix D I July 25, 2012

239

$1,744,000
$6,400,000

Preferred Stock w/ Warrants
Preferred Stock w/ Warrants

Preferred Stock w/ Exercised Warrants
Preferred Stock w/ Exercised Warrants
Preferred Stock
Subordinated Debentures
w/ Exercised Warrants

Preferred Stock w/ Warrants
Preferred Stock w/ Exercised Warrants

Banner County Ban Corporation, Harrisburg, NE2,49

Bar Harbor Bankshares, Bar Harbor, ME

BB&T Corp., Winston-Salem, NC

BBCN Bancorp, Inc.
(Center Financial Corporation), Los Angeles, CA66

BBCN Bancorp, Inc.
(Nara Bancorp, Inc.), Los Angeles, CA66

BCB Holding Company, Inc., Theodore, AL2

BCSB Bancorp, Inc., Baltimore, MD

Beach Business Bank, Manhattan Beach, CA2

Berkshire Hills Bancorp, Inc., Pittsfield, MA

Bern Bancshares, Inc., Bern, KS2,49

Birmingham Bloomfield Bancshares, Inc,
Birmingham, MI2,49

Birmingham Bloomfield Bancshares, Inc,
Birmingham, MI2,10a,49

Biscayne Bancshares, Inc., Coconut Grove, FL

Blackhawk Bancorp, Inc., Beloit, WI2

Blackridge Financial, Inc., Fargo, ND2

Blue Ridge Bancshares, Inc., Independence, MO2

Blue River Bancshares, Inc., Shelbyville, IN2,71

Blue Valley Ban Corp, Overland Park, KS

BNB Financial Services Corporation, New York,
NY2

BNC Bancorp, Thomasville, NC

BNC Financial Group, Inc., New Canaan, CT2,49

BNCCORP, Inc., Bismarck, ND2

BOH Holdings, Inc., Houston, TX2,49

2/6/2009

1/16/2009

11/14/2008

12/12/2008

11/21/2008

4/3/2009

12/23/2008

1/30/2009

12/19/2008

2/13/2009

4/24/2009

12/18/2009

6/19/2009

3/13/2009

5/22/2009

3/6/2009

3/6/2009

12/5/2008

4/17/2009

12/5/2008

2/27/2009

1/16/2009

3/6/2009

5/15/2009

$5,000,000

$5,586,000

Subordinated Debentures w/ Exercised
Warrants
Preferred Stock w/ Warrants

Boscobel Bancorp, Inc, Boscobel, WI8

Boston Private Financial Holdings, Inc.,
Boston, MA

Bridge Capital Holdings, San Jose, CA

11/21/2008

12/23/2008

$6,000,000
$2,400,000

Preferred Stock
Subordinated Debentures w/ Exercised
Warrants

Broadway Financial Corporation,
Los Angeles, CA3,10a,72

Brogan Bankshares, Inc., Kaukauna, WI8

Brotherhood Bancshares, Inc., Kansas City, KS2,49

Business Bancshares, Inc., Clayton, MO2

Butler Point, Inc., Catlin, IL2

12/4/2009

5/15/2009

7/17/2009

4/24/2009

3/13/2009

$607,000

$15,000,000

Preferred Stock w/ Exercised Warrants
Preferred Stock w/ Exercised Warrants

$11,000,000

Preferred Stock w/ Exercised Warrants

$9,000,000

Preferred Stock

$38,000,000

Preferred Stock w/ Exercised Warrants

Bridgeview Bancorp, Inc., Bridgeview, IL2

Broadway Financial Corporation,
Los Angeles, CA3a,72

12/19/2008

11/14/2008

$23,864,000

Preferred Stock w/ Warrants

$154,000,000

$10,000,000

$4,797,000
$20,093,000

Preferred Stock w/ Exercised Warrants

$31,260,000

$7,500,000

$21,750,000

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Exercised Warrants

$12,000,000

$5,000,000

Preferred Stock w/ Exercised Warrants
Preferred Stock w/ Exercised Warrants

$10,000,000

$1,635,000

$985,000

$40,000,000

$6,000,000

$10,800,000

$1,706,000

$67,000,000

$55,000,000

$3,133,640,000

$18,751,000

$795,000

$124,000,000

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Exercised Warrants

8,10

Preferred Stock w/ Warrants

Banner Corporation, Walla Walla, WA74

$1,000,000

11/21/2008

Preferred Stock w/ Exercised Warrants

BankFirst Capital Corporation, Macon, MS2,49

BankGreenville, Greenville, SC2

$15,500,000

Investment Amount

1/23/2009

Preferred Stock w/ Exercised Warrants

Investment Description

(Continued)

2/13/2009

Institution

Purchase
Date

CPP TRANSACTION DETAIL, AS OF 6/30/2012

$300,000

$15,000,000
$8,864,000

2/23/2011
3/16/2011

11/2/2011

5/23/2012

$607,000

$6,000,000

$11,000,000

$104,000,000

6/16/2010

9/15/2011

$50,000,000

$10,000,000

$4,797,000

$2,250,000

$1,744,000

$1,635,000

$985,000

1/13/2010

7/14/2011

8/4/2011

6/27/2012

7/28/2011

7/28/2011

9/1/2011

$40,000,000

6/27/2012
5/27/2009

$1,200,000

6/6/2012

$1,500,000

10/19/2011
$1,500,000

$1,500,000

7/6/2011

3/7/2012

$10,800,000

$67,000,000

$55,000,000

$3,133,640,000

$18,751,000

$795,000

$108,071,915

$15,500,000

Capital Repayment
Amount (Loss)6

1/26/2011

6/27/2012

6/27/2012

6/17/2009

2/24/2010

7/28/2011

3/28/2012

9/8/2011

Capital
Repayment
Date

$—

$9,000,000

$—

$—

$8,864,000

$—

$104,000,000

$—

$—

$2,750,000

$—

$—

$—

$—

$—

$300,000

$1,500,000

$3,000,000

$4,500,000

$—

$—

$—

$—

$—

$—

$—

$—

Remaining
Capital Amount

11/2/2011

9/15/2011

4/20/2011

2/1/2011

7/14/2011

8/4/2011

N/A

7/28/2011

9/1/2011

6/24/2009

6/27/2012

7/22/2009

7/28/2010

7/28/2011

9/8/2011

Final
Disposition
Date

R

R

R

A

R

R

R

R

R

R

R

R

R

R

Note15

$30,000

$550,000

$1,395,000

$6,202,523

$500,000

$240,000

N/A

$82,000

$50,000

$1,040,000

$300,000

$67,010,402

$250,000

$40,000

$775,000

Final Disposition
Proceeds

$1.30

$16.15

$8.93

$2.11

$13.00

$7.86

$3.55

$0.02

$7.02

$3.30

$8.80

$22.00

$9.18

$13.50

$10.89

$30.85

$36.00

$21.91

Stock
Price as of
6/29/2012

$87,124

$2,506,855

$1,295,586

$402,720

$810,417

$2,393,156

$2,613,582

$11,022,222

$468,624

$1,283,777

$909,542

$636,921

$5,383,667

$440,542

$211,458

$529,105

$1,760,350

$825,326

$1,728,861

$1,516,271

$342,023

$137,063

$877,778

$963,317

$1,129,500

$173,508

$12,060,000

$9,739,583

$92,703,517

$1,036,514

$107,411

$20,873,747

$177,428

$2,217,469

Dividends/
Interest Paid to
Treasury

Continued on next page

543,337

111,083

183,465

337,480

243,998

Current
Outstanding
Warrants

240
Appendix D I Transaction Detail I July 25, 2012

Carolina Bank Holdings, Inc., Greensboro, NC

Carolina Trust Bank, Lincolnton, NC

Carrollton Bancorp, Baltimore, MD

Carver Bancorp, Inc, New York, NY3,30

Cascade Financial Corporation, Everett, WA47

Cathay General Bancorp, Los Angeles, CA

Catskill Hudson Bancorp, Inc, Rock Hill, NY2,49

Catskill Hudson Bancorp, Inc, Rock Hill, NY2,10a,49

2/6/2009

2/13/2009

1/16/2009

11/21/2008

12/5/2008

2/27/2009

12/22/2009

Central Pacific Financial Corp., Honolulu, HI37,46

1/9/2009

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Warrants

Common Stock w/ Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Warrants

Subordinated Debentures
w/ Exercised Warrants

Central Jersey Bancorp, Oakhurst, NJ

12/23/2008

Preferred Stock w/ Warrants

Central Federal Corporation, Fairlawn, OH

12/5/2008

Preferred Stock w/ Exercised Warrants

Centrue Financial Corporation, St. Louis, MO

Central Community Corporation, Temple, TX2

2/20/2009

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants

$10,000,000

$32,668,000

$7,500,000

$6,056,000

$11,385,000

$7,000,000

$135,000,000

$11,300,000

$7,225,000

$22,000,000

$5,800,000

$22,500,000

$10,000,000

Century Financial Services Corporation,
Santa Fe, NM8

Central Bancshares, Inc., Houston, TX2

1/30/2009

$15,000,000

$27,875,000

$2,250,000

$10,000,000

$3,564,000

Preferred Stock w/ Warrants

1/9/2009

Central Bancorp, Inc., Somerville, MA2

2/27/2009

$24,300,000
$11,560,000

Preferred Stock w/ Exercised Warrants

6/19/2009

Central Bancorp, Inc., Garland, TX50

12/5/2008

Preferred Stock w/ Exercised Warrants

Centra Financial Holdings, Inc., Morgantown, WV2

1/16/2009

Preferred Stock w/ Exercised Warrants
Preferred Stock w/ Warrants

Centrix Bank & Trust, Bedford, NH2,49

Centerstate Banks of Florida Inc., Davenport, FL

11/21/2008

2/6/2009

CenterBank, Milford, OH2

5/1/2009

Preferred Stock w/ Warrants

Centric Financial Corporation, Harrisburg, PA2,10,49

Center Bancorp, Inc., Union, NJ49

1/9/2009

Preferred Stock w/ Exercised Warrants

12/18/2009

CedarStone Bank, Lebanon, TN2

2/6/2009

Preferred Stock w/ Exercised Warrants
Preferred Stock w/ Warrants

Central Valley Community Bancorp, Fresno, CA50

Cecil Bancorp, Inc., Elkton, MD

12/23/2008

$1,753,000

Preferred Stock

Central Virginia Bankshares, Inc., Powhatan, VA

CBS Banc-Corp., Russellville, AL2

3/27/2009

$2,644,000

$4,114,000

Preferred Stock w/ Exercised Warrants
Preferred Stock w/ Exercised Warrants

$3,500,000

$3,000,000

$258,000,000

$38,970,000

$18,980,000

$9,201,000

$4,000,000

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Warrants

Preferred Stock

Preferred Stock w/ Warrants

Preferred Stock w/ Warrants

$16,000,000

$6,251,000

Preferred Stock w/ Warrants

$4,000,000

Subordinated Debentures
w/ Exercised Warrants

$3,555,199,000

$5,100,000

$41,279,000

$4,700,000

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Exercised Warrants

1/30/2009

CBB Bancorp, Cartersville, GA2,10a

12/29/2009

$1,037,000

Preferred Stock w/ Exercised Warrants
$4,656,000

$3,300,000

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants

$4,000,000

$44,000,000

$4,640,000

$4,767,000

$20,000,000

Investment Amount

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

Preferred Stock

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

Investment Description

(Continued)

1/30/2009

CB Holding Corp., Aledo, IL

CBB Bancorp, Cartersville, GA2

5/29/2009

2/20/2009

2,63

Cardinal Bancorp II, Inc., Washington, MO
8,50

1/9/2009

Capital Bank Corporation, Raleigh, NC35

12/12/2008

10/23/2009

Capital Bancorp, Inc., Rockville, MD2

12/23/2008

Capital Pacific Bancorp, Portland, OR2

CalWest Bancorp, Rancho Santa Margarita, CA2

1/23/2009

12/23/2008

Calvert Financial Corporation, Ashland, MO2

1/23/2009

Capital Commerce Bancorp, Inc., Milwaukee, WI2

California Oaks State Bank, Thousand Oaks, CA2

1/23/2009

Capital One Financial Corporation, McLean, VA

California Bank of Commerce, Lafayette, CA2,49

2/27/2009

11/14/2008

Cadence Financial Corporation, Starkville, MS33

1/9/2009

4/10/2009

Cache Valley Banking Company , Logan, UT2,49

Cache Valley Banking Company, Logan, UT2,10a,49

12/23/2008

C&F Financial Corporation, West Point, VA

1/9/2009

12/18/2009

Institution

Purchase
Date

CPP TRANSACTION DETAIL, AS OF 6/30/2012

$10,000,000

4/11/2012

$36,039,222

3/29/2012

7/28/2011

7/14/2011

$7,500,000

$6,056,000

$7,000,000

$35,883,281

6/17/2011

8/18/2011

$11,300,000

$5,800,000

$10,000,000

$15,000,000

$27,875,000

$10,000,000

$3,500,000

$3,000,000

$16,250,000

$18,980,000

$6,251,000

$3,555,199,000

$41,279,000

$4,700,000

$3,300,000

$4,000,000

$38,000,000

$4,640,000

11/24/2010

7/6/2011

8/25/2011

3/31/2009

9/30/2009

9/15/2011

7/21/2011

7/21/2011

6/30/2011

8/27/2010

9/8/2011

6/17/2009

1/28/2011

12/30/2010

12/8/2010

9/15/2011

3/4/2011

7/14/2011

$4,767,000

$10,000,000

7/27/2011

7/14/2011

Capital Repayment
Amount (Loss)6

Capital
Repayment
Date

$—

$—

$—

$—

$99,116,719

$—

$—

$—

$—

$—

$—

$—

$—

$—

$—

$—

$—

$—

$—

$—

$—

$—

$—

$—

$—

$10,000,000

Remaining
Capital Amount

7/28/2011

7/14/2011

9/28/2011

12/1/2010

7/6/2011

10/19/2011

4/15/2009

10/28/2009

12/7/2011

7/21/2011

7/21/2011

N/A

N/A

9/8/2011

12/3/2009

N/A

12/30/2010

12/8/2010

9/15/2011

N/A

N/A

7/14/2011

Final
Disposition
Date

R

R

R

R

R

R

R

R

R

R

R

R

A

R

R

R

R

Note15

$375,000

$182,000

$185,017

$319,659

$290,000

$2,525,000

$750,000

$212,000

$245,000

$113,000

$150,000

N/A

N/A

$313,000

$146,500,065

N/A

$235,000

$165,000

$200,000

N/A

N/A

$238,000

Final Disposition
Proceeds

$19.30

$0.57

$6.90

$14.12

$1.56

$31.72

$7.15

$11.25

$0.70

$17.75

$16.51

$2.65

$5.35

$3.00

$5.82

$54.66

$2.28

$0.28

$40.16

Stock
Price as of
6/29/2012

$2,437,761

$571,690

$1,012,791

$501,822

$450,656

$892,500

$2,362,500

$1,084,486

$612,118

$3,880,097

$769,177

$1,361,111

$2,411,625

$172,938

$1,196,303

$372,781

$1,341,667

$636,071

$516,989

$4,217,049

$674,671

$271,580

$685,071

$44,433,333

$1,428,900

$1,531,581

$922,656

$505,000

$2,297,625

$983,480

$739,989

$105,174,638

$304,973

$3,973,104

$517,281

$396,164

$187,178

$337,219

$555,900

$3,984,063

$1,029,334

$2,902,778

Dividends/
Interest Paid to
Treasury

Continued on next page

508,320

263,542

79,288

67,314

261,538

523,076

1,846,374

205,379

86,957

357,675

749,619

167,504

Current
Outstanding
Warrants

Transaction detail I Appendix D I July 25, 2012

241

$20,500,000

Preferred Stock w/ Warrants

Preferred Stock w/ Exercised Warrants
Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants
Preferred Stock w/ Warrants
Preferred Stock

Citigroup Inc., New York, NY11,23

Citizens & Northern Corporation, Wellsboro, PA

Citizens Bancorp, Nevada City, CA2,61

Citizens Bancshares Co., Chillicothe, MO2

Citizens Bancshares Corporation, Atlanta, GA3,30

Citizens Bank & Trust Company, Covington, LA2

Citizens Commerce Bancshares, Inc.,
Versailles, KY2

Citizens Community Bank, South Hill, VA2,49

Citizens First Corporation, Bowling Green, KY

Citizens Republic Bancorp, Inc., Flint, MI

Citizens South Banking Corporation, Gastonia, NC50

City National Bancshares Corporation,
Newark, NJ2,3

City National Corporation, Beverly Hills, CA

10/28/2008

1/16/2009

12/23/2008

5/29/2009

3/6/2009

3/20/2009

2/6/2009

12/23/2008

12/19/2008

12/12/2008

12/12/2008

4/10/2009

11/21/2008

CoBiz Financial Inc., Denver, CO50

Codorus Valley Bancorp, Inc., York, PA49

ColoEast Bankshares, Inc., Lamar, CO2

Colonial American Bank, West Conshohocken, PA2

Colony Bankcorp, Inc., Fitzgerald, GA

8/28/2009

12/19/2008

1/9/2009

2/13/2009

3/27/2009

1/9/2009

Community First Bancshares, Inc., Harrison, AR2

Community First Inc., Columbia, TN2

2/27/2009

Community Financial Corporation, Staunton, VA

12/19/2008

4/3/2009

Community Business Bank, West Sacramento, CA2

2/27/2009

Community Financial Shares, Inc., Glen Ellyn, IL2

Community Bankers Trust Corporation, Glen
Allen, VA

12/19/2008

Community First Bancshares Inc., Union City, TN2,49

Preferred Stock w/ Warrants

Community Bank Shares of Indiana, Inc., New
Albany, IN49

5/29/2009

3/20/2009

Preferred Stock w/ Warrants

Community Bank of the Bay, Oakland, CA3,30

1/16/2009

5/15/2009

Preferred Stock

Community Bancshares, Inc., Kingman, AZ2,10

7/24/2009

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants

Community Bancshares of Mississippi, Inc.,
Brandon, MS2,30

9/11/2009

$17,806,000

$12,725,000

$20,000,000

$6,970,000

$12,643,000

$3,976,000

$17,680,000

$19,468,000

$1,747,000

$3,872,000

$52,000,000

$500,000

Preferred Stock w/ Exercised Warrants

$7,701,000

Community Bancshares of Kansas, Inc., Goff, KS2

3/6/2009

Preferred Stock w/ Exercised Warrants

$5,000,000
$20,400,000

$2,550,000

Community 1st Bank, Roseville, CA2

1/16/2009

Subordinated Debentures
w/ Exercised Warrants

$2,250,000,000

$2,260,000

$76,898,000

$28,000,000

$574,000

$10,000,000

$16,500,000

$64,450,000

$16,015,000

$9,950,000

$3,000,000

$400,000,000

$9,439,000

$8,779,000

$3,000,000

$6,300,000

$2,400,000

$7,462,000

$24,990,000

$10,400,000

$26,440,000

$25,000,000,000

$2,330,000,000

$7,000,000

Preferred Stock w/ Exercised Warrants

Commonwealth Business Bank, Los Angeles, CA2

1/23/2009

Preferred Stock w/ Warrants

Commerce National Bank, Newport Beach, CA

Commonwealth Bancshares, Inc., Louisville, KY8

1/9/2009

5/22/2009

Preferred Stock w/ Warrants

Comerica Inc., Dallas, TX

11/14/2008

Preferred Stock w/ Exercised Warrants

2/27/2009

Preferred Stock w/ Warrants

Columbia Banking System, Inc., Tacoma, WA

Columbine Capital Corp., Buena Vista, CO2,49

11/21/2008

Preferred Stock w/ Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Exercised Warrants

CoastalSouth Bancshares, Inc.,
Hilton Head Island, SC2,10

Preferred Stock w/ Exercised Warrants
Preferred Stock w/ Warrants

Clover Community Bankshares, Inc., Clover, SC

Coastal Banking Company, Inc.,
Fernandina Beach, FL

12/5/2008

Preferred Stock w/ Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants

Contingent Value Rights

3/27/2009
2

$300,000,000

Common Stock w/ Warrants

CIT Group Inc., New York, NY16

12/31/2008

Preferred Stock w/ Exercised Warrants

$19,817,000

Chicago Shore Corporation , Chicago, IL2

7/31/2009

Subordinated Debentures
w/ Exercised Warrants

Chambers Bancshares, Inc., Danville, AR8

5/29/2009

Investment Amount

Investment Description

Institution

(Continued)

Purchase
Date

CPP TRANSACTION DETAIL, AS OF 6/30/2012

8/18/2011

9/15/2011

9/29/2010

9/29/2010

10/7/2009

3/17/2010

9/22/2011

8/11/2010

10/26/2011

8/18/2011

$20,000,000

$19,468,000

$1,747,000

$52,000,000

$5,000,000

$2,250,000,000

$2,260,000

$76,898,000

$574,000

$16,500,000

$64,450,000

$200,000,000

9/8/2011

$200,000,000

3/3/2010

$20,500,000

$2,212,308

$3,000,000

$7,462,000

$26,440,000

$25,000,000,000

$—

Capital Repayment
Amount (Loss)6

12/30/2009

9/22/2011

2/16/2011

7/28/2011

8/13/2010

8/4/2010

**

2/8/2010

Capital
Repayment
Date

$—

$—

$—

$—

$—

$—

$—

$—

$—

$—

$—

$—

$200,000,000

$—

$6,566,692

$—

$—

$—

$—

$—

Remaining
Capital Amount

8/18/2011

10/19/2011

N/A

9/29/2010

5/6/2010

9/22/2011

9/1/2010

10/26/2011

9/28/2011

11/18/2011

4/7/2010

11/9/2011

7/28/2011

N/A

9/1/2010

1/25/2011

N/A

Final
Disposition
Date

R

R

R

A

R

R

R

R

P

R

R

R

R

A

Note15

$1,000,000

$1,100,870

N/A

$2,600,000

$181,102,043

$113,000

$3,301,647

$29,000

$526,604

$143,677

$18,500,000

$225,157

$150,000

N/A

$400,000

$54,621,849

N/A

Final Disposition
Proceeds

$2.20

$3.68

$6.10

$1.80

$12.58

$9.61

$9.50

$30.71

$18.79

$4.73

$13.84

$6.26

$4.25

$48.58

$6.78

$17.13

$8.45

$4.00

$0.01

$19.05

$27.41

$35.64

Stock
Price as of
6/29/2012

$1,908,453

$2,161,377

$2,628,111

$569,865

$2,152,822

$697,084

$1,982,529

$2,233,412

$76,189

$573,012

$2,975,700

$86,973

$139,020

$445,348

$5,101,405

$36,111

$150,937,500

$316,479

$6,621,772

$3,990,000

$65,143

$1,229,278

$2,151,875

$8,763,410

$1,235,449

$967,361

$307,925

$23,916,667

$281,859

$2,847,222

$13,875,000

$1,356,907

$424,646

$180,259

$248,883

$535,813

$628,033

$223,571

$2,049,100

$932,291,667

$43,687,500

$1,065,021

$4,923,341

Dividends/
Interest Paid to
Treasury

Continued on next page

351,194

780,000

87,209

500,000

205,579

1,757,813

254,218

Current
Outstanding
Warrants

242
Appendix D I Transaction Detail I July 25, 2012

Preferred Stock w/ Exercised Warrants
Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants
Preferred Stock w/ Warrants
Preferred Stock w/ Exercised Warrants
Preferred Stock w/ Exercised Warrants
Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants
Preferred Stock w/ Warrants

Preferred Stock w/ Warrants
Preferred Stock w/ Exercised Warrants

Community West Bancshares, Goleta, CA

Congaree Bancshares, Inc., Cayce, SC2

Corning Savings and Loan Association,
Corning, AR2

Country Bank Shares, Inc., Milford, NE2

Covenant Financial Corporation, Clarksdale, MS2

Crazy Woman Creek Bancorp, Inc., Buffalo, WY2

Crescent Financial Bancshares, Inc.
(Crescent Financial Corporation), Cary, NC65

Crosstown Holding Company, Blaine, MN2

CSRA Bank Corp., Wrens, GA2

Customers Bancorp, Inc.
(Berkshire Bancorp, Inc.), Phoenixville, PA2,60

CVB Financial Corp, Ontario, CA

D.L. Evans Bancorp, Burley, ID2,49

Deerfield Financial Corporation, Deerfield, WI

Delmar Bancorp, Delmar, MD2

DeSoto County Bank, Horn Lake, MS2

DeSoto County Bank, Horn Lake, MS2,10a

Diamond Bancorp, Inc., Washington, MO8

Dickinson Financial Corporation II, Kansas City, MO2

Discover Financial Services , Riverwoods, IL

DNB Financial Corporation, Downingtown, PA49

Duke Financial Group, Inc., Minneapolis, MN8

Eagle Bancorp, Inc., Bethesda, MD49

East West Bancorp, Pasadena, CA

Eastern Virginia Bankshares, Inc.,
Tappahannock, VA

ECB Bancorp, Inc., Engelhard, NC

Emclaire Financial Corp., Emlenton, PA49

Encore Bancshares Inc., Houston, TX50

Enterprise Financial Services Corp., St. Louis, MO

Enterprise Financial Services Group, Inc.,
Allison Park, PA2,49

Equity Bancshares, Inc., Wichita, KS2,49

Exchange Bank, Santa Rosa, CA2

F & C Bancorp, Inc., Holden, MO8

F & M Bancshares, Inc., Trezevant, TN

F & M Bancshares, Inc., Trezevant, TN2,10a

F & M Financial Corporation, Salisbury, NC

1/9/2009

12/19/2008

1/9/2009

2/13/2009

1/30/2009

6/5/2009

2/20/2009

1/9/2009

1/23/2009

3/27/2009

6/12/2009

12/5/2008

2/27/2009

5/15/2009

12/4/2009

2/13/2009

12/29/2009

5/22/2009

1/16/2009

3/13/2009

1/30/2009

6/19/2009

12/5/2008

12/5/2008

1/9/2009

1/16/2009

12/23/2008

12/5/2008

12/19/2008

6/12/2009

1/30/2009

12/19/2008

5/22/2009

1/30/2009

11/6/2009

2/6/2009
2

Preferred Stock w/ Exercised Warrants

Community Trust Financial Corporation,
Ruston, LA2,49

2

$10,650,000

Subordinated Debentures
w/ Exercised Warrants

Community Pride Bank Corporation,
Ham Lake, MN8,10

11/13/2009

8,49

$24,900,000

Preferred Stock w/ Warrants

Community Partners Bancorp, Middletown, NJ49

1/30/2009

$24,000,000

$12,000,000
$38,235,000

Subordinated Debentures
w/ Exercised Warrants
Preferred Stock w/ Warrants

$34,000,000

Preferred Stock w/ Warrants

Preferred Stock w/ Exercised Warrants

$17,000,000

$3,535,000

$4,609,000

Preferred Stock w/ Exercised Warrants
Preferred Stock

$2,993,000

$43,000,000

Preferred Stock w/ Exercised Warrants
Subordinated Debentures
w/ Exercised Warrants

$8,750,000

Preferred Stock w/ Exercised Warrants

$4,000,000

$35,000,000

$7,500,000

$17,949,000

$24,000,000

Preferred Stock w/ Warrants

Preferred Stock w/ Warrants

$11,750,000

Preferred Stock w/ Warrants

$306,546,000

$1,224,558,000

$146,053,000

Preferred Stock w/ Warrants

Preferred Stock w/ Exercised Warrants

$20,445,000

$1,508,000

Preferred Stock
Subordinated Debentures
w/ Exercised Warrants

$1,173,000

$9,000,000

$2,639,000

$19,891,000

$130,000,000

$2,892,000

$2,400,000

$3,100,000

$5,000,000

$7,525,000

$638,000

$3,285,000

$15,600,000

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants

Subordinated Debentures
w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

$4,400,000

$9,000,000

$2,600,000

$1,050,000

Community Investors Bancorp, Inc., Bucyrus, OH2

12/23/2008

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants

Community Holding Company of Florida, Inc.,
Miramar Beach, FL2

2/6/2009

Investment Amount

Investment Description

(Continued)

Institution

Purchase
Date

CPP TRANSACTION DETAIL, AS OF 6/30/2012

$32,500,000

9/2/2009

8/11/2011

8/25/2011

9/27/2011

8/18/2011

$8,750,000

$4,000,000

$34,000,000

$7,500,000

$306,546,000

$23,235,000

12/29/2010

$15,000,000

12/23/2009

$11,750,000

$1,224,558,000

$2,639,000

7/14/2011

8/4/2011

4/21/2010

9/8/2011

$19,891,000

$97,500,000

8/26/2009

9/27/2011

$2,892,000

$24,000,000

$9,000,000

Capital Repayment
Amount (Loss)6

12/28/2011

7/6/2011

8/11/2011

Capital
Repayment
Date

$—

$—

$—

$—

$—

$—

$23,235,000

$—

$—

$—

$—

$—

$32,500,000

$—

$—

$—

Remaining
Capital Amount

8/11/2011

8/25/2011

11/18/2011

12/7/2011

1/26/2011

11/18/2011

9/21/2011

7/7/2010

9/8/2011

9/27/2011

10/28/2009

12/28/2011

7/6/2011

10/26/2011

Final
Disposition
Date

R

R

P

R

R

P

R

R

R

R

R

R

R

R

Note15

$438,000

$200,000

$637,071

$51,113

$14,500,000

$2,794,422

$458,000

$172,000,000

$132,000

$995,000

$1,307,000

$145,000

$1,200,000

$460,000

Final Disposition
Proceeds

$10.96

$20.63

$19.95

$9.36

$3.72

$23.46

$15.75

$13.50

$34.58

$11.65

$4.52

$7.10

$2.70

$2.50

$5.70

Stock
Price as of
6/29/2012

$3,034,288

$1,272,996

$748,600

$7,395,044

$1,206,873

$480,206

$5,959,722

$4,778,889

$994,792

$2,989,008

$2,220,000

$31,676,420

$3,817,732

$3,076,173

$1,475,278

$67,690,844

$2,631,197

$5,112,555

$387,509

$832,488

$512,339

$2,800,592

$4,739,583

$407,478

$180,940

$1,922,001

$4,230,091

$546,741

$810,989

$1,349,880

$113,228

$608,728

$2,461,333

$3,259,100

$448,253

$1,138,750

$480,993

$186,676

Dividends/
Interest Paid to
Treasury

Continued on next page

324,074

144,984

373,832

521,158

Current
Outstanding
Warrants

Transaction detail I Appendix D I July 25, 2012

243

Preferred Stock w/ Exercised Warrants
Preferred Stock w/ Exercised Warrants

Farmers & Merchants Bancshares, Inc.,
Houston, TX2

Farmers & Merchants Financial Corporation,
Argonia, KS2

Farmers Bank , Windsor, VA2

Farmers Capital Bank Corporation, Frankfort, KY87

Farmers Enterprises, Inc., Great Bend, KS

Farmers State Bankshares, Inc., Holton, KS2, 50

FBHC Holding Company, Boulder, CO8,10,38

FC Holdings, Inc., Houston, TX2

FCB Bancorp, Inc., Louisville, KY2,50

FFW Corporation, Wabash, IN2

Fidelity Bancorp, Inc, Baton Rouge, LA8

Fidelity Bancorp, Inc., Pittsburgh, PA

Fidelity Federal Bancorp, Evansville, IN2,10

Fidelity Financial Corporation, Wichita, KS2

Fidelity Southern Corporation, Atlanta, GA92

Fifth Third Bancorp, Cincinnati, OH

Financial Institutions, Inc., Warsaw, NY

12/23/2008

3/6/2009

3/20/2009

1/23/2009

1/9/2009

6/19/2009

3/20/2009

12/29/2009

6/26/2009

12/19/2008

12/19/2008

5/29/2009

12/12/2008

11/13/2009

12/19/2008

12/19/2008

12/31/2008

12/23/2008

$3,942,000

Subordinated Debentures
w/ Exercised Warrants

First Choice Bank, Cerritos, CA2,10a,30

First Citizens Banc Corp, Sandusky, OH94

First Colebrook Bancorp, Inc., Colebrook, NH2,49

First Community Bancshares Inc., Bluefield, VA

12/22/2009

1/23/2009

3/20/2009

11/21/2008

First Choice Bank, Cerritos, CA2, 30

2/13/2009

$2,836,000

Preferred Stock w/ Exercised Warrants
Preferred Stock w/ Warrants

$41,500,000

$4,500,000

$23,184,000

Preferred Stock
Preferred Stock w/ Warrants

$2,200,000

$10,958,000

$25,000,000

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Warrants

First Capital Bancorp, Inc., Glen Allen, VA90

4/3/2009

$2,032,000

$2,211,000

$100,000,000

Preferred Stock w/ Exercised Warrants

$295,400,000

Preferred Stock w/ Warrants

$10,000,000

Preferred Stock w/ Exercised Warrants

First California Financial Group, Inc, Westlake
Village, CA50

First Busey Corporation, Urbana, IL50

3/6/2009

12/19/2008

First Banks, Inc., Clayton, MO2

12/31/2008

Preferred Stock w/ Exercised Warrants

Preferred Stock

First Bankers Trustshares, Inc., Quincy, IL2,50

1/16/2009

$3,345,000

Preferred Stock w/ Exercised Warrants

First Business Bank, N.A., San Diego, CA2

First Bank of Charleston, Inc., Charleston, WV2,50

2/6/2009

$7,350,000

$424,174,000

Preferred Stock w/ Exercised Warrants

Common Stock w/ Warrants

First Business Bank, N.A., San Diego, CA2,10a

First BancTrust Corporation, Paris, IL2

2/20/2009

12/11/2009

First Bancorp, Troy, NC28

1/16/2009

$65,000,000

$17,000,000

$50,000,000

$3,422,000

$1,177,000

Preferred Stock w/ Warrants

Preferred Stock

4/10/2009

First American International Corp., Brooklyn, NY3,30

First BanCorp, San Juan, PR50

3/13/2009

Subordinated Debentures
w/ Exercised Warrants

First American Bank Corporation,
Elk Grove Village, IL8

7/24/2009

1/9/2009

Preferred Stock w/ Exercised Warrants

First Alliance Bancshares, Inc., Cordova, TN2

6/26/2009

Preferred Stock w/ Exercised Warrants

First Advantage Bancshares Inc., Coon Rapids, MN2

$3,742,000

5/22/2009

$5,000,000

Financial Security Corporation, Basin, WY2,50

Financial Services of Winger, Inc., Winger, MN8,10,49

7/31/2009

Subordinated Debentures
w/ Exercised Warrants

$37,515,000

$3,408,000,000

$48,200,000

$36,282,000

$6,657,000

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants

$7,000,000

$7,289,000

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

$9,294,000

$21,042,000

$3,035,000

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants

Subordinated Debentures
w/ Exercised Warrants

$700,000

$12,000,000

Preferred Stock w/ Exercised Warrants

$30,000,000

Subordinated Debentures
w/ Exercised Warrants

$8,752,000

$442,000

$11,000,000

$31,762,000

$100,000,000

$17,243,000

Investment Amount

Preferred Stock w/ Warrants

2/13/2009

8

Preferred Stock w/ Warrants

F.N.B. Corporation (Parkvale Financial
Corporation), Monroeville, PA67

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

F&M Financial Corporation, Clarksville, TN2

F.N.B. Corporation, Hermitage, PA

2/13/2009

Preferred Stock w/ Exercised Warrants

Investment Description

(Continued)

