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SIGTARP OFFICE OF THE SPECIAL INSPECTOR GENERAL FOR THE TROUBLED ASSET RELIEF PROGRAM QUARTERLY REPORT TO CONGRESS JANUARY 27, 2017 SIGTARP BY THE NUMBERS 374 Criminally Charged 269 * Convicted 192 ** Sentenced to Prison Including 88 Wall Street brokers criminally charged with securities fraud Defendants criminally charged with scamming homeowners Borrowers criminally charged with defrauding banks Bankers criminally charged with fraud $10 Billion Recovered from JP Morgan, General Motors,, Goldman Sachs, Morgan Stanley + Others $2 Billion In Government Cost Savings If SIGTARP Recommendations Are Implemented Recoveries include homeowner relief Charges are not evidence of guilt | Many defendants await trial and sentencing *Includes two reversed on appeal and two vacated due to death or cooperation **Includes two reversed on appeal As of January 4, 2017. LETTER FROM THE SPECIAL INSPECTOR GENERAL I am excited and honored to introduce you to SIGTARP. We are special agents, investigators, auditors, and forensic specialists Protecting taxpayer conducting oversight through audits and criminal investigations. dollars and Unlike most inspectors general, we conduct oversight not of an programs drives agency but a program: TARP—a program that goes beyond the bank SIGTARP’s mission bailout of 2008 and is far from over. Congress requires a dedicated or “special” inspector general because of TARP’s massive size and unprecedented nature. Under current TARP programs, Treasury will pay up to $14 billion through 2023. As a watchdog over these dollars, we will investigate and audit harmful and costly fraud, waste, and abuse. We will find crime, identify cost savings, and recover money lost to fraud. SIGTARP IS A 40 TIMES RETURN ON INVESTMENT SIGTARP has already had a significant, positive impact—far greater than would be expected for our small size—and we will continue that positive impact in 2017. We will stand guard over the more than $10 billion Treasury will pay through 2023, to 139 mortgage servicers (like Ocwen and Wells Fargo), and to 19 state agencies, 390 cities and other local partners, and hundreds of contractors. This year, as a law enforcement agency, we will also work to recover TARP funds lost to fraud. And we will not be a burden on taxpayers. With $10 billion in recoveries from our investigations (nearly $9 billion of which was recovered last year), we have already generated a 40 times return on investment compared to our annual budget.i Already in fiscal 2017, the Government recovered $52 million from our investigation with the Department of Justice into Ally Financial (formerly GMAC). This recovery exceeds our 2017 budget request, and helps offset the $2.47 billion in losses that Treasury suffered on the principal TARP investment into Ally.ii We also save the Government money as SIGTARP auditors have identified $2 billion in cost savings since 2013. Each quarter, Treasury spends approximately $1 billion on TARP housing programs, so in 2017, we will be looking for waste, mismanagement, inefficiency, and situations where dollars are at risk of being lost to fraud. Already this year, we identified costs savings in the $811 million blight demolition program. We recommended protections from overcharging and back room contracts, which Treasury is implementing, which will save up to $161 million. Right now, we are auditing how 19 state agencies spent nearly $700 million in administrative expenses paid by Treasury. If there is waste, we will find it. Already in this fiscal year, we have caught and exposed $8.2 million in waste by a Nevada state agency contractor who spent federal dollars earmarked for homeowners on parties, a cocktail bar, employee gifts, a Mercedes Benz for the CEO and more. SIGTARP recommended that Treasury fire the contractor and require the state agency to pay Treasury $8.2 million. Treasury has not taken this action. We achieve additional Government cost savings by deterring fraud and waste. Our exposure of waste in Nevada, and our publicly announced audit, serves to deter waste and fraud for the approximately $30 million a quarter Treasury pays to state agencies for their expenses in administering a TARP program. i As of end of fiscal year 2016, recovery number includes full homeowner relief by Goldman Sachs. ii Ally Financial paid Treasury TARP dividends and interest for Treasury taking on risk. Treasury wrote off the loss on the principal investment. SIGTARP makes Government better and our nation’s banking, housing, automobile, and securities industries safer and stronger In addition to returning money lost to fraud or waste, SIGTARP’s work keeps our nation’s industries safe. The bank fraud that we have found, and continue to find, hurts bank lending. We shut down homeowner abuse in all 50 states. The fraudulent sales tactics we have found, and continue to find, in the mortgage-backed securities industry fraudulently drives up traders’ sales commissions. One example of how we made the auto industry safer is the result of our investigation with U.S. Attorney Preet Bharara, where we found criminal conduct by TARP recipient General Motors that led to deaths and injuries.iii In the wake of our investigation, GM’s federal regulator changed its practices, and auto manufacturers now have a quicker response to rectify defects, with vehicle recalls skyrocketing from 20 million in 2013, to 50+ million in 2014, and 51+ million in 2015. Our past record shows that SIGTARP delivers, and we are poised to deliver equally strong results in the future. We deliver through targeted law enforcement and audit strategies. Sworn to protect TARP programs funded by Americans, we guard these dollars from fraud, waste, and abuse by not following precedent. Instead, we design our own oversight techniques – techniques that leverage best practices with data analytics and trend analysis. Right now, we are analyzing data and conducting trend analysis to find crime proactively in the $811 million demolition program, rather than solely relying on tips and referrals. As a result of SIGTARP investigations 88 bankers criminally charged, including 2 this quarter 44 bankers* already sentenced to prison Although most banks are now out of TARP, our special agents continue to investigate crime in those banks, particularly where Treasury took a loss. In 2017, we anticipate more bankers indicted and convicted, based on this quarter’s results: • A failed TARP bank chairman was sentenced to five years in federal prison. He was the 42nd banker (and 186th defendant) we investigated to be sentenced to prison. His fraud took down the bank causing $7 million in Treasury losses. • An officer at a bank currently in TARP was sentenced to 18 months in federal prison. His fraud nearly caused the bank to fail, hurt its ability to repay Treasury for TARP, and hurt its ability to lend to the community. * Includes one reversed on appeal. iii His office deferred prosecution of GM. GM: (1) admitted failing to disclose a safety defect to the National Highway Traffic Safety Administration and misleading U.S. consumers about that defect; (2) agreed to significant corporate changes to prevent the criminal conduct from repeating; and (3) paid $900 million to the Government. • The CEO and vice president of a failed TARP bank were indicted. Both were criminally charged in a fraud scheme.iv Our special agents and investigators continue to investigate crime in prior (and current) TARP banks because it hurts lending, and causes Treasury and taxpayer losses. Just as a bank robber must be prosecuted even if he repays what he stole, so must a banker who defrauded a bank that is now out of TARP. The reason is clear: they are more likely to repeat their crime if not stopped, and to hurt bank lending in the future. We have a significant number of open bank investigations, as well as investigating serious crime in the TARP-demolition program, and other areas. With our new investigative method of finding bank fraud, prosecutions are moving quickly compared to the past, and we recoup Treasury and FDIC lost funds – money then available for the government to spend or reduce the federal budget. I am excited to work with you, and would welcome an opportunity to talk to you further about how SIGTARP can add value in the upcoming year. Respectfully, CHRISTY GOLDSMITH ROMERO Special Inspector General iv An indictment contains an allegation that a defendant committed a crime. Every defendant is presumed innocent until and unless proven guilty. CONTENTS Section 1 SIGTARP INVESTIGATIONS SIGTARP Investigated Defendants Sentenced to Prison SIGTARP’s Unique Investigative Strategy Proposal to Congress: A New Law Enforcement Tool to Bring Accountability to the Insulated CEO Top Law Enforcement Priorities Section 2 SIGTARP AUDITS AND RECOMMENDATIONS Cost Savings to the Government from SIGTARP Recommendations Key Issues and High Risks in TARP Programs Priority Recommendations Section 3 SIGTARP’S OVERSIGHT BY TARP PROGRAM SIGTARP’S Oversight Over Capital Purchase Program Banks SIGTARP’S Oversight Over Community Development Capital Initiative Banks and Credit Unions SIGTARP’S Oversight Over Trading in Mortgage-Backed Securities Related to TARP SIGTARP’S Oversight Over the Auto Bailout SIGTARP’S Oversight Over HAMP SIGTARP’S Oversight Over the Hardest Hit Fund Endnotes APPENDICES A. Transactions Detail B. CDCI Recommendation Letter 3 6 12 13 16 21 23 25 28 33 35 55 60 67 70 86 204 214 286 SECT IO N 1 SIGTARP INVESTIGATIONS 4 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 LAW ENFORCEMENT MISSION SIGTARP is a federal law enforcement agency that targets financial institution crime. SIGTARP uses an analytical, experience-based approach to identify hidden crime at financial institutions. Our special agents have the authority to search, seize, and arrest. SIGTARP primarily investigates crime at financial institutions that received TARP funds to recover dollars lost to fraud and bring accountability through prosecution. We also investigate ongoing TARP housing programs, which Treasury is currently spending at a rate of about $1 billion per quarter. This includes the $811 million TARP-funded blight demolition program. Once our special agents, investigative attorneys, analysts and forensic agents build a strong case against an individual or financial institution, we work with the Justice Department and other prosecutors to bring justice to individuals and institutions that break the law, by taking the case to trial or securing a guilty plea. SIGTARP’s Investigative Results 40x $10 RATE OF RETURN BILLION RECOVERED* Based on SIGTARP’s Annual Budget *Includes Homeowner Relief 374 269 192 * Criminally Charged Convicted ** Sentenced to Prison Charges are not evidence of guilt. Every defendant is presumed innocent until and unless proven guilty in court. *Includes two reversed on appeal and two vacated due to death or cooperation. **Includes two reversed on appeal. Already 192 defendants investigated by SIGTARP have been sentenced to prison. 5 6 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM 44 BANKERS INVESTIGATED BY SIGTARP SENTENCED TO PRISON* Edward Woodard Stephen Fields Mark A. Conner Gilbert Lundstrom Shawn Leo Portmann Ebrahim Shabudin Catherine Kissick Troy Brandon Woodard Clayton A. Coe Gary Patton Hall Jerry J. Williams Adam Teague Zulfakir Esmail Jeffrey Levine William R. Beamon, Jr. Robert E. Maloney, Jr. Christopher Tumbaga James A. Laphen Charles Antonucci Jeff H. Bell Thomas Hebble Angel Guerzon Reginald Harper James Ladio 23 Years in Prison 5 Years Supervised Release CEO, President Bank of the Commonwealth 8 Years in Prison 3 Years Supervised Release Senior Vice President Colonial Bank 5 Years in Prison CEO, Chairman; President Premier Bank; Premier Bancorp 2 Years and 6 Months in Prison 2 Years Supervised Release CEO Park Avenue Bank 17 Years in Prison 5 Years Supervised Release Executive Vice President, Commercial Loan Officer Bank of the Commonwealth 8 Years in Prison 5 Years Supervised Release Vice President Bank of the Commonwealth (Subsidiary) 5 Years in Prison 5 Years Supervised Release Executive Vice President Omni Bank 2 Years and 6 Months in Prison 3 Years Supervised Release President; Head Factoring Division, Transportation Alliance Bank; Stearns Bank 12 Years in Prison 5 Years Supervised Release Acting CEO, Chairman, Vice Chairman, President, COO First City Bank 7 Years and 3 Months in Prison 5 Years Supervised Release Vice President, Senior Commercial Loan Officer FirstCity Bank 3 Years and 6 Months in Prison 5 Years Supervised Release Vice President Appalachian Community Bank 2 Years and 6 Months in Prison 3 Years Supervised Release Executive Vice President Orion Bank 11 Years in Prison 2 Years Supervised Release CEO, Chairman TierOne Bank 7 Years in Prison 3 Years Supervised Release CEO, President Tifton Bank 3 Years and 3 Months in Prison 3 Years Supervised Release In-house Attorney FirstCity Bank 2 Years in Prison 3 Years Supervised Release Senior Vice President Orion Bank 10 Years in Prison 5 Years Supervised Release Senior Vice President, Loan Officer Pierce Commercial Bank 6 Years in Prison 3 Years Supervised Release CEO, President, Chairman Orion Bank 3 Years in Prison 4 Years Supervised Release Commercial Loan Officer Colorado East Bank & Trust 2 Years in Prison 3 Years Supervised Release CEO, President First Community Bank 8 Years and 1 Month in Prison 3 Years Supervised Release Chief Credit Officer, Executive Vice President, Chief Operating Officer United Commercial Bank (UCBH) 5 Years and 10 Months in Prison 5 Years Supervised Release Senior Vice President Appalachian Community Bank 2 Years and 10 Months in Prison 2 Years Supervised Release Acting CEO, COO, President TierOne Bank 2 Years in Prison 3 Years Supervised Release CEO, President; Chief Lending Officer MidCoast Community Bank; Artisan’s Bank QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 Don A. Langford Karim Lawrence Allen Reichman Poppi Metaxas Paul Ryan *David Weinmert Michael Sean Davis Brian Hartline Jose Martins Matthew L. Morris Jeanette Salsi Brian W. Harrison Phillip Alan Owen Candice White Teresa Kelly Alice Lorrraine Barney Sonja Lightfoot Justin Brough Robert Pennington Helene DeCillis 1 Year and 9 Months in Prison 2 Years Supervised Release Chief Credit Officer, Senior Vice President TierOne Bank 1 Year and 3 Months in Prison President Premier Community Bank of the Emerald Coast; Bank of America, Beach Community Bank 6 Months in Prison 5 Years Supervised Release Branch Manager Superior Bank Time Served 5 Years Supervised Release Vice President Citizens First National Bank 1 Year and 9 Months in Prison 5 Years Supervised Release Vice President, Loan Officer Omni Bank 1 Year and 2 Months in Prison 3 Years Supervised Release CEO, President NOVA Bank 3 Months in Prison 5 Years Supervised Release Senior Vice President Front Range Bank Time Served 3 Years Supervised Release Chief Operating Officer Lend America, Gateway Bank 1 Year and 9 Months in Prison 2 Years Supervised Release Executive Director of Investments Oppenheimer 1 Year in Prison 3 Years Supervised Release Loan Officer Wells Fargo 3 Months in Prison 3 Years Supervised Release Operations Supervisor Colonial Bank 1 Year and 6 Months in Prison 3 Years Supervised Release CEO, President Gateway Bank 1 Year in Prison 2 Years Supervised Release Senior Vice President Park Avenue Bank 2 Months in Prison 3 Years Supervised Release Assistant to Shawn Portmann Pierce Commercial Bank 1 Year and 6 Months in Prison 3 Years Supervised Release Loan Officer Broadway Federal Bank 7 Months in Prison 3 Years Supervised Release Senior Underwriter Pierce Commercial Bank 1 Month in Prison 3 Years Supervised Release Senior Vice President of Residential Lending Pierce Commercial Bank 1 Year and 6 Months in Prison 3 Years Supervised Release Senior Vice President in Lending Administration; President, Anchor Bank; Investment Directions, Inc. (Subsidiary) Reversed on Appeal 6 Months in Prison 6 Months Supervised Release Vice President, Loan Officer Farmer’s Bank Time Served 5 Years Supervised Release Senior Vice President Bank of America 7 8 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM 37 BANKER CO-CONSPIRATORS INVESTIGATED BY SIGTARP SENTENCED TO PRISON Lee Bently Farkas Mark Anthony McBride George Hranowskyj Delroy Davy Wilbur Anthony Huff Eric Menden Lawrence Wright Desiree Brown Francesco Mileto Delton DeArmas William Cody Paul Chemidlin Richard Pinto [deceased] Dwight Etheridge Peter Pinto Leonard Potillo Paul Allen Brent Merriell Brian Headle Delio Coutinho Ray Bowman Carmine Fusco Tommy Arney Kenneth Sweetman Christopher Woods Matthew Amento Troy A. Fouquet Chester Peggese Salvatore Leone Carlos Peralta Alberto Solaroli Jose Luis Salguero Bedoya Christopher Ju Sean Ragland Mark W. Shoemaker Michael Bradley Bowen Yazmin Soto-Cruz 30 Years in Prison 3 Years Supervised Release Chairman, CEO Taylor, Bean & Whitaker (Colonial Bank Case) 6 Years in Prison 3 Years Supervised Release Vice President, Treasurer Taylor, Bean & Whitaker (Colonial Bank Case) 4 Years in Prison 3 Years Supervised Release CEO, President Oxford Collection Agency (Ally Financial, CitiGroup, JP Morgan, U.S. Bank, Webster Bank, Wells Fargo Case) 2 Years and 3 Months in Prison 3 Years Supervised Release Appraiser (Bank of America, CitiGroup, PNC Bank, U.S. Bank, Wells Fargo Case) 1 Year in Prison 3 Years Supervised Release Project Manager/Partner TBC Enterprises, LLC, North Dover Holdings, LLC, Shoppes at FieldStone Village, LLC (Wilmington Trust Case) 1 Day in Prison 5 Years Supervised Release C-Note Development Company LLC (GulfSouth Private Bank Case) 14 Years and 2 Months in Prison 5 Years Supervised Release (Omni National Bank Case) 5 Years and 5 Months in Prison 5 Years Supervised Release Owner Florida Metro One, LLC, Southeast Retail Portfolio, LLC, Trust Member, LLC, TMLS Heritage, LLC, (Orion Bank Case) 3 Years and 10 Months in Prison 3 Years Supervised Release Owner United Credit Recovery LLC (Ally Financial, CitiGroup, JP Morgan, U.S. Bank, Webster Bank, Wells Fargo Case) 2 Years and 3 Months in Prison 3 Years Supervised Release Owner/Operator Body Shop Go-Go club, Bootleggers, Maxwell’s Tavern (Bank of the Commonwealth Case) 1 Year in Prison 3 Years Supervised Release (Park Avenue Bank Case) 1 Day in Prison 3 Years Supervised Release (Bank