1/9/2009

Institution

Purchase
Date

CPP TRANSACTION DETAIL, AS OF 6/30/2012

7/8/2009

9/22/2011

6/27/2012

9/24/2010

9/24/2010

6/13/2012

7/14/2011

8/25/2011

9/8/2011

7/21/2011

1/18/2012

9/1/2011

8/13/2010

12/21/2011

9/1/2011

$41,500,000

$4,500,000

$20,689,633

$2,836,000

$2,200,000

$9,931,327

$25,000,000

$100,000,000

$10,000,000

$3,345,000

$3,675,000

$65,000,000

$17,000,000

$15,000,000

$3,742,000

$5,000,000

$25,010,000

7/21/2011

$12,505,000

3/30/2011

$3,408,000,000

$42,757,786

$9,294,000

$650,000

$700,000

$21,594,229

$31,762,000

$100,000,000

Capital Repayment
Amount (Loss)6

2/23/2011

2/2/2011

6/27/2012

9/22/2011

3/9/2011

7/21/2011

6/13/2012

1/3/2012

9/9/2009

Capital
Repayment
Date

$—

$—

$—

$—

$—

$—

$—

$—

$—

$—

$3,675,000

$—

$—

$35,000,000

$—

$—

$—

$25,010,000

$—

$—

$—

$—

$—

$—

$—

$—

Remaining
Capital Amount

11/18/2011

9/22/2011

N/A

9/24/2010

8/24/2011

11/18/2011

9/8/2011

7/21/2011

11/18/2011

N/A

9/1/2011

7/21/2011

5/11/2011

3/16/2011

9/22/2011

N/A

7/21/2011

11/18/2011

Final
Disposition
Date

P

R

R

R

P

R

R

P

R

R

R

R

R

R

P

Note15

$30,600

$225,000

N/A

$110,000

$599,042

$63,677

$500,000

$167,000

$924,462

N/A

$112,000

$250,000

$2,079,963

$280,025,936

$465,000

N/A

$40,000

$690,100

Final Disposition
Proceeds

$14.43

$8.45

$2.34

$6.88

$4.82

$23.50

$10.77

$17.00

$8.89

$16.88

$13.40

$8.64

$10.41

$6.57

$10.87

Stock
Price as of
6/29/2012

$1,308,403

$614,488

$3,838,240

$300,643

$1,759,344

$3,211,806

$620,001

$12,347,222

$6,037,238

$1,441,222

$448,105

$1,236,732

$8,594,444

$32,999,386

$1,204,167

$11,318,975

$538,231

$191,232

$633,322

$664,597

$4,192,649

$355,946,667

$8,207,389

$6,734,009

$—

$1,198,750

$979,300

$1,352,721

$1,397,234

$156,090

$154,592

$90,174

$2,925,316

$5,166,600

$1,579,466

$75,919

$1,913,405

$3,333,333

$4,808,414

$3,059,343

Dividends/
Interest Paid to
Treasury

Continued on next page

469,312

250,947

616,308

389,484

2,462,439

121,387

223,992

819,640

Current
Outstanding
Warrants

244
Appendix D I Transaction Detail I July 25, 2012

Preferred Stock w/ Warrants

First Community Bank Corporation of America,
Pinellas Park, FL39

First Community Corporation, Lexington, SC

First Community Financial Partners, Inc., Joliet, IL2

First Defiance Financial Corp., Defiance, OH89

First Eagle Bancshares, Inc., Hanover Park, IL8,30

First Express of Nebraska, Inc., Gering, NE

First Federal Bancshares of Arkansas, Inc.,
Harrison, AR42

First Financial Bancorp, Cincinnati, OH

12/23/2008

11/21/2008

12/11/2009

12/5/2008

9/11/2009

2/6/2009

3/6/2009

12/23/2008

$5,000,000

Preferred Stock w/ Exercised Warrants
Preferred Stock w/ Exercised Warrants
Preferred Stock w/ Exercised Warrants

First Freedom Bancshares, Inc., Lebanon, TN2,10

First Gothenburg Bancshares, Inc.,
Gothenburg, NE2

First Guaranty Bancshares, Inc., Hammond, LA2,49

First Horizon National Corporation, Memphis, TN

First Independence Corporation, Detroit, MI2,3

First Intercontinental Bank, Doraville, GA2

First Litchfield Financial Corporation, Litchfield, CT

First M&F Corporation, Kosciusko, MS30

12/22/2009

2/27/2009

8/28/2009

11/14/2008

8/28/2009

3/13/2009

12/12/2008

2/27/2009

Preferred Stock w/ Exercised Warrants

First NBC Bank Holding Company,
New Orleans, LA2,49

First Niagara Financial Group, Lockport, NY

First Northern Community Bancorp, Dixon, CA49

First PacTrust Bancorp, Inc., Chula Vista, CA

First Place Financial Corp., Warren, OH

First Priority Financial Corp., Malvern, PA2

First Priority Financial Corp., Malvern, PA2,10a

First Reliance Bancshares, Inc., Florence, SC

First Resource Bank, Exton, PA2,50

First Resource Bank, Exton, PA2,10a,49

First Security Group, Inc., Chattanooga, TN

3/20/2009

11/21/2008

3/13/2009

11/21/2008

3/13/2009

2/20/2009

12/18/2009

3/6/2009

1/30/2009

12/11/2009

1/9/2009

First Sound Bank, Seattle, WA

First South Bancorp, Inc., Lexington, TN8

First Southern Bancorp, Inc., Boca Raton, FL2

First Southwest Bancorporation, Inc., Alamosa, CO2

First State Bank of Mobeetie, Mobeetie, TX2

First Texas BHC, Inc., Fort Worth, TX2,49

12/23/2008

7/17/2009

1/30/2009

3/6/2009

2/27/2009

3/6/2009

2

Preferred Stock w/ Exercised Warrants

First National Corporation, Strasburg, VA2

3/13/2009

Preferred Stock w/ Exercised Warrants

$13,533,000

$731,000

$5,500,000

Preferred Stock w/ Exercised Warrants

$10,900,000

Preferred Stock w/ Exercised Warrants

$50,000,000

$7,400,000

$33,000,000

$2,417,000

$2,600,000

$15,349,000

$4,596,000

$4,579,000

$72,927,000

Preferred Stock w/ Exercised Warrants

Subordinated Debentures
w/ Exercised Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Warrants

Preferred Stock

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

$19,300,000

$17,390,000

Preferred Stock w/ Warrants
Preferred Stock w/ Warrants

$184,011,000

Preferred Stock w/ Warrants

$17,836,000

$13,900,000

$193,000,000

$46,400,000

Preferred Stock w/ Warrants

Trust Preferred Securities

First Midwest Bancorp, Inc., Itasca, IL

12/5/2008

$69,600,000

Preferred Stock w/ Warrants

First Merchants Corporation, Muncie, IN27,49,50

$4,797,000

Preferred Stock w/ Exercised Warrants

2/20/2009

$12,000,000

Preferred Stock w/ Exercised Warrants

First Manitowoc Bancorp, Inc., Manitowoc, WI2

First Menasha Bancshares, Inc., Neenah, WI2,49

1/16/2009

$30,000,000

Preferred Stock w/ Warrants

2/13/2009

$10,000,000

$6,398,000

$3,223,000

$866,540,000

$8,700,000

$20,000,000

Preferred Stock w/ Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock

Preferred Stock w/ Warrants

$7,570,000
$20,699,000

Preferred Stock w/ Warrants

First Financial Service Corporation,
Elizabethtown, KY

1/9/2009

$65,000,000

Preferred Stock w/ Warrants

First Financial Bancshares, Inc., Lawrence, KS8,10,49

First Financial Holdings Inc., Charleston, SC75

$3,756,000

$80,000,000

6/12/2009

Subordinated Debentures
w/ Exercised Warrants

Preferred Stock w/ Warrants

$16,500,000

Preferred Stock w/ Exercised Warrants
Preferred Stock w/ Warrants

$7,500,000

$37,000,000

$22,000,000

Subordinated Debentures w/ Exercised
Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Exercised Warrants

$11,350,000

$10,685,000

$14,800,000

Investment Amount

12/5/2008

2

Preferred Stock w/ Exercised Warrants

First Community Bancshares, Inc,
Overland Park, KS2

5/15/2009

Preferred Stock w/ Warrants

Investment Description

(Continued)

Institution

Purchase
Date

CPP TRANSACTION DETAIL, AS OF 6/30/2012

9/15/2011

4/14/2010

6/16/2010

9/28/2011

9/15/2011

9/15/2011

12/15/2010

9/15/2011

5/27/2009

8/4/2011

11/23/2011

9/22/2011

9/22/2011

9/15/2011

5/27/2009

9/29/2010

4/7/2010

12/22/2010

9/22/2011

3/28/2012

9/22/2011

2/24/2010

5/3/2011

2/15/2012

9/17/2010

6/13/2012

5/31/2011

Capital
Repayment
Date

$13,533,000

$731,000

$10,900,000

$13,125,000

$2,417,000

$2,600,000

$19,300,000

$17,390,000

$184,011,000

$17,836,000

$193,000,000

$46,400,000

$69,600,000

$4,797,000

$12,000,000

$30,000,000

$10,000,000

$866,540,000

$20,699,000

$55,926,478

$3,756,000

$80,000,000

$6,000,000

$5,000,000

$7,500,000

$35,084,144

$7,754,267

Capital Repayment
Amount (Loss)6

$—

$—

$—

$36,875,000

$—

$—

$—

$—

$—

$—

$—

$—

$—

$—

$—

$—

$—

$—

$—

$—

$—

$—

$—

$—

$—

$—

$—

Remaining
Capital Amount

9/15/2011

4/14/2010

6/16/2010

N/A

9/15/2011

1/5/2011

11/16/2011

6/24/2009

8/4/2011

12/21/2011

11/18/2011

9/15/2011

5/27/2009

4/7/2010

3/9/2011

9/22/2011

9/22/2011

6/2/2010

N/A

2/15/2012

9/17/2010

N/A

Final
Disposition
Date

R

R

R

R

R

R

R

R

R

P

R

R

R

R

R

R

A

R

R

Note15

$677,000

$37,000

$545,000

N/A

$130,000

$1,003,227

$375,000

$2,700,000

$892,000

$900,000

$367,500

$240,000

$600,000

$1,488,046

$79,700,000

$1,030,000

$113,000

$2,966,288

N/A

$250,000

$375,000

N/A

Final Disposition
Proceeds

$0.03

$3.00

$3.55

$0.62

$11.86

$6.00

$7.65

$10.98

$12.46

$15.45

$5.18

$8.65

$2.25

$10.72

$15.98

$8.10

$17.12

$8.00

Stock
Price as of
6/29/2012

$1,862,389

$45,087

$207,327

$818,468

$11,225,272

$330,944

$1,402,500

$584,794

$2,042,406

$1,361,039

$7,009,095

$1,994,333

$2,178,580

$4,753,618

$2,305,990

$2,403,117

$28,628,333

$2,848,444

$12,167,111

$676,865

$237,983

$2,383,333

$659,722

$757,454

$437,343

$91,227,406

$2,330,477

$1,327,473

$1,099,102

$1,600,000

$10,815,494

$694,280

$4,677,778

$570,625

$824,313

$639,738

$6,546,862

$2,910,906

$1,976,792

$744,982

$604,950

Dividends/
Interest Paid to
Treasury

Continued on next page

114,080

823,627

3,670,822

513,113

215,983

241,696

550,595

195,915

Current
Outstanding
Warrants

Transaction detail I Appendix D I July 25, 2012

245

First Western Financial, Inc., Denver, CO2,10a

Firstbank Corporation, Alma, MI97

FirstMerit Corporation, Akron, OH

12/11/2009

1/30/2009

1/9/2009

Green City Bancshares, Inc., Green City, MO2

Greer Bancshares Incorporated, Greer, SC2

Gregg Bancshares, Inc., Ozark, MO2

2/27/2009

1/30/2009

2/13/2009

GrandSouth Bancorporation, Greenville, SC2,10a,49

12/11/2009

Green Circle Investments, Inc., Clive, IA2

GrandSouth Bancorporation, Greenville, SC2,50

1/9/2009

Green Bankshares, Inc., Greeneville, TN59

Grand Mountain Bancshares, Inc., Granby, CO2

5/29/2009

2/27/2009

Grand Financial Corporation, Hattiesburg, MS8

9/25/2009

12/23/2008

Grand Capital Corporation, Tulsa, OK2,49

4/24/2009

Great River Holding Company, Baxter, MN8

Goldwater Bank, N.A., Scottsdale, AZ2

1/30/2009

Great Southern Bancorp, Springfield, MO50

Gold Canyon Bank, Gold Canyon, AZ2,10

6/26/2009

7/17/2009

Preferred Stock w/ Exercised Warrants

Germantown Capital Corporation, Inc.,
Germantown, TN2

3/6/2009

12/5/2008

Preferred Stock w/ Exercised Warrants

Georgia Primary Bank, Atlanta, GA2

5/1/2009

$2,443,320

Subordinated Debentures
w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants

$825,000

$9,993,000

$651,000

$2,400,000

$72,278,000

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

$8,400,000
$58,000,000

Preferred Stock w/ Warrants

$6,319,000

Preferred Stock

$9,000,000

Subordinated Debentures
w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants

$3,076,000

$4,000,000

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants

$2,568,000

$1,607,000

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants

$4,967,000

$4,500,000

$8,700,000

Preferred Stock w/ Exercised Warrants

Georgia Commerce Bancshares, Inc., Atlanta, GA2

2/6/2009

$6,000,000

$376,500,000

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

Fulton Financial Corporation, Lancaster, PA

$3,000,000

Subordinated Debentures
w/ Exercised Warrants

Gateway Bancshares, Inc., Ringgold, GA2,80

Frontier Bancshares, Inc., Austin, TX8

4/24/2009

$1,968,000

$35,000,000

Subordinated Debentures
w/ Exercised Warrants
Preferred Stock w/ Exercised Warrants

$3,000,000

5/8/2009

Fresno First Bank, Fresno, CA2

$5,097,000

Subordinated Debentures
w/ Exercised Warrants

$3,240,000

Preferred Stock w/ Exercised Warrants

$5,800,000

Preferred Stock w/ Exercised Warrants

$3,100,000

Preferred Stock w/ Exercised Warrants
Preferred Stock w/ Warrants

$1,300,000

$15,000,000

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants

$51,500,000

$12,000,000

Common Stock w/ Warrants

$70,000,000

Preferred Stock w/ Exercised Warrants

$9,495,000

$20,471,000

$266,657,000

$125,000,000

$33,000,000

$11,881,000

$8,559,000

$6,000,000

$30,000,000

Preferred Stock w/ Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Warrants

Preferred Stock

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

$4,900,000

$17,969,000

Subordinated Debentures
w/ Exercised Warrants
Preferred Stock w/ Exercised Warrants

Investment Amount

Investment Description

(Continued)

12/23/2008

Fremont Bancorporation, Fremont, CA8

FPB Financial Corp., Hammond, LA2

1/23/2009

1/23/2009

FPB Bancorp, Inc., Port St. Lucie, FL55

12/5/2008

6/26/2009

Fortune Financial Corporation, Arnold, MO2,50

4/3/2009

Franklin Bancorp, Inc., Washington, MO2

Fort Lee Federal Savings Bank, Fort Lee, NJ2,82

5/22/2009

Freeport Bancshares, Inc., Freeport, IL8

Foresight Financial Group, Inc., Rockford, IL2

5/15/2009

5/8/2009

FNB United Corp., Asheboro, NC58

2/13/2009

5/22/2009

Flushing Financial Corporation, Lake Success, NY

FNB Bancorp, South San Francisco, CA2,50

12/19/2008

2/27/2009

Florida Business BancGroup, Inc., Tampa, FL2,49

First Western Financial, Inc., Denver, CO2

2/6/2009

2/20/2009

First Vernon Bancshares, Inc., Vernon, AL2,10,30

6/12/2009

Flagstar Bancorp, Inc., Troy, MI

First United Corporation, Oakland, MD

1/30/2009

Florida Bank Group, Inc., Tampa, FL2

First ULB Corp., Oakland, CA2

1/23/2009

1/30/2009

First Trust Corporation, New Orleans, LA8

6/5/2009

7/24/2009

Institution

Purchase
Date

CPP TRANSACTION DETAIL, AS OF 6/30/2012

7/14/2010

9/7/2011

8/18/2011

9/8/2011

9/8/2011

9/8/2011

2/16/2011

4/13/2012

$651,000

$68,700,000

$58,000,000

$6,319,000

$9,000,000

$4,000,000

$8,700,000

$6,000,000

$376,500,000

$1,400,000

10/6/2010
7/14/2010

$1,600,000

$2,240,000

6/16/2010

11/24/2009

$1,000,000

$3,100,000

$12,000,000

$70,000,000

$9,495,000

$125,000,000

$30,587,530

$6,000,000

$4,900,000

Capital Repayment
Amount (Loss)6

12/16/2009

9/15/2011

9/15/2011

10/28/2009

9/22/2011

4/22/2009

6/27/2012

9/29/2010

4/22/2009

Capital
Repayment
Date

$—

$—

$—

$—

$—

$—

$—

$—

$—

$—

$1,400,000

$—

$2,240,000

$—

$—

$—

$—

$—

$—

$—

$—

Remaining
Capital Amount

7/14/2010

N/A

9/21/2011

N/A

9/8/2011

9/8/2011

2/16/2011

4/13/2012

9/8/2010

10/6/2010

6/16/2010

9/15/2011

9/15/2011

12/30/2009

9/22/2011

5/27/2009

9/29/2010

4/22/2009

Final
Disposition
Date

R

R

R

R

R

R

R

R

R

R

R

R

R

R

R

R

Note15

$33,000

N/A

$6,436,364

N/A

$450,000

$200,000

$435,000

$300,000

$10,800,000

$150,000

$162,000

$155,000

$600,000

$900,000

$475,000

$5,025,000

$245,000

$245,000

Final Disposition
Proceeds

$4.50

$27.58

$4.50

$9.99

$0.02

$12.80

$12.99

$16.15

$13.63

$0.84

$16.51

$9.80

$4.31

Stock
Price as of
6/29/2012

$45,190

$975,831

$49,037

$420,740

$5,942,858

$7,838,056

$759,575

$1,856,917

$—

$540,896

$517,145

$145,750

$53,860

$864,059

$—

$961,471

$960,795

$29,335,625

$258,192

$321,660

$8,475,080

$759,993

$827,998

$221,722

$273,889

$413,928

$87,185

$2,452,500

$2,589,305

$1,667,700

$3,004,167

$1,339,751

$1,180,793

$37,220,872

$1,788,194

$5,431,250

$2,969,910

$417,770

$2,312,500

$66,021

$1,046,896

Dividends/
Interest Paid to
Treasury

Continued on next page

183,158

22,071

6,451,379

578,947

326,323

Current
Outstanding
Warrants

246
Appendix D I Transaction Detail I July 25, 2012

Preferred Stock
Preferred Stock w/ Warrants

Preferred Stock w/ Warrants
Preferred Stock w/ Exercised Warrants
Preferred Stock
Preferred Stock w/ Exercised Warrants

Guaranty Federal Bancshares, Inc., Springfield, MO

GulfSouth Private Bank, Destin, FL10,21

Gulfstream Bancshares, Inc., Stuart, FL2,50

Hamilton State Bancshares, Hoschton, GA2

Hampton Roads Bankshares, Inc., Norfolk, VA31

Harbor Bankshares Corporation, Baltimore, MD2,3

Hartford Financial Services Group, Inc.,
Hartford, CT

Haviland Bancshares, Inc., Haviland, KS2

Hawthorne Bancshares, Inc., Lee’s Summit, MO

HCSB Financial Corporation, Loris, SC

Heartland Bancshares, Inc., Franklin, IN2,10

Heartland Financial USA, Inc., Dubuque, IA50

Heritage Bankshares, Inc., Norfolk, VA2,10,50

Heritage Commerce Corp., San Jose, CA

Heritage Financial Corporation, Olympia, WA

Heritage Oaks Bancorp, Paso Robles, CA

HF Financial Corp., Sioux Falls, SD

Highlands Bancorp, Inc. (Highlands State Bank),
Vernon, NJ2,13 ,49

Highlands Bancorp, Inc. (Highlands State Bank),
Vernon, NJ2,10a,13,49

Highlands Independent Bancshares, Inc.,
Sebring, FL2

Hilltop Community Bancorp, Inc., Summit, NJ2

HMN Financial, Inc., Rochester, MN

1/30/2009

9/25/2009

6/26/2009

2/20/2009

12/31/2008

7/17/2009

6/26/2009

3/13/2009

12/19/2008

3/6/2009

9/11/2009

12/19/2008

9/25/2009

11/21/2008

11/21/2008

3/20/2009

11/21/2008

5/8/2009

12/22/2009

3/6/2009

1/30/2009

12/23/2008

Preferred Stock w/ Warrants

Preferred Stock w/ Exercised Warrants

HomeTown Bankshares Corporation,
Roanoke, VA2,10

HopFed Bancorp, Hopkinsville, KY

Horizon Bancorp, Michigan City, IN50

Howard Bancorp, Inc., Ellicott City, MD

HPK Financial Corporation, Chicago, IL2,10a

HPK Financial Corporation, Chicago, IL2

Huntington Bancshares, Columbus, OH

Hyperion Bank, Philadelphia, PA2

IA Bancorp, Inc., Iselin, NJ2,10

IBC Bancorp, Inc., Chicago, IL3,8,30

Iberiabank Corporation, Lafayette, LA

9/18/2009

12/12/2008

12/19/2008

2/27/2009

11/13/2009

5/1/2009

11/14/2008

2/6/2009

9/18/2009

5/15/2009

12/5/2008

IBT Bancorp, Inc., Irving, TX2

IBW Financial Corporation , Washington, DC2,3a,30

ICB Financial, Ontario, CA2

Idaho Bancorp, Boise, ID2

Illinois State Bancorp, Inc., Chicago, IL2,49

Illinois State Bancorp, Inc., Chicago, IL2,10a,49

3/27/2009

3/13/2009

3/6/2009

1/16/2009

5/22/2009

12/29/2009

2,49

Preferred Stock w/ Exercised Warrants

Hometown Bancshares, Inc., Corbin, KY2

2/13/2009

$24,000,000

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants

$4,000,000

$6,272,000

$6,900,000

$6,000,000

$6,000,000

Preferred Stock w/ Exercised Warrants

$2,295,000

Preferred Stock

$90,000,000

$4,205,000

$5,976,000

$1,552,000

$1,398,071,000

$4,000,000

$5,000,000

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

Subordinated Debentures

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants

$5,983,000

$25,000,000

Preferred Stock w/ Warrants
Preferred Stock w/ Exercised Warrants

$18,400,000

$10,000,000

$1,900,000

$3,250,000

$50,000,000

$26,000,000

$4,000,000

$6,700,000

$2,359,000

$3,091,000

$25,000,000

$21,000,000

Preferred Stock w/ Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

Home Bancshares, Inc., Conway, AR

Hometown Bancorp of Alabama, Inc., Oneonta, AL2

1/16/2009

2/20/2009

Preferred Stock w/ Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

$40,000,000

$10,103,000

Preferred Stock w/ Exercised Warrants
Preferred Stock w/ Warrants

$81,698,000

$7,000,000

$12,895,000

$30,255,000

$425,000

$3,400,000,000

$6,800,000

$80,347,000

$7,000,000

$7,500,000

$7,500,000

$17,000,000

$14,000,000

$6,920,000

Investment Amount

Preferred Stock w/ Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Exercised Warrants

Common Stock w/ Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

Subordinated Debentures

Preferred Stock w/ Exercised Warrants

Guaranty Bancorp, Inc., Woodsville, NH2,50

Guaranty Capital Corporation, Belzoni, MS3,8,30

2/20/2009

Investment Description

(Continued)

9/25/2009

Institution

Purchase
Date

CPP TRANSACTION DETAIL, AS OF 6/30/2012

$7,497,000

8/11/2011

9/22/2011

9/22/2011

9/3/2010

3/31/2009

9/10/2010

12/22/2010

$4,000,000

$6,272,000

$6,000,000

$90,000,000

$4,205,000

$1,398,071,000

$5,983,000

$18,750,000

8/25/2011
9/22/2011

$6,250,000

$50,000,000

$4,000,000

$2,359,000

$3,091,000

$25,000,000

$24,000,000

11/10/2010

7/6/2011

4/21/2010

9/22/2011

9/22/2011

6/3/2009

12/22/2010

$40,000,000

$2,606,000

3/16/2011

3/7/2012

$81,698,000

$12,000,000

$425,000

$3,400,000,000

$7,000,000

$7,500,000

$5,000,000

$14,000,000

$6,920,000

Capital Repayment
Amount (Loss)6

9/15/2011

5/9/2012

12/29/2010

3/31/2010

4/13/2011

8/18/2011

6/13/2012

7/30/2010

9/15/2011

Capital
Repayment
Date

$—

$—

$—

$—

$—

$—

$—

$—

$18,750,000

$—

$—

$—

$—

$—

$—

$—

$—

$7,497,000

$—

$18,255,000

$—

$—

$—

$—

$12,000,000

$—

$—

Remaining
Capital Amount

9/22/2011

9/22/2011

N/A

5/20/2009

N/A

1/19/2011

9/22/2011

11/18/2011

7/27/2011

4/21/2010

N/A

9/22/2011

6/30/2009

8/17/2011

8/11/2011

9/28/2011

12/29/2010

9/21/2010

4/13/2011

8/18/2011

N/A

9/15/2011

Final
Disposition
Date

R

R

R

R

R

P

R

R

R

R

R

R

R

R

A

R

R

R

Note15

$92,000

$314,000

N/A

$1,200,000

N/A

$49,100,000

$299,000

$1,750,551

$1,300,000

$200,000

N/A

$155,000

$650,000

$450,000

$303,000

$1,800,000

$21,000

$706,264,560

$350,000

$375,000

N/A

$346,000

Final Disposition
Proceeds

$0.02

$3.76

$10.50

$50.45

$6.40

$6.55

$26.30

$7.20

$4.95

$30.58

$3.00

$5.75

$4.25

$19.00

$5.57

$14.65

$6.50

$12.20

$24.00

$13.25

$0.25

$9.23

$17.63

$1.09

$7.91

Stock
Price as of
6/29/2012

$1,158,113

$124,306

$1,043,675

$453,067

$391,980

$1,450,000

$427,216

$837,500

$277,131

$147,185,809

$1,321,339

$837,793

$3,106,771

$3,151,000

$1,456,279

$337,113

$573,342

$6,180,556

$2,462,778

$267,050

$617,712

$547,251

$666,667

$3,435,502

$2,503,333

$6,761,267

$947,284

$11,188,087

$1,009,349

$1,090,702

$5,141,755

$41,524

$129,861,111

$282,744

$2,510,844

$819,166

$876,542

$757,380

$2,817,361

$913,299

$969,040

Dividends/
Interest Paid to
Treasury

Continued on next page

253,666

833,333

611,650

462,963

91,714

276,090

53,034

459,459

Current
Outstanding
Warrants

Transaction detail I Appendix D I July 25, 2012

247

Preferred Stock w/ Warrants
Subordinated Debentures
w/ Exercised Warrants

International Bancshares Corporation, Laredo, TX

Intervest Bancshares Corporation, New York, NY

Investors Financial Corporation of Pettis County,
Inc., Sedalia, MO8

JPMorgan Chase & Co., New York, NY

12/23/2008

12/23/2008

5/8/2009

10/28/2008

Preferred Stock w/ Warrants

Preferred Stock w/ Warrants

Kirksville Bancorp, Inc., Kirksville, MO2

KS Bancorp, Inc., Smithfield, NC2

Lafayette Bancorp, Inc., Oxford, MS2,30

Lafayette Bancorp, Inc., Oxford, MS2,10a,30

Lakeland Bancorp, Inc., Oak Ridge, NJ

3/20/2009

8/21/2009

2/20/2009

12/29/2009

2/6/2009

Preferred Stock w/ Exercised Warrants

11/14/2008

Liberty Financial Services, Inc., New Orleans,
LA3,30

Liberty Shares, Inc., Hinesville, GA2

Lincoln National Corporation, Radnor, PA

LNB Bancorp Inc., Lorain, OH 88

Lone Star Bank, Houston, TX2

LSB Corporation, North Andover, MA

M&F Bancorp, Inc., Durham, NC2,3,10,30

M&T Bank Corporation (Provident Bancshares
Corp.), Baltimore, MD

M&T Bank Corporation, Buffalo, NY

M&T Bank Corporation (Wilmington Trust
Corporation), Wilmington, DE43

Mackinac Financial Corporation, Manistique, MI

Madison Financial Corporation, Richmond, KY2

Magna Bank, Memphis, TN2,49

2/6/2009

2/20/2009

7/10/2009

12/12/2008

2/6/2009

12/12/2008

6/26/2009

12/23/2008

11/14/2008

12/12/2008

4/24/2009

3/13/2009

12/23/2008

Manhattan Bancorp, El Segundo, CA

Liberty Bancshares, Inc., Fort Worth, TX2,10

12/4/2009

12/5/2008

Preferred Stock w/ Warrants

Liberty Bancshares, Inc., Springfield, MO2,50

2/13/2009

Mainline Bancorp, Inc., Ebensburg, PA2, 73

Preferred Stock w/ Warrants

Liberty Bancshares, Inc., Jonesboro, AR2,50

1/23/2009

MainSource Financial Group, Inc., Greensburg, IN78

Preferred Stock
Preferred Stock w/ Warrants

Legacy Bancorp, Inc., Milwaukee, WI3,53

1/30/2009

12/29/2009

Preferred Stock

Leader Bancorp, Inc., Arlington, MA2

12/23/2008

1/16/2009

Preferred Stock w/ Exercised Warrants

LCNB Corp., Lebanon, OH

1/9/2009

Preferred Stock w/ Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants

$1,700,000

$57,000,000

$4,500,000

$13,795,000

$3,370,000

$11,000,000

$330,000,000

$151,500,000

$600,000,000

$11,735,000

$15,000,000

$3,072,000

$25,223,000

$950,000,000

$17,280,000

$5,645,000

$6,500,000

$21,900,000

$57,500,000

$5,498,000

Preferred Stock
Preferred Stock w/ Exercised Warrants

$5,830,000

$13,400,000

$3,000,000

$56,044,000

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Exercised Warrants

Lakeland Financial Corporation, Warsaw, IN

Layton Park Financial Group, Milwaukee, WI2

2/27/2009

12/18/2009

$59,000,000

$2,453,000

$1,998,000

Preferred Stock w/ Exercised Warrants
Preferred Stock

$4,000,000

$470,000

$2,500,000,000

$10,449,000

$25,000,000,000

$4,000,000

$25,000,000

$216,000,000

$27,000,000

$83,586,000

$21,500,000

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

Katahdin Bankshares Corp., Houlton, ME2,49

KeyCorp, Cleveland, OH

1/30/2009

Preferred Stock w/ Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Warrants

Integra Bank Corporation, Evansville, IN14,57

Indiana Community Bancorp, Columbus, IN

12/12/2008

$1,312,000

$74,426,000

Preferred Stock w/ Exercised Warrants

Intermountain Community Bancorp, Sandpoint, ID

Indiana Bank Corp., Dana, IN2

4/24/2009

Mandatorily Convertible Preferred
Stock w/ Warrants

12/19/2008

Independent Bank Corporation, Ionia, MI22

12/12/2008

$78,158,000

$1,065,000

Investment Amount

Preferred Stock w/ Warrants

Preferred Stock w/ Exercised Warrants

Investment Description

(Continued)

2/27/2009

Independence Bank, East Greenwich, RI2

Independent Bank Corp., Rockland, MA

1/9/2009

1/9/2009

Institution

Purchase
Date

CPP TRANSACTION DETAIL, AS OF 6/30/2012

9/16/2009

3/28/2012

3/9/2012

$1,700,000

$52,277,171

$4,500,000

$6,885,000

8/18/2011

$—

$—

$—

$—

$6,885,000

$3,455,000
6/8/2011

$—

$230,000,000

$—

$—

$—

$—

$—

$—

$—

$—

$—

$—

$10,340,000

$330,000,000

$370,000,000

$11,735,000

$15,000,000

$21,863,750

$950,000,000

$5,645,000

$21,900,000

$57,500,000

$5,830,000

$13,400,000

$56,044,000

$—

$19,000,000

$39,000,000

$—

$—

$—

$—

$—

$—

Remaining
Capital Amount

$3,455,000

11/24/2009

5/13/2011

5/18/2011

8/20/2010

11/18/2009

6/13/2012

6/30/2010

9/24/2010

8/18/2011

7/21/2011

11/24/2010

10/21/2009

6/9/2010

$19,000,000

2/8/2012

$20,000,000
$20,000,000

8/4/2010
3/16/2011

$2,453,000

$1,998,000

$2,500,000,000

$10,449,000

$25,000,000,000

$78,158,000

Capital Repayment
Amount (Loss)6

9/29/2010

9/29/2010

3/30/2011

8/18/2011

6/17/2009

4/22/2009

Capital
Repayment
Date

10/14/2009

3/9/2012

8/18/2011

N/A

12/16/2009

9/16/2010

N/A

8/18/2011

7/21/2011

11/24/2010

11/18/2011

11/18/2011

2/29/2012

N/A

9/29/2010

4/20/2011

8/18/2011

12/10/2009

5/27/2009

Final
Disposition
Date

R

R

R

R

A

R

R

R

P

P

R

R

R

R

A

R

Note15

$63,364

$225,000

$690,000

N/A

$560,000

$213,671,319

N/A

$1,095,000

$2,875,000

$292,000

$602,557

$877,557

$2,800,000

N/A

$100,000

$70,000,000

$522,000

$936,063,469

$2,200,000

Final Disposition
Proceeds

$3.85

$11.83

$69.50

$5.99

$82.57

$6.58

$21.87

$13.33

$26.83

$10.52

$4.00

$7.74

$13.00

$35.73

$3.83

$19.52

$1.05

$22.05

$2.47

$29.21

Stock
Price as of
6/29/2012

$66,347

$9,159,773

$538,188

$1,661,468

$169,422

$1,682,083

$39,920,833

$100,531,250

$9,489,792

$674,763

$700,000

$—

$4,438,492

$46,180,555

$1,399,560

$461,009

$838,516

$3,000,452

$7,816,966

$355,079

$609,961

$524,833

$393,763

$3,596,156

$6,460,833

$267,134

$595,867

$80,900

$297,222,222

$1,452,047

$795,138,889

$174,325

$1,118,056

$36,660,000

$1,222,500

$1,950,340

$3,681,875

$165,139

$2,430,000

$1,118,094

$194,367

Dividends/
Interest Paid to
Treasury

Continued on next page

571,906

379,310

95,383

1,218,522

407,542

561,343

691,882

1,326,238

653,226

7,418,876

188,707

346,154

Current
Outstanding
Warrants

248
Appendix D I Transaction Detail I July 25, 2012

$35,500,000

$7,186,000

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants
Preferred Stock w/ Exercised Warrants
Preferred Stock w/ Exercised Warrants

Merchants and Manufacturers Bank Corporation,
Joliet, IL2,49

Merchants and Planters Bancshares, Inc., Toone,
TN2,62

Meridian Bank, Devon, PA2

Meridian Bank, Devon, PA2,10a

Metro City Bank, Doraville, GA

MetroCorp Bancshares, Inc., Houston, TX95

Metropolitan Bank Group, Inc.
(NC Bancorp, Inc.), Chicago, IL2,41

Metropolitan Bank Group, Inc., Chicago, IL

Metropolitan Capital Bancorp, Inc., Chicago, IL2

Metropolitan Capital Bancorp, Inc., Chicago, IL2,10a

Mid Penn Bancorp, Inc., Millersburg, PA

Middleburg Financial Corporation, Middleburg, VA

Midland States Bancorp, Inc., Effingham, IL2

MidSouth Bancorp, Inc., Lafayette, LA49

Midtown Bank & Trust Company, Atlanta, GA2

Midwest Banc Holdings, Inc., Melrose Park, IL14,20

Midwest Regional Bancorp, Inc., Festus, MO2

MidWestOne Financial Group, Inc., Iowa City, IA

Mid-Wisconsin Financial Services, Inc., Medford, WI2

Millennium Bancorp, Inc., Edwards, CO2,84

Mission Community Bancorp, San Luis Obispo, CA3

Mission Valley Bancorp, Sun Valley, CA3,30

Monadnock Bancorp, Inc., Peterborough, NH2

Monarch Community Bancorp, Inc., Coldwater, MI

Monarch Financial Holdings, Inc., Chesapeake, VA

Moneytree Corporation, Lenoir City, TN2,50

Monument Bank, Bethesda, MD2,49

Morgan Stanley, New York, NY

6/19/2009

3/6/2009

2/13/2009

12/11/2009

1/30/2009

1/16/2009

6/26/2009

6/26/2009

4/10/2009

11/20/2009

12/19/2008

1/30/2009

1/23/2009

1/9/2009

2/27/2009

12/5/2008

2/13/2009

2/6/2009

2/20/2009

4/3/2009

1/9/2009

12/23/2008

12/19/2008

2/6/2009

12/19/2008

3/13/2009

1/30/2009

10/28/2008

Morrill Bancshares, Inc., Merriam, KS2

Moscow Bancshares, Inc., Moscow, TN2

Mountain Valley Bancshares, Inc., Cleveland, GA2

1/16/2009

1/23/2009

9/25/2009

2,41

$74,706,000

Preferred Stock w/ Exercised Warrants

Mercantile Capital Corp., Boston, MA2,49

2/6/2009

2

Preferred Stock w/ Exercised Warrants

Mercantile Bank Corporation, Grand Rapids, MI

5/15/2009

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants

$3,300,000

$6,216,000

$13,000,000

$10,000,000,000

$4,734,000

Preferred Stock w/ Warrants

$9,516,000

Preferred Stock w/ Exercised Warrants

$14,700,000

$6,785,000

$1,834,000

$5,500,000

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock

$5,116,000

$7,260,000

Preferred Stock

$10,000,000

Preferred Stock w/ Exercised Warrants

$16,000,000

$700,000

$89,388,000

$5,222,000

$20,000,000

$10,189,000

$22,000,000

$10,000,000

$2,348,000

$2,040,000

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Exercised Warrants

Mandatorily Convertible Preferred
Stock w/ Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Warrants

Preferred Stock

Preferred Stock w/ Exercised Warrants

$7,700,000

Preferred Stock w/ Exercised Warrants
$45,000,000

$6,335,000

$6,200,000

$1,881,000

$3,510,000

$3,500,000

$21,000,000

$9,698,000

Preferred Stock

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Exercised Warrants

$11,800,000

$6,000,000

$196,000,000

Medallion Bank, Salt Lake City, UT2,10a,49

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

12/22/2009

$1,700,000

$1,715,000,000

Medallion Bank, Salt Lake City, UT2,49

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Exercised Warrants

McLeod Bancshares, Inc., Shorewood, MN2,50

Marshall & Ilsley Corporation, Milwaukee, WI44

11/14/2008

$20,300,000

2/27/2009

Marquette National Corporation, Chicago, IL2

12/19/2008

Subordinated Debentures
w/ Exercised Warrants

$2,060,000

11/20/2009

Market Street Bancshares, Inc., Mt. Vernon, IL8

5/15/2009

Preferred Stock w/ Exercised Warrants

Maryland Financial Bank, Towson, MD2

Market Bancorporation, Inc., New Market, MN2

2/20/2009

$3,000,000

$2,639,000

Preferred Stock w/ Exercised Warrants

MB Financial Inc., Chicago, IL

Marine Bank & Trust Company, Vero Beach, FL2

3/6/2009

Subordinated Debentures
w/ Exercised Warrants

12/5/2008

Manhattan Bancshares, Inc., Manhattan, IL8

6/19/2009

Investment Amount

Investment Description

(Continued)

3/27/2009

Institution

Purchase
Date

CPP TRANSACTION DETAIL, AS OF 6/30/2012

4/25/2012

7/20/2011

6/17/2009

8/11/2011

9/15/2011

12/23/2009

8/20/2010

12/28/2011

7/6/2011

11/10/2009

8/25/2011

12/23/2009

12/23/2009

6/27/2012

9/7/2011

9/8/2011

$1,100,000

$13,000,000

$10,000,000,000

$4,734,000

$9,516,000

$14,700,000

$5,500,000

$5,116,000

$16,000,000

$700,000

$20,000,000

$10,189,000

$22,000,000

$43,490,360

$1,881,000

$3,510,000

$3,500,000

$10,500,000

6/6/2012
8/4/2011

$9,698,000
$10,500,000

7/21/2011

$11,800,000

$6,000,000

$196,000,000

$1,715,000,000

Capital Repayment
Amount (Loss)6

4/4/2012

7/21/2011

8/18/2011

3/14/2012

7/5/2011

Capital
Repayment
Date

$5,116,000

$—

$—

$—

$—

$—

$—

$—

$—

$—

$—

$—

$—

$—

$—

$—

$—

$—

$10,500,000

$—

$—

$—

$—

$—

Remaining
Capital Amount

7/20/2011

8/12/2009

8/11/2011

9/15/2011

2/10/2010

N/A

N/A

7/27/2011

11/10/2009

11/18/2011

12/23/2009

11/18/2011

9/7/2011

9/8/2011

8/4/2011

7/21/2011

7/21/2011

8/18/2011

5/2/2012

7/5/2011

Final
Disposition
Date

R

R

R

R

R

R

R

P

R

P

R

R

R

R

R

R

R

R

Note15

$650,000

$950,000,000

$237,000

$476,000

$260,000

N/A

N/A

$1,000,000

$35,000

$206,557

$509,000

$301,001

$94,000

$176,000

$175,000

$55,000

$590,000

$300,000

$1,518,072

$3,250,000

Final Disposition
Proceeds

$14.59

$9.85

$1.21

$4.95

$3.01

$6.00

$21.50

$10.95

$10.67

$18.45

$21.54

$107.00

Stock
Price as of
6/29/2012

$474,604

$1,118,716

$1,779,122

$318,055,555

$652,959

$1,299,481

$743,167

$262,919

$190,517

$456,042

$759,584

$343,053

$1,082,431

$1,933,333

$28,294

$824,289

$275,105

$2,627,778

$508,989

$986,944

$1,702,778

$636,219

$3,454,185

$332,256

$7,528,750

$1,381,348

$1,869,051

$256,560

$424,668

$475,815

$3,166,021

$2,317,675

$570,433

$32,095,000

$197,653

$226,522,917

$6,588,899

$5,109,510

$138,778

$235,713

$643,345

Dividends/
Interest Paid to
Treasury

Continued on next page

260,962

4,282,020

73,099

771,429

616,438

Current
Outstanding
Warrants

Transaction detail I Appendix D I July 25, 2012

249

Subordinated Debentures
w/ Exercised Warrants
Preferred Stock w/ Warrants
Preferred Stock w/ Exercised Warrants

Preferred Stock
Preferred Stock w/ Warrants

Naples Bancorp, Inc., Naples, FL2

National Bancshares, Inc., Bettendorf, IA2

National Penn Bancshares, Inc., Boyertown, PA

Nationwide Bankshares, Inc., West Point, NE8

NCAL Bancorp, Los Angeles, CA2

NEMO Bancshares Inc., Madison, MO8

New Hampshire Thrift Bancshares, Inc.,
Newport, NH49

New York Private Bank & Trust Corporation,
New York, NY2

NewBridge Bancorp, Greensboro, NC

Nicolet Bankshares, Inc., Green Bay, WI2,49

North Central Bancshares, Inc., Fort Dodge, IA

Northeast Bancorp, Lewiston, ME

Northern State Bank, Closter, NJ2

Northern State Bank, Closter, NJ2,10a

Northern States Financial Corporation,
Waukegan, IL

2/27/2009

12/12/2008

12/11/2009

12/19/2008

6/19/2009

1/16/2009

1/9/2009

12/12/2008

12/23/2008

1/9/2009

12/12/2008

5/15/2009

12/18/2009

2/20/2009

Preferred Stock w/ Exercised Warrants
Preferred Stock w/ Exercised Warrants
Preferred Stock w/ Exercised Warrants

Northwest Commercial Bank, Lakewood, WA2

Oak Ridge Financial Services, Inc., Oak Ridge, NC

Oak Valley Bancorp, Oakdale, CA50

OceanFirst Financial Corp., Toms River, NJ

Ojai Community Bank, Ojai, CA2

Old Line Bancshares, Inc., Bowie, MD

Old National Bancorp, Evansville, IN

Old Second Bancorp, Inc., Aurora, IL

Omega Capital Corp., Lakewood, CO2

One Georgia Bank, Atlanta, GA2,56

OneFinancial Corporation , Little Rock, AR8,10

OneUnited Bank, Boston, MA2,3

Oregon Bancorp, Inc., Salem, OR2

OSB Financial Services, Inc., Orange, TX8

Pacific Capital Bancorp, Santa Barbara, CA

Pacific City Financial Corporation, Los Angeles, CA2

Pacific Coast Bankers’ Bancshares,
San Francisco, CA2,50

Pacific Coast National Bancorp,
San Clemente, CA2,19

Pacific Commerce Bank, Los Angeles, CA2

Pacific International Bancorp, Seattle, WA

Park Bancorporation, Inc., Madison, WI2

Park National Corporation, Newark, OH

Parke Bancorp, Inc., Sewell, NJ

2/13/2009

1/30/2009

12/5/2008

1/16/2009

1/30/2009

12/5/2008

12/12/2008

1/16/2009

4/17/2009

5/8/2009

6/5/2009

12/19/2008

4/24/2009

5/1/2009

11/21/2008

12/19/2008

12/23/2008

1/16/2009

12/23/2008

12/12/2008

3/6/2009

12/23/2008

1/30/2009

29

Northwest Bancorporation, Inc., Spokane, WA2

2/13/2009

$13,500,000

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Exercised Warrants

$16,288,000

$100,000,000

$23,200,000

$6,500,000

$4,060,000

$4,120,000

$11,600,000

$16,200,000

$195,045,000

$6,100,000

Subordinated Debentures w/ Exercised
Warrants
Common Stock w/ Warrants

$3,216,000

$12,063,000

$17,300,000

$5,500,000

$2,816,000

$73,000,000

$100,000,000

$7,000,000

$2,080,000

Preferred Stock w/ Exercised Warrants

Preferred Stock

Subordinated Debentures
w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Warrants

$38,263,000

Preferred Stock w/ Warrants
Preferred Stock w/ Warrants

$7,700,000

$1,992,000

$10,500,000

$10,000,000

$1,576,000,000

$17,211,000

$1,230,000

$1,341,000

$4,227,000

$10,200,000

$14,964,000

$52,372,000

$267,274,000

$10,000,000

$2,330,000

$10,000,000

$2,000,000

$150,000,000

$24,664,000

$4,000,000

$32,382,000

$7,723,000

Investment Amount

Preferred Stock w/ Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

Northern Trust Corporation, Chicago, IL

Northway Financial, Inc., Berlin, NH2,49

11/14/2008

1/30/2009

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Exercised Warrants

Subordinated Debentures
w/ Exercised Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

3/27/2009

Preferred Stock w/ Exercised Warrants

MS Financial, Inc., Kingwood, TX2

MutualFirst Financial, Inc., Muncie, IN50

3/27/2009

Investment Description

Institution

(Continued)

12/23/2008

Purchase
Date

CPP TRANSACTION DETAIL, AS OF 6/30/2012

4/25/2012

2/11/2010

7/28/2011

10/5/2011

3/31/2009

7/15/2009

12/30/2009

8/11/2011

9/15/2011

6/17/2009

3/28/2012

3/28/2012

12/14/2011

9/1/2011

8/25/2011

12/29/2010

3/16/2011

8/25/2011

10/19/2011

Capital
Repayment
Date

$100,000,000

$—

$11,600,000

$6,100,000

$100,000,000

$7,000,000

$38,263,000

$13,500,000

$10,000,000

$1,576,000,000

$1,230,000

$1,341,000

$10,200,000

$14,964,000

$10,000,000

$2,000,000

$150,000,000

$32,382,000

$7,723,000

Capital Repayment
Amount (Loss)6

$—

$—

$—

$—

$—

$—

$—

$—

$—

$—

$—

$—

$—

$—

$—

$—

$—

$—

$—

Remaining
Capital Amount

5/2/2012

N/A

7/28/2011

10/5/2011

5/8/2009

9/2/2009

2/3/2010

9/28/2011

9/15/2011

8/26/2009

N/A

3/28/2012

1/11/2012

9/1/2011

2/15/2012

12/29/2010

4/13/2011

9/28/2011

10/19/2011

Final
Disposition
Date

R

R

R

R

R

R

R

R

R

R

R

R

R

R

R

R

R

Note15

$2,842,400

N/A

$580,000

$305,000

$1,200,000

$225,000

$430,797

$560,000

$500,000

$87,000,000

N/A

$67,000

$600,000

$748,000

$737,100

$100,000

$1,000,000

$900,194

$386,000

Final Disposition
Proceeds

$5.21

$69.75

$1.99

$3.49

$45.73

$8.00

$1.30

$12.01

$10.27

$5.25

$14.36

$6.96

$4.54

$11.35

$46.02

$0.82

$8.48

$30.55

$4.38

$12.75

$1.96

$9.55

$10.50

Stock
Price as of
6/29/2012

$2,680,733

$16,694,444

$4,035,543

$463,125

$387,223

$18,088

$1,641,964

$358,065

$2,107,397

$1,257,315

$536,095

$93,823

$3,782,991

$—

$50,311

$5,769,028

$1,513,889

$213,889

$316,463

$1,828,122

$1,811,250

$1,267,292

$272,103

$575,430

$1,430,625

$46,623,333

$418,323

$349,782

$723,874

$1,494,583

$2,192,843

$8,968,705

$48,797,641

$1,304,167

$568,199

$1,311,028

$176,190

$16,958,333

$2,307,492

$356,067

$4,326,595

$1,097,290

Dividends/
Interest Paid to
Treasury

Continued on next page

399,006

15,120

815,339

163,830

584,084

67,958

2,567,255

Current
Outstanding
Warrants

250
Appendix D I Transaction Detail I July 25, 2012

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

Pascack Bancorp, Inc.(Pascack Community Bank),
Westwood, NJ2,13

Patapsco Bancorp, Inc., Dundalk, MD2

Pathfinder Bancorp, Inc., Oswego, NY49

Pathway Bancorp, Cairo, NE2

Patriot Bancshares, Inc., Houston, TX2

Patterson Bancshares, Inc, Patterson, LA2

Peapack-Gladstone Financial Corporation,
Gladstone, NJ

2/6/2009

12/19/2008

9/11/2009

3/27/2009

12/19/2008

4/17/2009

1/9/2009

$12,660,000
$3,900,000

Preferred Stock w/ Warrants
Preferred Stock w/ Exercised Warrants
Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants
Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants
Preferred Stock w/ Warrants

Peoples Bancorp Inc., Marietta, OH

Peoples Bancorp of North Carolina, Inc.,
Newton, NC93

Peoples Bancorporation, Inc., Easley, SC2,83

Peoples Bancshares of TN, Inc, Madisonville, TN2

PeoplesSouth Bancshares, Inc., Colquitt, GA2

PFSB Bancorporation, Inc., Pigeon Falls, WI2,10,50

PGB Holdings, Inc., Chicago, IL3,30

Pierce County Bancorp, Tacoma, WA2,51

Pinnacle Bank Holding Company, Inc.,
Orange City, FL2

Pinnacle Financial Partners, Inc., Nashville, TN

Plains Capital Corporation, Dallas, TX2,49

Plato Holdings Inc., Saint Paul, MN8,10

Plumas Bancorp, Quincy, CA

Popular, Inc., San Juan, PR12

Porter Bancorp Inc., Louisville, KY

Prairie Star Bancshares, Inc., Olathe, KS2

Premier Bancorp, Inc., Wilmette, IL3,8,30

Premier Bank Holding Company, Tallahassee, FL2

Premier Financial Bancorp, Inc., Huntington, WV

Premier Financial Corp, Dubuque, IA8

Premier Service Bank, Riverside, CA

PremierWest Bancorp, Medford, OR

Presidio Bank, San Francisco, CA2,10

Princeton National Bancorp, Inc., Princeton, IL

Private Bancorporation, Inc., Minneapolis, MN2

Private Bancorporation, Inc., Minneapolis, MN2,10a

PrivateBancorp, Inc., Chicago, IL

Providence Bank, Rocky Mount, NC2,10,49

Provident Community Bancshares, Inc.,
Rock Hill, SC

PSB Financial Corporation, Many, LA2,30

Puget Sound Bank, Bellevue, WA2,49

1/30/2009

12/23/2008

4/24/2009

3/20/2009

3/6/2009

9/11/2009

2/6/2009

1/23/2009

3/6/2009

12/12/2008

12/19/2008

7/17/2009

1/30/2009

12/5/2008

11/21/2008

4/3/2009

5/8/2009

3/20/2009

10/2/2009

5/22/2009

2/20/2009

2/13/2009

11/20/2009

1/23/2009

2/27/2009

12/29/2009

1/30/2009

10/2/2009

3/13/2009

2/27/2009

1/16/2009

2

$25,054,000

Preferred Stock w/ Warrants

Peoples Bancorp, Lynden, WA2,62

$10,800,000

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

Preferred Stock

Preferred Stock w/ Exercised Warrants

$4,500,000

$9,270,000

$9,266,000

$4,000,000

$243,815,000

$3,262,000

$4,960,000

$25,083,000

Preferred Stock w/ Exercised Warrants
Preferred Stock w/ Warrants

$41,400,000

$4,000,000

Preferred Stock w/ Warrants

$6,349,000

Preferred Stock w/ Exercised Warrants

$22,252,000

Subordinated Debentures
w/ Exercised Warrants

Preferred Stock w/ Warrants

$9,500,000

$6,784,000

Subordinated Debentures
Preferred Stock w/ Exercised Warrants

$2,800,000

$35,000,000

$935,000,000

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

Trust Preferred Securities w/ Warrants

$11,949,000

$2,500,000

Preferred Stock w/ Warrants

$87,631,000

Subordinated Debentures w/ Exercised
Warrants

$95,000,000

$4,389,000

$6,800,000

$3,000,000

$1,500,000

$12,325,000

$39,000,000

$18,000,000

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

Preferred Stock

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants

$9,960,000

$6,000,000

2/13/2009

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

Peninsula Bank Holding Co., Palo Alto, CA

Penn Liberty Financial Corp., Wayne, PA2,49

1/30/2009

$28,685,000

$3,690,000

$26,038,000

$3,727,000

$6,771,000

$6,000,000

$3,756,000

Investment Amount

4/17/2009

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Exercised Warrants

Investment Description

(Continued)

Institution

Purchase
Date

CPP TRANSACTION DETAIL, AS OF 6/30/2012

$18,000,000

12/28/2011

8/11/2011

9/29/2010

9/15/2011

8/13/2010

$4,500,000

$9,270,000

$4,000,000

$6,784,000

$87,631,000

$71,250,000

6/20/2012
9/27/2011

$23,750,000

$3,000,000

$1,500,000

$12,660,000

12/28/2011

8/13/2010

8/25/2011

4/24/2012

$23,033,635

$21,000,000

2/2/2011

6/27/2012

$18,000,000

8/3/2011

$9,960,000

1/11/2012

9/1/2011

$7,172,000
$14,341,000

3/2/2011

$250,000
$7,172,000

3/7/2012

$6,771,000

$3,756,000

Capital Repayment
Amount (Loss)6

1/6/2010

9/1/2011

10/19/2011

Capital
Repayment
Date

$—

$—

$—

$—

$—

$—

$71,250,000

$—

$—

$—

$—

$—

$18,000,000

$—

$—

$—

$14,341,000

$21,513,000

$3,440,000

$—

$—

Remaining
Capital Amount

8/11/2011

9/29/2010

9/15/2011

N/A

9/27/2011

N/A

8/25/2011

4/24/2012

2/15/2012

8/3/2011

9/1/2011

4/4/2012

2/1/2012

10/19/2011

Final
Disposition
Date

R

R

R

R

R

R

R

R

R

R

R

R

Note15

$225,000

$464,000

$175,000

N/A

$4,382,000

N/A

$71,000

$633,000

$1,200,724

$900,000

$498,000

$110,000

$537,633

$188,000

Final Disposition
Proceeds

$9.75

$0.16

$14.76

$0.20

$7.75

$1.37

$1.45

$7.35

$1.51

$16.61

$3.12

$19.51

$7.95

$21.98

$15.51

$9.00

$0.62

Stock
Price as of
6/29/2012

$630,157

$802,802

$543,091

$421,312

$40,127,885

$498,860

$2,271,405

$1,415,219

$1,046,500

$54,500

$522,263

$2,924,868

$467,413

$660,215

$132,253

$4,783,333

$148,171,528

$622,344

$534,286

$13,239,940

$16,163,194

$284,999

$207,948

$227,917

$159,163

$2,143,811

$670,123

$2,069,910

$4,252,221

$4,725,833

$2,425,250

$1,287,689

$1,008,943

$3,280,740

$635,844

$2,704,136

$77,852

$667,696

$377,867

$553,313

Dividends/
Interest Paid to
Treasury

Continued on next page

178,880

645,013

155,025

109,039

628,588

330,561

2,093,284

237,712

267,455

357,234

81,670

Current
Outstanding
Warrants

Transaction detail I Appendix D I July 25, 2012

251

Preferred Stock w/ Exercised Warrants
Preferred Stock w/ Exercised Warrants
Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants
Subordinated Debentures
w/ Exercised Warrants

Redwood Financial Inc., Redwood Falls, MN2,49

Regent Bancorp, Inc., Davie, FL2

Regent Capital Corporation, Nowata, OK2,49

Regents Bancshares, Inc., Vancouver, WA2,10,69

Regional Bankshares, Inc., Hartsville, SC2

Regions Financial Corporation, Birmingham, AL

Reliance Bancshares, Inc., Frontenac, MO2

Ridgestone Financial Services, Inc., Brookfield, WI2

Rising Sun Bancorp, Rising Sun, MD2

River Valley Bancorporation, Inc., Wausau, WI8

Riverside Bancshares, Inc., Little Rock, AR8

Rogers Bancshares, Inc., Little Rock, AR

Royal Bancshares of Pennsylvania, Inc.,
Narberth, PA

S&T Bancorp, Indiana, PA

Saigon National Bank, Westminster, CA2

Salisbury Bancorp, Inc., Lakeville, CT49

Sandy Spring Bancorp, Inc., Olney, MD

Santa Clara Valley Bank, N.A., Santa Paula, CA2

Santa Lucia Bancorp, Atascadero, CA64

SBT Bancorp, Inc., Simsbury, CT2,49

SCBT Financial Corporation, Columbia, SC

Seacoast Banking Corporation of Florida,
Stuart, FL77

Seacoast Commerce Bank, Chula Vista, CA2,49

Security Bancshares of Pulaski County, Inc.,
Waynesville, MO2

Security Business Bancorp, San Diego, CA

Security California Bancorp, Riverside, CA2,49

Security Capital Corporation, Batesville, MS2,10,30

Security Federal Corporation, Aiken, SC30

Security State Bancshares, Inc., Charleston, MO2,49

Security State Bank Holding-Company,
Jamestown, ND8

Severn Bancorp, Inc., Annapolis, MD

Shore Bancshares, Inc., Easton, MD

1/9/2009

3/6/2009

2/27/2009

10/23/2009

2/13/2009

11/14/2008

2/13/2009

2/27/2009

1/9/2009

6/12/2009

5/15/2009

1/30/2009

2/20/2009

1/16/2009

12/23/2008

3/13/2009

12/5/2008

2/13/2009

12/19/2008

3/27/2009

1/16/2009

12/19/2008

12/23/2008

2/13/2009

1/9/2009

1/9/2009

6/26/2009

12/19/2008

2/20/2009

5/1/2009

11/21/2008

1/9/2009

Somerset Hills Bancorp, Bernardsville, NJ

Sonoma Valley Bancorp, Sonoma, CA2,25

Sound Banking Company, Morehead City, NC2

South Financial Group, Inc., Greenville, SC26

SouthCrest Financial Group, Inc., Fayetteville, GA2

1/16/2009

1/9/2009

12/5/2008

7/17/2009

12/12/2008

2/20/2009

Signature Bancshares, Inc., Dallas, TX

Signature Bank, New York, NY

6/26/2009

8

$5,803,000

Preferred Stock w/ Warrants

Redwood Capital Bancorp, Eureka, CA2,49

1/16/2009

2,49

$2,152,000

Preferred Stock w/ Warrants

RCB Financial Corporation, Rome, GA2,10

2

Randolph Bank & Trust Company, Asheboro, NC2

6/19/2009

$1,500,000

$4,000,000

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Warrants

Subordinated Debentures
w/ Exercised Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Warrants

$12,900,000

$347,000,000

$3,070,000

$8,653,000

$7,414,000

$120,000,000

$1,700,000

$25,000,000

$23,393,000

$10,750,000

$12,500,000

$18,000,000

$17,388,000

Preferred Stock w/ Exercised Warrants
Preferred Stock w/ Warrants

$6,815,000

Preferred Stock w/ Exercised Warrants

$1,800,000

$50,000,000

$64,779,000

$4,000,000

$2,900,000

$83,094,000

$8,816,000

$1,549,000

$108,676,000

$30,407,000

Preferred Stock w/ Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Warrants

$25,000,000

$1,100,000

Subordinated Debentures
w/ Exercised Warrants
Preferred Stock w/ Exercised Warrants

$15,000,000

Subordinated Debentures
w/ Exercised Warrants

$5,983,000

$10,900,000

Preferred Stock w/ Exercised Warrants
Preferred Stock w/ Exercised Warrants

$40,000,000

Preferred Stock w/ Exercised Warrants

$3,500,000,000

Preferred Stock w/ Exercised Warrants
Preferred Stock w/ Warrants

$12,700,000

$2,655,000

$9,982,000

$2,995,000

$3,800,000

$8,900,000

$6,229,000

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants

$38,237,000

10/30/2009

Preferred Stock w/ Warrants

Pulaski Financial Corp, Creve Coeur, MO96

QCR Holdings, Inc., Moline, IL49

$32,538,000

Investment Amount

1/16/2009

Preferred Stock w/ Warrants

Investment Description

(Continued)

2/13/2009

Institution

Purchase
Date

CPP TRANSACTION DETAIL, AS OF 6/30/2012

$41,547,000

12/15/2010

9/30/2010

5/20/2009

3/31/2009

12/15/2010

4/15/2009

9/22/2011

9/29/2010

9/29/2010

9/15/2011

7/14/2011

9/1/2011

3/28/2012

5/20/2009

8/11/2011

$130,179,219

$7,414,000

$120,000,000

$1,700,000

$25,000,000

$12,500,000

$18,000,000

$17,388,000

$6,815,000

$5,803,000

$1,800,000

$40,404,700

$64,779,000

$4,000,000

$2,800,000

$41,547,000

7/21/2010

10/21/2011

$8,816,000

$108,676,000

$10,500,000

$3,500,000,000

$12,700,000

$2,655,000

$2,995,000

$3,800,000

$38,237,000

$28,460,338

Capital Repayment
Amount (Loss)6

8/25/2011

12/7/2011

6/6/2012

4/4/2012

1/27/2012

7/21/2011

8/18/2011

7/21/2011

9/15/2011

6/27/2012

Capital
Repayment
Date

$—

$—

$—

$—

$—

$—

$—

$—

$—

$—

$—

$—

$—

$—

$—

$—

$41,547,000

$—

$—

$4,500,000

$—

$—

$—

$—

$—

$—

$—

Remaining
Capital Amount

9/30/2010

6/24/2009

3/10/2010

12/15/2010

11/16/2011

9/22/2011

9/29/2010

9/15/2011

7/14/2011

9/1/2011

5/30/2012

6/24/2009

8/11/2011

N/A

2/23/2011

11/2/2011

5/2/2012

1/27/2012

7/21/2011

8/18/2011

7/21/2011

11/16/2011

Final
Disposition
Date

R

R

A

R

R

R

R

R

R

R

R

R

R

R

R

R

R

R

R

R

R

Note15

$400,000

$275,000

$11,150,940

$85,000

$25,000

$625,000

$522,000

$341,000

$290,000

$90,000

$55,000

$1,400,000

$200,000

N/A

$4,450,000

$205,000

$45,000,000

$381,000

$133,000

$150,000

$190,000

$1,100,000

Final Disposition
Proceeds

$4.00

$4.30

$8.50

$60.97

$5.98

$3.12

$8.50

$9.65

$4.25

$1.49

$35.25

$0.34

$5.26

$18.00

$24.65

$0.66

$18.47

$1.81

$15.64

$0.70

$6.75

$11.60

$7.00

$13.10

$7.41

Stock
Price as of
6/29/2012

$933,494

$16,386,111

$560,656

$347,164

$127,686

$1,816,667

$209,588

$333,333

$3,781,869

$1,414,005

$1,763,680

$1,600,000

$1,153,111

$996,698

$795,018

$381,942

$263,780

$8,585,770

$1,115,639

$517,145

$331,111

$158,928

$7,593,868

$1,079,960

$—

$15,712,738

$358,971

$738,021

$276,870

$3,728,275

$195,637

$277,224

$3,827,111

$593,055,555

$266,142

$1,513,339

$347,328

$784,282

$425,811

$520,626

$893,934

$608,163

$4,949,567

$5,418,481

Dividends/
Interest Paid to
Treasury

Continued on next page

172,970

556,976

137,966

517,012

1,104,370

778,421

Current
Outstanding
Warrants

252
Appendix D I Transaction Detail I July 25, 2012

Preferred Stock w/ Exercised Warrants

Southern Heritage Bancshares, Inc.,
Cleveland, TN2,50

Southern Illinois Bancorp, Inc., Carmi, IL2,49

Southern Missouri Bancorp, Inc., Poplar Bluff, MO49

SouthFirst Bancshares, Inc., Sylacauga, AL2

Southwest Bancorp, Inc., Stillwater, OK

Sovereign Bancshares, Inc., Dallas, TX2,49

Spirit BankCorp, Inc., Bristow, OK2

St. Johns Bancshares, Inc., St. Louis, MO2

Standard Bancshares, Inc., Hickory Hills, IL2

State Bankshares, Inc., Fargo, ND2

5/15/2009

1/23/2009

12/5/2008

6/12/2009

12/5/2008

3/13/2009

3/27/2009

3/13/2009

4/24/2009

1/16/2009

Stockmens Financial Corporation, Rapid City, SD2

Stonebridge Financial Corp., West Chester, PA2

Suburban Illinois Bancorp, Inc., Elmhurst, IL8

Summit State Bank, Santa Rosa, CA49

Sun Bancorp, Inc., Vineland, NJ

SunTrust Banks, Inc., Atlanta, GA

SunTrust Banks, Inc., Atlanta, GA

Superior Bancorp Inc., Birmingham, AL17,54

Surrey Bancorp, Mount Airy, NC2

Susquehanna Bancshares, Inc, Lititz, PA

SV Financial, Inc., Sterling, IL2

SVB Financial Group, Santa Clara, CA

Sword Financial Corporation , Horicon, WI8,49

Synovus Financial Corp., Columbus, GA

2/6/2009

1/23/2009

6/19/2009

12/19/2008

1/9/2009

11/14/2008

12/31/2008

12/5/2008

1/9/2009

12/12/2008

4/10/2009

12/12/2008

5/8/2009

12/19/2008

TCB Corporation, Greenwood, SC8,10,50

Stewardship Financial Corporation,
Midland Park, NJ49

1/30/2009

8/28/2009

Sterling Financial Corporation, Spokane, WA24

12/5/2008

Syringa Bancorp, Boise, ID2

Sterling Bancshares, Inc., Houston, TX

12/12/2008

Taylor Capital Group, Rosemont, IL86

Sterling Bancorp, New York, NY

12/23/2008

11/21/2008

Preferred Stock w/ Warrants

StellarOne Corporation, Charlottesville, VA

12/19/2008

1/16/2009

Common Stock w/ Warrants

Steele Street Bank Corporation, Denver, CO

9/25/2009
8,10,50

Stearns Financial Services, Inc., St. Cloud, MN8

6/26/2009

$15,000,000

Preferred Stock w/ Warrants

$42,000,000

$15,000,000

Subordinated Debentures
w/ Exercised Warrants

Subordinated Debentures
w/ Exercised Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

Subordinated Debentures
w/ Exercised Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Exercised Warrants

Trust Preferred Securities w/ Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Warrants

$9,720,000

$104,823,000

$8,000,000

$967,870,000

$13,644,000

$235,000,000

$4,000,000

$300,000,000

$2,000,000

$69,000,000

$1,350,000,000

$3,500,000,000

$89,310,000

$8,500,000

$10,973,000

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

$15,568,000

$10,000,000

$303,000,000

$125,198,000

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

$30,000,000

$11,019,000

Subordinated Debentures
w/ Exercised Warrants
Preferred Stock w/ Warrants

$24,900,000

Subordinated Debentures
w/ Exercised Warrants

Preferred Stock w/ Warrants

$2,000,000,000

Preferred Stock w/ Exercised Warrants

State Capital Corporation, Greenwood, MS

State Street Corporation, Boston, MA

$50,000,000

Preferred Stock w/ Exercised Warrants

2/13/2009

$60,000,000

Preferred Stock w/ Exercised Warrants

$3,000,000

$30,000,000

Preferred Stock w/ Exercised Warrants

$18,215,000

Preferred Stock w/ Exercised Warrants

$70,000,000

$2,760,000

$9,550,000

$5,000,000

$4,862,000

$17,299,000

$42,750,000

$11,000,000

Investment Amount

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

10/28/2008

2,30

Preferred Stock w/ Warrants

Southern First Bancshares, Inc., Greenville, SC98

2/27/2009

Preferred Stock w/ Exercised Warrants

Preferred Stock
Preferred Stock w/ Warrants

Southern Bancorp, Inc., Arkadelphia, AR3,30

Southern Community Financial Corp.,
Winston-Salem, NC

1/16/2009

Investment Description

(Continued)

12/5/2008

Institution

Purchase
Date

CPP TRANSACTION DETAIL, AS OF 6/30/2012

$22,500,000

12/28/2011

$11,568,000

3/16/2011

9/8/2011

6/13/2012

9/15/2011

12/23/2009

$9,720,000

$92,254,460

$13,644,000

$235,000,000

$4,000,000

$100,000,000

12/22/2010
8/31/2011

$200,000,000

$2,000,000

$1,350,000,000

$3,500,000,000

$89,310,000

4/21/2010

12/29/2010

3/30/2011

3/30/2011

4/8/2009

$8,500,000

$4,000,000

1/14/2011

8/4/2011

$10,000,000

125,198,000

9/1/2011

5/5/2009

$42,000,000

$7,500,000

4/27/2011

$11,019,000

9/1/2011

$24,900,000

$2,000,000,000

4/13/2011

1/18/2012

6/17/2009

$15,000,000

$37,500,000

9/29/2010

$12,500,000

8/12/2009

$18,215,000

$9,550,000

$5,000,000

$4,862,000

$15,403,722

$11,000,000

Capital Repayment
Amount (Loss)6

6/29/2011

9/22/2011

7/21/2011

8/25/2011

9/8/2011

6/27/2012

8/6/2010

Capital
Repayment
Date

$—

$—
9/8/2011

9/15/2011

6/16/2010

$—
$—

8/31/2011

1/19/2011

12/29/2010

9/22/2011

9/22/2011

5/27/2009

9/14/2011

3/16/2011

10/26/2011

6/9/2010

5/18/2011

9/1/2011

1/18/2012

7/8/2009

9/29/2010

6/29/2011

9/22/2011

8/25/2011

9/8/2011

N/A

Final
Disposition
Date

$—

$—

$100,000,000

$—

$—

$—

$—

$—

$—

$11,568,000

$—

$—

$—

$—

$22,500,000

$—

$—

$—

$—

$—

$37,500,000

$—

$—

$—

$—

$—

$—

Remaining
Capital Amount

R

R

R

R

R

R

A

A

R

R

R

R

A

R

R

R

R

R

R

R

R

R

Note15

$292,000

$682,000

$6,820,000

$200,000

$5,269,179

$100,000

$15,996,899

$14,069,763

$2,100,000

$315,000

$778,000

$107,398

$2,857,915

$945,775

$331,000

$1,245,000

$60,000,000

$750,000

$2,500,000

$911,000

$250,000

$243,000

N/A

Final Disposition
Proceeds

$16.39

$0.04

$1.98

$58.72

$10.28

$9.00

$24.23

$2.68

$5.75

$4.60

$18.89

$9.98

$12.48

$44.64

$9.41

$1.75

$21.50

$8.50

$3.16

Stock
Price as of
6/29/2012

$1,599,381

$18,751,438

$253,122

$164,806,753

$2,693,234

$12,109,028

$521,383

$23,722,222

$214,972

$4,983,333

$567,986,111

$1,103,971

$1,115,625

$2,083,520

$634,609

$1,755,554

$1,293,055

$6,733,333

$2,486,571

$4,923,333

$4,271,875

$1,728,673

$5,350,442

$63,611,111

$1,330,709

$5,508,472

$6,730,750

$518,658

$2,261,750

$2,506,669

$8,555,556

$364,796

$1,254,764

$705,472

$613,111

$2,782,256

$4,156,250

$855,556

Dividends/
Interest Paid to
Treasury

Continued on next page

1,462,647

15,510,737

1,923,792

97,541

302,623

703,753

114,326

399,970

1,623,418

Current
Outstanding
Warrants

Transaction detail I Appendix D I July 25, 2012

253

Preferred Stock w/ Warrants
Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants
Preferred Stock w/ Warrants
Preferred Stock w/ Warrants

TCF Financial Corporation, Wayzata, MN

TCNB Financial Corp., Dayton, OH2

Tennessee Commerce Bancorp, Inc., Franklin, TN70

Tennessee Valley Financial Holdings, Inc.,
Oak Ridge, TN2

Texas Capital Bancshares, Inc., Dallas, TX

Texas National Bancorporation, Jacksonville, TX2

The ANB Corporation, Terrell, TX2,49

The Bancorp, Inc., Wilmington, DE

The Bank of Currituck, Moyock, NC2,34

The Bank of Kentucky Financial Corporation,
Crestview Hills, KY

The Bank of New York Mellon Corporation,
New York, NY

The Baraboo Bancorporation, Baraboo, WI

The Connecticut Bank and Trust Company,
Hartford, CT81

The Elmira Savings Bank, FSB, Elmira, NY49

The First Bancorp, Inc., Damariscotta, ME

The First Bancshares, Inc., Hattiesburg, MS30

The Freeport State Bank, Harper, KS2

The Goldman Sachs Group, Inc., New York, NY

11/14/2008

12/23/2008

12/19/2008

12/23/2008

1/16/2009

1/9/2009

8/7/2009

12/12/2008

2/6/2009

2/13/2009

10/28/2008

1/16/2009

12/19/2008

12/19/2008

1/9/2009

2/6/2009

2/6/2009

10/28/2008

Subordinated Debentures
w/ Exercised Warrants
Preferred Stock w/ Exercised Warrants
Preferred Stock w/ Exercised Warrants
Preferred Stock w/ Exercised Warrants

The Private Bank of California, Los Angeles, CA2,49

The Queensborough Company, Louisville, GA2

The State Bank of Bartley, Bartley, NE8,10,49

The Victory Bancorp, Inc. (The Victory Bank),
Limerick, PA2,10a,49

The Victory Bancorp, Inc., Limerick, PA2,13,49

Three Shores Bancorporation, Inc. (Seaside
National Bank & Trust), Orlando, FL2,13