of America, CitiGroup, PNC Bank, U.S. Bank, Wells Fargo Case) 14 Years in Prison 3 Years Supervised Release Owner/Operator 345 Granby, LLC, Norfolk Property Development LLC (Bank of the Commonwealth Case) 5 Years in Prison 3 Years Supervised Release CFO Taylor, Bean & Whitaker (Colonial Bank Case) 3 Years and 4 Months in Prison 2 Years Supervised Release CEO Taylor, Bean & Whitaker (Colonial Bank Case) 2 Years in Prison 3 Years Supervised Release Title Agent (Bank of America, CitiGroup, PNC Bank, U.S. Bank, Wells Fargo Case) 1 Year in Prison 2 Years Supervised Release Owner CET Racing (OneFinancial Corporation Case) 14 Years in Prison 5 Years Supervised Release Owner Quantum Builders LLC, Jamsen Properties LLC, Realty Group LLC, DNK Investment Group LLC (Omni National Bank Case) 5 Years in Prison 5 Years Supervised Release C&C Holdings, LLC, Global Southern Resources, LLC (GulfSouth Private Bank Case) 3 Years and 3 Months in Prison 5 Years Supervised Release (Omni National Bank Case) 1 Year and 6 Months in Prison 3 Years Supervised Release Owner/Operator Champ Construction LLC (Bank of America, CitiGroup, PNC Bank, U.S. Bank, Wells Fargo Case) 10 Months in Prison 3 Years Supervised Release Owner New Jersey Real Estate Holding, New Jersey Property Management (Bank of America, CitiGroup, PNC Bank, U.S. Bank, Wells Fargo Case) 12 Years in Prison 4 Years Supervised Release Owner O2HR, LLC, Oxygen Unlimited, LLC, General Employment Enterprises (Park Avenue Bank Case) 5 Years in Prison 3 Years Supervised Release (Bank of America, CitiGroup, PNC Bank, U.S. Bank, Wells Fargo Case) 3 Years in Prison 4 Years Supervised Release Owner Investment One LLC (ColoEast Bank and Trust Case) 1 Year and 6 Months in Prison 3 Years Supervised Release Owner/Operator Residential Real Estate and Construction, LLC (Bank of America, CitiGroup, PNC Bank, U.S. Bank, Wells Fargo Case) 10 Months in Prison 2 Years Probation Title Agent (Bank of America, CitiGroup, PNC Bank, U.S. Bank, Wells Fargo Case) 11 Years and 6 Months in Prison 3 Years Supervised Release Owner/Operator 345 Granby, LLC, Norfolk Property Development LLC (Bank of the Commonwealth Case) 5 Years in Prison 5 Years Supervised Release Chairman, co-founder Oxford Collection Agency (Ally Financial, CitiGroup, JP Morgan, U.S. Bank, Webster Bank, Wells Fargo Case) 3 Years in Prison 3 Years Supervised Release Loan Officer Ameridream (Bank of America, CitiGroup, PNC Bank, U.S. Bank, Wells Fargo Case) 1 Year and 6 Months in Prison 3 Years Supervised Release Owner Team Mgmt LLC, TRISA (First Community Bank Case) 3 Months in Prison 3 Years Supervised Release Senior Financial Analyst Taylor, Bean & Whitaker (Colonial Bank Case) 6 Years and 3 Months in Prison 5 Years Supervised Release Bluewater Real Estate Investments, LLC (GulfSouth Private Bank Case) 4 Years and 2 Months in Prison 5 Years Supervised Release Owner/Operator Tivest Development and Construction LLC (Bank of the Commonwealth Case) 2 Years and 6 Months in Prison 2 Years Supervised Release President Taylor, Bean & Whitaker (Colonial Bank Case) 1 Year in Prison 5 Years Supervised Release Loan Consultant (Broadway Federal Bank Case) 1 Day in Prison 5 Years Supervised Release Burnt Pine Properties, LLC (GulfSouth Private Bank Case) QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 22 DEFENDANTS WHO DEFRAUDED TARP BANKS INVESTIGATED BY SIGTARP SENTENCED TO PRISON David McMaster Robert Egan Scott Powers Edward Shannon Polen Chung Yu Yeung Bernard McGarry Steven Pitchersky Michael Edward Filmore Winston Shillingford Selim Zherka Cheri Fu Marleen Shilingford Clint Dukes Joseph D. Wheliss, Jr. Joseph L. Capano Thomas Fu Steven Moorhouse Robert Ilunga James Crews Michael Hilbert Pasquale Scarpa 15 Years and 8 Months in Prison 5 Years Supervised Release Vice President of Lending Operations AMS (Victim: BNC National Bank) 4 Years in Prison 5 Years Supervised Release Operator Healthcare Parnters Group, LLC (Victim: Pulaski Bank) 1 Year and 9 Months in Prison 5 Years Supervised Release Managing Member Riverbend Community LLC (Victim: Cecil Bank) Genaro Morales Time Served 2 Years Supervised Release (Victim: Capital One, Signature Bank, Sovereign Bank) 11 Years in Prison 5 Years Supervised Release President Mount Vernon Money Center (Victim: U.S. Bank, Webster Bank, Bank of America, NY Community Bank Corp) 4 Years in Prison 5 Years Supervised Release Co-owner Waikele Properties Corp (Victim: Goldman Sachs, Wells Fargo, JP Morgan, Deutsche Bank) 1 Year and 9 Months in Prison 5 Years Supervised Release CFO, Secretary, Treasurer Galleria USA (Victim: Bank of America, United Commercial Bank (UCBH), Cathay Bank, City National Bank, East National Bank, DBS Bank, United Overseas Bank) 8 Years in Prison 5 Years Supervised Release CEO AMS (Victim: BNC National Bank) 3 Years and 1 Month in Prison 5 Years Supervised Release Owner, Publisher Cheetah’s Gentleman’s Club, V.I.P Club, The Westchester Guardian (Victim: Capital One, Signature Bank, Sovereign Bank) 1 Year and 9 Months in Prison 5 Years Supervised Release President Jefsco Manufacturing Co., Inc. (aka Fanplastic Molding Company) (Victim: Old Second National Bank) 5 Years and 11 Months in Prison 5 Years Supervised Release Owner Polen’s Lawn Care (Victim: F&M Bank, U.S. Bank, Fifth Third Bank, Sumner Bank & Trust, Bank of Nashville, First Bank) 3 Years in Prison 5 Years Supervised Release President, owner Galleria USA (Victim: Bank of America, United Commercial Bank (UCBH), Cathay Bank, City National Bank, East National Bank, DBS Bank, United Overseas Bank) 1 Year and 6 Months in Prison 5 Years Supervised Release Operator Waikele Properties Corp (Victim: Goldman Sachs, Wells Fargo, JP Morgan, Deutsche Bank) 5 Years and 3 Months in Prison 5 Years Supervised Release Vice President ETQ, Eastern Tools and Equipment (Victim: United Commercial Bank 3 Years in Prison 5 Years Supervised Release Co-owner Waikele Properties Corp (Victim: Goldman Sachs, Wells Fargo, JP Morgan, Deutsche Bank) Time Served 5 Years Supervised Release (Victim: Excel Bank) 5 Years in Prison 5 Years Supervised Release COO Mount Vernon Money Center (Victim: U.S. Bank, Webster Bank, Bank of America, NY Community Bank Corp) 2 Years in Prison 5 Years Supervised Release Owner Dukes Auto Repair (Victim: First Community Bank, U.S. Bank) Time Served 5 Years Supervised Release (Victim: Excel Bank) 4 Years and 3 Months in Prison 5 Years Supervised Release Owner/Operator Nationwide Mortgage Concepts (Victim: Ally Bank) 2 Years in Prison 5 Years Supervised Release Owner National Embrodiery Works, Inc. (Victim: Pinnacle National Bank) Time Served 5 Years Supervised Release (Victim: Capital One, Signature Bank, Sovereign Bank) 9 10 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM DEFENDANTS INVESTIGATED BY SIGTARP WHO DEFRAUDED HOMEOWNERS AND WERE SENTENCED TO PRISON MORTGAGE SCAMMERS VICTIMIZING HOMEOWNERS 68 SENTENCED TO PRISON Ped Abghari 2 years Serj Geutssoyan 4 years Jonathan Lyons 1 year Joshua Sanchez 12 years Thomas J. Adams 364 days (suspended) Frederic Gladle 5 years Lori Macakanja 6 years Jason Sant 6 years Daniel Al Saffar 6 months Christopher S. Godfrey 7 years Aria Maleki 9 years Ziad Nabil Mohammed Al Saffar 1 year Angel Gonzalez Time served, 3 years supervised release Jefferson Maniscan 10 years Scott Schreiber Time served, 3 years supervised release Kristen Ayala 11 years Walter Bruce Harrell 1 year Michael Bates 1 year Jonathan L. Herbert 11 years Anthony Blackwell 1 year Mindy Holt 1 year Crystal Buck 5 years Najia Jalan 5 years Vernell Burris, Jr. 1 year Joshua David Johnson 10 years Jacob J. Cunningham 8 months Roger Jones 2 years Raymund Oquendo Dacanay 5 years Brian M. Kelly 1 year Catalina Deleon 2 years Darrell Keys Time served, 3 years supervised release Alberto DiRoberto 5 years Mark Farhood 11 years Dennis Fischer 7 years Dionysius Fiumano 16 years Gregory Flahive 1 year Christopher George 20 years Isaak Khafizov 9 years Cuong Huy King 1 year Justin D. Koelle 9 months Ray Kornfeld 5 years Michelle Lefaoseu 1 year John Linderman 2 years Mehdi Moarefian 4 years Duy K. Nguyen 1 year Dominic A. Nolan 6 months Lynn Nunes 1 year Yadira Padilla 4 years Michael Lewis Parker 6 years Iris Pelayo 4 years Isaac Joshua Perez 10 years Andrew M. Phalen 1 year Andrea Ramirez 18 years James Reese 364 days (suspended) Robyn Reese 364 days (suspended) Sara Beth Bushore Rosengrant 1 year Glenn Steven Rosofsky [deceased] 5 years Hamid Reza Shalviri 3 months Daniel Shiau 4 years Howard Shmuckler 7 years John D. Silva 8 months Alan Tikal 24 years Tamara Teresa Tikal 3 years Michael Trap 2 years Roscoe Ortega Umali 18 years John Vescera 1 year Glen Alan Ward 11 years Kowit Yuktanon 1 year QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 DEFENDANTS INVESTIGATED BY SIGTARP WHO SCAMMED TARP OR USED TARP TO SCAM INVESTORS SENTENCED TO PRISON SCAMS USING TARP 14 SENTENCED TO PRISON Julius Blackwelder 3 years Abraham Kirschenbaum 1 year Marvin Solis 2 years John Farahi 10 years Carla Lee Miller 8 months David Tamman 7 years Leigh Farrington Fiske 3 years Thomas Dickey Price 1 year Mark Steven Thompson 1 year Gordon Grigg 10 years Michael Ramdat 1 year Robert Wertheim 1 year Xue Heu 5 years