TIB Financial Corp, Naples, FL

Tidelands Bancshares, Inc, Mount Pleasant, SC

Tifton Banking Company, Tifton, GA2,52

Timberland Bancorp, Inc., Hoquiam, WA

Titonka Bancshares, Inc, Titonka, IA2

Todd Bancshares, Inc., Hopkinsville, KY2

TowneBank, Portsmouth, VA50

Treaty Oak Bancorp, Inc., Austin, TX2,36

Triad Bancorp, Inc., Frontenac, MO2,49

Tri-County Financial Corporation, Waldorf, MD2,49

Trinity Capital Corporation , Los Alamos, NM2

Tri-State Bank of Memphis, Memphis, TN2,3,30

TriState Capital Holdings, Inc., Pittsburgh, PA2

TriSummit Bank, Kingsport, TN2

TriSummit Bank, Kingsport, TN2,10a

2/20/2009

1/9/2009

9/4/2009

12/11/2009

2/27/2009

1/23/2009

12/5/2008

12/19/2008

4/17/2009

12/23/2008

4/3/2009

2/6/2009

12/12/2008

1/16/2009

3/27/2009

12/19/2008

3/27/2009

4/3/2009

2/27/2009

4/3/2009

12/22/2009

32

Preferred Stock w/ Warrants

The PNC Financial Services Group Inc.,
Pittsburgh, PA

12/31/2008

Preferred Stock

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants

Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants

The Landrum Company, Columbia, MO2,49

The Little Bank, Incorporated, Kinston, NC2

12/23/2008

Preferred Stock w/ Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Exercised Warrants

5/22/2009

2

Preferred Stock w/ Exercised Warrants

TCB Holding Company, Texas Community Bank,
The Woodlands, TX2

1/16/2009
Preferred Stock w/ Warrants

Investment Description

(Continued)

Institution

Purchase
Date

CPP TRANSACTION DETAIL, AS OF 6/30/2012

$4,237,000

$2,765,000

$23,000,000

$2,795,000

$35,539,000

$15,540,000

$3,700,000

$3,268,000

$76,458,000

$4,000,000

$2,117,000

$16,641,000

$3,800,000

$14,448,000

$37,000,000

$5,677,000

$541,000

$1,505,000

$1,697,000

$12,000,000

$5,450,000

$7,579,200,000

$7,500,000

$15,000,000

$10,000,000,000

$301,000

$5,000,000

$25,000,000

$9,090,000

$5,448,000

$20,749,000

$3,000,000,000

$34,000,000

$4,021,000

$45,220,000

$20,000,000

$3,981,000

$75,000,000

$3,000,000

$30,000,000

$2,000,000

$361,172,000

$11,730,000

Investment Amount

$17,000,000

11/23/2011

8/13/2010

9/22/2011

9/22/2011

2/15/2011

9/22/2011

4/4/2012

9/30/2010

9/22/2011

9/22/2011

9/22/2011

9/1/2011

2/10/2010

8/18/2011

6/17/2009

9/29/2010

8/24/2011

8/25/2011

4/19/2012

$2,795,000

$15,540,000

$3,700,000

$500,000

$76,458,000

$2,117,000

$12,119,637

$541,000

$1,505,000

$1,697,000

$5,450,000

$7,579,200,000

$15,000,000

$10,000,000,000

$5,000,000

$12,500,000

$9,090,000

$5,448,000

$3,000,000,000

$17,000,000

12/22/2010

6/17/2009

$1,742,850

$45,220,000

$20,000,000

$3,981,000

$75,000,000

$2,000,000

$361,172,000

Capital Repayment
Amount (Loss)6

12/3/2010

3/10/2010

8/25/2011

5/19/2010

5/13/2009

8/3/2011

4/22/2009

Capital
Repayment
Date

$—

$—

$—

$—

$—

$—

$—

$—

$—

$—

$—

$—

$—

$—

$—

$12,500,000

$—

$—

$—

$—

$17,000,000

$—

$—

$—

$—

$—

$—

$—

Remaining
Capital Amount

N/A

9/22/2011

9/22/2011

4/4/2012

9/30/2010

9/22/2011

9/22/2011

9/22/2011

9/1/2011

4/29/2010

8/18/2011

7/22/2009

4/19/2012

8/5/2009

N/A

9/8/2010

8/25/2011

5/19/2010

3/11/2010

8/3/2011

12/15/2009

Final
Disposition
Date

R

R

R

R

R

R

R

R

A

R

R

R

R

R

R

R

A

R

A

Note15

N/A

$777,000

$185,000

$106,000

$40,000

$27,000

$34,000

$51,000

$273,000

$320,277,984

$750,000

$1,100,000,000

$792,783

$136,000,000

N/A

$4,753,985

$1,000,000

$199,000

$6,559,066

$100,000

$9,449,981

Final Disposition
Proceeds

$0.25

$14.00

$5.05

$10.83

$61.11

$95.86

$17.00

$19.28

$8.40

$4.00

$21.95

$26.64

$9.43

$40.39

$11.48

Stock
Price as of
6/29/2012

$977,440

$4,036,268

$190,215

$6,107,966

$2,336,116

$501,325

$192,415

$10,619,167

$713,950

$346,491

$1,952,236

$223,208

$1,195,973

$1,284,722

$1,024,491

$215,183

$282,299

$882,900

$751,752

$421,066,667

$1,387,480

$1,830,292

$318,055,555

$53,710

$411,806

$3,734,375

$1,219,575

$662,083

$3,766,127

$95,416,667

$3,940,694

$169,834

$2,813,689

$2,234,500

$295,308

$1,218,750

$146,242

$3,233,333

$284,611

$7,925,719

$690,832

Dividends/
Interest Paid to
Treasury

Continued on next page

3,098,341

554,330

571,821

54,705

225,904

116,538

274,784

461,538

Current
Outstanding
Warrants

254
Appendix D I Transaction Detail I July 25, 2012

$10,300,000
$14,400,000

Preferred Stock w/ Warrants

Preferred Stock w/ Warrants
Preferred Stock w/ Warrants
Subordinated Debentures
w/ Exercised Warrants
Preferred Stock w/ Warrants
Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants
Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Exercised Warrants
Preferred Stock w/ Warrants

Union Bank & Trust Company, Oxford, NC2,50

Union Bank & Trust Company, Oxford, NC2,10a,49

Union Financial Corporation, Albuquerque, NM

Union First Market Bankshares Corporation
(First Market Bank, FSB), Bowling Green, VA18

Union First Market Bankshares Corporation (Union
Bankshares Corporation), Bowling Green, VA18

United American Bank, San Mateo, CA2

United Bancorp, Inc., Tecumseh, MI91

United Bancorporation of Alabama, Inc.,
Atmore, AL30

United Bank Corporation, Barnesville, GA

United Community Banks, Inc., Blairsville, GA

United Financial Banking Companies, Inc.,
Vienna, VA2,49

Unity Bancorp, Inc., Clinton, NJ

Universal Bancorp, Bloomfield, IN2

University Financial Corp, Inc., St. Paul, MN3,8,30

US Metro Bank, Garden Grove, CA2

Uwharrie Capital Corp, Albemarle, NC2

Valley Commerce Bancorp, Visalia, CA2

Valley Community Bank, Pleasanton, CA2

Valley Financial Corporation, Roanoke, VA

Valley Financial Group, Ltd., 1st State Bank,
Saginaw, MI2,49

Valley National Bancorp (State Bancorp, Inc.)68

Valley National Bancorp, Wayne, NJ

Veritex Holdings, Inc.
(Fidelity Resources Company), Dallas, TX2,40

Village Bank and Trust Financial Corp,
Midlothian, VA

Virginia Commerce Bancorp, Arlington, VA

Virginia Company Bank, Newport News, VA2,10

Vision Bank - Texas, Richardson, TX2

VIST Financial Corp., Wyomissing, PA

W.T.B. Financial Corporation, Spokane, WA2,50

Wachusett Financial Services, Inc., Clinton, MA2,10

Wainwright Bank & Trust Company, Boston, MA

Washington Banking Company, Oak Harbor, WA

Washington Federal, Inc., Seattle, WA

5/1/2009

12/18/2009

12/29/2009

2/6/2009

12/19/2008

2/20/2009

1/16/2009

12/23/2008

5/22/2009

12/5/2008

1/16/2009

12/5/2008

5/22/2009

6/19/2009

2/6/2009

12/23/2008

1/30/2009

1/9/2009

12/12/2008

12/18/2009

12/5/2008

11/14/2008

6/26/2009

5/1/2009

12/12/2008

6/12/2009

4/24/2009

12/19/2008

1/30/2009

12/11/2009

12/19/2008

1/16/2009

11/14/2008

8

Preferred Stock

Umpqua Holdings Corp., Portland, OR

2,10

UCBH Holdings, Inc., San Francisco, CA14

11/14/2008

Preferred Stock w/ Warrants

$1,300,000

Preferred Stock w/ Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants

$200,000,000

$26,380,000

$22,000,000

$12,000,000

$110,000,000

$25,000,000

$1,500,000

Preferred Stock w/ Warrants

$4,700,000

Preferred Stock w/ Exercised Warrants

$71,000,000

$14,738,000

$3,000,000

$300,000,000

$36,842,000

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Warrants

$16,019,000

$5,500,000

$7,700,000

Preferred Stock w/ Exercised Warrants
Preferred Stock w/ Exercised Warrants

$10,000,000

$2,861,000

$11,926,000

$9,900,000

$20,649,000

$5,658,000

$180,000,000

$20,600,000

$8,700,000

$59,000,000

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants

Subordinated Debentures

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Exercised Warrants

$2,179,000

Preferred Stock w/ Exercised Warrants
$33,900,000

$2,997,000

$3,194,000

$214,181,000

$298,737,000

Preferred Stock

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

$8,950,000

$50,236,000

$6,599,000,000

11/14/2008

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

$12,000,000

$215,000,000

U.S. Century Bank, Miami, FL2

U.S. Bancorp, Minneapolis, MN

11/14/2008

Preferred Stock w/ Warrants
Preferred Stock w/ Exercised Warrants

UBT Bancshares, Inc., Marysville, KS2,49

Two Rivers Financial Group, Burlington, IA2,49

5/29/2009

Investment Amount

1/30/2009

Trustmark Corporation, Jackson, MS

11/21/2008

Investment Description

(Continued)

8/7/2009

Institution

Purchase
Date

CPP TRANSACTION DETAIL, AS OF 6/30/2012

5/27/2009

1/12/2011

11/24/2009

4/4/2012

9/15/2011

8/25/2011

$200,000,000

$26,380,000

$22,000,000

$3,000,000

$110,000,000

$3,000,000

$100,000,000

12/23/2009

$75,000,000
$125,000,000

6/3/2009
9/23/2009

$36,842,000

$1,300,000

$7,700,000

12/14/2011

9/22/2011

3/21/2012

$11,926,000

$2,658,000

7/30/2010

$3,000,000

9/15/2011

$10,300,000

$16,750,221

$59,000,000

$35,595,000

$2,997,000

$3,194,000

$214,181,000

$8,950,000

$6,599,000,000

$12,000,000

$215,000,000

Capital Repayment
Amount (Loss)6

12/15/2010

9/3/2010

6/13/2012

11/18/2009

12/7/2011

9/22/2011

9/22/2011

2/17/2010

8/11/2011

6/17/2009

9/1/2011

12/9/2009

Capital
Repayment
Date

$—

$—

$—

$9,000,000

$—

$—

$—

$100,000,000

$225,000,000

$—

$—

$—

$—

$—

$2,658,000

$—

$—

$—

$—

$—

$—

$—

$—

$—

$—

$—

Remaining
Capital Amount

3/9/2010

3/2/2011

12/16/2009

9/15/2011

8/25/2011

5/18/2010

9/22/2011

3/21/2012

N/A

9/15/2011

12/23/2009

N/A

N/A

9/22/2011

3/31/2010

8/11/2011

7/15/2009

9/1/2011

12/30/2009

Final
Disposition
Date

A

R

R

R

R

A

R

R

R

R

R

R

R

R

R

R

Note15

$15,388,874

$1,625,000

$568,700

$5,500,000

$150,000

$5,421,615

$65,000

$385,000

N/A

$283,000

$450,000

N/A

N/A

$160,000

$4,500,000

$450,000

$139,000,000

$600,000

$10,000,000

Final Disposition
Proceeds

$16.89

$13.90

$11.62

$8.43

$1.25

$10.60

$1.70

$11.00

$3.95

$4.50

$6.00

$16.94

$8.57

$9.01

$14.45

$13.16

$32.16

$15.10

$24.48

Stock
Price as of
6/29/2012

$5,361,111

$2,623,344

$1,023,611

$1,544,026

$15,736,874

$4,256,944

$250,019

$725,020

$12,158,750

$1,318,232

$353,796

$12,979,167

$5,572,353

$124,775

$2,781,430

$629,476

$1,318,401

$1,849,972

$432,678

$1,022,886

$1,608,159

$3,556,217

$708,964

$31,018,750

$3,600,991

$872,639

$3,527,704

$—

$2,695,972

$5,239,859

$272,969

$680,292

$13,475,555

$7,509,920

$1,234,912

$745,312

$195,220,417

$1,475,133

$11,287,500

Dividends/
Interest Paid to
Treasury

Continued on next page

2,696,203

499,029

488,847

344,742

219,908

108,264

311,492

7,847,732

Current
Outstanding
Warrants

Transaction detail I Appendix D I July 25, 2012

255

WashingtonFirst Bankshares, Inc., Reston, VA2,13,49

Waukesha Bankshares, Inc., Waukesha, WI2,10

Webster Financial Corporation, Waterbury, CT

1/30/2009

6/26/2009

11/21/2008

West Bancorporation, Inc., West Des Moines, IA

Westamerica Bancorporation, San Rafael, CA

Western Alliance Bancorporation, Las Vegas, NV

Western Community Bancshares, Inc.,
Palm Desert, CA2

Western Illinois Bancshares Inc., Monmouth, IL2

Western Illinois Bancshares Inc., Monmouth, IL2,10a

Western Reserve Bancorp, Inc, Medina, OH2

White River Bancshares Company, Fayetteville, AR2

Whitney Holding Corporation, New Orleans, LA45

Wilshire Bancorp, Inc., Los Angeles, CA76

Wintrust Financial Corporation, Lake Forest, IL

Worthington Financial Holdings, Inc., Huntsville, AL2

WSFS Financial Corporation79

Yadkin Valley Financial Corporation, Elkin, NC

Yadkin Valley Financial Corporation, Elkin, NC

York Traditions Bank , York, PA2,50

Zions Bancorporation, Salt Lake City, UT

12/5/2008

12/31/2008

2/13/2009

11/21/2008

12/23/2008

12/23/2008

12/29/2009

5/15/2009

2/20/2009

12/19/2008

12/12/2008

12/19/2008

5/15/2009

1/23/2009

1/16/2009

7/24/2009

4/24/2009

11/14/2008

Total Purchase Amount *

Preferred Stock w/ Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Exercised Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Warrants

($2,794,703,500)
$10,889,606,012

Total Treasury CPP Investment
Outstanding

$204,943,827,320

$191,259,517,808

$700,000,000

$4,871,000

$47,435,299

$250,000,000

$57,766,994

$300,000,000

140,000,000

Total Losses***

3/28/2012

7/14/2011

3/28/2012

12/22/2010

3/28/2012

6/3/2011

9/27/2011

41,863,000

$41,863,000

9/2/2009
11/18/2009

$36,000,000

$75,000,000

6/29/2011

9/9/2009

$25,000,000,000

$200,000,000

12/23/2009

$100,000,000

12/29/2010

$100,000,000

$6,633,000

$6,842,000

Capital Repayment
Amount (Loss)6

10/13/2010

3/3/2010

8/4/2011

8/4/2011

Capital
Repayment
Date

Total
Capital
Repayment
Amount **

$1,400,000,000

$4,871,000

$13,312,000

$36,000,000

$52,625,000

$2,720,000

$250,000,000

$62,158,000

$300,000,000

$4,700,000
$16,800,000

Preferred Stock w/ Exercised Warrants

$4,567,000

$6,855,000

Preferred Stock w/ Exercised Warrants

Preferred Stock

Preferred Stock w/ Exercised Warrants

$7,290,000

$140,000,000

Preferred Stock w/ Warrants
Preferred Stock w/ Exercised Warrants

$83,726,000

$36,000,000

$75,000,000

$25,000,000,000

$400,000,000

$5,625,000

Preferred Stock w/ Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Warrants

Preferred Stock w/ Exercised Warrants

$6,633,000

$6,842,000

Investment Amount

7/14/2011

2/8/2011

6/20/2012

6/3/2011

11/18/2011

11/18/2011

8/31/2011

12/23/2009

5/20/2010

6/2/2011

8/4/2011

N/A

Final
Disposition
Date

R

A

R

R

P

P

R

R

A

A

R

Note15

Total Warrant Proceeds****

$700,000,000

$—

$—

$—

$—

$—

$—

$—

$41,863,000

$—

$—

$—

$—

$200,000,000

$300,000,000

$—

$—

Remaining
Capital Amount

$7,677,500,194

$244,000

$25,600,564

$760,000

$6,900,000

$415,000

$878,256

$700,000

$950,000

$840,374,892

$20,388,842

$332,000

N/A

Final Disposition
Proceeds

$19.42

$2.65

$40.41

$35.50

$5.47

$27.00

$9.36

$47.19

$9.51

$21.26

$33.44

$21.66

Stock
Price as of
6/29/2012

5,789,909

385,990

273,534

175,105

246,698

Current
Outstanding
Warrants

$240,625,000

$590,022

$4,782,227

$8,405,558

$370,600

$25,104,167

$10,282,176

$36,833,333

$1,589,583

$768,450

$1,811,199

$554,083

$19,950,000

$2,755,981

$4,495,000

$2,854,167

$1,440,972,222

$36,944,444

$855,616

$1,510,318

Dividends/
Interest Paid to
Treasury

Continued on next page

* Total purchase amount includes the capitalization of accrued dividends referred to in Notes 20, 22, 28 and 29.
** Total repaid includes (i) the amount of $25 billion applied as repayment under the Capital Purchase Program from the total proceeds of $31.85 billion received pursuant to the sales of Citigroup, Inc. common stock as of December 6, 2010 (see Note 23 and “Capital Purchase Program - Citigroup
Common Stock Disposition” on following pages) and (ii) the amount of $355,724,000 repaid by institutions that have completed exchanges for investments under the Community Development Capital Initiative (see Note 30 and “Community Development Capital Initiative” on following pages).
*** Losses include (i) the investment amount for institutions that have completed bankruptcy proceedings (see Notes 16 and 19) and (ii) the investment amount less the amount of final proceeds for institutions where Treasury has completed a sale (see Notes 26, 32, 33, 34, 38, 39, 42, 46, 47, 59, 64,
74, 75, 76, 77, 78, 79), but excludes investment amounts for institutions that have pending receivership or bankruptcy proceedings (see Notes 14, 25, 51, 52, 53, 54, 55, 56, 57, 61, 63, 70, and 71).
**** Total warrant proceeds includes $7,566,000, which represents the total amount of warrants that were included in nine institutions’ exchange into the CDCI program (see Note 30a).

Notes: Numbers may not total due to rounding. Data as of 6/30/2012. Numeric notes were taken verbatim from Treasury’s 6/27/2012 Transactions Report. All amounts and totals reflect cumulative receipts from inception through 6/30/2012.

Wells Fargo & Company, San Francisco, CA

WesBanco, Inc., Wheeling, WV

10/28/2008

49

Preferred Stock

WashingtonFirst Bankshares, Inc. (WashingtonFirst
Bank), Reston, VA2,10a,49

10/30/2009
Preferred Stock w/ Exercised Warrants

Investment Description

(Continued)

Institution

Purchase
Date

CPP TRANSACTION DETAIL, AS OF 6/30/2012

256
Appendix D I Transaction Detail I July 25, 2012

Continued on next page

This transaction was included in previous Transaction Reports with Merrill Lynch & Co., Inc. listed as the qualifying institution and a 10/28/2008 transaction date, footnoted to indicate that settlement was deferred pending merger. The purchase of Merrill Lynch by Bank of America was completed on
1/1/2009, and this transaction under the CPP was funded on 1/9/2009.
	The warrant disposition proceeds amount are stated pro rata in respect of the CPP investments in Bank of America Corporation that occurred on 10/28/2008 and 1/9/2009. The total net disposition proceeds from CPP warrants on 3/3/2010 was $305,913,040, consisting of $183,547,824 and
$122,365,216. Proceeds from the disposition of TIP warrants on 3/3/2010 appear on a following page of this report.
2
Privately-held qualified financial institution; Treasury received a warrant to purchase additional shares of preferred stock (unless the institution is a CDFI), which it exercised immediately.
3
To promote community development financial institutions (CDFIs), Treasury does not require warrants as part of its investment in certified CDFIs when the size of the investment is $50 million or less.
3a
Treasury cancelled the warrants received from this institution due to its designation as a CDFI.
4
Repayment pursuant to Title VII, Section 7001(g) of the American Recovery and Reinvestment Act of 2009.
5
Redemption pursuant to a qualified equity offering.
6
This amount does not include accrued and unpaid dividends, which must be paid at the time of capital repayment.
7
The proceeds associated with the disposition of this investment do not include accrued and unpaid dividends.
8
Subchapter S corporation; Treasury received a warrant to purchase additional subordinated debentures (unless the institution is a CDFI), which it exercised immediately.
9
In its qualified equity offering, this institution raised more capital than Treasury’s original investment, therefore, the number of Treasury’s shares underlying the warrant was reduced by half.
10
This institution participated in the expansion of CPP for small banks.
10a
This institution received an additional investment through the expansion of CPP for small banks.
11
	Treasury made three separate investments in Citigroup Inc. (Citigroup) under the CPP, Targeted Investment Program (TIP), and Asset Guarantee Program (AGP) for a total of $49 billion. On 6/9/2009, Treasury entered into an agreement with Citigroup to exchange up to $25 billion of Treasury’s investment in
Fixed Rate Cumulative Perpetual Preferred Stock, Series H (CPP Shares) “dollar for dollar” in Citigroup’s Private and Public Exchange Offerings. On 7/23/2009 and 7/30/2009, Treasury exchanged a total of $25 billion of the CPP shares for Series M Common Stock Equivalent (“Series M”) and a warrant to
purchase shares of Series M. On 9/11/2009, Series M automatically converted to 7,692,307,692 shares of common stock and the associated warrant terminated on receipt of certain shareholder approvals.
12
On 8/24/2009, Treasury exchanged its series C preferred stock issued by Popular, Inc. for a like amount of non tax-deductible trust preferred securities issued by Popular Capital Trust III, administrative trustee for Popular, Inc. Popular, Inc. paid a $13 million exchange fee in connection with this transaction.
13
This institution converted to a bank holding company structure and Treasury exchanged its securities for a like amount of securities that comply with the CPP terms applicable to bank holding companies. The institution in which Treasury’s original investment was made is shown in parentheses.
14
	As of the date of this report, this institution is in bankruptcy proceedings.
15
	For final disposition of warrants, “R” represents proceeds from a repurchase of warrants by the financial institution in a negotiated sale pursuant to the terms of the related securities purchase agreement, “A” represents the proceeds to Treasury, after underwriting fees, from a sale by Treasury in a registered
public offering of the warrants issued by the financial institution, and “P” represents the proceeds to Treasury, before placement expenses, from a sale by Treasury in a private auction principally involving qualified institutional buyers.
16
	On 12/10/2009, the bankruptcy reorganization plan of CIT Group Inc. became effective and Treasury’s preferred stock and warrant investment were extinguished and replaced by contingent value rights (CVRs). On 2/8/2010, the CVRs expired without value as the terms and conditions for distribution of
common shares to holders of CVRs were not met.
17
On 12/11/2009, Treasury exchanged its series A preferred stock issued by Superior Bancorp, Inc. for a like amount of non tax-deductible Trust Preferred Securities issued by Superior Capital Trust II, administrative trustee for Superior Bancorp.
18
	On 2/1/2010, following the acquisition of First Market Bank (First Market) by Union Bankshares Corporation (the acquiror), the preferred stock and exercised warrants issued by First Market on 2/6/2009 were exchanged for a like amount of securities of the acquiror in a single series but with a blended
dividend rate equivalent to those of Treasury’s original investment.
19
On 2/11/2010, Pacific Coast National Bancorp dismissed its bankruptcy proceedings with no recovery to any creditors or investors, including Treasury, and the investment was extinguished.
20
	On 3/8/2010, Treasury exchanged its $84,784,000 of preferred stock in Midwest Banc Holdings, Inc. (MBHI) for $89,388,000 of mandatory convertible preferred Stock (MCP), which is equivalent to the initial investment amount of $84,784,000, plus $4,604,000 of capitalized previously accrued and unpaid
dividends. Subject to the fulfillment by MBHI of the conditions related to its capital plan, the MCP may be converted to common stock.
21
	On 3/30/2010, Treasury exchanged its $7,500,000 of subordinated debentures in GulfSouth Private Bank for an equivalent amount of preferred stock, in connection with its conversion from a Subchapter S corporation, that comply with the CPP terms applicable to privately held qualified financial institutions.
22
	On 4/16/2010, Treasury exchanged its $72,000,000 of preferred stock in Independent Bank Corporation (Independent) for $74,426,000 of mandatory convertible preferred Stock (MCP), which is equivalent to the initial investment amount of $72,000,000, plus $2,426,000 of capitalized previously accrued
and unpaid dividends. Subject to the fulfillment by Independent of the conditions related to its capital plan, the MCP may be converted to common stock.
23
	Treasury received Citigroup common stock pursuant to the June 2009 Exchange Agreement between Treasury and Citigroup which provided for the exchange into common shares of the preferred stock that Treasury purchased in connection with Citigroup’s participation in the Capital Purchase Program (see
note 11). On 4/26/2010, Treasury gave Morgan Stanley & Co. Incorporated (Morgan Stanley) discretionary authority as its sales agent to sell subject to certain parameters up to 1,500,000,000 shares of the common stock from time to time during the period ending on 6/30/2010 (or on completion of
the sale). Completion of the sale under this authority occurred on 5/26/2010. On 5/26/2010, Treasury again gave Morgan Stanley discretionary authority as its sales agent to sell subject to certain parameters up to 1,500,000,000 shares of the common stock from time to time during the period ending
on 6/30/2010 (or on completion of the sale). Completion of the sale under this authority occurred on 6/30/2010. On 7/23/2010, Treasury again gave Morgan Stanley discretionary authority as its sales agent to sell subject to certain parameters up to 1,500,000,000 shares of the common stock from
time to time during the period ending on 9/30/2010 (or on completion of the sale). Completion of the sale under this authority occurred on 9/30/2010. On 10/19/2010, Treasury gave Morgan Stanley & Co. Incorporated (Morgan Stanley) discretionary authority, as its sales agent, to sell subject to certain
parameters up to 1,500,000,000 shares of common stock from time to time during the period ending on 12/31/2010 (or upon completion of the sale), which plan was terminated on 12/6/2010. All such sales were generally made at the market price. On 12/6/2010, Treasury commenced an underwritten
public offering of its remaining 2,417,407,607 shares. See “Capital Purchase Program - Citigroup, Inc., Common Stock Disposition” on following page for the actual number of shares sold by Morgan Stanley, the weighted average price per share and the total proceeds to Treasury from all such sales during
those periods.
24
	On 8/26/2010, Treasury completed the exchange of its $303,000,000 of preferred stock in Sterling Financial Corporation (Sterling) for a like amount of mandatorily convertible preferred Stock (MCP), pursuant to the terms of the exchange agreement between Treasury and Sterling entered into on
4/29/2010. Since Sterling also fulfilled the conversion conditions set forth in the Certificate of Designations for the MCP, including those related to its capital plan, Treasury’s $303,000,000 of MCP was subsequently, as of 8/26/2010, converted into 378,750,000 shares of common stock.
25
On 8/20/2010, Sonoma Valley Bank, Sonoma, CA, the banking subsidiary of Sonoma Valley Bancorp, was closed by the California Department of Financial Institutions, and the Federal Deposit Insurance Corporation (FDIC) was named Receiver.
26
	On 9/30/2010, Treasury completed the sale of all preferred stock and warrants issued by South Financial Group, Inc. to Toronto-Dominion Bank (TD) at an aggregate purchase price of $130,179,218.75 for the preferred stock and $400,000 for the warrants, pursuant to the terms of the agreement between
Treasury and TD entered into on 5/18/2010.
27
On 6/30/2010, Treasury exchanged $46,400,000 of its series A preferred stock in First Merchants Corporation for a like amount of non tax-deductible Trust Preferred Securities issued by First Merchants Capital Trust III.
28
	On 7/20/2010, Treasury completed the exchange of its $400,000,000 of preferred stock in First BanCorp for $424,174,000 of mandatorily convertible preferred Stock (MCP), which is equivalent to the initial investment amount of $400,000,000, plus $24,174,000 of capitalized previously accrued and
unpaid dividends. On 10/7/2011, following the completion of the conversion conditions set forth in the Certificate of Designations for the MCP, all of Treasury’s MCP was converted into 32,941,797 shares of common stock of First BanCorp. Treasury received all accrued and previously unpaid dividends on
the MCP at the time of the conversion. First BanCorp has agreed to have a Treasury observer attend board of directors meetings.
29
	On 8/31/2010, following the completion of the conditions related to Pacific Capital Bancorp’s (Pacific Capital) capital plan, Treasury exchanged its $180,634,000 of preferred stock in Pacific Capital for $195,045,000 of mandatorily convertible preferred Stock (MCP), which is equivalent to the initial
investment amount of $180,634,000, plus $14,411,000 of capitalized previously accrued and unpaid dividends. On 9/27/2010, following the completion of the conversion conditions set forth in the Certificate of Designations for the MCP, all of Treasury’s MCP was converted into 360,833,250 shares of
common stock of Pacific Capital. Pacific Capital has agreed to have Treasury observers attend board of directors meetings.
30
This institution qualified to participate in the Community Development Capital Initiative (CDCI), and has completed an exchange of its Capital Purchase Program investment for an investment under the terms of the CDCI program. See “Community Development Capital Initiative” below.
30a
	At the time of this institution’s exchange into the CDCI program, the warrant preferreds were included in the total amount of preferred stock exchanged for Treasury’s CDCI investment. Therefore this disposition amount does not represent cash proceeds to Treasury.
31
	On 9/30/2010, Treasury completed the exchange of its $80,347,000 of preferred stock in Hampton Roads Bankshares, Inc. (Hampton) for a like amount of mandatorily convertible preferred Stock (MCP), pursuant to the terms of the exchange agreement between Treasury and Hampton entered into on
8/12/2010. Since Hampton also fulfilled the conversion conditions set forth in the Certificate of Designations for the MCP, Treasury’s $80,347,000 of MCP was subsequently converted into 52,225,550 shares of common stock.
32
	On 9/30/2010, Treasury completed the sale of all preferred stock and warrants issued by TIB Financial Corp. to North American Financial Holdings, Inc. (NAFH) at an aggregate purchase price of $12,119,637.37 for the preferred stock and $40,000 for the warrants, pursuant to the terms of the agreement
between Treasury and NAFH entered into on 9/24/2010.
33
	On 3/4/2011, Treasury completed the sale to Community Bancorp LLC (“CBC”) of all preferred stock and warrants issued by Cadence Financial Corporation (“Cadence”) to Treasury for an aggregate purchase price of $39,014,062.50, pursuant to the terms of the agreement between Treasury and CBC
entered into on 10/29/2010.
34
	On 12/3/2010, Treasury completed the sale of all preferred stock (including the preferred stock received upon the exercise of warrants) issued by The Bank of Currituck (“Currituck”) to Treasury for an aggregate purchase price of $1,742,850, pursuant to the terms of the agreement between Treasury and
Currituck entered into on 11/5/2010.
35
	Treasury entered into an agreement on 1/28/2011 with North American Financial Holdings, Inc. for the sale of all preferred stock and warrants issued by Capital Bank Corporation to Treasury for an aggregate purchase price of $41,279,000. Since the conditions to closing of the sale were satisfied, the
closing of the sale also occurred on 1/28/2011.
36
	On 2/15/2011, Treasury completed the sale of all preferred stock (including the preferred stock received upon the exercise of warrants) issued by Treaty Oak Bancorp (“Treaty Oak”) to Treasury for (i) a cash payment of $500,000, (ii) the right to receive up to $150,000 in principal payments on a note
payable by Carlile Bancshares, Inc. in favor of Treaty Oak, and (iii) a newly issued warrant to purchase 3,098,341 shares of Treaty Oak common stock, pursuant to the terms of the agreement between Treasury and Treaty Oak entered into on 2/15/2011.
37
On 2/18/2011, Treasury completed the exchange of its $135,000,000 of preferred stock (including accrued and unpaid dividends thereon) in Central Pacific Financial Corp. for not less than 5,620,117 shares of common stock, pursuant to an exchange agreement dated 2/17/2011.
38
	On 3/9/2011, Treasury completed the sale of all subordinated debentures (including the subordinated debentures received upon the exercise of warrants) issued by FBHC Holding Company (“FBHC”) to Treasury for an aggregate purchase price of $650,000, pursuant to the terms of the agreement between
Treasury and FBHC entered into on 3/9/2011.
39
	On 5/31/2011, Treasury completed the sale of all preferred stock and warrants issued by First Community Bank Corporation of America (FCBCA) for an aggregate purchase price of (i) $7.20 million plus (ii) 72% of the remaining cash assets after giving effect to the payment of defined acquisition expenses,
debts, liabilities and distributions to other classes of security holders, pursuant to the terms of the agreement between Treasury and FCBCA entered into on 3/11/2011.
40
	As a result of the acquisition of Fidelity Resources Company (the acquired company) by Veritex Holdings, Inc. (the acquiror), the preferred stock and exercised warrants issued by the acquired company on 6/26/2009 were exchanged for a like amount of securities of the acquiror, pursuant to the terms of an
agreement among Treasury, the acquired company and the acquiror entered into on 3/23/2011.
41
	As a result of the acquisition of NC Bancorp, Inc. (the acquired company) by Metropolitan Bank Group, Inc. (the acquiror), Treasury exchanged $6,880,000 of its preferred stock in NC Bancorp, Inc. and $71,526,000 of its preferred stock in Metropolitan Bank Group, Inc. for $81,892,000 of a new series of
preferred stock in Metropolitan Bank Group, Inc., which is equivalent to the combined initial investment amount of $78,406,000 plus $3,486,000 of capitalized previously accrued and unpaid dividends, pursuant to the terms of an agreement among Treasury, the acquired company and the acquiror entered
into on 3/30/2011. Exercised warrants were also exchanged at the time of the agreement.
42
	On 5/3/2011, Treasury completed the sale of all First Federal Bancshares of Arkansas, Inc. preferred stock and warrants held by Treasury to Bear State Financial Holdings, LLC (“Bear State”) for an aggregate purchase price of $6,000,000.00, pursuant to the terms of the agreement between Treasury and
Bear State entered into on 5/3/2011.
43
	On 5/13/2011, Treasury completed the sale of all Wilmington Trust Corporation preferred stock held by Treasury to M&T Bank Corporation (“M&T”) for an aggregate purchase price of $330,000,000.00 plus accrued dividends and exchanged its Wilmington Trust Corporation warrant for an equivalent warrant
issued by M&T Bank Corporation, pursuant to the terms of the agreement between Treasury and M&T entered into on 5/13/2011.
44
	On 7/5/2011, Treasury completed a transaction with Harris Financial Corp., a wholly-owned subsidiary of Bank of Montreal (“BMO”), for the sale of (i) all Marshall & Ilsley Corporation (“M&I”) Preferred Stock held by Treasury for a purchase price of $1,715,000,000 plus accrued dividends and (ii) the Treasuryheld M&I Warrant for an amount equal to $3,250,000, pursuant to the terms of the agreement between Treasury and BMO entered into on 5/16/2011.
45
	On 6/3/2011, Treasury completed the sale of all Whitney Holding Corporation preferred stock and the related warrant held by Treasury to Hancock Holding Company (“HHC”) for an aggregate purchase price equal to (i) the par amount of the preferred stock ($300,000,000) plus accrued and unpaid dividends
thereon and (ii) $6,900,000 for the warrant, pursuant to the terms of the agreement between Treasury and HHC entered into on 6/3/2011.

1b

1a 

Transaction detail I Appendix D I July 25, 2012

257

	On 6/22/2011, Treasury completed the sale of 2,850,000 shares of common stock at $12.590625 per share (which represents the $12.75 public offering price less underwriting discounts) for net proceeds of $35,883,281.25 pursuant to an underwriting agreement executed on 6/17/2011. On
4/4/2012, Treasury completed the sale of all of Treasury’s remaining 2,770,117 shares of Central Pacific Financial Corp. common stock at $13.01 per share (which represents the $13.15 public offering price less underwriting discounts) for net proceeds of $36,039,222.17, pursuant to an underwriting
agreement executed on 3/29/2012.
47
	On 6/30/2011, Treasury completed the sale of all Cascade Financial Corporation preferred stock held by Treasury and the related warrant to Opus Acquisition, Inc. (“Opus”) for an aggregate purchase price of $16,250,000.00, pursuant to the terms of the agreement between Treasury and Opus entered into
on 6/28/2011.
49
Repayment pursuant to Title VII, Section 7001(g) of the American Recovery and Reinvestment Act of 2009 using proceeds received in connection with the institution’s participation in the Small Business Lending Fund.
50
Repayment pursuant to Title VII, Section 7001(g) of the American Recovery and Reinvestment Act of 2009 — part of the repayment amount obtained from proceeds received in connection with the institution’s participation in the Small Business Lending Fund.
51
On 11/5/2010, Pierce Commercial Bank, Tacoma, WA, the banking subsidiary of Pierce County Bancorp, was closed by the Washington Department of Financial Institutions, and the Federal Deposit Insurance Corporation (FDIC) was named Receiver.
52
On 11/12/2010, Tifton Banking Company, Tifton, GA, was closed by the Georgia Department of Banking & Finance, and the Federal Deposit Insurance Corporation (FDIC) was named Receiver.
53
On 3/11/2011, Legacy Bank, Milwaukee, WI, the banking subsidiary of Legacy Bancorp, Inc., was closed by the State of Wisconsin Department of Financial Institutions, and the Federal Deposit Insurance Corporation (FDIC) was named Receiver.
54
On 4/15/2011, Superior Bank, Birmingham, AL, the banking subsidiary of Superior Bancorp Inc., was closed by the Office of Thrift Supervision, and the Federal Deposit Insurance Corporation (FDIC) was named Receiver.
55
On 7/15/2011, First Peoples Bank, Port Saint Lucie, Florida, the banking subsidiary of FPB Bancorp, Inc., was closed by the Florida Office of Financial Regulation, and the Federal Deposit Insurance Corporation (FDIC) was named Receiver.
56
On 7/15/2011, One Georgia Bank, Atlanta, GA was closed by the State of Georgia Department of Banking & Finance, and the Federal Deposit Insurance Corporation (FDIC) was named Receiver.
57
On 7/29/2011, Integra Bank, National Association, Evansville, Indiana, the banking subsidiary of Integra Bank Corporation, was closed by the Office of the Comptroller of the Currency, which appointed the Federal Deposit Insurance Corporation (FDIC) as receiver.
58
	On 10/21/2011, Treasury completed the exchange of all FNB United Corp. (“FNB United”) preferred stock and warrants held by Treasury for 108,555,303 shares of FNB United common stock and an amended and restated warrant, pursuant to the terms of the agreement between Treasury and FNB United
entered into on 8/12/2011.
59
	On 9/7/2011, Treasury completed the sale of all Green Bankshares, Inc. preferred stock held by Treasury and the related Warrant to North American Financial Holdings, Inc. (“NAFH”) for an aggregate purchase price of $68,700,000.00, pursuant to the terms of the agreement between Treasury and NAFH
entered into on 9/6/2011.
60
	As a result of the acquisition of Berkshire Bancorp, Inc. (the acquired company) by Customers Bancorp, Inc. (the acquiror), the preferred stock and exercised warrants issued by the acquired company on 6/12/2009 were exchanged for a like amount of securities of the acquiror plus accrued and previously
unpaid dividends, pursuant to the terms of an agreement among Treasury, the acquired company and the acquiror entered into on 9/16/2011.
61
On 9/23/2011, Citizens Bank of Northern California, Nevada City, California, the banking subsidiary of Citizens Bancorp, was closed by the California Department of Financial Institutions, which appointed the Federal Deposit Insurance Corporation (FDIC) as receiver.
62
Repayment pursuant to Title VII, Section 7001(g) of the American Recovery and Reinvestment Act of 2009 in connection with the institution’s participation in the Small Business Lending Fund, which occurred at a later date.
63
On 10/14/2011, Country Bank, Aledo, Illinois, the banking subsidiary of CB Holding Corp., was closed by the Illinois Department of Financial and Professional Regulation - Division of Banking, which appointed the Federal Deposit Insurance Corporation (FDIC) as receiver.
64
On 10/21/2011, Treasury completed the sale of all Santa Lucia Bancorp preferred stock and warrants held by Treasury to CCI One Acquisition Corporation (“CCI”) for an aggregate purchase price of $2,800,000.00, pursuant to the terms of the agreement between Treasury and CCI entered into on 10/20/2011.
65
	As a result of a reincorporation transaction whereby Crescent Financial Corporation (CFC) was merged into Crescent Financial Bancshares, Inc. (CFB), the preferred stock and warrant issued by CFC on 1/9/2009 were exchanged for a like amount of securities of CFB, pursuant to the terms of an agreement
among Treasury, CFC and CFB entered into on 11/15/2011.
66
	As a result of the acquisition of Center Financial Corporation by BBCN Bancorp, Inc. (formerly Nara Bancorp, Inc.), the preferred stock and warrant issued by Center Financial Corporation were exchanged for a like amount of securities of BBCN Bancorp, Inc., pursuant to the terms of an agreement among
Treasury, Center Financial Corporation, and BBCN Bancorp, Inc. entered into on 11/30/2011.
67
	On 1/3/2012, Treasury completed (i) the sale to F.N.B. Corporation (“F.N.B.”) of all of the preferred stock that had been issued to Treasury by Parkvale Financial Corporation (“Parkvale”) for a purchase price of $31,762,000 plus accrued dividends and (ii) the exchange of the Parkvale warrant held by Treasury
for a like F.N.B. warrant, pursuant to the terms of the agreement between Treasury and F.N.B. entered into on 12/29/2011 in connection with the merger of Parkvale and F.N.B. effective 1/1/2012.
68
	As a result of the acquisition of State Bancorp, Inc. (the acquired company) by Valley National Bancorp (the acquiror), the warrant issued by the acquired company on 12/5/2008 was exchanged for a like security of the acquiror, pursuant to the terms of an agreement among Treasury, the acquired company
and the acquiror entered into on 1/1/2012.
69
	On 1/27/2012, pursuant to the terms of the merger of Regents Bancshares, Inc. (“Regents”) with Grandpoint Capital, Inc., Treasury received $13,214,858.00 (representing the par amount together with accrued and unpaid dividends thereon) in respect of the preferred stock (including that received from the
exercise of warrants) that had been issued to Treasury by Regents.
70
On 1/27/2012, Tennessee Commerce Bank, Franklin, TN, the banking subsidiary of Tennessee Commerce Bancorp, Inc., was closed by the Tennessee Department of Financial Institutions, and the Federal Deposit Insurance Corporation (FDIC) was named Receiver.
71
On 2/10/2012, SCB Bank, Shelbyville, Indiana, the banking subsidiary of Blue River Bancshares, Inc., was closed by the Office of the Comptroller of the Currency, which appointed the Federal Deposit Insurance Corporation (FDIC) as receiver.
72
	On 2/10/2012, Treasury entered into an agreement with Broadway Financial Corporation to exchange Treasury’s $15,000,000 of preferred stock for common stock. The exchange is subject to the fulfillment by Broadway Financial Corporation of certain conditions, including the satisfactory completion of a
capital plan.
73
	On 3/9/2012, Treasury completed the sale of all Mainline Bancorp, Inc. preferred stock and exercised warrants held by Treasury to 9th Street Holdings, Inc., a subsidiary of S&T Bancorp, Inc., for an aggregate purchase price of $4,725,000 plus accrued and unpaid dividends, pursuant to the terms of an
agreement among Treasury, 9th Street Holdings, Inc., and S&T Bancorp, Inc. entered into on 3/8/2012.
74
On 4/3/2012, Treasury completed the sale of 124,000 shares of Banner Corporation preferred stock at $884.82 per share (less underwriting discounts) for net proceeds of $108,071,914.80 plus accrued and unpaid dividends, pursuant to an underwriting agreement executed on 3/28/2012.
75
On 4/3/2012, Treasury completed the sale of 65,000 shares of First Financial Holdings, Inc. preferred stock at $873.51 per share (less underwriting discounts) for net proceeds of $55,926,477.75 plus accrued and unpaid dividends, pursuant to an underwriting agreement executed on 3/28/2012.
76
On 4/3/2012, Treasury completed the sale of 62,158 shares of Wilshire Bancorp, Inc. preferred stock at $943.51 per share (less underwriting discounts) for net proceeds of $57,766,994.16 plus accrued and unpaid dividends, pursuant to an underwriting agreement executed on 3/28/2012.
77
On 4/3/2012, Treasury completed the sale of 2,000 shares of Seacoast Banking Corporation of Florida preferred stock at $20,510.00 per share (less underwriting discounts) for net proceeds of $40,404,700.00 plus accrued and unpaid dividends, pursuant to an underwriting agreement executed on 3/28/2012.
78
On 4/3/2012, Treasury completed the sale of 57,000 shares of MainSource Financial Group, Inc. preferred stock at $931.11 per share (less underwriting discounts) for net proceeds of $52,277,170.95 plus accrued and unpaid dividends, pursuant to an underwriting agreement executed on 3/28/2012.
79
On 4/3/2012, Treasury completed the sale of 52,625 shares of WSFS Financial Corporation preferred stock at $915.11 per share (less underwriting discounts) for net proceeds of $47,435,298.79 plus accrued and unpaid dividends, pursuant to an underwriting agreement executed on 3/28/2012.
80
	On 4/13/2012, Treasury completed the sale of all Gateway Bancshares, Inc. preferred stock held by Treasury to First Volunteer Corporation (“First Volunteer”) for an aggregate purchase price of $6,300,000.00 plus accrued and unpaid dividends, pursuant to the terms of the agreement between Treasury
and First Volunteer entered into on 4/13/2012.
81
	On 4/20/2012, Treasury completed the sale of all The Connecticut Bank and Trust Company preferred stock held by Treasury to Berkshire Bank for an aggregate purchase price of $6,289,966.33 consisting of (a) (i) $5,448,000.00 for the preferred stock plus (ii) all accrued and unpaid dividends and (b)
$792,783.00 for the Warrant, pursuant to the terms of the agreement by and among Treasury, The Connecticut Bank and Trust Company, and Berkshire Bank entered into on 4/19/2012.
82
On 4/20/2012, Fort Lee Federal Savings Bank, FSB, Fort Lee, New Jersey, was closed by the Office of the Comptroller of the Currency, which appointed the Federal Deposit Insurance Corporation (FDIC) as receiver.
83
	On 4/24/2012, Treasury completed the sale of all Peoples Bancorporation, Inc. (“Peoples”) preferred stock held by Treasury to SCBT Financial Corporation (“SCBT”) for an aggregate purchase price of $13,293,000 plus accrued and unpaid dividends, pursuant to the terms of the agreement by and among
Treasury, Peoples, and SCBT entered into on 4/24/2012.
84
	On 4/20/2012, Treasury entered into an agreement with CIC Bancshares, Inc. (CIC) pursuant to which Treasury agreed to sell to CIC all Preferred Stock issued by Millennium Bancorp, Inc. (Millennium) to Treasury for an aggregate purchase price of (i) $2.904 million plus (ii) accrued and unpaid dividends on
the Preferred Stock as of the closing date. Closing of the sale is subject to certain conditions including completion of the acquisition and merger of Millennium by CIC.
85
On 6/19/2012, Treasury completed the sale of 52,000 shares of Ameris Bancorp preferred stock at $930.60 per share (less underwriting discounts) for net proceeds of $47,665,332.00 plus accrued and unpaid dividends, pursuant to an underwriting agreement executed on 6/13/2012.
86
On 6/19/2012, Treasury completed the sale of 104,823 shares of Taylor Capital Group preferred stock at $893.50 per share (less underwriting discounts) for net proceeds of $92,254,460.24 plus accrued and unpaid dividends, pursuant to an underwriting agreement executed on 6/13/2012.
87
On 6/19/2012, Treasury completed the sale of 30,000 shares of Farmers Capital Bank Corporation preferred stock at $869.17 per share (less underwriting discounts) for net proceeds of $21,594,228.79 plus accrued and unpaid dividends, pursuant to an underwriting agreement executed on 6/13/2012.
88
On 6/19/2012, Treasury completed the sale of 25,223 shares of LNB Bancorp Inc. preferred stock at $739.89 per share (less underwriting discounts) for net proceeds of $21,863,749.50 plus accrued and unpaid dividends, pursuant to an underwriting agreement executed on 6/13/2012.
89
On 6/19/2012, Treasury completed the sale of 37,000 shares of First Defiance Financial Corp. preferred stock at $962.66 per share (less underwriting discounts) for net proceeds of $35,084,143.70 plus accrued and unpaid dividends, pursuant to an underwriting agreement executed on 6/13/2012.
90
On 6/19/2012, Treasury completed the sale of 10,958 shares of First Capital Bancorp, Inc. preferred stock at $920.11 per share (less underwriting discounts) for net proceeds of $9,931,326.90 plus accrued and unpaid dividends, pursuant to an underwriting agreement executed on 6/13/2012.
91
On 6/19/2012, Treasury completed the sale of 20,600 shares of United Bancorp, Inc. preferred stock at $825.50 per share (less underwriting discounts) for net proceeds of $16,750,220.50 plus accrued and unpaid dividends, pursuant to an underwriting agreement executed on 6/13/2012.
92
On 6/27/2012, Treasury executed an underwriting agreement for the sale of 48,200 shares of Fidelity Southern Corporation preferred stock at $900.60 per share (less underwriting discounts) for net proceeds of $42,757,786.20 plus accrued and unpaid dividends.
93
On 6/27/2012, Treasury executed an underwriting agreement for the sale of 25,054 shares of Peoples Bancorp of North Carolina, Inc. preferred stock at $933.36 per share (less underwriting discounts) for net proceeds of $23,033,635.42 plus accrued and unpaid dividends.
94
On 6/27/2012, Treasury executed an underwriting agreement for the sale of 23,184 shares of First Citizens Banc Corp preferred stock at $906.00 per share (less underwriting discounts) for net proceeds of $20,689,633.44 plus accrued and unpaid dividends.
95
On 6/27/2012, Treasury executed an underwriting agreement for the sale of 45,000 shares of MetroCorp Bancshares, Inc. preferred stock at $981.17 per share (less underwriting discounts) for net proceeds of $43,490,360.25 plus accrued and unpaid dividends.
96
On 6/27/2012, Treasury executed an underwriting agreement for the sale of 32,538 shares of Pulaski Financial Corp preferred stock at $888.00 per share (less underwriting discounts) for net proceeds of $28,460,337.84 plus accrued and unpaid dividends.
97
On 6/27/2012, Treasury executed an underwriting agreement for the sale of 33,000 shares of Firstbank Corporation preferred stock at $941.01 per share (less underwriting discounts) for net proceeds of $30,587,530.05 plus accrued and unpaid dividends.
98
On 6/27/2012, Treasury executed an underwriting agreement for the sale of 17,299 shares of Southern First Bancshares, Inc. preferred stock at $904.00 per share (less underwriting discounts) for net proceeds of $15,403,721.56 plus accrued and unpaid dividends.

Sources: Treasury, Transactions Report, 6/27/2012; Dividends and Interest Report, 7/11/2012; Treasury, response SIGTARP data call, 7/9/2012; Bloomberg, LP, accessed 7/2/2012.‑

46

258
Appendix D I Transaction Detail I July 25, 2012

4/26/2010 - 5/26/2010

5/26/2010 - 6/30/2010

7/23/2010 - 9/30/2010

10/19/2010 - 12/6/2010

12/6/2010

1

2

3

4

5

$4.35

$4.26

$3.91

$3.90

$4.12

Pricing Mechanism6

Proceeds7

$10,515,723,090
$31,852,354,471

Total Proceeds:

$4,967,921,811

$5,863,489,587

$4,322,726,825

$6,182,493,158

2,417,407,607

1,165,928,228

1,500,000,000

1,108,971,857

1,500,000,000

Number of Shares

Source: Treasury, Transactions Report, 6/27/2012.

Notes: Numbers may not total due to rounding. Data as of 6/30/2012. Numbered notes taken verbatim from 6/27/2012 Transactions Report.
1	
On 4/26/2010, Treasury gave Morgan Stanley & Co. Incorporated (Morgan Stanley) discretionary authority, as its sales agent, to sell subject to certain
parameters up to 1,500,000,000 shares of common stock from time to time during the period ending on 6/30/2010 (or upon completion of the sale).
Completion of the sale under this authority occurred on 5/26/2010.
2	
On 5/26/2010, Treasury gave Morgan Stanley & Co. Incorporated (Morgan Stanley) discretionary authority, as its sales agent, to sell subject to certain
parameters up to 1,500,000,000 shares of common stock from time to time during the period ending on 6/30/2010 (or upon completion of the sale).
Completion of the sale under this authority occurred on 6/30/2010.
3 
On 7/23/2010, Treasury gave Morgan Stanley & Co. Incorporated (Morgan Stanley) discretionary authority, as its sales agent, to sell subject to certain
parameters up to 1,500,000,000 shares of common stock from time to time during the period ending on 9/30/2010 (or upon completion of the sale).
Completion of the sale under this authority occured on 9/30/2010.
4	
On 10/19/2010, Treasury gave Morgan Stanley & Co. Incorporated (Morgan Stanley) discretionary authority, as its sales agent, to sell subject to certain
parameters up to 1,500,000,000 shares of common stock from time to time during the period ending on 12/31/2010 (or upon completion of the sale),
which plan was terminated on 12/6/2010.
5	
On 12/6/2010, Treasury commenced an underwritten public offering of its remaining 2,417,407,607 shares. Closing of the offering is subject to the
fulfillment of certain closing conditions.
6	
The price set forth is the weighted average price for all sales of Citigroup, Inc. common stock made by Treasury over the course of the
corresponding period.
7	
Amount represents the gross proceeds to Treasury.

Date

Note

CPP - CITIGROUP, INC. COMMON STOCK DISPOSITION, AS OF 6/30/2012

Table D.2

Transaction detail I Appendix D I July 25, 2012

259

Buffalo Cooperative Federal Credit Union, Buffalo, NY

Butte Federal Credit Union, Biggs, CA

Carter Federal Credit Union, Springhill, LA

9/24/2010

9/24/2010

9/29/2010

Community First Guam Federal Credit Union, Hagatna, GU

Community Plus Federal Credit Union, Rantoul, IL

Cooperative Center Federal Credit Union, Berkeley, CA

D.C. Federal Credit Union, Washington, DC

East End Baptist Tabernacle Federal Credit Union, Bridgeport, CT

Episcopal Community Federal Credit Union, Los Angeles, CA

Fairfax County Federal Credit Union, Fairfax, VA

Faith Based Federal Credit Union, Oceanside, CA

Fidelis Federal Credit Union, New York, NY

9/29/2010

9/29/2010

9/24/2010

9/29/2010

9/24/2010

9/29/2010

9/29/2010

9/29/2010

9/24/2010

9/29/2010

9/29/2010

1

1, 2

First Eagle Bancshares, Inc., Hanover Park, IL

First Legacy Community Credit Union, Charlotte, NC

9/17/2010

9/29/2010

1

Lafayette Bancorp, Inc., Oxford, MS

Kilmichael Bancorp, Inc., Kilmichael, MS

9/3/2010

9/29/2010

Independent Employers Group Federal Credit Union, Hilo, HI

9/29/2010

1

IBW Financial Corporation, Washington, DC

9/3/2010

IBC Bancorp, Inc., Chicago, IL

9/10/2010

Hope Federal Credit Union, Jackson, MS

9/17/2010

1

Hill District Federal Credit Union, Pittsburgh, PA

9/29/2010

1, 2

Guaranty Capital Corporation, Belzoni, MS

7/30/2010

1

Genesee Co-op Federal Credit Union, Rochester, NY

9/17/2010

Greater Kinston Credit Union, Kinston, NC

Gateway Community Federal Credit Union, Missoula, MT

9/24/2010

9/29/2010

Freedom First Federal Credit Union, Roanoke, VA

9/29/2010

5

First Vernon Bancshares, Inc., Vernon, AL

9/29/2010

1

First M&F Corporation, Kosciusko, MS

9/29/2010

1

First Choice Bank, Cerritos, CA

9/24/2010

1

First American International Corp., Brooklyn, NY

8/13/2010

1

Community Bancshares of Mississippi, Inc., Brandon, MS

Community Bank of the Bay, Oakland, CA

9/17/2010

2a

Citizens Bancshares Corporation, Atlanta, GA

8/13/2010

CFBanc Corporation, Washington, DC

Brooklyn Cooperative Federal Credit Union, Brooklyn, NY

9/30/2010

9/17/2010

Brewery Credit Union, Milwaukee, WI

9/24/2010

Carver Bancorp, Inc, New York, NY

Border Federal Credit Union, Del Rio, TX

9/29/2010

8/27/2010

Bethex Federal Credit Union, Bronx, NY

Bancorp of Okolona, Inc., Okolona, MS

9/29/2010

BankAsiana, Palisades Park, NJ

Bainbridge Bancshares, Inc., Bainbridge, GA

9/24/2010

9/29/2010

Atlantic City Federal Credit Union, Lander, WY

9/24/2010

9/29/2010

American Bancorp of Illinois, Inc., Oak Brook, IL

9/17/2010

BancPlus Corporation, Ridgeland, MS

Alternatives Federal Credit Union, Ithaca, NY

9/24/2010

9/29/2010

Name of Institution

Purchase Date

1

1, 3

1, 2

Note

Seller

Preferred Stock

Subordinated Debentures

Subordinated Debentures

Preferred Stock

Subordinated Debentures

Subordinated Debentures

Subordinated Debentures

Subordinated Debentures

Subordinated Debentures

Subordinated Debentures

Subordinated Debentures

Subordinated Debentures

Preferred Stock

Preferred Stock

Subordinated Debentures

Subordinated Debentures

Preferred Stock

Preferred Stock

Subordinated Debentures

Subordinated Debentures

Subordinated Debentures

Subordinated Debentures

Subordinated Debentures

Subordinated Debentures

Subordinated Debentures

Subordinated Debentures

Subordinated Debentures

Preferred Stock

Preferred Stock

Preferred Stock

Preferred Stock

Preferred Stock

Common Stock

Subordinated Debentures

Subordinated Debentures

Subordinated Debentures

Subordinated Debentures

Subordinated Debentures

Subordinated Debentures

Subordinated Debentures

Preferred Stock

Preferred Stock

Subordinated Debentures

Preferred Stock

Subordinated Debentures

Subordinated Debentures

Subordinated Debentures

Investment Description

CDCI PROGRAM TRANSACTION DETAIL, AS OF 6/30/2012

Table D.3

$4,551,000

$­—

$­—

$6,000,000

$4,205,000

$­—

$­—

$14,000,000

$­—

$­—

$­—

$­—

$6,245,000

$30,000,000

$­—

$7,875,000

$5,146,000

$17,000,000

$­—

$­—

$­—

$­—

$­—

$­—

$­—

$­—

$­—

$1,747,000

$54,600,000

$­—

$7,462,000

$­—

$18,980,000

$­—

$­—

$­—

$­—

$­—

$­—

$­—

$­—

$50,400,000

$­—

$­—

$­—

$­—

$­—

Amount from CPP

$­—

$­—

$­—

$­—

$3,881,000

$­—

$­—

$­—

$­—

$­—

$­—

$­—

$­—

$­—

$­—

$­—

$­—

$­—

$­—

$­—

$­—

$­—

$­—

$­—

$­—

$­—

$­—

$2,313,000

$­—

$4,379,000

$­—

$­—

$­—

$­—

$­—

$­—

$­—

$­—

$­—

$­—

$­—

$30,514,000

$­—

$­—

$­—

$­—

$­—

Additional Investment

Purchase Details

$4,551,000

$3,154,000

$698,000

$6,000,000

$8,086,000

$4,520,000

$100,000

$14,000,000

$350,000

$300,000

$1,657,000

$9,278,000

$6,245,000

$30,000,000

$1,000,000

$7,875,000

$5,146,000

$17,000,000

$14,000

$30,000

$8,044,000

$100,000

$7,000

$1,522,000

$2,799,000

$450,000

$2,650,000

$4,060,000

$54,600,000

$11,841,000

$­—

$5,781,000

$18,980,000

$6,300,000

$1,000,000

$145,000

$300,000

$1,096,000

$3,260,000

$502,000

$5,250,000

$80,914,000

$3,297,000

$3,372,000

$2,500,000

$5,457,000

$2,234,000

Investment Amount

Par

Continued on next page

$148,160.33

$22,723.78

$204,000.00

$421,258.14

$150,164.44

$3,255.56

$777,583.33

$10,714.44

$9,966.67

$54,404.83

$302,050.44

$15,959.44

$976,666.67

$32,555.56

$405,518.75

$168,960.33

$171,888.89

$455.78

$976.67

$264,111.33

$3,255.56

$227.89

$49,549.56

$91,900.50

$14,650.00

$87,008.33

$111,875.56

$1,777,533.33

$407,479.22

$192,057.67

$446,507.39

$205,100.00

$32,833.33

$4,760.83

$9,750.00

$35,985.33

$106,131.11

$16,342.89

$170,916.67

$2,634,200.22

$166,370.28

$110,714.00

$82,083.33

$281,005.18

$73,349.67

Dividend/Interest
Paid to Treasury

$166,215.80

$­—

Remaining
Investment Amount

Par

4/10/20125

Date

Disposition Details

Par

Par

Par

Par

Par

Par

Par

Par

Par

Par

Par

Par

Par

Par

Par

Par

Par

Par

Par

Par

Par

Par

Par

Par

Par

Par

Par

Par

Par

Par

Par

Par

Par

Par

Par

Par

Par

Par

Par

Par

Par

Par

Par

Par

Par

Pricing
Mechanism

260
Appendix D I Transaction Detail I July 25, 2012

Subordinated Debentures

University Financial Corp, Inc., St. Paul, MN

UNO Federal Credit Union, New Orleans, LA

Vigo County Federal Credit Union, Terre Haute, IN

Virginia Community Capital, Inc., Christiansburg, VA

7/30/2010

9/24/2010

9/29/2010

9/24/2010

Subordinated Debentures

Subordinated Debentures

Subordinated Debentures

Subordinated Debentures

Preferred Stock
Subordinated Debentures

UNITEHERE Federal Credit Union, (Workers United Federal Credit
Union), New York, NY

Subordinated Debentures

United Bancorporation of Alabama, Inc., Atmore, AL

Union Settlement Federal Credit Union, New York, NY

9/29/2010

Subordinated Debentures

9/3/2010

Union Baptist Church Federal Credit Union, Fort Wayne, IN

9/24/2010

Subordinated Debentures

Preferred Stock

9/29/2010

Tulane-Loyola Federal Credit Union, New Orleans, LA

Subordinated Debentures

$569,723,000

TOTAL TREASURY COMMUNITY DEVELOPMENT INITIATIVE (CDCI) INVESTMENT AMOUNT

$570,073,000

Total Purchase
Amount

Par

Par

Par

Par

Par

Par

Par

Par

Par

Par

Par

Par

Par

Par

Par

Par

Par

Par

Par

Par

Par

Par

Par

Par

Par

Par

Par

Par

Par

Par

Par

Par

Par

Par

Par

Par

Par

Par

Par

Date

Remaining
Investment Amount

$350,000

$1,915,000

$1,229,000

$743,000

$22,115,000

$57,000

$10,300,000

$295,000

$10,000

$424,000

$2,795,000

$1,600,000

$75,000

$7,922,000

$17,123,000

$15,750,000

$1,100,000

$1,709,000

$33,800,000

$2,646,000

$22,000,000

$17,910,000

$2,828,000

$31,000

$2,500,000

$9,734,000

$273,000

$6,784,000

$153,000

$3,000,000

$1,091,000

$350,000

$325,000

$283,000

$10,336,000

$­—

$11,735,000

$898,000

$11,334,000

$435,000

Investment Amount

$­—

$­—

$­—

$10,189,000

$­—

$­—

$­—

$­—

$­—

$­—

$­—

$­—

$­—

$12,123,000

$­—

$­—

$­—

$22,800,000

$­—

$4,000,000

$­—

$­—

$­—

$­—

$­—

$­—

$­—

$­—

$­—

$­—

$­—

$­—

$­—

$4,836,000

$­—

$­—

$­—

$5,689,000

$­—

Additional Investment

Pricing
Mechanism

Total Capital Repayment
Amount

$­—

$­—

$­—

$11,926,000

$­—

$10,300,000

$­—

$­—

$­—

$2,795,000

$­—

$­—

$­—

$5,000,000

$15,750,000

$­—

$­—

$11,000,000

$­—

$18,000,000

$17,910,000

$­—

$­—

$­—

$9,734,000

$­—

$6,784,000

$­—

$3,000,000

$­—

$­—

$­—

$­—

$­—

$5,500,000

$11,735,000

$­—

$5,645,000

$­—

Amount from CPP

Purchase Details

$62,875.83

$40,010.78

$24,395.17

$1,228,303.96

$1,855.67

$350,200.00

$9,603.89

$328.33

$13,921.33

$98,135.56

$52,533.33

$2,462.50

$399,752.92

$557,448.78

$512,750.00

$35,811.11

$55,636.64

$1,199,900.00

$86,142.00

$716,222.22

$583,070.00

$92,852.67

$1,009.22

$82,083.33

$316,895.78

$8,963.50

Sources: Treasury, Transactions Report, 6/27/2012; Treasury, Dividends and Interest Report, 7/11/2012.

$—

$5,023.50

$30,333.33

$35,518.11

$11,491.67

$10,580.56

$9,291.83

$349,754.22

$407,465.28

$29,484.33

$372,133.00

$14,282.50

Dividend/Interest
Paid to Treasury

Disposition Details

Notes: Numbers may not total due to rounding. Data as of 6/30/2012. Numbered notes are taken verbatim from Treasury’s 6/27/2012 Transactions Report.
1	
This institution qualified to participate in the Community Development Capital Initiative (CDCI), and has exchanged its Capital Purchase Program investment for an equivalent amount of investment with Treasury under the CDCI program terms.
2	
Treasury made an additional investment in this institution at the time it entered the CDCI program.
2a
Treasury made an additional investment in this institution after the time it entered the CDCI program.
3	
On 10/28/2011, Treasury completed the exchange of all Carver Bancorp, Inc. (“Carver”) preferred stock held by Treasury for 2,321,286 shares of Carver common stock, pursuant to the terms of the agreement between Treasury and Carver entered into on 6/29/2011. Accrued and
previously unpaid dividends were paid on the date of the exchange.
4
On 3/23/2012, Premier Bank, Wilmette, IL, the banking subsidiary of Premier Bancorp, Inc., was closed by the Illinois Department of Financial and Professional Regulation — Division of Banking, and the Federal Deposit Insurance Corporation (FDIC) was named Receiver.
5
Repayment pursuant to Section 5.2 of the CDCI Securities Purchase Agreement.

1, 2

1

Tri-State Bank of Memphis, Memphis, TN

9/24/2010

Tongass Federal Credit Union, Ketchikan, AK

9/24/2010

8/13/2010

Subordinated Debentures

Thurston Union of Low-Income People (TULIP) Cooperative Credit
Union, Olympia, WA

9/24/2010

1

Subordinated Debentures

The Magnolia State Corporation, Bay Springs, MS

9/29/2010

Preferred Stock

The First Bancshares, Inc., Hattiesburg, MS

9/29/2010

Preferred Stock

Subordinated Debentures

1, 2

State Capital Corporation, Greenwood, MS

Southside Credit Union, San Antonio, TX

9/29/2010

Southern Chautauqua Federal Credit Union, Lakewood, NY

9/29/2010

9/29/2010

Preferred Stock

Subordinated Debentures

Preferred Stock

Preferred Stock

Subordinated Debentures

Subordinated Debentures

Subordinated Debentures

Preferred Stock

Subordinated Debentures

Subordinated Debentures

Subordinated Debentures

Preferred Stock

Subordinated Debentures

Subordinated Debentures

Subordinated Debentures

Subordinated Debentures

Preferred Stock

Preferred Stock

Preferred Stock

Subordinated Debentures

Preferred Stock

Subordinated Debentures

Investment Description

(CONTINUED)

1

Southern Bancorp, Inc., Arkadelphia, AR

8/6/2010

Shreveport Federal Credit Union, Shreveport, LA

9/29/2010

1, 2

Security Federal Corporation, Aiken, SC

Security Capital Corporation, Batesville, MS

9/29/2010

Santa Cruz Community Credit Union, Santa Cruz, CA

9/24/2010

9/29/2010

Renaissance Community Development Credit Union, Somerset, NJ

9/29/2010

1, 2

PSB Financial Corporation, Many, LA

Pyramid Federal Credit Union, Tucson, AZ

9/29/2010

Prince Kuhio Federal Credit Union, Honolulu, HI

9/24/2010

9/24/2010

Premier Bancorp, Inc., Wilmette, IL

8/13/2010

Phenix Pride Federal Credit Union, Phenix City, AL

9/24/2010

Opportunities Credit Union, Burlington, VT

9/29/2010

PGB Holdings, Inc., Chicago, IL

Northeast Community Federal Credit Union, San Francisco, CA

9/24/2010

8/13/2010

North Side Community Federal Credit Union, Chicago, IL

1

1

1, 4

1

Neighborhood Trust Federal Credit Union, New York, NY

Mission Valley Bancorp, Sun Valley, CA

9/29/2010

9/24/2010

2a

9/24/2010

8/20/2010

1

M&F Bancorp, Inc., Durham, NC

Lower East Side People’s Federal Credit Union, New York, NY

9/24/2010

8/20/2010

Liberty Financial Services, Inc., New Orleans, LA

Liberty County Teachers Federal Credit Union, Liberty, TX

9/24/2010

9/24/2010

Name of Institution

Purchase Date

1

1, 2

Note

Seller

CDCI PROGRAM TRANSACTION DETAIL, AS OF 6/30/2012

Transaction detail I Appendix D I July 25, 2012

261

General
Motors,b,c
Detroit, MI

GMAC (Ally),
Detroit, MI
$1,250,000,000

$2,540,000,000

$884,024,131

$13,400,000,000

$2,000,000,000

$4,000,000,000

$360,624,198

Convertible
Preferred Stock
w/ Exercised
Warrants

Trust Preferred
Securities
w/ Exercised
Warrants

Purchase GMAC

12/30/2009 Purchase GMAC

12/30/2009 Purchase GMAC

General
12/29/2008 Purchase Motors
Debt Obligation
Corporation

General
Debt Obligation
12/31/2008 Purchase Motors
w/ Additional
Corporation Note

General
Debt Obligation
Purchase Motors
w/ Additional
Corporation Note

General
Debt Obligation
Purchase Motors
w/ Additional
Corporation Note

Debt Obligation
General
w/ Additional
Purchase Motors
Corporation Note

General
Debt Obligation
Purchase Motors
w/ Additional
Corporation Note

5/21/2009

4/22/2009

5/20/2009

5/27/2009

6/3/2009

$30,100,000,000

$7,500,000,000

Convertible
Preferred Stock
w/ Exercised
Warrants

8

6

5

4

2

22,
26

22

Debt left at Old GM

7/10/2009

$985,805,085

$7,072,488,605

Transfer of debt to
New GM

$360,624,198

Exchange for
preferred and
common stock in
New GM

7/10/2009

$4,000,000,000

Exchange for
preferred and
common stock in
New GM

$22,041,706,310

$2,000,000,000

Exchange for
preferred and
common stock in
New GM

7/10/2009

$13,400,000,000

Exchange for
preferred and
common stock in
New GM

$884,024,131

Exchange for
preferred and
common stock in
New GM

7/10/2009

7/10/2009

7/10/2009

7/10/2009

5/29/2009

Exchange for equity
interest in GMAC

$2,670,000,000

Exchange for
amended and
restated Trust
Preferred Securities

3/1/2011

$5,500,000,000

$3,000,000,000

$5,000,000,000

9

9

9

7

7

7

7

3

27

26

Motors
Liquidation
Company

General
Motors
Holdings
LLC

General
Motors
Company

General
Motors
Company

GMAC (Ally)

GMAC (Ally)

GMAC (Ally)

Amount Note Obligor

Partial conversion of
12/30/2010 preferred stock for
common stock

Partial conversion of
12/30/2009 preferred stock for
common stock

Exchange for
12/30/2009 convertible preferred
stock

Type

Exchange/Transfer/Other Details

Amount Note Date
$5,000,000,000

Description

Preferred Stock
w/ Exercised
Warrants

Seller

12/29/2008 Purchase GMAC

Date

Transaction
Type

Initial Investment

AIFP TRANSACTION DETAIL, AS OF 6/30/2012

Table D.4

29

11,
12

10,
11,
25

10,
11,
24

27

3,
26,
32

21,
22

Debt
Obligation

Debt
Obligation

Common
Stock

Preferred
Stock

Trust
Preferred
Securities

Common
Stock

Convertible
Preferred
Stock

Note Description

Amount/
Equity % Date

Partial
Repayment
Repayment

3/31/2010
4/20/2010

$1,000,000,000

12/18/2009

$50,000,000

$45,000,000
$15,887,795
$144,444
$18,890,294
$6,713,489

Partial
Repayment
Partial
Repayment
Partial
Repayment
Partial
Repayment
Partial
Repayment
Partial
Repayment

4/5/2011
5/3/2011
12/16/2011
12/23/2011
1/11/2012

$4,676,779,986

$1,000,000,000

$35,084,421

$360,624,198
Partial
Repayment

7/10/2009

1/21/2010

$1,761,495,577
Partial
Repayment

11/26/2010

Partial
Repayment

Common
Stock

Partial
Disposition25

Debt
Obligation

Debt
Obligation

Debt
Obligation

$756,714,508

$2,870,909,382

Dividend/
Interest Paid to
Treasury

Continued on next page

$849,169,063

$855,882,552

$874,772,846

$874,917,290

$890,805,085

Debt
Obligation
Debt
Obligation

$935,805,085

$—

$4,676,779,986

$5,676,779,986

$5,711,864,407

$6,711,864,407

32.04%

36.9%

$—

$—

Remaining
Investment
Amount/
Equity %

Debt
Obligation

N/A

Debt
Obligation

Debt
Obligation

Debt
Obligation

Debt
Obligation

Common
Stock

Partial
$11,743,303,903
Disposition25

N/A

11/18/2010

$985,805,085 3/31/2011

$7,072,488,605

60.8%

$2,667,000,000

Remaining
Investment
Description

N/A

Repayment

Disposition28

Type

Amount/
Proceeds

Payment or Disposition1

$2,139,406,778

$2,100,000,000 12/15/2010

$2,670,000,000 3/2/2011

73.8%

$5,937,500,000

Treasury Investment After
Exchange/Transfer/Other

262
Appendix D I Transaction Detail I July 25, 2012

Chrysler,
Auburn
Hills, MI

Chrysler
FinCo,
Farmington
Hills, MI

5/27/2009

Total Initial Investment Amount

New
Purchase
Chrysler

Debt Obligation
w/ Additional
Note, Zero
Coupon Note,
Equity

$81,344,932,551

$6,642,000,000

$­—

Debt Obligation
Purchase Old Chrysler w/ Additional
Note

5/20/2009

$1,888,153,580

Debt Obligation
Purchase Old Chrysler w/ Additional
Note

5/1/2009

$280,130,642

Debt Obligation
w/ Additional
Note

Purchase

4/29/2009

Chrysler
Holding

Purchase

4/29/2009

$­—

Purchase

1/2/2009

Debt Obligation
w/ Additional
Note

$1,500,000,000

Chrysler
Holding

Debt Obligation
w/ Additional
Note

Chrysler
FinCo

18

17

16

15

14

13

6/10/2009

4/30/2010

6/10/2009

Issuance of equity in
New Chrysler

Completion
of bankruptcy
proceeding; transfer
of collateral security
to liquidation trust

Transfer of debt to
New Chrysler

Type

Exchange/Transfer/Other Details

(CONTINUED)

Amount Note Date

$4,000,000,000

1/16/2009

Description

Seller

Debt Obligation
w/ Additional
Note

Purchase

Date

Chrysler
Holding

Transaction
Type

Initial Investment

AIFP TRANSACTION DETAIL, AS OF 6/30/2012

$­—

($1,888,153,580)

$500,000,000

23

19

19,
31

30

Chrysler
Group LLC

23

20

Common
equity

Debt
obligation
w/ additional
note & zero
coupon
note

Right to
recover
proceeds

Debt
obligation
w/ additional
note

Note Description

Chrysler
Group LLC

Old Carco
Liquidation
Trust

Chrysler
Holding

Amount Note Obligor

Repayment*

7/14/2009

$7,844,409

Proceeds
from sale of
collateral
Proceeds
from sale of
collateral

12/29/2010

4/30/2012

$100,000,000

Repayment* Zero Coupon
Note
5/24/2011

$­—

Additional
Note

$40,896,959,538

$1,171,263,942

$7,405,894

Dividend/
Interest Paid to
Treasury

Continued on next page

$34,894,279,433

$403,000,000

$­—

$­—

N/A

N/A

N/A

N/A

$­—

$­—

Total Treasury Investment Amount

N/A

N/A

Right to
recover
proceeds

Right to
recover
proceeds

Right to
recover
proceeds

Right to
recover
proceeds

N/A

N/A

$­—

$1,369,197,029

Debt
Obligation
w/ Additional
Note

N/A

$1,413,554,739

$1,464,690,823

Debt
Obligation
w/ Additional
Note
Debt
Obligation
w/ Additional
Note

$1,496,500,945

Remaining
Investment
Amount/
Equity %

Debt
Obligation
w/ Additional
Note

Remaining
Investment
Description

Payment or Disposition1

Total Payments

Additional Proceeds*

$560,000,000

$288,000,000

Repayment*
- Additional
Note
5/24/2011

Disposition

$2,065,540,000

Termination
of undrawn
facility31
5/24/2011

6.6% 7/21/2011

$5,076,460,000

Repayment Principal
$7,142,000,000 5/24/2011

$9,302,185

$9,666,784

$30,544,528

$280,130,642

Proceeds
from sale of
collateral

Proceeds
from sale of
collateral

Repayment

$1,900,000,000

$15,000,000

9/9/2010

N/A 5/10/2010

7/10/2009

Termination
and
settlement
payment20

Repayment

7/14/2009

$3,500,000,000 5/14/2010

$44,357,710

Partial
Repayment

6/17/2009

$1,369,197,029

$51,136,084

Partial
Repayment

$31,810,122

Partial
Repayment

4/17/2009

5/18/2009

$3,499,055

Partial
Repayment

Type

Amount/
Proceeds

3/17/2009

Amount/
Equity % Date

Treasury Investment After Exchange/
Transfer/Other

Transaction detail I Appendix D I July 25, 2012

263

For the purpose of this table, income (dividends and interest) are presented in aggregate for each AIFP participant.												
	According to Treasury, the GM warrant was “Exchanged out of bankruptcy exit.”														
This table includes AWCP transactions.