Eduardo Garcia Sabag 3 months SIGTARP’s Impact Created to protect Federal bailout dollars distributed following the 2009 financial crisis, SIGTARP’s law enforcement has already had far greater impact than originally envisioned, and we have a significant number of open investigations. Banks: Our special agents and investigators continue to investigate crime in prior and current TARP banks because it hurts lending and causes Treasury and taxpayer losses. Just as a bank robber must be prosecuted even if he repays what he stole, so must a banker who defrauded a bank that is now out of TARP. The reason is clear: they are more likely to repeat their crime if not stopped and hurt bank lending in the future. SIGTARP pioneered a new wave of complex bank fraud investigations that has led to DOJ prosecutions for crimes. SIGTARP found, and continues to find, bankers committing bank fraud and securities fraud by cooking the books. SIGTARP is at the forefront of investigations into this type of bank fraud, which are not over. These bankers’ crimes often went undetected by bank regulators and law enforcement because it was hidden in complex transactions. Crime in banks must be caught and stopped because of its impact on the bank, local businesses, and economies (local, regional, and national). Banks need to lend, and law enforcement of crime by bank officers plays a role in that. Although most banks are now out of TARP, our special agents continue to investigate crime in those banks, particularly where Treasury took a loss. Most of SIGTARP’s cases against bankers 11 12 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM are not crisis-causing conduct and therefore could repeat, hurting a bank’s lending ability in the future. We have a significant number of open bank investigations, which are critical to continue because bank fraud hurts bank lending. If the bank failed, victims include hardworking Americans and local businesses that lost an important source of lending. Near failures, takeovers, or other weakened financial positions can also drain the bank’s ability to lend. And where Treasury, and taxpayers, and the FDIC took a loss in TARP because of the fraud, it is important for SIGTARP to use law enforcement tools to recover dollars that can offset that loss. In 2017, we anticipate more bankers indicted and convicted. With our new investigative method of finding bank fraud, prosecutions are moving quickly compared to the past, and we recoup Treasury and FDIC lost funds – money then available for the government to spend or reduce the federal budget. Residential Mortgage Backed Securities Industry: In the last year, we found fraud by Goldman Sachs, Morgan Stanley, Ally Financial, and others in disclosures to investors about residential mortgage backed securities. In addition, trials against RMBS traders who bought and traded these securities through a TARP-funded program are scheduled for this year, based on allegations of securities fraud. All of these cases are necessary for banks to lend and to have integrity in our securities industry. These cases give the American people confidence in banks and the justice system. SIGTARP’S UNIQUE INVESTIGATIVE STRATEGY Our past record shows that SIGTARP delivers, and we are poised to deliver equally strong results in the the future. We deliver through a targeted law enforcement strategy. Sworn to protect TARP programs funded by Americans, we guard these dollars from fraud and other crime not by following precedent. Instead we design our own oversight techniques – techniques that mirror best practices with data analytics and trend analysis. SIGTARP investigates financial institution fraud without distraction. Our special agents and other investigators use an analytical, experience-based approach to self-generate investigations and root out hidden crime, rather than rely on bank self-reporting or referrals from bank examiners. While bank self-reporting can identify traditional notions of bank fraud, it is not effective in identifying the type of fraud where top bank executives cook the books because that would require those bank officials to self-report their crimes. In addition, referrals from bank examiners are rare in SIGTARP investigations. SIGTARP uses its expertise of this type of fraud to analyze bank information (bank records and examiner reports) compared to red flags we have developed from our investigations. A bank’s application or receipt of TARP bailout funds brought QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 them within SIGTARP’s cross-jurisdictional bounds over TARP programs, which allows for comprehensive oversight including access to documents from multiple Federal and state agencies. Each of the red flags we have developed may seem inconsequential on their own, but collectively lead to SIGTARP developing an investigative process that has used trends about crime in banks to uncover hidden crime throughout the financial sector—an investigative process could be applied in the future throughout the banking and securities industry. SIGTARP has unique cross-cutting authority to prevent stove-piping because we have authority to investigate all involved in TARP programs and obtain documents across federal and state agency lines (such as from the FDIC, Federal Reserve, and the state banking regulator, who each may have examined the same bank). Right now, we are identifying red flags to find crime proactively with the $811 million demolition program, rather than solely relying on tips and referrals. SIGTARP’s work keeps our nation’s industries safe. For example, SIGTARP and U.S. Attorney Preet Bharara’s office found criminal conduct by General Motors related to a faulty ignition switch that caused the deaths of many young drivers, which led to a complete overhaul in the way auto companies and the Government deal with recalls of auto parts, improving safety. In the wake of our investigation, the federal regulator for auto companies changed its practices, and auto manufactuers now have a quicker response to rectify automobile defects, with vehicle recalls increasing from 20 million in 2013, to 51 million in 2014, to 51+ million in 2015. As an Office of Inspector General, SIGTARP also has a role in recommending change to prevent fraud, waste and abuse. Proposal To Congress: A New Law Enforcement Tool to Bring Accountability to the Insulated CEO “Require the CEO, CFO, COO, and CCO at the six largest Wall Street banks that took TARP bailout funds to sign an annual certification to law enforcement that they have conducted due diligence and can certify that there is no criminal conduct or civil fraud within their organization.” SIGTARP’s investigative approach has resulted in the successful prosecution of senior executives including 16 CEOs, 3 CFOs, and 6 COOs or CCOs at medium sized banks and smaller banks. In each of these cases, SIGTARP obtained evidence required to prove criminal intent of the bank official based on their knowledge of the fraud. In comparison, we have faced significant difficulties proving criminal intent of senior officials in large organizations that are designed to insulate high level officials from knowing about crime or civil fraud. 13 14 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM That’s why Special Inspector General Goldsmith Romero has proposed that Congress consider requiring an annual crime and fraud certification. Crime and fraud should have no protection, and corporate culture should not allow crime and fraud to go unchecked, but that starts with the tone at the top. This certification to law enforcement would apply to the six largest Wall Street banks, which collectively received more than $160 billion in TARP funds: Bank of America, Wells Fargo, Citigroup, Goldman Sachs, Morgan Stanley, and JP Morgan. All have faced a law enforcement action in recent years based on major violations of the law that caused massive harm to victims. Several of those actions resulted from SIGTARP’s investigations, which found major fraud in the way these banks conducted business. With each scandal, Congress holds hearings seeking accountability from CEOs who testify that they had no knowledge of the fraud. With only one exception – the New York Attorney General’s civil action against Bank of America’s former CEO and CFO, which SIGTARP jointly investigated – have the CEO or CFO of the six largest TARP banks ever been individually charged. SIGTARP does not have the law enforcement tools required to prove criminal intent of large bank CEOs, “SIGTARP does not have the law CFOs, COOs or CCOs as long as they enforcement tools to prove criminal continue to insulate themselves from knowledge of crime or fraud within intent of large bank CEOs, CFOs, their organization. Until CEOs, CFOs, COOs, or CCOs as long as they COOs and CCOs have an affirmative continue to insulate themselves from duty to look for crime or civil fraud in their organization, it is likely that they knowledge of crime or fraud within will continue to be “in the dark” about their organization.” wrongdoing. By staying in the dark, these high level officials lose a critical opportunity to stop the crime or fraud and save victims from harm. This is not