Sources: Treasury, Transactions Report, 6/27/2012; For Treasury’s web version of its Transactions Report, please refer to the following web address: www.treasury.gov/initiatives/financial-stability/briefing-room/reports/tarp-transactions/Pages/default.aspx; Treasury, Dividends and Interest Report, 7/11/2012.

c

b

a

3

2

1

Payment amount does not include accrued and unpaid interest on a debt obligation, which must be paid at the time of principal repayment.					
	Treasury committed to lend General Motors Corporation up to $1,000,000,000. The ultimate funding was dependent upon the level of investor participation in GMAC LLC’s rights offering. The amount has been updated to reflect the final level of funding.				
	Pursuant to its rights under the loan agreement with Old GM reported on 12/29/2008, Treasury exchanged its $884 million loan to Old GM for a portion of Old GM’s common equity interest in GMAC. Treasury held a 35.4% common equity interest in GMAC until the transactions reported on 12/30/2009. (See transactions
marked by orange line in the table above and footnote 22.)															
4
This transaction is an amendment to Treasury’s 12/31/2008 agreement with Old GM (the “Old GM Loan”), which brought the total loan amount to $15,400,000,000.									
5
This transaction was a further amendment to the Old GM Loan, which brought the total loan amount to $19,400,000,000.												
6
	This transaction was a further amendment to the Old GM Loan, which brought the total loan amount to $19,760,624,198. The $360,624,198 loan was used to capitalize GM Warranty LLC, a special purpose vehicle created by Old GM. On 7/10/2009, the principal amount was included in the $7.07 billion of debt assumed
by the new GM, as explained in footnote 10.																
7
On 7/10/2009, the principal amount outstanding under the Old GM Loan and interest accrued thereunder were extinguished and exchanged for privately placed preferred and common equity in New GM. (See green lines in the table above.)					
8
	Under the terms of the $33.3 billion debtor-in-possession credit agreement dated 6/3/2009 with Old GM (the “GM DIP Loan”), Treasury’s commitment amount was $30.1 billion. The remaining $2.2 billion of the financing was provided by Canadian government entities. As of 7/9/2009, $30.1 billion of funds had been
disbursed by Treasury.
9
	On 7/10/2009, Treasury and Old GM amended the GM DIP Loan, and the principal amount and interest accrued thereunder were extinguished and exchanged for privately placed preferred and common equity in New GM, except for (i) $7.07 billion, which was assumed by New GM as a new obligation under the terms of a
separate credit agreement between Treasury and New GM (see transactions marked by green lines in table above) and (ii) $986 million, which remained a debt obligation of Old GM.									
10
In total, for the exchange of the Old GM Loan and the GM DIP Loan (other than as explained in footnote 9), Treasury received $2.1 billion in preferred shares and 60.8% of the common shares of New GM. (See transactions marked by green lines in the table above.)			
11
	Pursuant to a corporate reorganization completed on or about 10/19/2009, the shareholders of New GM, including with respect to Treasury’s preferred and common stock, became shareholders of General Motors Holding Company (the ultimate parent company of New GM), which was renamed “General Motors Company”
on an equal basis to their shareholdings in New GM, and New GM was converted to “General Motors LLC”. General Motors LLC is a wholly owned subsidiary of General Motors Holdings LLC, and General Motors Holdings LLC is a wholly owned subsidiary of General Motors Company.		
12
Pursuant to a corporate reorganization completed on 10/19/2009, Treasury’s loan with New GM was assigned and assumed by General Motors Holdings LLC.									
13
The loan was funded through Chrysler LB Receivables Trust, a special purpose vehicle created by Chrysler FinCo. The amount of $1,500,000,000 represents the maximum loan amount. The loan was incrementally funded until it reached the maximum amount of $1.5 billion on 4/9/2009.		
14
This transaction was an amendment to Treasury’s 1/2/2009 agreement with Chrysler Holding. As of 4/30/2009, Treasury’s obligation to lend any funds committed under this amendment had terminated. No funds were disbursed.					
15
The loan was used to capitalize Chrysler Warranty SPV LLC, a special purpose vehicle created by Old Chrysler.												
16
	This transaction was set forth in a credit agreement with Old Chrysler fully executed on 5/5/2009 following a term sheet executed on 5/1/2009 and made effective on 4/30/2009. Treasury’s commitment was $3.04 billion of the total $4.1 billion debtor-in-possession credit facility (the “Chrysler DIP Loan”). As of
6/30/2009, Treasury’s commitment to lend under the Chrysler DIP Loan had terminated. The remaining principal amount reflects the final amount of funds disbursed under the Chrysler DIP Loan.								
17
	This transaction was an amendment to Treasury’s commitment under the Chrysler DIP Loan, which increased Treasury’s commitment by an amount $756,857,000 to a total of $3.8 billion under the Chrysler DIP Loan. As of 6/30/2009, Treasury’s obligation to lend funds committed under the Chrysler DIP Loan had
terminated.
18
	This transaction, first reported based on a term sheet fully executed on 5/27/2009 for an amount up to $6.943 billion, was set forth in a credit agreement with New Chrysler fully executed on 6/10/2009. Under the terms of the credit agreement, Treasury made a new commitment to New Chrysler of up to $6.642 billion.
The total loan amount is up to $7.142 billion including $500 million of debt assumed on 6/10/2009 from Chrysler Holding originally incurred under Treasury’s 1/2/2009 credit agreement with Chrysler Holding. The debt obligations are secured by a first priority lien on the assets of New Chrysler. When the sale to new
Chrysler was completed, Treasury acquired the rights to 9.85% of the common equity in new Chrysler.													
19
Pursuant to the agreement explained in footnote 18, $500 million of this debt obligation was assumed by New Chrysler. 										
20
	Under loan agreement, as amended on 7/23/2009, Treasury was entitled to proceeds Chrysler Holdco received from Chrysler FinCo equal to the greater of $1.375 billion or 40% of the equity value of Chrysler FinCo. Pursuant to a termination agreement dated 5/14/2010, Treasury agreed to accept a settlement payment
of $1.9 billion as satisfaction in full of all existing debt obligations (including additional notes and accrued and unpaid interest) of Chrysler Holdco, and upon receipt of such payment to terminate all such obligations.						
21
	Amount of the Treasury investment exchange includes the exercised warrants from Treasury’s initial investments.											
22
Under the terms of an agreement dated 12/30/2009, the convertible preferred shares will mandatorily convert to common stock under the conditions and the conversion price as set forth in the terms of the agreement.				
23
	On 4/30/2010, the Plan of Liquidation for the debtors of Old Chrysler approved by the respective bankruptcy court became effective (the “Liquidation Plan”). Under the Liquidation Plan, the loan Treasury had provided to Old Chrysler was extinguished without repayment, and all assets of Old Chrysler were transferred to a
liquidation trust. Treasury retained the right to recover the proceeds from the liquidation from time to time of the specified collateral security attached to such loan.										
24
	On 10/27/2010, Treasury accepted an offer by General Motors Company (GM) to repurchase all of the approximately $2.1 billion preferred stock at a price per share of $25.50, which is equal to 102% of the liquidation preference, subject to the closing of the proposed initial public offering of GM’s common stock. The
repurchase was completed on 12/15/2010.																	
25
	On 11/17/2010, Treasury agreed to sell 358,546,795 shares of common stock at $32.7525 per share (which represents the $33 public sale price less underwriting discounts and fees) pursuant to an underwriting agreement. Following settlement, the net proceeds to Treasury were $11,743,303,903. On 11/26/2010,
the underwriters exercised their option to purchase an additional 53,782,019 shares of common stock from Treasury at the same purchase price resulting in additional proceeds of $1,761,495,577. Treasury’s aggregate net proceeds from the sale of common stock pursuant to the underwriting agreement total
$13,504,799,480.
26
On 12/30/2010, Treasury converted $5,500,000,000 of the total convertible preferred stock then outstanding and held by Treasury (including exercised warrants) into 531,850 shares of common stock of Ally. Following this conversion, Treasury holds $5,937,500,000 of convertible preferred stock.
27
	On 3/1/2011, Treasury entered into an agreement with Ally Financial, Inc. (Ally) and certain other parties to amend and restate the $2,667,000,000 in aggregate liquidation preference of its Ally trust preferred securities so to facilitate a public underwritten offering. At the time of amendment and restatement, Treasury
received all outstanding accrued and unpaid dividends and a distribution fee of $28,170,000.														
28
	On 3/2/2011, Treasury entered into an underwritten offering for all of its Ally trust preferred securities, the proceeds of which were $2,638,830,000, which together with the distribution fee referred to in footnote 27, provided total disposition proceeds to Treasury of $2,667,000,000. This amount does not include the
accumulated and unpaid dividends on the trust preferred securities from the date of the amendment and restatement through but excluding the closing date that Treasury will receive separately at settlement.							
29
	On 3/31/2011, the Plan of Liquidation for Motors Liquidation Company (Old GM) became effective, Treasury’s $986 million loan to Old GM was converted to an administrative claim and the assets remaining with Old GM, including Treasury’s liens on certain collateral and other rights attached to the loan, were transferred to
liquidation trusts. On 12/15/2011, Old GM was dissolved, as required by the Plan of Liquidation. Treasury retained the right to recover additional proceeds; however, any additional recovery is dependent on actual liquidation proceeds and pending litigation.				
30
	In June 2009, Treasury provided a $6.6 billion loan commitment to Chrysler Group LLC and received a 9.9 percent equity ownership in Chrysler Group LLC (Chrysler). In January and April 2011, Chrysler met the first and second of three performance related milestones. As a result, Fiat’s ownership automatically increased
from 20% to 30%, and Treasury’s ownership was reduced to 8.6%. On 5/24/2011, Fiat, through the exercise of an equity call option, purchased an incremental 16% fully diluted ownership interest in Chrysler for $1.268 billion, reducing Treasury’s ownership to 6.6% (or 6.0% on a fully diluted basis). On 7/21/2011, Fiat,
through the exercise of an equity call option, purchased Treasury’s ownership interest for $500 million. In addition, Fiat paid $60 million to Treasury for its rights under an agreement with the UAW retirement trust pertaining to the trust’s shares in Chrysler.					
31
On 5/24/2011, Chrysler Group LLC terminated its ability to draw on the remaining $2.066 billion outstanding under this loan facility.											
32
On 11/1/2011, Treasury received a $201,345.42 pro-rata tax distribution on its common stock from Ally Financial, Inc. pursuant to the terms of the Sixth Amended and Restated Limited Liability Company Operating Agreement of GMAC LLC dated 5/22/2009.			

Notes: Numbers may not total due to rounding. Data as of 6/30/2012. Numbered notes were taken verbatim from Treasury’s 6/27/2012 Transaction Report. 											
GMAC refers to GMAC Inc., formerly known as GMAC LLC., and now known as Ally Financial, Inc. (“Ally”).
“Old GM” refers to General Motors Corporation, which is now known as Motors Liquidation Company.
“New GM” refers to General Motors Company, the company that purchased Old GM’s assets on 7/10/2009 in a sale pursuant to section 363 of the Bankruptcy Code. See also footnote 11.										
“Chrysler FinCo” refers to Chrysler Financial Services Americas LLC.																	
“Chrysler Holding” refers to CGI Holding LLC, the company formerly known as “Chrysler Holding LLC.”														
“Old Chrysler” refers to Old Carco LLC (fka Chrysler LLC).																
“New Chrysler” refers to Chrysler Group LLC, the company that purchased Old Chrysler’s assets on 6/10/2009 in a sale pursuant to section 363 of the Bankruptcy Code.										

264
Appendix D I Transaction Detail I July 25, 2012

4/9/2009

4/9/2009

1

2

Purchase

Chrysler Receivables SPV LLC
Wilmington, DE

$5,000,000,000

Purchase

Transaction
Type

GM Supplier Receivables LLC
Wilmington, DE

Institution Name

Debt Obligation w/
Additional Note

Debt Obligation w/
Additional Note

Investment
Description

$101,074,947

($500,000,000)

$413,076,735

7/8/20093

($1,000,000,000)

7/8/20093

Adjusted Total

N/A

$1,500,000,000

Adjustment
Amount

Adjustment
Date

Total Proceeds from Additional Notes

N/A

Pricing
Mechanism

$3,500,000,000

Investment
Amount

3/9/2010
4/7/2010

$123,076,735

Payment7

Repayment5

Payment6

3/4/2010
4/5/2010

Repayment5

2/11/2010

Debt Obligation w/
Additional Note

Partial
repayment

$56,541,893

Total Repayments

None

$413,076,735

$44,533,054

$123,076,735

None
Additional Note

$50,000,000

$100,000,000

$140,000,000

Amount

Additional Note

Debt Obligation w/
Additional Note

Remaining
Investment
Description

Type

Partial
repayment

11/20/2009

Date

Repayment4

$1,000,000,000

$290,000,000

$2,500,000,000

Adjusted
Investment
Amount

Adjustment Details

$5,787,176

$9,087,808

Dividend/Interest
Paid to Treasury

Purchase

Purchase

Citigroup Inc.

Bank of America
Corporation

1/16/2009

Transaction
Type

12/31/2008

Institution
Name

$40,000,000,000
$­—

$40,000,000,000
Total Treasury TIP Investment Amount

Total Investment

$20,000,000,000

$20,000,000,000

Par

Par

Pricing
Mechanism

Total Capital
Repayment

$20,000,000,000

$20,000,000,000

Investment
Amount

Preferred Stock w/ Warrants

Trust Preferred Securities w/
Warrants

Investment Description

Capital
Repayment
Amount

12/9/2009

12/23/2009

Capital
Repayment
Date2

Capital Repayment Details

$—

$—

Remaining
Capital
Amount

Warrants

Warrants

Remaining
Capital
Description

Treasury Investment
Remaining After Capital
Repayment

3/3/2010 A

1/25/2011 A

Final
Disposition
Date3

Warrants

Warrants

Final
Disposition
Description

Stock
Price

Total Warrant Proceeds

$8.18

$190,386,428 $27.41

Final
Disposition
Proceeds

$1,236,804,513

Final Disposition

$1,427,190,941

Outstanding
Warrant Shares

$1,435,555,556

$1,568,888,889

Dividends/
Interest Paid to
Treasury

Market and Warrant Data

Sources: Treasury, Transactions Report, 6/27/2012; Treasury, Dividends and Interest Report, 7/11/2012; Bloomberg LP, accessed 7/2/2012.

Notes: Numbers may not total due to rounding. Data as of 6/30/2012. Numbered notes were taken verbatim from Treasury’s 6/27/2012 Transactions Report.
1
	Treasury made three separate investments in Citigroup Inc. (“Citigroup”) under CPP, TIP, and AGP for a total of $49 billion. On 6/9/2009, Treasury entered into an agreement with Citigroup to exchange all of Treasury’s investments. On 7/30/2009, Treasury exchanged all of its Fixed Rate Cumulative
Perpetual Preferred Stock, Series I (TIP Shares) “dollar for dollar” for Trust Preferred Securities.
2
Repayment pursuant to Title VII, Section 7001 of the American Recovery and Reinvestment Act of 2009.
3
For final disposition of warrants, “R” represents proceeds from a repurchase of warrants by the financial institution, and “A” represents the proceeds to Treasury, after underwriting fees, from a sale by Treasury in a registered public offering of the warrants issued by the financial institution.

1

Note Date

Seller

TIP TRANSACTION DETAIL, AS OF 6/30/2012

Table D.6

Sources: Treasury, Transactions Report, 6/27/2012; Treasury, Dividends and Interest Report, 7/11/2012.

1

Notes: Numbers may not total due to rounding. Data as of 6/30/2012. Numbered notes were taken verbatim from Treasury’s 6/27/2012 Transactions Report.
	The loan was funded through GM Supplier Receivables, LLC, a special purpose vehicle created by General Motors Corporation. The amount of $3,500,000,000 represents the maximum loan amount. The loan will be incrementally funded. The credit agreement was fully executed on 4/9/2009, but was
made effective as of 4/3/2009. General Motors Company assumed GM Supplier Receivables LLC on 7/10/2009.
2
	The loan was funded through Chrysler Receivables SPV LLC, a special purpose vehicle created by Chrysler LLC. The amount of $1,500,000,000 represents the maximum loan amount. The loan will be incrementally funded. The credit agreement was fully executed on 4/9/2009, but was made effective as
of 4/7/2009. Chrysler Group LLC assumed Chrysler Receivables SPV LLC on 6/10/2009.
3
Treasury issued notice to the institution of the permanent reduced commitment on 7/8/2009; the reduction was effective on 7/1/2009.
4
Does not include accrued and unpaid interest due on the amount of principal repayment, which interest must be paid at the time of principal repayment.
5
	All outstanding principal drawn under the credit agreement was repaid.
6
	Treasury’s commitment was $2.5 billion (see note 3). As of 4/5/2010, Treasury’s commitment to lend under the credit agreement had terminated and the borrower has paid its obligations with respect to the Additional Note. The final investment amount reflects the total funds disbursed under the loan, all of
which have been repaid.
7
	Treasury’s commitment was $1 billion (see note 3). As of 4/7/2010, Treasury’s commitment to lend under the credit agreement had terminated and the borrower has paid its obligations with respect to the Additional Note. The final investment amount reflects the total funds disbursed under the loan, all of
which have been repaid.

Initial Total

Date

Note

Seller

ASSP TRANSACTION DETAIL, AS OF 6/30/2012

Table D.5

Transaction detail I Appendix D I July 25, 2012

265

1/16/2009

12/23/2009

1,2,3,
4,5

3

Citigroup Inc.

Citigroup Inc.,
New York, NY

Institution
Name

Termination

Guarantee

$5,000,000,000

($5,000,000,000)
$­—

Termination
Agreement

Total

Guarantee Limit

Master
Agreement

Transaction
Type
Description

Preferred
Stock w/
Warrants

Description

$4,034,000,000

Amount

Premium

Trust
Preferred
Securities w/
Warrants

Exchange
preferred
stock for trust
preferred
securities
Exchange
trust preferred
securities for
trust preferred
securities

6/9/2009

9/29/2010

Trust
Preferred
Securities w/
Warrants

Description

Type

Date

$2,246,000,000

$4,034,000,000

Amount

Exchange/Transfer/Other Details

Total Proceeds

Warrant
Auction

Disposition

9/30/2010
1/25/2011

Partial
cancellation
for early
termination
of guarantee

Payment
Type

12/23/2009

Date
Trust
Preferred
Securities w/
Warrants

$2,313,197,045

$67,197,045 None

$2,246,000,000 Warrants

($1,800,000,000)

Remaining
Payment Premium
Amount Description

Payment or Disposition

$—

$—

$2,234,000,000

Dividends/
Interest Paid
to Treasury

$27.41 $442,964,764

Stock
Price

Market and Warrant Data
Remaining Outstanding
Premium Warrant
Amount Shares

3/3/2009

1,2

TALF LLC, Wilmington, DE

Institution

Purchase

Transaction
Type
$20,000,000,000
$4,300,000,000

Total

Investment Amount

Debt Obligation w/ Additional Note

Investment Description
N/A

Pricing
Mechanism
7/19/2010

Adjusted
Investment Date

$4,300,000,000

Adjusted
Investment Amount

Sources: Treasury, Transactions Report, 6/27/2012.

Notes: Numbers may not total due to rounding. Data as of 6/30/2012. Numbered notes were taken verbatim from Treasury’s 6/27/2012 Transactions Report.
1
	The loan was funded through TALF LLC, a special purpose vehicle created by The Federal Reserve Bank of New York (“FRBNY”). The amount of $20,000,000,000 represents the maximum loan amount. The loan
will be incrementally funded.
2
	On 7/19/2010, Treasury, the FRBNY and TALF LLC entered into an amendment of the credit agreement previously entered into on 3/3/2009, which amendment reduced Treasury’s maximum loan amount to
$4,300,000,000.

Date

Note

Seller

TALF TRANSACTION DETAIL, AS OF 6/30/2012

Table D.8

Sources: Treasury, Transactions Report, 6/27/2012; Treasury, Dividends and Interest Report, 7/11/2012; Bloomberg LP, accessed 7/2/2012.

Notes: Numbers may not total due to rounding. Data as of 6/30/2012. Numbered notes were taken verbatim from Treasury’s 6/27/2012 Transactions Report.
1
In consideration for the guarantee, Treasury received $4.03 billion of preferred stock, which pays 8% interest.
2
	Treasury made three separate investments in Citigroup Inc. (“Citigroup”) under CPP, TIP, and AGP for a total of $49 billion. On 6/9/2009, Treasury entered into an agreement with Citigroup to exchange all of Treasury’s investments. On 7/30/2009, Treasury exchanged all of its Fixed Rate Cumulative Perpetual Preferred
Stock Series G (AGP Shares), received as premium with the AGP agreement, “dollar for dollar” for Trust Preferred Securities.
3
	On 12/23/2009, Treasury entered into a Termination Agreement with the other parties to the Master Agreement which served to terminate Treasury’s guarantee and obligations under the Master Agreement. In connection with the early termination of the guarantee, Treasury agreed to cancel $1.8 billion of the AGP
Trust Preferred Securities, and the Federal Deposit Insurance Corporation (FDIC) and Treasury agreed that, subject to the conditions set out in the Termination Agreement, the FDIC may transfer $800 million of Trust Preferred Securities to Treasury at the close of Citigroup’s participation in the FDIC’s Temporary Liquidity
Guarantee Program.
4
	On 9/29/2010, Treasury entered into an agreement with Citigroup Inc. to exchange $2,234,000,000 in aggregate liquidation preference of its trust preferred securities for $2,246,000,000 in aggregate liquidation preference of trust preferred securities with certain modified terms. At the time of exchange, Citigroup Inc.
paid the outstanding accrued and unpaid dividends.
5
On 9/30/2010, Treasury entered into underwritten offering of the trust preferred securities, the gross proceeds of which do not include accumulated and unpaid distributions from the date of the exchange through the closing date.

Date

Note

Initial Investment

AGP TRANSACTION DETAIL, AS OF 6/30/2012

Table D.7

266
Appendix D I Transaction Detail I July 25, 2012

Date

11/25/2008

4/17/2009

Date

1/14/2011

1/14/2011

1/14/2011

Note

1

2, 3

Note

4,7,8

5

6

Exchange

Transfer

Common Stock
(non-TARP)

Exchange
N/A

N/A

Par

Exchange

Exchange

Pricing
Mechanism

$69,835,000,000

$29,835,000,000

Preferred Stock
w/ Warrants
(Series F)

Initial Total

$40,000,000,000

Investment
Amount

Preferred Stock
w/ Warrants
(Series D)

Transaction
Type

Preferred Stock
(Series E)

Preferred Stock
(Series F)

Investment
Description

Purchase

Purchase

Recapitalization

AIG, New York, NY

AIG, New York, NY

Transaction
Type

Name of
Institution

Investment
Description

Purchase Details

Seller

Date

Final Disposition

Exchange

Transaction Type

Common Stock

$562,868,096

$924,546,133

$167,623,733

$3,375,328,432

$16,916,603,568

AIA Preferred Units

ALICO Junior Preferred Interests

$2,000,000,000

Preferred Stock (Series G)

Amount / Shares

Treasury Holdings Post-Recapitalization

See table below for
exchange/transfer details
in connection with the
recapitalization conducted on
1/14/2011.

4/17/2009

Date

Investment Description

Par

Par

Pricing
Mechanism

Exchange/Transfer Details

SSFI (AIG) PROGRAM TRANSACTION DETAIL, AS OF 6/30/2012

Table D.9

Total

5/7/2012

5/6/2012

$749,999,972

Partial
Disposition

$38,610,313,300

$4,999,999,993

$6,000,000,008

Partial
Disposition
3/8/2012

Partial
Disposition

$5,800,000,000

$44,941,843
Partial
Disposition

Payment

3/15/2012

$1,383,888,037

$2,009,932,072

$1,493,250,339

$1,521,632,096

$5,576,121,382

$971,506,765

$55,885,302

$2,153,520,000

$97,008,351

$55,833,333

$5,511,067,614

$185,726,192

$—

Proceeds

8

Pricing
Mechanism

Par

Pricing
Mechanism

Final Disposition

Proceeds

$40,000,000,000

Amount

5/24/2011

Payment

Payment

2/14/2011
3/8/2011

Payment

3/22/2012

Payment

9/2/2011

Payment

Payment

8/18/2011

3/15/2012

Payment

8/17/2011

Payment

Payment

3/15/2011

Payment

Payment

3/8/2011

3/8/2012

Payment

11/1/2011

Cancellation

2/14/2011

Transaction
Type

Transaction
Type

1

5/27/2011

Date

Warrants
(Series F)

Warrants
(Series E)

Investment

Preferred Stock w/
Warrants (Series E)

Investment Description

N/A

N/A

N/A

N/A

Par

Par

Par

Par

Par

Par

Par

Par

Par

Par

Par

Par

Par

N/A

Pricing
Mechanism

$32.09

$32.09

Stock Price

61%

1,059,616,82112

63%

1,084,206,98412

70%

1,248,141,41011

77%

1,455,037,962 9

$—

$—

$—10

Remaining Recap
Investment Amount,
Shares, or Equity %

150

2,686,938

Outstanding
Warrant Shares

Continued on next page

$641,275,676

$—

Dividends/Interest Paid
to Treasury

Transaction detail I Appendix D I July 25, 2012

267

Floating Rate SBA 7a security due 2021

Floating Rate SBA 7a security due 2029

Floating Rate SBA 7a security due 2026

Floating Rate SBA 7a security due 2035

Floating Rate SBA 7a security due 2034

9/14/2010

9/14/2010

9/28/2010

9/28/2010

Floating Rate SBA 7a security due 2024

8/31/2010

9/14/2010

Floating Rate SBA 7a security due 2020

8/31/2010

Floating Rate SBA 7a security due 2020

Floating Rate SBA 7a security due 2020

8/17/2010

Floating Rate SBA 7a security due 2020

Floating Rate SBA 7a security due 2019

8/17/2010

8/31/2010

Floating Rate SBA 7a security due 2020

8/17/2010

9/14/2010

Floating Rate SBA 7a security due 2034

Floating Rate SBA 7a security due 2020

6/17/2010

7/29/2010

Floating Rate SBA 7a security due 2033

5/25/2010

Floating Rate SBA 7a security due 2017

Floating Rate SBA 7a security due 2029

5/25/2010

7/29/2010

Floating Rate SBA 7a security due 2033

5/11/2010

Floating Rate SBA 7a security due 2034

Floating Rate SBA 7a security due 2035

5/11/2010

7/14/2010

Floating Rate SBA 7a security due 2020

5/11/2010

Floating Rate SBA 7a security due 2025

Floating Rate SBA 7a security due 2016

4/8/2010

7/14/2010

Floating Rate SBA 7a security due 2034

4/8/2010

Floating Rate SBA 7a security due 2034

Floating Rate SBA 7a security due 2022

3/19/2010

Floating Rate SBA 7a security due 2020

Floating Rate SBA 7a security due 2022

3/19/2010

6/17/2010

Floating Rate SBA 7a security due 2025

3/19/2010

7/14/2010

Investment Description

Purchase
Date

Coastal Securities

Coastal Securities

Coastal Securities

Coastal Securities

Shay Financial

Shay Financial

Coastal Securities

Shay Financial

Shay Financial

Coastal Securities

Coastal Securities

Shay Financial

Shay Financial

Coastal Securities

Shay Financial

Shay Financial

Coastal Securities

Coastal Securities

Coastal Securities

Coastal Securities

Coastal Securities

Coastal Securities

Coastal Securities

Coastal Securities

Coastal Securities

Coastal Securities

Coastal Securities

Coastal Securities

Coastal Securities

Institution Name

Purchase Details1

83165AFT6

83164K5M1

83164K5L3

83164K5F6

83165AFK5

83165AFC3

83164K5H2

83165AFA7

83165AEW0

83165AE91

83165AFB5

83165AEZ3

83164K4M2

83164K4E0

83165AE42

83164K4J9

83164K3Y7

83165AEP5

83165AEQ3

83165AEK6

83164K3B7

83165AED2

83164K2Q5

83165AEE0

83164KZH9

83165AD84

83165ADE1

83165ADC5

83164KYN7

CUSIP

UCSB TRANSACTION DETAIL, AS OF 6/30/2012

Table D.10

$11,482,421

$3,450,000

$5,741,753

$5,750,000

$8,050,000

$8,902,230

$6,900,000

$10,350,000

$9,272,482

$10,000,000

$5,000,000

$8,279,048

$9,719,455

$2,598,386

$13,183,361

$6,860,835

$6,004,156

$28,209,085

$34,441,059

$17,119,972

$8,417,817

$8,744,333

$12,898,996

$10,751,382

$8,900,014

$23,500,000

$8,030,000

$7,617,617

$4,070,000

Purchase Face
Amount3

113.838

110.875

110.5

106.5

110.759

111.584

105.875

112.476

110.515

110.821

110.088

110.198

106.75

108.438

111.86

108.505

106.625

112.028

110.785

109.553

110.125

110.798

109.42

106.806

107.5

110.502

108.875

109

107.75

Pricing
Mechanism

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

TBA or
PMF3

Sources: Treasury, Transactions Report, 6/27/2012; Treasury, Dividends and Interest Report, 7/11/2012; Bloomberg LP, accessed 7/2/2012.

12/30/2010

11/30/2010

11/30/2010

11/30/2010

11/30/2010

10/29/2010

11/30/2010

10/29/2010

9/29/2010

10/29/2010

10/29/2010

9/30/2010

10/29/2010

9/30/2010

9/30/2010

9/30/2010

9/30/2010

8/30/2010

8/30/2010

7/30/2010

7/30/2010

6/30/2010

6/30/2010

6/30/2010

4/30/2010

5/28/2010

3/24/2010

3/24/2010

3/24/2010

Settlement
Date

$13,109,070

$3,834,428

$6,361,173

$6,134,172

$8,940,780

$9,962,039

$7,319,688

$11,672,766

$10,277,319

$11,115,031

$5,520,652

$9,150,989

$10,394,984

$2,826,678

$14,789,302

$7,462,726

$6,416,804

$31,693,810

$38,273,995

$18,801,712

$9,294,363

$9,717,173

$14,151,229

$11,511,052

$9,598,523

$26,041,643

$8,716,265

$8,279,156

$4,377,249

Investment
Amount2, 3

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

TBA or
PMF3

Settlement Details

$6,535

$1,912

$3,172

$3,061

$4,458

$4,966

$3,652

$5,820

$5,123

$5,541

$2,752

$4,561

$5,187

$1,408

$7,373

$3,722

$3,200

$15,801

$19,077

$9,377

$4,635

$4,844

$7,057

$5,741

$4,783

$12,983

$4,348

$4,130

$2,184

Senior
Security
Proceeds4

1/24/2012

10/19/2011

1/24/2012

1/24/2012

1/24/2012

1/24/2012

1/24/2012

10/19/2011

9/20/2011

10/19/2011

10/19/2011

9/20/2011

6/21/2011

1/24/2012

6/21/2011

10/19/2011

6/21/2011

9/20/2011

6/21/2011

9/20/2011

6/7/2011

6/7/2011

6/7/2011

6/7/2011

6/7/2011

6/7/2011

6/21/2011

10/19/2011

6/21/2011

Trade Date

$889,646

$82,832

$1,433,872

$276,276

$996,133

$1,398,549

$663,200

$250,445

$868,636

$969,461

$419,457

$1,853,831

$188,009

$694,797

$478,520

$339,960

$348,107

$2,278,652

$1,784,934

$2,089,260

$246,658

$261,145

$328,604

$932,112

$2,357,796

$1,149,633

$2,022,652

$1,685,710

$902,633

Life-to-date
Principal
Received1, 8

$10,592,775

$3,367,168

$4,307,881

$5,473,724

$7,053,867

$7,503,681

$6,236,800

$10,099,555

$8,403,846

$9,030,539

$4,580,543

$6,425,217

$9,531,446

$1,903,407

$12,704,841

$6,520,875

$5,656,049

$25,930,433

$32,656,125

$15,030,712

$8,171,159

$8,483,188

$12,570,392

$9,819,270

$6,542,218

$22,350,367

$5,964,013

$5,891,602

$3,151,186

Current Face
Amount6, 8

$11,818,944

$3,698,411

$4,693,918

$5,764,858

$7,703,610

$8,269,277

$6,556,341

$11,314,651

$9,230,008

$9,994,806

$5,029,356

$7,078,089

$10,223,264

$2,052,702

$14,182,379

$7,105,304

$6,051,772

$29,142,474

$36,072,056

$16,658,561

$8,985,818

$9,482,247

$13,886,504

$10,550,917

$7,045,774

$25,039,989

$6,555,383

$6,462,972

$3,457,746

Disposition
Amount5, 6

Final Disposition

Continued on next page

$512,131

$111,165

$239,527

$156,481

$354,302

$447,356

$209,956

$425,545

$386,326

$433,852

$213,319

$335,082

$181,124

$140,130

$423,725

$255,370

$146,030

$1,254,222

$1,286,450

$657,863

$287,624

$368,608

$479,508

$348,599

$414,561

$1,089,741

$371,355

$449,518

$169,441

Interest Paid to Treasury

Notes: Numbers may not total due to rounding. Data as of 6/30/2012. Numbered notes were taken verbatim from the Treasury’s 6/27/2012 Transactions Report, and Treasury’s 7/10/2012 Dividends and Interest Report.
1
	On 4/17/2009, Treasury exchanged its Series D Fixed Rate Cumulative Preferred Shares for Series E Fixed Rate Non-Cumulative Preferred Shares with no change to Treasury’s initial investment amount. In addition, in order for AIG to fully redeem the Series E Preferred Shares, it had an additional obligation to Treasury of
$1,604,576,000 to reflect the cumulative unpaid dividends for the Series D Preferred Shares due to Treasury through and including the exchange date.
2
The investment amount reflected Treasury’s commitment to invest up to $30 billion less a reduction of $165 million representing retention payments AIG Financial Products made to its employees in March 2009.
3
This transaction does not include AIG’s commitment fee of an additional $165 million paid from its operating income over the life of the facility. A $55 million payment was received by Treasury on 12/17/2010. The remaining $110 million payment was received by Treasury on 5/27/2011.
4
	On 1/14/2011, (A) Treasury exchanged $27,835,000,000 of Treasury’s investment in AIG’s Fixed Rate Non-Cumulative Perpetual Preferred Stock (Series F) which is equal to the amount funded (including amounts drawn at closing) under the Series F equity capital facility, for (i) the transferred SPV preferred interests and
(ii) 167,623,733 shares of AIG Common Stock, and (B) Treasury exchanged $2,000,000,000 of undrawn Series F for 20,000 shares of preferred stock under the new Series G Cumulative Mandatory Convertible Preferred Stock equity capital facility under which AIG has the right to draw up to $2,000,000,000.
5
On 1/14/2011, Treasury exchanged an amount equivalent to the $40 billion initial investment plus capitalized interest from the April 2009 exchange (see note 1 above) of Fixed Rate Non-Cumulative Perpetual Preferred Stock (Series E) for 924,546,133 shares of AIG Common Stock.
6
	On 1/14/2011, Treasury received 562,868,096 shares of AIG Common Stock from the AIG Credit Facility Trust, which trust was established in connection with the credit facility between AIG and the Federal Reserve Bank of New York. This credit facility was repaid and terminated pursuant to this recapitalization
transaction. The trust had received 562,868,096 shares of AIG common stock in exchange for AIG’s Series C Perpetual, Convertible Participating Preferred Stock, which was previously held by the trust for the benefit of the U.S. Treasury.
7
The amount of Treasury’s AIA Preferred Units and ALICO Junior Preferred Interests holdings do not reflect preferred returns on the securities that accrue quarterly.
8
Proceeds include amounts applied to pay (i) accrued preferred returns and (ii) redeem the outstanding liquidation amount.
9
On 5/27/2011, Treasury completed the sale of 200,000,000 shares of common stock at $29.00 per share for an aggregate amount equal to $5,800,000,000, pursuant to an underwriting agreement executed on 5/24/2011.
10
On 5/27/2011, pursuant to the terms of the agreements governing the Preferred Stock (Series G), the available amount of the Preferred Stock (Series G) was reduced to $0 as a result of AIG’s primary offering of its common stock and the Preferred Stock (Series G) was cancelled.
11
On 3/13/2012, Treasury completed the sale of 206,896,552 shares of common stock at $29.00 per share for an aggregate amount equal to $6,000,000,008, pursuant to an underwriting agreement executed on 3/8/2012.
12
On 5/10/2012, Treasury completed the sale of 188,524,589 shares of common stock at $30.50 per share for total proceeds of $5,749,999,965, pursuant to an underwriting agreement executed on 5/6/2012.

268
Appendix D I Transaction Detail I July 25, 2012

Floating Rate SBA 7a security due 2034

Floating Rate SBA 7a security due 2035

9/28/2010

9/28/2010

83165AFQ2

83165AFM1

CUSIP

Total Purchase Face Amount

Shay Financial

Shay Financial

Institution Name

Sources: Treasury, Transactions Report, 6/27/2012, Treasury, Dividends and Interest Report, 7/11/2012.

1

Purchase

Purchase

UST/TCW
Senior Mortgage
Wilmington DE
Securities Fund,
L.P.

1,4,5 9/30/2009

City

2,4,5 9/30/2009

Institution

UST/TCW
Senior Mortgage
Wilmington DE
Securities Fund,
L.P.

Date

114.006

113.9

Pricing
Mechanism

—

—

TBA or
PMF3

12/30/2010

11/30/2010

Settlement
Date

Total Investment Amount*

$2,222,222,222

Par 1/4/2010

Par 1/4/2010

$368,145,452

$17,092,069

$15,308,612

Investment
Amount2, 3

Total
Senior
Security
Proceeds

—

—

TBA or
PMF3

Settlement Details

Date

$156,250,000 1/4/2010

$156,250,000

$200,000,000

Amount

Final Commitment Amount7

$200,000,000 1/4/2010

Amount

Adjusted Investment3

Investment
Pricing
Amount Mechanism Date

Membership
$1,111,111,111
Interest

Debt
Obligation
w/
Contingent
Proceeds

Transaction Investment
State Type
Description

Seller

PPIP TRANSACTION DETAIL, AS OF 6/30/2012

Table D.11

Note

$332,596,893

$14,950,000

$13,402,491

Purchase Face
Amount3

(Continued)

$183,555

$8,521

$7,632

Senior
Security
Proceeds4

1/24/2012

10/19/2011

Trade Date

$14,562,161

$12,963,737

Current Face
Amount6, 8

$334,924,711

$16,383,544

$14,433,039

Disposition
Amount5, 6

Final Disposition

Total Disposition Proceeds

$387,839

$438,754

Life-to-date
Principal
Received1, 8

$13,347,352

$681,819

$516,624

Interest Paid to Treasury

$156,250,000

$200,000,000

$156,250,000

$166,000,000

1/12/2010

1/15/2010

$34,000,000

1/11/2010

Repayment
Amount

Capital Repayment Details

Repayment
Amount
Date

Final
Investment
Amount9

—

—

$166,000,000

Amount

Membership Interest

Contingent Proceeds

Description

Final
Distribution

2/24/2010

Final
Distribution

1/29/2010 Distribution

2/24/2010

$342,176

Interest/
Distributions
Paid to
Treasury

Continued on next page

$48,922

$20,091,872

$1,223

$502,302

Proceeds

Distribution or Disposition

1/29/2010 Distribution

Debt Obligation w/
Contingent Proceeds

DescriptionDate

Investment After Capital Repayment

Notes: Numbers affected by rounding. Data as of 6/30/2012. Numbered notes were taken verbatim from Treasury’s 6/27/2012 Transactions Report.
*Subject to adjustment
The amortizing principal and interest payments are reported on the monthly Dividends and Interest Report available at www.FinancialStability.gov.
2
Investment Amount is stated after applying the appropriate month’s factor and includes accrued interest paid at settlement, if applicable.
3
	If a purchase is listed as TBA, or To-Be-Announced, the underlying loans in the SBA Pool have yet to come to market, and the TBA pricing mechanism, purchase face amount, investment amount and senior security proceeds will be adjusted within the variance permitted under the program terms. If a purchase is listed
as PMF, or Prior-Month-Factor, the trade was made prior to the applicable month’s factor being published and the SBA 7a security and senior security are priced according to the prior-month’s factor. The PMF investment amount and senior security proceeds will be adjusted after publication of the applicable month’s
factor (on or about the 11th business day of each month).
4
	In order to satisfy the requirements under Section 113 of the Emergency Economic Stabilization Act of 2008, Treasury will acquire a senior indebtedness instrument (a Senior Security) from the seller of each respective SBA 7a Security. Each Senior Security will (i) have an aggregate principal amount equal to the
product of (A) 0.05% and (B) the Investment Amount (excluding accrued interest) paid by Treasury for the respective SBA 7a Security, and (ii) at the option of the respective seller, may be redeemed at par value immediately upon issuance, or remain outstanding with the terms and conditions as set forth in the Master
Purchase Agreement.
5
Disposition Amount is stated after applying the appropriate month’s factor and includes accrued interest received at settlement, if applicable. If the disposition is listed as PMF, the disposition amount will be adjusted after publication of the applicable month’s factor.
6
	If a disposition is listed as PMF, or Prior-Month-Factor, the trade was made prior to the applicable month’s factor being published and the SBA 7a security is priced according to the prior-month’s factor. The PMF disposition amount will be adjusted after publication of the applicable month’s factor (on or about the 11th
business day of each month).
7
	Total Program Proceeds To Date includes life-to-date disposition proceeds, life-to-date principal received, life-to-date interest received, and senior security proceeds (excluding accruals).
8
The sum of Current Face Amount and Life-to-date Principal Received will equal Purchase Face Amount for CUSIPs that were originally purchased as TBAs only after the applicable month’s factor has been published and trailing principal & interest payments have been received.

Investment Description

Purchase
Date

Purchase Details1

UCSB TRANSACTION DETAIL, AS OF 6/30/2012

Transaction detail I Appendix D I July 25, 2012

269

City

Wilmington DE

Wilmington DE

Institution

Invesco Legacy
Securities
Master Fund,
L.P.

Invesco Legacy
Securities
Master Fund,
L.P.

Date

9/30/2009

Note

1,6

2,6,8 9/30/2009

Purchase

Purchase

$580,960,000

$2,222,222,222

Par 3/22/2010 $2,488,875,000 9/26/2011 $1,161,920,000 $1,161,920,000

$856,000,000

Amount

$77,704,254
$28,883,733
$9,129,709
$31,061,747
$10,381,214
$6,230,731
$1,183,959
$1,096,185
$1,601,688
$3,035,546
$161,386,870

4/14/2011
5/20/2011
6/14/2011
7/15/2011
8/12/2011
10/17/2011
12/14/2011
1/17/2012
2/14/2012
3/14/2012
3/29/2012

—

$161,386,870

$164,422,415

$166,024,103

$167,120,288

$168,304,246

$174,534,977

$184,916,192

$215,977,938

$225,107,647

$253,991,380

$331,695,634

$132,928,628
$31,689,230
$27,355,590
$92,300,138
$128,027,536
$155,409,286
$75,085,485
$18,259,513
$62,979,809
$20,762,532
$37,384,574
$7,103,787
$6,577,144
$9,610,173
$284,468,750

11/15/2010
12/14/2010
1/14/2010
2/14/2011
3/14/2011
4/14/2011
5/20/2011
6/14/2011
7/15/2011
8/12/2011
10/17/2011
12/14/2011
1/17/2012
2/14/2012
3/14/2012

—

$284,468,750

$294,078,924

$300,656,067

$307,759,854

$345,144,428

$365,906,960

$428,886,768

$447,146,281

$522,231,766

$677,641,052

$805,668,588

$897,968,726

$925,324,316

$957,013,546

$60,022,674 $1,089,942,174

$68,765,544

3/14/2011

$400,461,178

9/15/2010

$48,523,845

2/14/2011

$448,985,023

$7,066,434 $1,149,964,848

$13,677,726

1/14/2011

$462,662,749

$478,507,285

4/15/2010

$15,844,536

12/14/2010

$4,888,718 $1,157,031,282

$66,463,982

11/15/2010

$544,971,267

$574,982,454

$578,515,653

Amount

Description

Contingent Proceeds3/29/2012 Distribution 5

Debt Obligation w/
Contingent Proceeds

Debt Obligation w/
Contingent Proceeds

Debt Obligation w/
Contingent Proceeds

Debt Obligation w/
Contingent Proceeds

Debt Obligation w/
Contingent Proceeds

Debt Obligation w/
Contingent Proceeds

Debt Obligation w/
Contingent Proceeds

Debt Obligation w/
Contingent Proceeds

Debt Obligation w/
Contingent Proceeds

Debt Obligation w/
Contingent Proceeds

Debt Obligation w/
Contingent Proceeds

Debt Obligation w/
Contingent Proceeds

Debt Obligation w/
Contingent Proceeds

Debt Obligation w/
Contingent Proceeds

Debt Obligation w/
Contingent Proceeds

Debt Obligation w/
Contingent Proceeds

Debt Obligation w/
Contingent Proceeds

$99,336,742

Interest/
Distributions
Paid to
Treasury

Continued on next page

$3,434,460

$56,390,209

Proceeds

Distribution or Disposition

Membership Interest103/29/2012 Distribution 5

Membership Interest10

Membership Interest10

Membership Interest10

Membership Interest10

Membership Interest10

Membership Interest10

Membership Interest10

Membership Interest10

Membership Interest10

Membership Interest10

Membership Interest10

Membership Interest10

Membership Interest10

Membership Interest10

Membership Interest10

Membership Interest10

Membership Interest10

Membership Interest10

DescriptionDate

Investment After Capital Repayment

2/18/2010

$3,533,199
$30,011,187

4/15/2010
9/15/2010

$2,444,347

2/18/2010

Repayment
Amount

Capital Repayment Details

Repayment
Amount
Date

Final
Investment
Amount9

Debt
Obligation
w/
Contingent
Proceeds

Date

Final Commitment Amount7

Par 3/22/2010 $1,244,437,500 7/16/2010

Amount

Adjusted Investment3

Investment
Pricing
Amount Mechanism Date

(CONTINUED)

Membership
$1,111,111,111
Interest

Transaction Investment
State Type
Description

Seller

PPIP TRANSACTION DETAIL, AS OF 6/30/2012
270
Appendix D I Transaction Detail I July 25, 2012

Wilmington DE

Wilmington DE

AG GECC PPIF
10/30/2009 Master Fund,
L.P.

AG GECC PPIF
10/30/2009 Master Fund,
L.P.

2,6

1,6

Purchase

Purchase

Purchase

Wilmington DE

Blackrock PPIF,
L.P.

10/2/2009

1,6

Purchase

Wilmington DE

Blackrock PPIF,
L.P.

10/2/2009

2,6

Purchase

AllianceBernstein
Legacy
Securities
Wilmington DE
Master Fund,
L.P.

10/2/2009

1,6

Purchase

AllianceBernstein
Legacy
Securities
Wilmington DE
Master Fund,
L.P.

10/2/2009

2,6

Purchase

10/1/2009

1,6

Wellington
Management
Legacy
Wilmington DE
Securities PPIF
Master Fund, LP

City

Purchase

10/1/2009

2,6

Institution

Wellington
Management
Legacy
Wilmington DE
Securities PPIF
Master Fund, LP

Date

Note

$2,222,222,222

Membership
$1,111,111,111
Interest

Par 3/22/2010 $1,271,337,500 7/16/2010 $1,243,275,000

Par 3/22/2010 $2,542,675,000 7/16/2010 $2,486,550,000

Debt
Obligation
w/
Contingent
Proceeds
$2,222,222,222

Par 3/22/2010 $1,244,437,500 7/16/2010

Membership
$1,111,111,111
Interest

$694,980,000

Par 3/22/2010 $2,488,875,000 7/16/2010 $1,389,960,000

$2,222,222,222

Debt
Obligation
w/
Contingent
Proceeds

Par 3/22/2010 $2,488,875,000 7/16/2010 $2,300,847,000

Par 3/22/2010 $1,262,037,500 7/16/2010 $1,149,487,000

Par 3/22/2010 $1,244,437,500 7/16/2010 $1,150,423,500

$2,222,222,222

Amount

Membership
$1,111,111,111
Interest

Debt
Obligation
w/
Contingent
Proceeds

Date

Final Commitment Amount7

Par 3/22/2010 $2,524,075,000 7/16/2010 $2,298,974,000

Amount

Adjusted Investment3

Investment
Pricing
Amount Mechanism Date

(CONTINUED)

Membership
$1,111,111,111
Interest

Debt
Obligation
w/
Contingent
Proceeds

Transaction Investment
State Type
Description

Seller

PPIP TRANSACTION DETAIL, AS OF 6/30/2012

$80,000,000 $2,190,514,339
$30,000,000 $2,160,514,339
$500,000,000 $1,660,514,339
$44,200,000 $1,616,314,339
$120,000,000 $1,496,314,339

5/3/2012
5/14/2012
5/23/2012
6/14/2012
6/25/2012

5/14/2012

$74,999,625

5/14/2012

$981,713,808

$99,462,003 $1,056,713,433

3/14/2012

$150,000,000 $1,963,425,000

5/14/2012

$87,099,565 $1,156,175,436

$198,925,000 $2,113,425,000

3/14/2012

2/14/2012

$174,200,000 $2,312,350,000

2/14/2012

$808,734,092

$39,999,800 $1,095,832,657

4/14/2011

$287,098,565

$7,118,388 $1,135,832,457

3/14/2011

6/14/2012

$712,284 $1,149,667,172
$6,716,327 $1,142,950,845

2/14/2011

$44,043 $1,150,379,457

$88,087 $2,270,514,339

6/14/2011

1/15/2010

$30,244,575 $2,270,602,425

$125,000,000 $2,173,974,000

Amount

Membership Interest10

Membership Interest10

Membership Interest10

Debt Obligation w/
Contingent Proceeds

Debt Obligation w/
Contingent Proceeds

Debt Obligation w/
Contingent Proceeds

Membership Interest10

Membership Interest10

Membership Interest10

Membership Interest10

Membership Interest10

Membership Interest10

Debt Obligation w/
Contingent Proceeds

Debt Obligation w/
Contingent Proceeds

Debt Obligation w/
Contingent Proceeds

Debt Obligation w/
Contingent Proceeds

Debt Obligation w/
Contingent Proceeds

Debt Obligation w/
Contingent Proceeds

Debt Obligation w/
Contingent Proceeds

Debt Obligation w/
Contingent Proceeds

DescriptionDate

Investment After Capital Repayment

5/16/2011

6/26/2012

Repayment
Amount

Capital Repayment Details

Repayment
Amount
Date

Final
Investment
Amount9

Description

$215,789,752

$33,658,950

$230,852,891

$158,206,437

Interest/
Distributions
Paid to
Treasury

Continued on next page

Proceeds

Distribution or Disposition

Transaction detail I Appendix D I July 25, 2012

271

Purchase

Initial Investment Amount

Wilmington DE

Oaktree PPIP
Fund, L.P.

Purchase

$2,222,222,222

Amount

$30,000,000,000

Membership
$1,111,111,111
Interest

$2,222,222,222

Final Investment Amount

$21,856,403,574

Par 3/22/2010 $1,244,437,500 7/16/2010 $1,160,784,100

Par 3/22/2010 $2,488,875,000 7/16/2010 $2,321,568,200

$474,550,000

$949,100,000

$620,578,258

Debt
Obligation
w/
Contingent
Proceeds

Par 3/22/2010 $2,488,875,000 7/16/2010

Par 3/22/2010 $1,244,437,500 7/16/2010

Par 3/22/2010 $1,244,437,500 7/16/2010

$2,222,222,222

Date

Par 3/22/2010 $2,488,875,000 7/16/2010 $1,241,156,516

Amount

Final Commitment Amount7

Membership
$1,111,111,111
Interest

Debt
Obligation
w/
Contingent
Proceeds

Membership
$1,111,111,111
Interest

Debt
Obligation
w/
Contingent
Proceeds

Adjusted Investment3

Investment
Pricing
Amount Mechanism Date

(CONTINUED)

Amount

$39,387,753 $1,081,896,544

3/14/2012

Total
Capital
Repayment $4,409,958,040

$39,499,803 $1,121,284,298

7/15/2011

$78,775,901 $2,163,792,299

3/14/2012

$615,853,465

$79,000,000 $2,242,568,200

$3,521,835

4/14/2011

$619,375,301

7/15/2011

$1,202,957

Membership Interest10

Membership Interest10

Debt Obligation w/
Contingent Proceeds

Debt Obligation w/
Contingent Proceeds

Membership Interest10

Membership Interest10

Debt Obligation w/
Contingent Proceeds

DescriptionDate

Investment After Capital Repayment

$13,531,530 $1,227,624,986

3/14/2011

5/13/2011

Repayment
Amount

Capital Repayment Details

Repayment
Amount
Date

Final
Investment
Amount9

Proceeds

Total Proceeds $80,468,989

Description

Distribution or Disposition

$22,479,266

$66,007,835

$143,961,297

Interest/
Distributions
Paid to
Treasury

Sources: Treasury, Transactions Report, 6/27/2012; Treasury, Dividends and Interest Report, 7/11/2012.

Notes: Numbers may not total due to rounding. Data as of 6/30/2012. Numbered notes were taken verbatim from Treasury’s 6/27/2012 Transactions Report.
1
The equity amount may be incrementally funded. Commitment amount represents Treasury’s maximum obligation if the limited partners other than Treasury fund their maximum equity capital obligations.
2
The loan may be incrementally funded. Commitment amount represents Treasury’s maximum obligation if Treasury and the limited partners other than Treasury fund 100% of their maximum equity obligations.
3
	Adjusted to show Treasury’s maximum obligations to a fund.
4
On 1/4/2010, Treasury and the fund manager entered into a Winding-Up and Liquidation Agreement.
5
	Distributions after capital repayments will be considered profit and are paid pro rata (subject to prior distribution of Contingent Proceeds to Treasury) to the fund’s partners, including Treasury, in proportion to their membership interests. These figures exclude pro-rata distributions to Treasury of gross investment proceeds (reported on
the Dividends and Interest Report), which may be made from time to time in accordance with the terms of the fund’s Limited Partnership Agreement.
6
	Following termination of the TCW fund, the $3.33 billion of obligations have been reallocated to the remaining eight funds pursuant to consent letters from Treasury dated as of 3/22/2010. $133 million of maximum equity capital obligation and $267 million of maximum debt obligation were reallocated per fund, after adjustment for the
$17.6 million and $26.9 million equity capital reallocations from private investors in the TCW fund to the Wellington fund and the AG GECC fund, respectively. The $356 million of final investment in the TCW fund will remain a part of Treasury’s total maximum S-PPIP investment amount.
7
	Amount adjusted to show Treasury’s final capital commitment (membership interest) and the maximum amount of Treasury’s debt obligation that may be drawn down in accordance with the Loan Agreement.
8
On 9/26/2011, the General Partner notified Treasury that the Investment Period was terminated in accordance with the Limited Partnership Agreement. As a result, the Final Investment Amount, representing Treasury’s debt obligation, has been reduced to the cumulative amount of debt funded.
9
Cumulative capital drawn at end of the Investment Period.
10
The amount is adjusted to reflect pro-rata equity distributions that have been deemed to be capital repayments to Treasury.

12/18/2009

1,6

Wilmington DE

1,6

Oaktree PPIP
Fund, L.P.

Purchase

Marathon Legacy
Securities
11/25/2009 Public-Private
Wilmington DE
Investment
Partnership, L.P.

2,6

12/18/2009

Purchase

Marathon Legacy
Securities
11/25/2009 Public-Private
Wilmington DE
Investment
Partnership, L.P.

2,6

Purchase

Wilmington DE

RLJ Western
Asset Public/
Private Master
Fund, L.P.

11/4/2009

1,6

Purchase

Wilmington DE

11/4/2009

RLJ Western
Asset Public/
Private Master
Fund, L.P.

2,6

City

Institution

Date

Note

Transaction Investment
State Type
Description

Seller

PPIP TRANSACTION DETAIL, AS OF 6/30/2012

272
Appendix D I Transaction Detail I July 25, 2012

Name of Institution

Select Portfolio Servicing,
Salt Lake City, UT

Date

4/13/2009

Purchase

Transaction
Type

Servicer Modifying Borrowers’ Loans

Financial
Instrument for
Home Loan
Modifications

Investment
Description

$376,000,000

Cap of Incentive
Payments on Behalf
of Borrowers and to
Servicers & Lenders/
Investors (Cap)1

HAMP TRANSACTION DETAIL, AS OF 6/30/2012

Table D.12

N/A

Pricing
Mechanism
Note

$128,690,000
$4,000,000
$59,807,784
($700,000)
$64,400,000
($639)
($2,300,000)
$100,000
$3,600,000

7/14/2010
9/30/2010
9/30/2010
11/16/2010
12/15/2010
1/6/2011
1/13/2011
2/16/2011
3/16/2011

$400,000
($100,000)
($6,805)
($100,000)
($200,000)
($100,000)
($100,000)
$200,000
$24,800,000
$1,900,000
$80,000
$8,710,000
($5,176)

5/13/2011
6/16/2011
6/29/2011
8/16/2011
9/15/2011
10/14/2011
11/16/2011
1/13/2012
3/15/2012
4/16/2012
5/16/2012
6/14/2012
6/28/2012

($100,000)

($355,530,000)

3/26/2010

4/13/2011

$131,340,000

12/30/2009

($735)

$750,807,784

$121,910,000

3/30/2011

$691,000,000

$284,590,000

6/12/2009
9/30/2009

$851,284,429

$851,289,605

$842,579,605

$842,499,605

$840,599,605

$815,799,605

$815,599,605

$815,699,605

$815,799,605

$815,999,605

$816,099,605

$816,106,410

$816,206,410

$815,806,410

$815,906,410

$815,907,145

$812,307,145

$812,207,145

$814,507,145

$814,507,784

$750,107,784

$687,000,000

$558,310,000

$913,840,000

$782,500,000

$660,590,000

Cap Adjustment
Amount

Adjustment
Date

Updated due to quarterly assessment and
reallocation

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Updated due to quarterly assessment and
reallocation

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Updated due to quarterly assessment and
reallocation

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Updated portfolio data from servicer

Updated portfolio data from servicer

Transfer of cap due to servicing transfer

Updated portfolio data from servicer

Initial FHA-HAMP cap and initial FHA-2LP
cap

Updated portfolio data from servicer

Updated portfolio data from servicer

Updated portfolio data from servicer &
HAFA initial cap

Updated portfolio data from servicer &
HPDP initial cap

Updated portfolio data from servicer

Adjusted Cap Reason for Adjustment

Adjustment Details

$34,417,040

Borrower’s
Incentives

$74,497,723

Lenders/
Investors
Incentives

$167,964,731

Total TARP
Incentive
Payments

Continued on next page

$59,049,968

Servicers
Incentives

TARP Incentive Payments

Transaction detail I Appendix D I July 25, 2012

273

Name of Institution

CitiMortgage, Inc.,
O’Fallon, MO

Date

4/13/2009

Purchase

Transaction
Type

Servicer Modifying Borrowers’ Loans

Financial
Instrument for
Home Loan
Modifications

Investment
Description

$2,071,000,000

N/A

Pricing
Mechanism

(CONTINUED)

Cap of Incentive
Payments on Behalf
of Borrowers and to
Servicers & Lenders/
Investors (Cap)1

HAMP TRANSACTION DETAIL, AS OF 6/30/2012

Note

($105,410,000)
($199,300,000)
($230,000)
($3,000,000)
($12,280,000)
($757,680,000)
($7,110,000)
($6,300,000)
($8,300,000)
$32,400,000
$101,287,484
($1,400,000)
($3,200,000)

12/30/2009
3/26/2010
4/19/2010
5/14/2010
6/16/2010
7/14/2010
7/16/2010
8/13/2010
9/15/2010
9/30/2010
9/30/2010
10/15/2010
11/16/2010

$100,000

($400,000)
($9,131)
($14,500,000)
($1,600,000)
$700,000
$15,200,000
($2,900,000)
($5,000,000)
($900,000)
($1,100,000)
($1,700,000)
($600,000)
($340,000)
($2,880,000)
($5,498)

6/16/2011
6/29/2011
7/14/2011
8/16/2011
9/15/2011
10/14/2011
11/16/2011
12/15/2011
1/13/2012
2/16/2012
3/15/2012
4/16/2012
5/16/2012
6/14/2012
6/28/2012

($1,031)

3/30/2011

($7,200,000)

($30,500,000)

3/16/2011

5/13/2011

($4,600,000)

2/16/2011

4/13/2011

($10,500,000)

1/13/2011

($981)

$1,123,677,484

$1,010,180,000

9/30/2009

1/6/2011

$1,022,390,000

($991,580,000)

6/12/2009

$1,050,340,843

$1,050,346,341

$1,053,226,341

$1,053,566,341

$1,054,166,341

$1,055,866,341

$1,056,966,341

$1,057,866,341

$1,062,866,341

$1,065,766,341

$1,050,566,341

$1,049,866,341

$1,051,466,341

$1,065,966,341

$1,065,975,472

$1,066,375,472

$1,073,575,472

$1,073,475,472

$1,073,476,503

$1,103,976,503

$1,108,576,503

$1,119,076,503

$1,119,077,484

$1,122,277,484

$989,990,000

$998,290,000

$1,004,590,000

$1,011,700,000

$1,769,380,000

$1,781,660,000

$1,784,660,000

$1,784,890,000

$1,984,190,000

$2,089,600,000

$1,079,420,000

Cap Adjustment
Amount

Adjustment
Date

Updated due to quarterly assessment and
reallocation

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Updated due to quarterly assessment and
reallocation

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Updated due to quarterly assessment and
reallocation

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Updated portfolio data from servicer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Updated portfolio data from servicer

Initial FHA-HAMP cap and initial FHA-2LP
cap

Transfer of cap to multiple servicers due to
servicing transfer

Transfer of cap to multiple servicers due to
servicing transfer

Transfer of cap to multiple servicers due to
servicing transfer

Updated portfolio data from servicer

Transfer of cap to multiple servicers due to
servicing transfer

Transfer of cap to Specialized Loan
Servicing, LLC due to servicing transfer

Transfer of cap to Service One, Inc. due to
servicing transfer

Updated portfolio data from servicer &
2MP initial cap

Updated portfolio data from servicer &
HAFA initial cap

Updated portfolio data from servicer &
HPDP initial cap

Updated portfolio data from servicer

Adjusted Cap Reason for Adjustment

Adjustment Details

$35,034,563

Borrower’s
Incentives

$116,114,690

Lenders/
Investors
Incentives

$221,270,328

Total TARP
Incentive
Payments

Continued on next page

$70,121,075

Servicers
Incentives

TARP Incentive Payments

274
Appendix D I Transaction Detail I July 25, 2012

Name of Institution

Wells Fargo Bank, NA,
Des Moines, IA

Date

4/13/2009

Purchase

Transaction
Type

Servicer Modifying Borrowers’ Loans

Financial
Instrument for
Home Loan
Modifications

Investment
Description

$2,873,000,000

N/A

Pricing
Mechanism

(CONTINUED)

Cap of Incentive
Payments on Behalf
of Borrowers and to
Servicers & Lenders/
Investors (Cap)1

HAMP TRANSACTION DETAIL, AS OF 6/30/2012

Note

$1,400,000
$200,000
($200,000)
($200,000)
($300,000)
($200,000)
($1,000,000)
($800,000)
($610,000)
($2,040,000)
($39,923)

10/14/2011
11/16/2011
12/15/2011
1/13/2012
2/16/2012
3/15/2012
4/16/2012
5/16/2012
6/14/2012
6/28/2012

($100,000)

3/16/2011

9/15/2011

($100,000)

1/13/2011

($1,100,000)

($6,312)

1/6/2011

($2,300,000)

$22,200,000

12/15/2010

8/16/2011

$8,413,225

12/3/2010

7/14/2011

$344,000,000

9/30/2010

($63,856)

($287,348,828)

9/30/2010

6/29/2011

($2,038,220,000)

7/14/2010

($600,000)

$683,130,000

3/26/2010

6/16/2011

$668,108,890

3/19/2010

$100,000

$54,767

3/12/2010

($9,800,000)

$2,050,236,344

2/17/2010

5/13/2011

$1,213,310,000

12/30/2009

4/13/2011

$65,070,000

9/30/2009

($7,171)

($462,990,000)

6/17/2009

3/30/2011

Cap Adjustment
Amount

Adjustment
Date

$5,121,197,135

$5,121,237,058

$5,123,277,058

$5,123,887,058

$5,124,687,058

$5,125,687,058

$5,125,887,058

$5,126,187,058

$5,126,387,058

$5,126,587,058

$5,126,387,058

$5,124,987,058

$5,126,087,058

$5,128,387,058

$5,128,450,914

$5,129,050,914

$5,128,950,914

$5,138,750,914

$5,138,758,085

$5,138,858,085

$5,138,958,085

$5,138,964,397

$5,116,764,397

$5,108,351,172

$4,764,351,172

$5,051,700,000

$7,089,920,000

$6,406,790,000

$5,738,681,110

$5,738,626,344

$3,688,390,000

$2,475,080,000

$2,410,010,000

Updated due to quarterly assessment and
reallocation

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Updated due to quarterly assessment and
reallocation

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Updated due to quarterly assessment and
reallocation

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Updated portfolio data from servicer

Updated portfolio data from servicer

Transfer of cap (from Wachovia) due to
merger

Initial FHA-HAMP cap, initial FHA-2LP cap,
and initial RD-HAMP

Updated portfolio data from servicer

Updated portfolio data from servicer

Updated portfolio data from servicer

Initial 2MP cap

Transfer of cap (from Wachovia) due to
merger

Transfer of cap (from Wachovia) due to
merger

Updated portfolio data from servicer &
HAFA initial cap

Updated portfolio data from servicer &
HPDP initial cap

Updated portfolio data from servicer

Adjusted Cap Reason for Adjustment

Adjustment Details

$93,044,464

Borrower’s
Incentives

$227,817,344

Lenders/
Investors
Incentives

$487,625,315

Total TARP
Incentive
Payments

Continued on next page

$166,763,508

Servicers
Incentives

TARP Incentive Payments

Transaction detail I Appendix D I July 25, 2012

275

Name of Institution

GMAC Mortgage, Inc.,
Ft. Washington, PA

Date

4/13/2009

Purchase

Transaction
Type

Servicer Modifying Borrowers’ Loans

Financial
Instrument for
Home Loan
Modifications

Investment
Description

$633,000,000

N/A

Pricing
Mechanism

(CONTINUED)

Cap of Incentive
Payments on Behalf
of Borrowers and to
Servicers & Lenders/
Investors (Cap)1

HAMP TRANSACTION DETAIL, AS OF 6/30/2012

Note

($1,679,520,000)
$190,180,000
$1,880,000
($881,530,000)
($3,700,000)
$119,200,000
$216,998,139
($500,000)
($1,734)
($100,000)

12/30/2009
3/26/2010
5/14/2010
7/14/2010
8/13/2010
9/30/2010
9/30/2010
12/15/2010
1/6/2011
3/16/2011

($200,000)
$3,400,000
$200,000
($800,000)
($200,000)
$2,600,000
($1,600,000)
($400,000)
($100,000)
($800,000)
($990,000)
($12,463)

9/15/2011
10/14/2011
11/16/2011
12/15/2011
1/13/2012
3/15/2012
4/16/2012
5/16/2012
6/14/2012
6/28/2012

($18,457)

6/29/2011

8/16/2011

($17,900,000)

5/13/2011

7/14/2011

($800,000)

4/13/2011

($2,024)

$1,518,398,139

$2,537,240,000

9/30/2009

3/30/2011

$1,301,400,000

$384,650,000

6/12/2009

$1,500,173,461

$1,500,185,924

$1,501,175,924

$1,501,975,924

$1,502,075,924

$1,502,475,924

$1,504,075,924

$1,501,475,924

$1,501,675,924

$1,502,475,924

$1,502,275,924

$1,498,875,924

$1,499,075,924

$1,499,094,381

$1,516,994,381

$1,517,794,381

$1,517,796,405

$1,517,896,405

$1,517,898,139

$1,182,200,000

$1,185,900,000

$2,067,430,000

$2,065,550,000

$1,875,370,000

$3,554,890,000

$1,017,650,000

Cap Adjustment
Amount

Adjustment
Date

Updated due to quarterly assessment and
reallocation

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Updated due to quarterly assessment and
reallocation

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Updated due to quarterly assessment and
reallocation