accountability by any definition of the word. A change in the laws is required to remove the insulation around CEOs, CFOs, COOs and CCOs at these six Wall Street banks that took TARP funds. The enforcement tool Special Inspector General Goldsmith Romero proposes that Congress consider is to have the CEO, CFO, COO and CCO (or the equivalent to the CCO) at the six largest Wall Street banks that took TARP funds look for crime and fraud within their organization each year and certify to law enforcement that they have conducted due diligence and that there is no criminal conduct or civil fraud in their organization. Law enforcement agencies would not be relieved of their burden to prove criminal intent. Rather than assume no crime or fraud exists, due diligence makes it more likely that knowledge about the crime or fraud will rise all the way up to the CEO. Stopping fraud and immediately reporting it to law enforcement is the right response. If the executives cannot certify, they should call law enforcement, such as SIGTARP, immediately. It is not QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 likely that the senior executive would face law enforcement action if she conducted due diligence but was were duped by a rogue employee. One of an inspector general’s key roles is to recommend action to prevent fraud, which is the intent of this proposed law enforcement tool. Given SIGTARP’s authority related to TARP, the Special Inspector General proposes that Congress consider requiring that this certification apply to prevent crime and fraud at the six largest TARP bailed out banks. An annual certification requirement provides an incentive to CEOs, CFOs, COOs and CCOs to look for crime and fraud within their organization so that they can stop it. In other words, to give them an incentive to be “in the know” about crime or civil fraud within their company (particularly major fraud in the way the company does business), rather than stay “in the dark.” This is something that these CEOs, CFOs, COOs and CCOs should already be doing. The incentive for a CEO to be “in the know” about crime in his or her bank already exist naturally for CEOs of mid-sized and smaller banks because that crime can take down the bank. Changing incentives for leaders of the top six Wall Street banks that took TARP funds could change culture to one of increased accountability. Examples of Wall Street culture driven by dollars without regard for consequences are too well known, and examples of wrongdoing have become too many to accept. But our nation also has a culture that rewards integrity, transparency, and accountability – not a CEO, CFO, COO or CCO that insulates them from knowing about crime and fraud in their organization. The time is ripe to make a difference for the future. Otherwise, without this enforcement tool, history could repeat itself. Our nation must have one system of justice that can be applied equally. To do that, Congress could prevent Wall Street bank leaders from insulating themselves from crime and fraud in their organization. 15 16 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM TOP LAW ENFORCEMENT PRIORITIES Priority 1: Bring justice to bankers committing fraud including already more than 100 bankers charged with fraud offenses. 1 11 BAN K E R S CH AR G ED 88 Bankers Criminally Charged 23 Bankers Civilly Charged Obtaining indictments: SIGTARP has a significant number of open bank fraud investigations. These complex investigations and prosecutions take time, which is why bank fraud carries a 10 year statute of limitations. On December 16, 2016, a SIGTARP investigation resulted in the indictment of the CEO and Vice President of a TARP bank that failed, bringing the total number of bankers we investigated charged with a crime to 88. We expect more bankers to be indicted and our highest priority is to obtaining those indictments where we have uncovered evidence of fraud. In other investigations of bankers, we are still obtaining evidence to determine whether there is evidence of fraud for referral to prosecutors. Securing convictions: SIGTARP supports the prosecution of defendants we investigated because we provide the evidence that the DOJ needs at trial. In 2016, 6 additional bankers have been convicted, bringing the number of convicted bankers investigated by SIGTARP to 66, including through 8 trials supported by SIGTARP, as shown in Figure 1.1. This includes one conviction reversed on appeal, and one conviction vacated due to cooperation. We have several trials scheduled for 2017. QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 FIGURE 1.1 INCREASE IN BANKERS INVESTIGATED BY SIGTARP WHO WERE CONVICTED OF A CRIME (CUMULATIVE)* 80 70 66 60 60 50 45 40 30 30 22 20 12 10 0 0 2 +2 2009 +10 2010 +10 2011 +8 2012 +15 2013 +15 2014 +6 2015 2016 CALENDAR YEAR *Includes one reversed on appeal and one vacated due to cooperation. In 2016, 10 additional bankers investigated by SIGTARP were sentenced to prison, bringing the number of bankers we investigated who were sentenced to prison to 44, as shown in Figure 1.2. FIGURE 1.2 INCREASE IN BANKERS INVESTIGATED BY SIGTARP WHO WERE SENTENCED TO PRISON (CUMULATIVE)* 50 44 43 40 33 30 20 10 0 22 19 8 6 0 2009 +0 0 2010 +6 +2 2011 +11 2012 +3 2013 +11 2014 +10 2015 +1 2016 2017 CALENDAR YEAR *Includes one reversed on appeal. In addition, there are 10 other bankers SIGTARP investigated who have been sentenced with probation, which can often be the case when the banker pleads guilty and cooperates including by testifying at the trial of his co-conspirator banker. There are 10 bankers investigated by SIGTARP that have been convicted but not yet sentenced. There are an additional three bankers not criminally charged but who DOJ agreed to defer prosecution based on their cooperation and, 23 bankers 17 18 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM investigated by SIGTARP who were not charged with a crime, have been civilly charged with fraud. SIGTARP will seek civil enforcement, including through a United States’ Attorney’s Office, DOJ’s Civil Division, a state Attorney General, or in some cases, the Securities and Exchange Commission. For example, the former CEO of Bank of America Ken Lewis & the former CFO of Bank of America Joe Price were banned from banking and fined by the New York Attorney General for civil violations following a SIGTARP investigation. In addition, it is often the case that a banker criminally charged will also be civilly charged. In these cases, SIGTARP counts only the criminal charge. Priority 2: Bringing accountability to non-bankers charged with a crime through convictions and sentencing In addition to the 88 bankers charged with a crime, an additional 286 defendants investigated by SIGTARP have been charged with a crime, most related to financial institution fraud. This includes, for example, Wall Street traders criminally charged with securities fraud, borrowers criminally charged with defrauding banks, and defendants criminally charged with scamming homeowners seeking to apply to TARP’s housing program HAMP. Our success in an additional 10 trials of non-bankers in 7 years puts us on good footing to provide the evidence that future juries require to convict. Already, 192 defendants investigated by SIGTARP have been sentenced to prison. The average prison sentence of 58 months is nearly two-thirds higher than the national average for white collar crime (37 months), reflecting the severity of the harm and magnitude of the crimes we investigate. Priority 3: Assisting in recovering the proceeds of crime or fraud for victims or for forfeiture SIGTARP is ensuring that crime does not pay by taking the profit out of crime. Already $10 billion has been recovered as a result of SIGTARP investigations, money to victims that can be used for other government spending or reduce the government budget. $10 BILLION RECOVERED* *Includes homeowner relief. QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 SIGTARP assists in tracing proceeds of the crime, including land, houses, cars, and boats purchased with the proceeds of the crime. Property already seized or ordered to be forfeited in SIGTARP cases include: • More than 30 businesses and waterfront homes, • More than 70 bank accounts (including a bank account located in the Cayman Islands), • Bitcoin cryptocurrency, bags of silver, U.S. currency, antique and collector coins (including gold, silver, and copper coins), artwork, antique furniture, Civil War memorabilia, • NetSpend Visa and CashPass MasterCard debit cards, and Western Union money orders with the “Pay To” line blank, • A 1969 Shelby Mustang, a 1932 Ford Model A, a 1954 Cadillac Eldorado convertible, a 1963 Rolls Royce, a 1965 Shelby Cobra, a 2013 Ferrari 458 Italia, a 1948 Pontiac Silver Streak and a 1957 Cadillac Coup de Ville, • Other property in Figure 1.3 FIGURE 1.3 ORDERED FORFEITED AND SEIZED 2013 Ferrari 458 Italia 2005 54’ Hylas yacht “Swept Away” 1957 Cadillac Coupe de Ville. 1948 Pontiac Silver Streak. 2010 Mercedes-Benz GLK 350 4Matic. Estimated value in 2013: $29,000. (Source Kelley Blue Book) 2005 Hummer H2. Estimated value in 2013: $24,000. (Source Kelley Blue Book) 19 20 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM 1958 Mercedes-Benz Cabriolet 220. Estimated value in 2013: $185,000. (Source Hagerty.com) Property located in Chesapeake, Virginia. (Photo courtesy of Bill Tiernan, The Virginian-Pilot) French-style gilt, bronze, and green malachite columnar 16-light torchères with bronze candelabra arms. Estimated appraised value: $8,000. Cash seized from safe, $158,000. Kubota tractor. Artwork with a total value of $71,525, including paintings worth up to $10,000 each. 19th century English painting of “Royal Family,” oil on canvas. Estimated appraised value: $6,000. Bitcoin Cryptocurrency Seizures and forfeitures bring money back to victims and the Government and ensure that crime does not pay, as defendants are unable to keep the proceeds of their crime. This money can then be used for other Government spending or to reduce the Government budget. SECT IO N 2 SIGTARP AUDITS AND RECOMMENDATIONS 22 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 “SIGTARP identifies wasteful spending to help the Government recover taxpayer funds. We identify abuse and vulnerabilities that put Federal dollars at risk of fraud.” Special Inspector General Goldsmith Romero TARP goes beyond the bank bailout of 2008 and is far from over. Under current TARP programs, Treasury will pay up to $14 billion through 2023. As a watchdog over these dollars, SIGTARP audits ongoing TARP programs to prevent fraud, identify cost savings, wasteful spending, inefficiency and mismanagement. TARP housing programs are focused on saving the homes of America’s working class including: The Hardest Hit Fund $9.6 billion SIGTARP’S OVERSIGHT IS VALUE ADDED TO CONGRESS • • Unemployment assistance in the Rust Belt, southern states, and other states • Demolition of abandoned houses to stabilize neighborhoods Home Affordable Modification Program $27.8 billion • • Lower homeowner interest rates through contracts to pay mortgage servicers • SIGTARP acts as a watchdog over these Federal dollars and programs • When our team of forensic auditors, in depth auditors, and evaluators find a program at risk, they get to work reviewing documents, interviewing and analyzing. When an audit confirms a program is at risk, we look for ways to fix the problem by leveraging best practices with data analytics and trend analysis. We then issue recommendations to Treasury, which we share with Congress and the public. • Cost Savings to the Government from SIGTARP Recommendations We also save the Government money. SIGTARP has identified $2 billion in cost savings since 2013. Each quarter, Treasury spends approximately $1 billion on TARP housing programs, so in 2017, we will be looking for waste, mismanagement, inefficiency and situations where dollars are at risk of being lost to fraud. $2 BILLION COST SAVINGS TO THE GOVERNMENT Much of SIGTARP’s audit work is at the request of Members of Congress Reports widely covered by Members of Congress and media which helps drive change Forensic audit team with the ability to deep dive to root out waste and refer potential fraud to SIGTARP special agents Cross-authority jurisdiction allows SIGTARP to audit everyone involved in TARP programs, not just Treasury, allowing for more complete findings. This includes for example, state agencies, city agencies, demolition contractors and subcontractors, and mortgage servicers. 23 24 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM Already this year, we identified potential cost savings of up to $161 million in the $811 million TARP-funded blight demolition program. We recommended protections from overcharging and back room deals, which Treasury is implementing. Specifically, on December 23, 2016, Treasury implemented SIGTARP recommendations to limit TARP funds to limit reimbursing 390 local partners for only those demolition costs that are necessary and reasonable and to require full and open competition for these Federal dollars which will save the Government up to $161 million. There is much more in cost savings recommended by SIGTARP that SIGTARP has not quantified, but would save costs. These recommendations have not been implemented. Key Cost-Saving Recommendations Without Specified $ Remove Nevada contractor that wasted and abused $8.2 m in HHF (Potential cost savings of millions of dollars) State agencies should determine necessary and reasonable demolition costs using independent experts, 3rd party fair market price quotes and current and historical cost information. State agencies should effectively benchmark claims against the agency’s analysis of necessary & reasonable demolition costs. Prohibit state agencies from charging the Hardest Hit fund for 100% of overhead costs SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 Key Issues and High Risks in TARP Programs SIGTARP Identified Widespread Waste and Abuse in Nevada’s Hardest Hit Fund • $8.2 million in waste identified-including holiday parties, luxury office rent, employee gifts, and other wasteful expenses, even a $500 car allowance for a Mercedes Benz • At the same time, Nevada’s already low number of homeowners admitted to the Hardest Hit Fund plummeted by 94% • SIGTARP recommends firing of contractor used in HHF program and repayment of $8.2 million • The money has not been repaid and the contractor is still being paid by Treasury ONGOING AUDIT WORK Based on concerns raised by Senator Chuck Grassley, in October 2016, SIGTARP initiated an audit into the spending of $678 million of TARP funds to state agencies in HHF for administrative expenses. ONGOING AUDIT WORK Based on concerns raised by Representative Dina Titus, in October 2016, SIGTARP initiated a second audit into spending at HHF Nevada. Our exposure of waste in Nevada, and our publicly announced audits, serve to deter waste and fraud for the approximately $30 million each quarter that Treasury pays to state agencies for their expenses in administering the Hardest Hit Fund. 25 26 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM SIGTARP Identified Abuse: Indiana Hardest Hit Fund Used TARP Funds to Demolish Occupied Homes SIGTARP identified abuse of the blight demolition program to evict people in Indiana so their homes would qualify as vacant and use TARP funds for demolition, clearing the area for a car dealership to move there. The picture above is one of the actual homes demolished, despite the fact that Treasury’s contract with the Indiana state agency limited HHF to vacant Occupied house in Evansville, Indiana, demolished using TARP funds, photo provided to SIGTARP. and abandoned houses. Concerns over SIGTARP’s findings prompted the House Oversight Committee to schedule a hearing. Although the hearing did not go forward, Treasury issued guidance to all state agencies that a house must be abandoned to qualify for HHF demolition funding, as SIGTARP recommended. SIGTARP also recommended that the Indiana state agency repay $246,490 spent on demolishing these homes. That money has not been repaid. SIGTARP Identified TARP Demolition Program at Significant Risk of Overcharging, Fraud, and Unfair Competitive Practices That Could Drive Up Costs SIGTARP reported that the $800 million demolition program is significantly vulnerable to fraud, bid rigging, other closed door contract awards, and overcharging. The report found there are no federal competition requirements or limitations that federal funds only pay for costs that are necessary and reasonable (as exist in a similar Housing and Urban Blighted house used in PowerPoint for Evansville, Indiana, public meeting about HHF demolitions, photo provided to SIGTARP. Development program). SIGTARP reported that most state agencies also have no competition requirements and no state agency has requirements that demolition costs be limited to necessary and reasonable costs. There are 390 local partners and their subcontractors receiving these Federal dollars without those protections. SIGTARP recommended that these vulnerabilities be reduced by adopting similar requirements to HUD’s program, including requiring full and open competition and specific requirements to ensure full and open competition. In January, Treasury implemented SIGTARP’s recommendation to require full and open competition and limit SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 TARP reimbursement to necessary and reasonable costs. Other SIGTARP recommendations that have not been implemented are designed to 1) arm state agencies with knowledge of what demolition costs are necessary and reasonable, use that as a benchmark for claims for TARP funds; 2) ensure full and open competition,through specific competition requirements that exists in the HUD demolition program. New Audit Report Unnecessary Program Criteria May Be Preventing Homeowners Earning Less Than $30,000 from Entry Into HHF FIGURE 2.1 HHF DENIALS FOR HOMEOWNERS MAKING LESS THAN $30,000 PER YEAR Particularly in Michigan & Ohio Where GM and Suppliers Closed Plants There remains more than $2 billion in unspent TARP funds for the Hardest Hit Fund. One of an inspector general’s roles is to recommend changes to make programs more efficient. We did that in the report by analyzing the people turned down for the Hardest Hit Fund by state