Transfer of cap due to servicing transfer

Updated portfolio data from servicer

Updated portfolio data from servicer

Updated portfolio data from servicer

Initial FHA-HAMP cap, initial FHA-2LP cap,
and initial 2MP cap

Transfer of cap due to servicing transfer

Updated portfolio data from servicer

Transfer of cap from Wilshire Credit
Corporation due to servicing transfer

Updated portfolio data from servicer

Updated portfolio data from servicer &
HAFA initial cap

Updated portfolio data from servicer &
HPDP initial cap

Updated portfolio data from servicer

Adjusted Cap Reason for Adjustment

Adjustment Details

$28,423,250

Borrower’s
Incentives

$80,202,635

Lenders/
Investors
Incentives

$163,764,096

Total TARP
Incentive
Payments

Continued on next page

$55,138,210

Servicers
Incentives

TARP Incentive Payments

276
Appendix D I Transaction Detail I July 25, 2012

Purchase

Purchase

Name of Institution

Saxon Mortgage Services,
Inc., Irving, TX

Chase Home Finance, LLC,
Iselin, NJ

Date

4/13/2009

4/13/2009

Transaction
Type

Servicer Modifying Borrowers’ Loans

$407,000,000

$3,552,000,000

Financial
Instrument for
Home Loan
Modifications

Financial
Instrument for
Home Loan
Modifications

Investment
Description

N/A

N/A

Pricing
Mechanism

(CONTINUED)

Cap of Incentive
Payments on Behalf
of Borrowers and to
Servicers & Lenders/
Investors (Cap)1

HAMP TRANSACTION DETAIL, AS OF 6/30/2012

2

Note

($22,980,000)
$1,800,000
$9,800,000
$116,222,668
$100,000
$8,900,000

7/16/2010
9/15/2010
9/30/2010
9/30/2010
10/15/2010
12/15/2010

($100,000)
$100,000
($17,500,000)
($760,000)
($354,290,000)
($1,831)

2/16/2012
3/15/2012
4/16/2012
5/16/2012
6/14/2012
6/28/2012

($3,552,000,000)

$17,500,000

12/15/2011

7/31/2009

($700,000)

9/15/2011

($6,144)

6/29/2011
$200,000

$2,100,000

4/13/2011

($100,000)

($654)

3/30/2011

8/16/2011

$700,000

3/16/2011

7/14/2011

$2,300,000

1/13/2011

($556)

($513,660,000)

7/14/2010

1/6/2011

($57,720,000)

$355,710,000

12/30/2009

($156,050,000)

$254,380,000

6/16/2010

$225,040,000

6/17/2009
9/30/2009

3/26/2010

Cap Adjustment
Amount

Adjustment
Date

$0

$277,983,483

$277,985,314

$632,275,314

$633,035,314

$650,535,314

$650,435,314

$650,535,314

$633,035,314

$633,735,314

$633,835,314

$633,635,314

$633,641,458

$631,541,458

$631,542,112

$630,842,112

$628,542,112

$628,542,668

$619,642,668

$619,542,668

$503,320,000

$493,520,000

$491,720,000

$514,700,000

$1,028,360,000

$1,184,410,000

$1,242,130,000

$886,420,000

$632,040,000

Termination of SPA

Updated due to quarterly assessment and
reallocation

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Updated due to quarterly assessment and
reallocation

Transfer of cap due to servicing transfer

Updated due to quarterly assessment and
reallocation

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Updated portfolio data from servicer

Updated portfolio data from servicer

Transfer of cap due to servicing transfer

Updated portfolio data from servicer

Initial FHA-HAMP cap and initial FHA-2LP
cap

Transfer of cap due to servicing transfer

Transfer of cap due to multiple servicing
transfers

Updated portfolio data from servicer

Transfer of cap to Ocwen Financial
Corporation, Inc. due to servicing transfer

Updated portfolio data from servicer

Updated portfolio data from servicer &
HAFA initial cap

Updated portfolio data from servicer &
HPDP initial cap

Updated portfolio data from servicer

Adjusted Cap Reason for Adjustment

Adjustment Details

$—

$19,771,279

Borrower’s
Incentives

$—

$42,179,792

Lenders/
Investors
Incentives

$—

$101,750,667

Total TARP
Incentive
Payments

Continued on next page

$—

$39,799,597

Servicers
Incentives

TARP Incentive Payments

Transaction detail I Appendix D I July 25, 2012

277

Name of Institution

Ocwen Financial
Corporation, Inc.,
West Palm Beach, FL

Bank of America, N.A.,
Simi Valley, CA

Date

4/16/2009

4/17/2009
as amended
on
1/26/2010

Purchase

Purchase

Transaction
Type

Servicer Modifying Borrowers’ Loans

Financial
Instrument for
Home Loan
Modifications

Financial
Instrument for
Home Loan
Modifications

Investment
Description

$798,900,000

$659,000,000

N/A

N/A

Pricing
Mechanism

(CONTINUED)

Cap of Incentive
Payments on Behalf
of Borrowers and to
Servicers & Lenders/
Investors (Cap)1

HAMP TRANSACTION DETAIL, AS OF 6/30/2012

Note

$23,710,000
$100,000
$3,742,740

7/16/2010
9/15/2010
9/30/2010

($900,000)
($200,000)
($17,893)

11/16/2011
5/16/2012
6/28/2012

$1,554,813,000

($300,000)
($120,700,000)

8/16/2011

($23,337)

6/29/2011

10/14/2011

$1,555,113,000

($2,548)

$1,432,995,107

$1,433,013,000

$1,433,213,000

$1,434,113,000

$1,555,136,337

$1,555,138,885

3/30/2011

$1,555,141,084

$1,332,200,000

($2,199)

9/30/2010

$1,236,900,000

$222,941,084

$95,300,000

7/14/2010

$1,603,650,000

$2,433,020,000

1/6/2011

($366,750,000)

3/26/2010

$1,632,630,000

$967,120,000

$804,440,000

$1,817,154,254

$1,817,160,562

$1,462,870,562

$1,339,340,562

$1,339,240,562

$1,338,840,562

$1,144,040,562

$1,144,140,562

$1,144,150,606

$1,144,151,720

$1,143,251,720

$1,143,252,740

$972,452,740

$968,710,000

$968,610,000

$944,900,000

$1,136,510,000

$980,460,000

$933,600,000

$655,960,000

$553,380,000

Updated due to quarterly assessment and
reallocation

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Updated due to quarterly assessment and
reallocation

Updated due to quarterly assessment and
reallocation

Updated portfolio data from servicer

Updated portfolio data from servicer

Initial FHA-HAMP cap, initial FHA-2LP cap,
and initial RD-HAMP

Updated portfolio data from servicer

Updated portfolio data from servicer

Initial 2MP cap

Updated portfolio data from servicer &
HAFA initial cap

Updated portfolio data from servicer &
HPDP initial cap

Updated portfolio data from servicer

Updated due to quarterly assessment and
reallocation

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Updated due to quarterly assessment and
reallocation

Updated due to quarterly assessment and
reallocation

Transfer of cap due to servicing transfer

Updated portfolio data from servicer

Transfer of cap due to servicing transfer

Updated portfolio data from servicer

Initial FHA-HAMP cap

Transfer of cap from Saxon Mortgage
Services, Inc. due to servicing transfer

Updated portfolio data from servicer

Transfer of cap from Saxon Mortgage
Services, Inc. due to servicing transfer

Updated portfolio data from servicer

Updated portfolio data from servicer &
HAFA initial cap

Updated portfolio data from servicer &
HPDP initial cap

Updated portfolio data from servicer

Adjusted Cap Reason for Adjustment

9/30/2010

$800,390,000
($829,370,000)

1/26/2010

$665,510,000

($6,308)

6/28/2012

12/30/2009

$354,290,000

6/14/2012

$5,540,000

$123,530,000

5/16/2012

$162,680,000

$100,000

3/15/2012

6/12/2009

$400,000

2/16/2012

9/30/2009

($100,000)

($10,044)

6/29/2011

$194,800,000

($1,114)

3/30/2011

1/13/2012

$900,000

2/16/2011

10/14/2011

($1,020)

1/6/2011

$170,800,000

($191,610,000)

7/14/2010

10/15/2010

$46,860,000

$277,640,000

12/30/2009

$156,050,000

$102,580,000

9/30/2009

6/16/2010

($105,620,000)

6/12/2009

3/26/2010

Cap Adjustment
Amount

Adjustment
Date

Adjustment Details

$4,267,062

$38,992,881

Borrower’s
Incentives

$17,852,012

$108,999,326

Lenders/
Investors
Incentives

$31,278,513

$229,489,717

Total TARP
Incentive
Payments

Continued on next page

$9,159,439

$81,497,510

Servicers
Incentives

TARP Incentive Payments

278
Appendix D I Transaction Detail I July 25, 2012

Name of Institution

Countrywide Home Loans
Servicing LP (BAC Home
Loans Servicing, LP),
Simi Valley, CA

Date

4/17/2009
as amended
on
1/26/2010

Purchase

Transaction
Type

Servicer Modifying Borrowers’ Loans

Financial
Instrument for
Home Loan
Modifications

Investment
Description

$1,864,000,000

N/A

Pricing
Mechanism

(CONTINUED)

Cap of Incentive
Payments on Behalf
of Borrowers and to
Servicers & Lenders/
Investors (Cap)1

HAMP TRANSACTION DETAIL, AS OF 6/30/2012

Note

($614,527,362)
$236,000,000
($8,012)
$1,800,000
$100,000
($9,190)
$200,000
$300,000
($1,000,000)
($82,347)

9/30/2010
12/15/2010
1/6/2011
2/16/2011
3/16/2011
3/30/2011
4/13/2011
5/13/2011
6/16/2011
6/29/2011

$800,000
($17,600,000)
($2,100,000)
($23,900,000)
($63,800,000)
$20,000
($8,860,000)
($58,550)

11/16/2011
12/15/2011
2/16/2012
3/15/2012
4/16/2012
5/16/2012
6/14/2012
6/28/2012

$317,956,289

$105,500,000

9/30/2010

10/19/2011

($1,787,300,000)

7/14/2010

$120,600,000

$286,510,000

6/16/2010

10/14/2011

$10,280,000

4/19/2010

($1,400,000)

$905,010,000

3/26/2010

9/15/2011

$450,100,000

1/26/2010

($200,000)

$2,290,780,000

12/30/2009

($3,400,000)

($717,420,000)

9/30/2009

8/16/2011

$3,318,840,000

6/12/2009

7/14/2011

Cap Adjustment
Amount

Adjustment
Date

$6,667,130,828

$6,667,189,378

$6,676,049,378

$6,676,029,378

$6,739,829,378

$6,763,729,378

$6,765,829,378

$6,783,429,378

$6,782,629,378

$6,464,673,089

$6,344,073,089

$6,345,473,089

$6,348,873,089

$6,349,073,089

$6,349,155,436

$6,350,155,436

$6,349,855,436

$6,349,655,436

$6,349,664,626

$6,349,564,626

$6,347,764,626

$6,347,772,638

$6,111,772,638

$6,726,300,000

$6,620,800,000

$8,408,100,000

$8,121,590,000

$8,111,310,000

$7,206,300,000

$6,756,200,000

$4,465,420,000

$5,182,840,000

Updated due to quarterly assessment and
reallocation

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap from Home Loan Services,
Inc. and Wilshire Credit Corporation due
to merger.

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Updated due to quarterly assessment and
reallocation

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Updated due to quarterly assessment and
reallocation

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Updated portfolio data from servicer

Updated portfolio data from servicer

Updated portfolio data from servicer

Initial FHA-HAMP cap, initial FHA-2LP cap,
and initial RD-HAMP

Updated portfolio data from servicer

Transfer of cap from Wilshire Credit
Corporation due to servicing transfer

Transfer of cap from Wilshire Credit
Corporation due to servicing transfer

Updated portfolio data from servicer

Initial 2MP cap

Updated portfolio data from servicer &
HAFA initial cap

Updated portfolio data from servicer &
HPDP initial cap

Updated portfolio data from servicer

Adjusted Cap Reason for Adjustment

Adjustment Details

$116,254,108

Borrower’s
Incentives

$278,785,183

Lenders/
Investors
Incentives

$593,332,513

Total TARP
Incentive
Payments

Continued on next page

$198,293,222

Servicers
Incentives

TARP Incentive Payments

Transaction detail I Appendix D I July 25, 2012

279

Purchase

Purchase

Name of Institution

Home Loan Services, Inc.,
Pittsburgh, PA

Wilshire Credit Corporation,
Beaverton, OR

Date

4/20/2009

4/20/2009

Transaction
Type

Servicer Modifying Borrowers’ Loans

$319,000,000

$366,000,000

Financial
Instrument for
Home Loan
Modifications

Financial
Instrument for
Home Loan
Modifications

Investment
Description

N/A

N/A

Pricing
Mechanism

(CONTINUED)

Cap of Incentive
Payments on Behalf
of Borrowers and to
Servicers & Lenders/
Investors (Cap)1

HAMP TRANSACTION DETAIL, AS OF 6/30/2012

13

13

Note

($249,670,000)
$119,700,000

9/30/2009
12/30/2009

($100,000)
$68,565,782
($247)
($294)
($2,779)
($162,895,068)

9/30/2010
1/6/2011
3/30/2011
6/29/2011
10/19/2011

($210,000)

7/16/2010
8/13/2010

$19,540,000

($286,510,000)

7/14/2010

6/16/2010

($1,880,000)

$87,130,000

6/12/2009

5/14/2010

($155,061,221)

10/19/2011

$52,270,000

($2,625)

6/29/2011

($10,280,000)

($400,000)

5/13/2011

4/19/2010

($278)

3/30/2011

3/26/2010

($400,000)

($77,126,410)

9/30/2010

($1,900,000)

$6,700,000

9/30/2010

3/16/2011

($73,010,000)

7/14/2010

2/16/2011

($17,440,000)

3/26/2010

($233)

$145,820,000

12/30/2009

1/6/2011

$46,730,000

9/30/2009

($314,900,000)

$128,300,000

6/12/2009

12/15/2010

Cap Adjustment
Amount

Adjustment
Date

$1,657,394

$164,552,462

$164,555,241

$164,555,535

$164,555,782

$95,990,000

$96,090,000

$96,300,000

$76,760,000

$363,270,000

$365,150,000

$375,430,000

$323,160,000

$203,460,000

$453,130,000

$6,309,233

$161,370,454

$161,373,079

$161,773,079

$161,773,357

$162,173,357

$164,073,357

$164,073,590

$478,973,590

$556,100,000

$549,400,000

$622,410,000

$639,850,000

$494,030,000

$447,300,000

Termination of SPA

Updated due to quarterly assessment and
reallocation

Updated due to quarterly assessment and
reallocation

Updated portfolio data from servicer

Updated portfolio data from servicer

Transfer of cap due to servicing transfer

Transfer of cap to Green Tree Servicing
LLC due to servicing transfer

Updated portfolio data from servicer

Transfer of cap to Countrywide Home
Loans due to servicing transfer

Transfer of cap to GMAC Mortgage, Inc.
due to servicing transfer

Transfer of cap to Countrywide Home
Loans due to servicing transfer

Updated portfolio data from servicer

Updated portfolio data from servicer &
HAFA initial cap

Updated portfolio data from servicer &
HPDP initial cap

Updated portfolio data from servicer

Termination of SPA

Updated due to quarterly assessment and
reallocation

Transfer of cap due to servicing transfer

Updated due to quarterly assessment and
reallocation

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Updated portfolio data from servicer

Updated portfolio data from servicer

Updated portfolio data from servicer

Initial FHA-2LP cap

Updated portfolio data from servicer

Updated portfolio data from servicer

Updated portfolio data from servicer &
HAFA initial cap

Updated portfolio data from servicer &
HPDP initial cap

Updated portfolio data from servicer

Adjusted Cap Reason for Adjustment

Adjustment Details

$—

$169,858

Borrower’s
Incentives

$490,394

$2,440,768

Lenders/
Investors
Incentives

$1,657,394

$6,309,233

Total TARP
Incentive
Payments

Continued on next page

$1,167,000

$3,698,607

Servicers
Incentives

TARP Incentive Payments

280
Appendix D I Transaction Detail I July 25, 2012

Name of Institution

Green Tree Servicing LLC,
Saint Paul, MN

Date

4/24/2009

Purchase

Transaction
Type

Servicer Modifying Borrowers’ Loans

Financial
Instrument for
Home Loan
Modifications

Investment
Description

$156,000,000

N/A

Pricing
Mechanism

(CONTINUED)

Cap of Incentive
Payments on Behalf
of Borrowers and to
Servicers & Lenders/
Investors (Cap)1

HAMP TRANSACTION DETAIL, AS OF 6/30/2012

Note

$1,200,000
$100,000
($2,302)
$1,900,000
$200,000
$200,000
$400,000
$900,000
$100,000
$3,260,000
$920,000
($1,622)

6/29/2011
7/14/2011
9/15/2011
10/14/2011
11/16/2011
2/16/2012
3/15/2012
5/16/2012
6/14/2012
6/28/2012

($213)

1/6/2011

6/16/2011

$400,000

10/15/2010

5/13/2011

$10,185,090

9/30/2010

($250)

$5,600,000

9/30/2010

3/30/2011

$2,200,000
$34,600,000

9/10/2010

$210,000

7/16/2010
8/13/2010

$13,080,000
($24,220,000)

12/30/2009

7/14/2010

($116,750,000)

9/30/2009

3/26/2010

($64,990,000)
$130,780,000

6/17/2009

Cap Adjustment
Amount

Adjustment
Date

$156,270,703

$156,272,325

$155,352,325

$152,092,325

$151,992,325

$151,092,325

$150,692,325

$150,492,325

$150,292,325

$148,392,325

$148,394,627

$148,294,627

$147,094,627

$147,094,877

$147,095,090

$146,695,090

$136,510,000

$130,910,000

$96,310,000

$94,110,000

$93,900,000

$118,120,000

$105,040,000

$221,790,000

$91,010,000

Updated due to quarterly assessment and
reallocation

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Updated due to quarterly assessment and
reallocation

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Updated due to quarterly assessment and
reallocation

Updated portfolio data from servicer

Transfer of cap due to servicing transfer

Updated portfolio data from servicer

Initial FHA-2LP cap and FHA-HAMP

Initial 2MP cap

Transfer of cap due to servicing transfer

Transfer of cap from Wilshire Credit
Corporation due to servicing transfer

Updated portfolio data from servicer

Updated portfolio data from servicer

Updated portfolio data from servicer &
HAFA initial cap

Updated portfolio data from servicer &
HPDP initial cap

Updated portfolio data from servicer

Adjusted Cap Reason for Adjustment

Adjustment Details

$902,609

Borrower’s
Incentives

$2,815,171

Lenders/
Investors
Incentives

$6,174,718

Total TARP
Incentive
Payments

Continued on next page

$2,456,938

Servicers
Incentives

TARP Incentive Payments

Transaction detail I Appendix D I July 25, 2012

281

Purchase

Purchase

Name of Institution

Carrington Mortgage
Services, LLC,
Santa Ana, CA

Aurora Loan Services, LLC,
Littleton, CO

Date

4/27/2009

5/1/2009

Transaction
Type

Servicer Modifying Borrowers’ Loans

$195,000,000

$798,000,000

Financial
Instrument for
Home Loan
Modifications

Financial
Instrument for
Home Loan
Modifications

Investment
Description

N/A

N/A

Pricing
Mechanism

(CONTINUED)

Cap of Incentive
Payments on Behalf
of Borrowers and to
Servicers & Lenders/
Investors (Cap)1

HAMP TRANSACTION DETAIL, AS OF 6/30/2012

Note

$3,763,685
$300,000
($325)

9/30/2010
12/15/2010
1/6/2011

$2,240,000
($2,520)
($338,450,000)
($11,860,000)
$21,330,000

6/14/2012
6/28/2012
6/17/2009
9/30/2009
12/30/2009

($342)
($374)
$18,000,000
($3,273)
($200,000)
$100,000
($500,000)
($1,768)

1/6/2011
3/30/2011
5/13/2011
6/29/2011
10/14/2011
3/15/2012
4/16/2012
6/28/2012

($8,454,269)

$850,000

5/16/2012

9/30/2010

$100,000

4/16/2012

$400,000

$1,100,000

2/16/2012

9/1/2010

$1,000,000

11/16/2011

$9,150,000

$100,000

9/15/2011

($76,870,000)

$1,800,000

8/16/2011

7/14/2010

($3,592)

6/29/2011

3/26/2010

($384)

3/30/2011

$2,400,000

$1,100,000

8/13/2010

1/13/2011

$74,520,000

$57,980,000

12/30/2009

($75,610,000)

$90,990,000

9/30/2009

7/14/2010

($63,980,000)

6/17/2009

3/26/2010

Cap Adjustment
Amount

Adjustment
Date

$410,639,974

$410,641,742

$411,141,742

$411,041,742

$411,241,742

$411,245,015

$393,245,015

$393,245,389

$393,245,731

$401,700,000

$401,300,000

$478,170,000

$469,020,000

$447,690,000

$459,550,000

$293,646,864

$293,649,384

$291,409,384

$290,559,384

$290,459,384

$289,359,384

$288,359,384

$288,259,384

$286,459,384

$286,462,976

$286,463,360

$284,063,360

$284,063,685

$283,763,685

$280,000,000

$278,900,000

$354,510,000

$279,990,000

$222,010,000

$131,020,000

Updated due to quarterly assessment and
reallocation

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Updated due to quarterly assessment and
reallocation

Transfer of cap due to servicing transfer

Updated due to quarterly assessment and
reallocation

Updated portfolio data from servicer

Updated portfolio data from servicer

Initial FHA-HAMP cap

Updated portfolio data from servicer

Updated portfolio data from servicer

Updated portfolio data from servicer &
HAFA initial cap

Updated portfolio data from servicer &
HPDP initial cap

Updated portfolio data from servicer

Updated due to quarterly assessment and
reallocation

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Updated due to quarterly assessment and
reallocation

Updated due to quarterly assessment and
reallocation

Transfer of cap due to servicing transfer

Updated portfolio data from servicer

Updated portfolio data from servicer

Updated portfolio data from servicer

Transfer of cap due to servicing transfer

Updated portfolio data from servicer

Updated portfolio data from servicer

Updated portfolio data from servicer &
HAFA initial cap

Updated portfolio data from servicer &
HPDP initial cap

Updated portfolio data from servicer

Adjusted Cap Reason for Adjustment

Adjustment Details

$15,384,192

$4,594,845

Borrower’s
Incentives

$39,290,553

$14,313,396

Lenders/
Investors
Incentives

$82,572,012

$28,962,212

Total TARP
Incentive
Payments

Continued on next page

$27,897,267

$10,053,971

Servicers
Incentives

TARP Incentive Payments

282
Appendix D I Transaction Detail I July 25, 2012

Purchase

Purchase

Name of Institution

Nationstar Mortgage LLC,
Lewisville, TX

Residential Credit
Solutions, Fort Worth,TX

Date

5/28/2009

6/12/2009

Transaction
Type

Servicer Modifying Borrowers’ Loans

$101,000,000

$19,400,000

Financial
Instrument for
Home Loan
Modifications

Financial
Instrument for
Home Loan
Modifications

Investment
Description

N/A

N/A

Pricing
Mechanism

(CONTINUED)

Cap of Incentive
Payments on Behalf
of Borrowers and to
Servicers & Lenders/
Investors (Cap)1

HAMP TRANSACTION DETAIL, AS OF 6/30/2012

Note

$420,000
$8,060,000
($313)

6/28/2012

$2,800,000

6/14/2012

$29,386,554

($1,900,000)

9/15/2011
11/16/2011
5/16/2012

$31,286,554

($329)

6/29/2011

$40,666,241

$40,666,554

$32,606,554

$32,186,554

$31,286,883

$100,000

$31,186,883

$31,186,920

$31,186,954

4/13/2011

($34)

1/6/2011

($37)

$586,954

9/30/2010

$30,600,000

$30,200,000

$44,070,000

$45,460,000

$17,540,000

$400,980,993

$400,983,950

$403,363,950

$403,273,950

$403,373,950

$403,273,950

$403,278,198

$383,200,695

$383,201,123

$353,401,123

$352,501,123

$352,501,486

$350,801,486

$313,400,000

3/30/2011

$400,000

$27,920,000

12/30/2009

9/30/2010

($1,860,000)

9/30/2009

($1,390,000)

($2,957)

6/28/2012

($13,870,000)

($2,380,000)

6/14/2012

7/14/2010

$90,000

5/16/2012

3/26/2010

$100,000

($4,248)

6/29/2011

($100,000)

$20,077,503

5/26/2011

3/15/2012

($428)

3/30/2011

11/16/2011

$29,800,000

3/16/2011

$1,700,000

12/15/2010

$900,000

$700,000

2/16/2011

$33,801,486

9/30/2010
11/16/2010

($363)

$350,101,486

$2,900,000

9/30/2010

1/6/2011

$316,300,000

$100,000

8/13/2010

$313,300,000

$399,200,000

$67,250,000

$331,950,000

($85,900,000)

12/30/2009

$251,700,000

$117,140,000

7/14/2010

$80,250,000

9/30/2009

Updated due to quarterly assessment and
reallocation

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Updated due to quarterly assessment and
reallocation

Transfer of cap due to servicing transfer

Updated due to quarterly assessment and
reallocation

Updated portfolio data from servicer

Updated portfolio data from servicer

Initial FHA-HAMP cap, initial FHA-2LP cap,
and initial 2MP cap

Updated portfolio data from servicer

Updated portfolio data from servicer

Updated portfolio data from servicer &
HAFA initial cap

Updated portfolio data from servicer &
HPDP initial cap

Updated due to quarterly assessment and
reallocation

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Updated due to quarterly assessment and
reallocation

Transfer of cap due to servicing transfer

Updated due to quarterly assessment and
reallocation

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Updated portfolio data from servicer

Updated portfolio data from servicer

Transfer of cap due to servicing transfer

Updated portfolio data from servicer

Initial FHA-HAMP cap, initial FHA-2LP cap,
initial RD-HAMP, and initial 2MP cap

Transfer of cap due to servicing transfer

Updated portfolio data from servicer

Updated portfolio data from servicer

Updated portfolio data from servicer &
HAFA initial cap

Updated portfolio data from servicer &
HPDP initial cap

Updated portfolio data from servicer

Adjusted Cap Reason for Adjustment

3/26/2010

$16,140,000
$134,560,000

6/12/2009

Cap Adjustment
Amount

Adjustment
Date

Adjustment Details

$579,534

$10,184,365

Borrower’s
Incentives

$1,717,443

$24,123,922

Lenders/
Investors
Incentives

$3,609,266

$53,351,657

Total TARP
Incentive
Payments

Continued on next page

$1,312,289

$19,043,370

Servicers
Incentives

TARP Incentive Payments

Transaction detail I Appendix D I July 25, 2012

283

Purchase

Purchase

Purchase

Purchase

Name of Institution

CCO Mortgage,
Glen Allen, VA

RG Mortgage Corporation,
San Juan, PR

First Federal Savings
and Loan,
Port Angeles, WA

Wescom Central Credit
Union, Anaheim, CA

Date

6/17/2009

6/17/2009

6/19/2009

6/19/2009

Transaction
Type

Servicer Modifying Borrowers’ Loans

$16,520,000

$57,000,000

$770,000

$540,000

Financial
Instrument for
Home Loan
Modifications

Financial
Instrument for
Home Loan
Modifications

Financial
Instrument for
Home Loan
Modifications

Financial
Instrument for
Home Loan
Modifications

Investment
Description

N/A

N/A

N/A

N/A

Pricing
Mechanism

(CONTINUED)

Cap of Incentive
Payments on Behalf
of Borrowers and to
Servicers & Lenders/
Investors (Cap)1

HAMP TRANSACTION DETAIL, AS OF 6/30/2012

9,12

Note

($46)
($55)
($452)
($309)
($11,300,000)
($42,210,000)

1/6/2011
3/30/2011
6/29/2011
6/28/2012
9/30/2009
12/30/2009

($14,260,000)
($1,800,000)

3/26/2010
7/14/2010

($2)
($2)
($1,800,000)
($1,872,787)
$990,000

1/6/2011
3/30/2011
5/13/2011
6/3/2011
6/14/2012

$1,551,668

9/30/2010

$1,500,000

$16,490,000

12/30/2009

7/30/2010

$330,000

$2,020,000

12/30/2009

9/30/2009

($462)

6/28/2012

$11,370,000

($616)

6/29/2011

($14,160,000)

($65)

5/26/2010

($51)

1/6/2011
3/30/2011

3/26/2010

$37,040,795

($4,300,000)

12/15/2010

$1,668,877

$678,877

$2,551,664

$4,351,664

$4,351,666

$4,351,668

$2,800,000

$1,300,000

$3,100,000

$17,360,000

$870,000

$0

$14,160,000

$2,790,000

$37,039,652

$37,040,114

$37,040,730

$37,040,846

($4,459,154)

$41,340,846

$45,800,000

$54,660,000

$69,130,000

$3,490,000

$45,700,000

$42,645,484

$42,645,793

$42,646,245

$42,646,300

$42,646,346

$34,800,000

$58,150,000

$175,100,000

$29,590,000

Transfer of cap due to servicing transfer

Termination of SPA

Transfer of cap due to servicing transfer

Updated due to quarterly assessment and
reallocation

Updated portfolio data from servicer

Updated portfolio data from servicer

Updated portfolio data from servicer

Updated portfolio data from servicer

Updated portfolio data from servicer

Updated portfolio data from servicer &
HAFA initial cap

Updated portfolio data from servicer &
HPDP initial cap

Termination of SPA

Updated portfolio data from servicer

Updated portfolio data from servicer &
HAFA initial cap

Updated due to quarterly assessment and
reallocation

Updated due to quarterly assessment and
reallocation

Updated due to quarterly assessment and
reallocation

Updated portfolio data from servicer

Updated portfolio data from servicer

Updated portfolio data from servicer

Updated portfolio data from servicer

Updated portfolio data from servicer

Updated portfolio data from servicer

Updated portfolio data from servicer &
HAFA initial cap

Updated portfolio data from servicer &
HPDP initial cap

Updated due to quarterly assessment and
reallocation

Updated due to quarterly assessment and
reallocation

Updated due to quarterly assessment and
reallocation

Updated portfolio data from servicer

Updated portfolio data from servicer

Updated portfolio data from servicer

Updated portfolio data from servicer

Updated portfolio data from servicer &
HAFA initial cap

Updated portfolio data from servicer &
HPDP initial cap

Adjusted Cap Reason for Adjustment

9/30/2010

($8,860,000)

$7,846,346

9/30/2010

7/14/2010

($23,350,000)

7/14/2010

$65,640,000

($116,950,000)

3/26/2010

($14,470,000)

$145,510,000

12/30/2009

4/9/2010

$13,070,000

9/30/2009

3/26/2010

Cap Adjustment
Amount

Adjustment
Date

Adjustment Details

$93,546

$—

$164,853

$1,068,026

Borrower’s
Incentives

$374,719

$—

$227,582

$2,828,713

Lenders/
Investors
Incentives

$678,877

$—

$793,769

$6,019,345

Total TARP
Incentive
Payments

Continued on next page

$210,613

$—

$401,334

$2,122,605

Servicers
Incentives

TARP Incentive Payments

284
Appendix D I Transaction Detail I July 25, 2012

Purchase

Purchase

Purchase

Name of Institution

Citizens First Wholesale
Mortgage Company,
The Villages, FL

Technology Credit Union,
San Jose, CA

National City Bank,
Miamisburg, OH

Date

6/26/2009

6/26/2009

6/26/2009

Transaction
Type

Servicer Modifying Borrowers’ Loans

$30,000

$70,000

$294,980,000

Financial
Instrument for
Home Loan
Modifications

Financial
Instrument for
Home Loan
Modifications

Financial
Instrument for
Home Loan
Modifications

Investment
Description

N/A

N/A

N/A

Pricing
Mechanism

(CONTINUED)

Cap of Incentive
Payments on Behalf
of Borrowers and to
Servicers & Lenders/
Investors (Cap)1

HAMP TRANSACTION DETAIL, AS OF 6/30/2012

Note

$0

($300,000)
$200,000
($100,000)
$200,000
($10,000)
($6,771)

11/16/2011
1/13/2012
2/16/2012
3/15/2012
6/14/2012
6/28/2012

($9,197)

6/29/2011

$300,000

($200,000)

6/16/2011

8/16/2011

($200,000)

10/14/2011

($2,300,000)

5/13/2011

($981)

3/30/2011
4/13/2011

$200,000

($828)

1/6/2011

($100,000)

$71,230,004

9/30/2010

3/16/2011

$80,600,000

9/30/2010

2/16/2011

($18,690,000)
($272,640,000)

$90,280,000

12/30/2009

7/14/2010

$315,170,000

9/30/2009

3/26/2010

($9)

6/28/2012

$558,602,227

$558,608,998

$558,618,998

$558,418,998

$558,518,998

$558,318,998

$558,618,998

$558,318,998

$558,318,998

$558,328,195

$558,528,195

$558,728,195

$561,028,195

$561,029,176

$561,129,176

$560,929,176

$560,930,004

$489,700,000

$409,100,000

$681,740,000

$700,430,000

$610,150,000

$1,160,422

$1,160,431

($12)

$1,160,445

6/29/2011

$60,445

9/30/2010

$1,100,000

$1,530,000

$1,160,443

($430,000)

7/14/2010

3/30/2011

($720,000)

3/26/2010

$2,250,000

$1,160,444

$2,180,000

12/30/2009

$0

$145,056

$100,000

$30,000

$610,000

$20,000

Updated due to quarterly assessment and
reallocation

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Updated due to quarterly assessment and
reallocation

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Updated due to quarterly assessment and
reallocation

Transfer of cap due to servicing transfer

Transfer of cap due to servicing transfer

Updated portfolio data from servicer

Updated portfolio data from servicer

Initial FHA-HAMP cap, Initial FHA-2LP cap,
and initial 2MP cap

Updated portfolio data from servicer

Updated portfolio data from servicer

Updated portfolio data from servicer &
HAFA initial cap

Updated portfolio data from servicer &
HPDP initial cap

Updated due to quarterly assessment and
reallocation

Updated due to quarterly assessment and
reallocation

Updated due to quarterly assessment and
reallocation

Updated portfolio data from servicer

Updated portfolio data from servicer

Updated portfolio data from servicer

Updated portfolio data from servicer

Updated portfolio data from servicer &
HAFA initial cap

Termination of SPA

Updated portfolio data from servicer

Updated portfolio data from servicer

Updated portfolio data from servicer

Updated portfolio data from servicer &
HAFA initial cap

Updated portfolio data from servicer &
HPDP initial cap

Adjusted Cap Reason for Adjustment

1/6/2011

$45,056
($145,056)

2/17/2011

$70,000

9/30/2010

($580,000)

$590,000

12/30/2009

7/14/2010

($10,000)

9/30/2009

3/26/2010

Cap Adjustment
Amount

Adjustment
Date

Adjustment Details

$1,171,443

$24,250

$—

Borrower’s
Incentives

$4,218,459

$96,423

$—

Lenders/
Investors
Incentives

$8,096,738

$163,089

$—

Total TARP
Incentive
Payments

Continued on next page

$2,706,837

$42,417

$—

Servicers
Incentives

TARP Incentive Payments

Transaction detail I Appendix D I July 25, 2012

285

Purchase

Purchase

Purchase

Name of Institution

Wachovia Mortgage, FSB,
Des Moines, IA

Bayview Loan Servicing,
LLC, Coral Gables, FL

Lake National Bank,
Mentor, OH

Date

7/1/2009

7/1/2009

7/10/2009

Transaction
Type

Servicer Modifying Borrowers’ Loans

$634,010,000

$44,260,000

$100,000

Financial
Instrument for
Home Loan
Modifications

Financial
Instrument for
Home Loan
Modifications

Financial
Instrument for
Home Loan
Modifications

Investment
Description

N/A

N/A

N/A

Pricing
Mechanism

(CONTINUED)

Cap of Incentive
Payments on Behalf
of Borrowers and to
Servicers & Lenders/
Investors (Cap)1

HAMP TRANSACTION DETAIL, AS OF 6/30/2012

3

Note

$23,850,000
$43,590,000
$34,540,000
$1,010,000
($34,250,000)
$600,000
($15,252,303)
($70)
($86)

9/30/2009
12/30/2009
3/26/2010
5/7/2010
7/14/2010
9/30/2010
9/30/2010
1/6/2011
3/30/2011

$900,000
$2,400,000
($100,000)
$200,000
$30,000
$1,810,000
($508)
$150,000
$130,000
$50,000
($30,000)

10/14/2011
1/13/2012
2/16/2012
3/15/2012
4/16/2012
5/16/2012
6/14/2012
6/28/2012
9/30/2009
12/30/2009
3/26/2010
7/14/2010

$435,165
$435,159

($6)
($4)

3/30/2011
6/29/2011
6/28/2012

$435,155

$435,166

$435,167

$400,000

$430,000

$380,000

$250,000

$85,786,262

$85,786,770

$83,976,770

$83,946,770

$83,746,770

$83,846,770

$81,446,770

$80,546,770

$99,446,770

$98,846,770

$98,847,541

$98,747,541

$98,347,541

$98,347,627

$98,347,697

$113,600,000

$113,000,000

$147,250,000

$146,240,000

$111,700,000

$68,110,000

$238,890

$293,656

$2,050,530,000

$1,357,890,000

Updated due to quarterly assessment and
reallocation

Updated due t