agencies. SIGTARP found that most of the people who were denied HHF funds earned less than $30,000 per year, calling into question whether the program is efficient in reaching those hardest hit. State agencies paid by Treasury to distribute Hardest Hit Fund unemployment assistance turned down 84,965 people who earned less than $30,000, including 64,979 people who made less than $20,000. As shown in Figure 2.1, SIGTARP found that, in 12 of the 19 states—mostly in the Rust Belt and south—nearly three out of four people turned down for these Federal funds earned less than $30,000 per year. Figure 2.1 shows the percentage of homeowners denied assistance who made less than $30,000 per year. Congress required that these TARP funds be used to bail out American workers, not just to bail out companies like General Motors. HHF funds could help autoworkers laid off when General Motors shut down their plants, as well as workers caught in the ripple effect of a shutdown, like workers at auto parts suppliers or at neighboring retail shops. Michigan and Ohio are among the states that have the most TARP dollars set aside, but also have some of the highest percentages of people turned down for the Hardest Hit Fund who earned less than $30,000. In cities where General Motors— which received $50 billion in TARP funds—or its suppliers closed plants or laid off workers, denial rates are even higher for those who made less than $30,000 per year as shown in Figure 2.2. Despite returning to profitability, GM and other auto companies closed plants and laid off workers, even in the last year. GM announced that 2,000 additional workers in Michigan and Ohio face layoffs early in the coming year. The findings uncovered by this evaluation indicate that there may be eligibility criteria that are too stringent. There may be valid reasons why these people were turned down, but it is impossible to know because SIGTARP found that state Source: SIGTARP, Audit Report “Improving TARP’s Investment in American Workers”, 1/11/2017, https://www.sigtarp.gov/Audit%20Reports/SIGTARP_HHF_Florida_Report.pdf, accessed 1/13/2017. FIGURE 2.2 PERCENTAGE OF DENIED WORKERS WHO EARNED LESS THAN $30,000, BY CITY * Includes Dayton and nearby cities of Moraine and Vandalia, Ohio. Combined, these cities denied 238 homeowners who earned less than $30,000. Source: SIGTARP, Audit Report “Improving TARP’s Investment in American Workers”, 1/11/2017, https://www.sigtarp.gov/Audit%20Reports/SIGTARP_HHF_Florida_Report.pdf, accessed 1/13/2017. 27 28 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM agencies’ records were non-existent, missing, or incomplete regarding why the agencies turned down people making less than $30,000 per year. State agencies should unlock the full potential of the program by eliminating unnecessary criteria that do not exist in other states or that do not reflect the reality of the working class in that state. For example, some states require that the person show enough income to pay their mortgage in the future, which is not realistic for some people seeking temporary help with their mortgage until they can get a full time job. This program has a lot more potential to provide a safety net in certain communities until jobs return to these towns, but that potential needs to be unlocked. ONGOING AUDIT WORK Based on concerns raised by Representative John Lewis, in September 2016, SIGTARP initiated an audit to determine whether HHF has adequately served those most in need of assistance in selected Georgia counties, and to identify areas for improvement. Priority Recommendations SIGTARP’s recommendations have the power to drive improvements in program effectiveness and efficiency, and prevent fraud, waste, abuse, and mismanagement of TARP dollars and programs. Priority recommendations that remain unimplemented are as follows: PRIORITY RECOMMENDATIONS Implement specific requirements that ensure full & open competition for blight demolition Establish necessary and reasonable demolition costs using independent experts, 3rd party fair market value quotes and current/historical costs Benchmark claims against necessary and reasonable cost analysis In January, Treasury implemented SIGTARP recommendations to require full and open competition and limit TARP reimbursement to necessary and reasonable demolition costs. These changes have the potential to save up to $161 million for the federal government. However, SIGTARP has additional recommendations in SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 the same audit that remain unimplemented. Without implementation of these related priority SIGTARP recommendations to provide the same protections as exist in HUD’s demolition program, this program is at risk. Treasury still can take action to mitigate these vulnerabilities to fraud and waste. SIGTARP recommended the state agency develop their own analysis of necessary and reasonable costs using independent experts, 3rd party fair market value quotes and current and historical costs. SIGTARP also recommended that state agencies benchmark claims against this analysis and require substantial justification for any claim that exceeds the benchmark. SIGTARP also made additional recommendations to implement requirements that exist in the HUD demolition program – requirements that ensure full and open competition. For example, full and open competition would prohibit requests for bids where only a certain small number of contractors could qualify. PRIORITY RECOMMENDATIONS Seek repayment of $8.2 million in waste from Nevada contractor Remove contractor from TARP By Treasury not seeking repayment of waste SIGTARP identified, the contractor chosen by the Nevada state agency is keeping TARP dollars that it wasted and abused. Any entity that was willing to abuse Federal dollars for lavish spending on their employees exposes the program to further waste and abuse. Protecting TARP from waste and abuse requires the removal of the contractor. NEW PRIORITY RECOMMENDATIONS Eliminate unnecessary criteria that may preclude lower-income workers from HHF Unemployment Bridge Maintain detailed records of why each person was denied HHF Unemployment Bridge Allow workers facing upcoming layoffs to be eligible for HHF before becoming past-due on their mortgage These three criteria are SIGTARP’s latest recommendations from its January 2017 audit, as discussed in more detail above. 29 30 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM PRIORITY RECOMMENDATIONS Take action to curb people canceling out of HAMP Determine extent of servicer misconduct in canceled homeowners (violation of Treasury contract) Ensure servicers properly transfer HAMP contract with transferred mortgage (violation of Treasury contract) Suspend and/or claw back Federal dollars when servicers violate Treasury’s contract With $7.5 billion already committed under Treasury contracts to pay to servicers, and potentially another $4 billion, HAMP requires strong oversight. Limiting the number of homeowners canceling out of HAMP represents a cost savings to the Government. SIGTARP made a series of recommendations to curb people canceling out of HAMP, some of which Treasury is in process of implementing, and some of which Treasury has not implemented. For example, SIGTARP recommended that Treasury analyze to what extent servicer misconduct contributes to homeowners canceling out of HAMP. Upon a SIGTARP recommendation, Treasury now looks for servicer misconduct in its compliance reviews of larger servicers but only on a small sample size. Despite finding over and over again that several of the largest servicers have wrongfully canceled people out of HAMP in violation of Treasury’s contract,Treasury then takes limited action. Treasury only requires servicers to put back into HAMP those specific wronged homeowners. Requiring servicers to conduct independent reviews and report to Treasury on all homeowners they wrongly canceled out of HAMP would help those homeowners, stop wasted taxpayer dollars, and lead to stronger servicer controls to prevent future contract violations. And SIGTARP recommended that Treasury ensure that all servicers comply with HAMP rules by vigorously enforcing the terms of Treasury contracts including withholding, permanently reducing, and clawing back TARP payments. Large servicers such as Ocwen, Wells Fargo, Bank of America and Nationstar should not continue to be paid significant TARP funds while they break Federal rules under their contract with Treasury. SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 NEW RECOMMENDATIONS Treasury not indicate what discount it will accept from banks still in TARP Treasury memorialize decision making on losses on TARP banks Treasury review proposals to take a loss on a bank consistently This past quarter, in November 2016, SIGTARP made new recommendations to Treasury to protect taxpayer dollars as Treasury negotiates for small banks and credit unions in the CDCI program to repay TARP amounts owed earlier than expected, and at a discount. SIGTARP recommended that Treasury not indicate what discount it will accept, memorialize decision making when taking a loss, review proposals consistently, publish losses taken, consult with the primary regulator, and provide SIGTARP with the identity of any CDCI institution repurchasing at a loss in case SIGTARP is performing a related criminal investigation. These recommendations are designed to limit taxpayer loss by ensuring that taxpayers get the highest repayment and facilitate oversight. SIGTARP’s letter to Treasury containing these and other recommendations, and Treasury’s response can be found in Appendix B. Treasury did not agree to implement SIGTARP’s recommendations, stating that they believed existing practices addressed the issues SIGTARP identified. SIGTARP was well aware of Treasury’s processes before making the recommendations and did not view those processes as sufficient to ensure taxpayers get the highest repayment or that the processes facilitate effective oversight of TARP. Without action to implement SIGTARP’s recommendations, Treasury is missing out on cost savings. 31 32 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM SECT IO N 3 SIGTARP’S OVERSIGHT BY TARP PROGRAM 34 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 SIGTARP’S OVERSIGHT OVER CAPITAL PURCHASE PROGRAM BANKS SIGTARP conducts oversight over the $204.9 billion—707—bank bailout known as the Capital Purchase Program primarily through its investigations, with limited audit work.1 SIGTARP Investigations Related to Capital Purchase Program Banks SIGTARP’s investigations are not limited to those banks still in TARP. Just as a bank robber must be prosecuted even if he repays what he stole, so must a banker who defrauded a bank that is now out of TARP. The reason is clear: they are more likely to repeat their crime if not stopped. SIGTARP began in 2009 and could not have possibly found all crime and had prosecutions in the following two years as most banks exited TARP. The bank fraud we find is not all crisis-causing misconduct, so it could very likely repeat, and hurt bank lending in the future. These complex cases take significant time, which is why bank fraud has a 10 year statute of limitations from the date of the last act of the fraud or conspiracy. SIGTARP often uncovers bank fraud conspiracies that continued for several years undetected. SIGTARP’s investigations have already resulted in: 35 36 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM RESULTS OF SIGTARP’S CPP INVESTIGATIONS BANKERS 88 INDICTED 66 CONVICTED* 44 SENTENCED** TO PRISON *As of January 4, 2017. *Includes one reversed on appeal and one vacated due to cooperation. **Includes one reversed on appeal. BANKER’S CO-CONSPIRATORS 85 INDICTED 51 CONVICTED 37 SENTENCED TO PRISON BORROWERS DEFRAUDING BANKS 46 INDICTED 32 CONVICTED 22 SENTENCED TO PRISON SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 SIGTARP Investigations of Capital Purchase Program Banks Still in TARP As of December 31, 2016, 22 banks remain in TARP (either with principal outstanding or with Treasury holding securities known as warrants) as shown in Table 3.1. SIGTARP’s investigations have resulted in criminal prosecutions involving 7 of the 22 banks still in TARP. TABLE 3.1 REMAINING CPP BANKS, AS OF 12/31/2016 ($ MILLIONS) Institution TARP Investment Outstanding Investment Warrants Remaining Missed Dividends SIGTARP Investigation Synovus Financial Corp. $967,870,000.00 $0 2,215,820 $0 First Bancorp (PR) $400,000,000.00 $124,966,504 1,285,900 $0 Wilmington Trust Corporation / M&T Bank Corporation $330,000,000.00 $0 95,383 $0 Hampton Roads Bankshares, Inc. $80,347,000.00 $0 757,633 $4,017,350 Porter Bancorp, Inc.(PBI) $35,000,000.00 $0 330,561 $6,737,500 Royal Bancshares Of Pennsylvania, Inc. $30,407,000.00 $0 1,368,041 $7,601,750 Severn Bancorp, Inc. $23,393,000.00 $0 556,976 $1,754,475 OneFinancial Corporation $17,300,000.00 $17,300,000 — $9,248,613 ✓ Broadway Financial Corporation $15,000,000.00 $8,047,221 — $0 ✓ Village Bank And Trust Financial Corp. $14,738,000.00 $0 31,189 $2,026,475 One United Bank $12,063,000.00 $12,063,000 — $6,001,343 Cecil Bancorp, Inc. $11,560,000.00 $11,560,000 523,076 $5,317,600 Harbor Bankshares Corporation $6,800,000.00 $6,800,000 — $2,822,000 Pacific International Bancorp / BBCN Bancorp, Inc. $6,500,000.00 $0 19,420 $0 Citizens Commerce Bancshares, Inc. $6,300,000.00 $6,300,000 — $3,182,288 Pinnacle Bank Holding Company, Inc. $4,389,000.00 $4,389,000 267,455 $1,993,440 AB&T Financial Corporation $3,500,000.00 $0 80,153 $481,250 Treaty Oak Bancorp, Inc. $3,268,000.00 $0 3,098,341 $133,553 Grand Mountain Bancshares, Inc. $3,076,000.00 $3,076,000 — $1,527,770 St. Johns Bancshares, Inc. $3,000,000.00 $3,000,000 — $0 Saigon National Bank / California International Bank, N.A. $1,549,000.00 $1,549,000 — $836,523 $1,976,060,000.00 $199,050,724 10,629,947 $53,681,928 Total Notes: Numbers may not total due to rounding. ✓ ✓ ✓ ✓ ✓ 37 38 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM For examplei: Wilmington Trust: Following a SIGTARP investigation, on January 6, 2016, TARP recipient Wilmington Trust Corporation was indicted, charged with concealing from the Federal Reserve, the Securities and Exchange Commission (SEC) and the investing public the total quantity of past due loans on its books from October 2009 through November 2010. Four senior bank officers were indicted in 2015, President Robert V.A. Harra, CFO David Gibson, CCO William North, and Controller Kevyn Rakowski. Wilmington Trust was required to report in its quarterly filings with both the SEC and the Federal Reserve the quantity of its loans for which payment was past due for 90 days or more. Investors and banking regulators consider the amount of past due loans at a bank as an important metric in evaluating the health of a bank’s loan portfolio. According to the indictment, Wilmington Trust, through the actions of defendants Harra, Gibson, North, and Rakowski, concealed the truth about the health of its loan portfolio from the SEC, the investing public and from Wilmington Trust’s regulators. During the course of the alleged conspiracy, in February 2010, Wilmington Trust raised approximately $273.9 million through a public stock offering. In November 2010, Wilmington Trust announced an agreement to be acquired by M&T Bank at a price of $3.84 per share, a discount of approximately 46% from the bank’s share price the prior trading day, and approximately $9.41 per share less than at the time of Wilmington Trust’s capital raise in February 2010. The decline in price from February represented a loss of $204 million in total market value of the shares bought during the capital raise.2 Three Wilmington Trust bank officers have already been convicted of crimes. Joseph Terranova, the bank’s Vice President/Division Manager of the Delaware Commercial Real Estate Division pled guilty to bank fraud conspiracy. Brian Bailey, the bank’s Delaware market manager overseeing all lending in the state pled guilty to conspiracy to commit an offense against the United States. Both conspired to conceal the bank’s true condition by extending new loans to clients to enable those clients to keep existing loans current and by causing the bank to misreport its reporting of past due and non-performing loans to the FDIC and the Federal Reserve. The bank underreported its past due and nonperforming loans by approximately $186 million in the first quarter of 2009; $234 million in the second quarter 2009; $463 million in the third quarter of 2009; and $373 million in the fourth quarter 2009.3 The conspiracy also involved extending credit to bank customers under terms inconsistent with what was approved by the bank’s loan committee, including to Dover real estate developer Michael Zimmerman who was also indicted.4 Bank Officer Bailey separately conspired with James Ladio, the former CEO of MidCoast Community Bank, over a 12-year period to make 20 loans to each other i An indictment contains allegations that a defendant has committed a crime. Every defendant is presumed innocent until and unless proven guilty. SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 totalling more than $1.5 million. Ladio, who used the loans to pay off personal debt, was sentenced to two years in prison. Bank Loan Officer Peter Hayes pled guilty to accepting a gift for procuring loans. During a four-year period Hayes admitted to funding millions of dollars in loans to one customer based on materially false statements or in contravention of loan agreements. He purchased two model homes from the customer, with the customer agreeing to pay Hayes’ mortgage. When Hayes sold the model homes and owed another $70,000, Hayes requested a loan from the customer, which came out of the customer’s operating account at Wilmington Trust. Additionally, Salvatore Leone was sentenced to one year and one day in prison and ordered to pay $784,568 to Wilmington Trust for fraudulently drawing down on bank construction loans by submitting phony invoices for work not performed, duplicate invoices, and false invoices, and diverting the bank funds to other construction projects and his own pockets. Saigon National Bank: In December 2015, SIGTARP agents, alongside other Federal law enforcement authorities, arrested 15 defendants (and charged 20 defendants across three indictments) in Operation “Phantom Bank,” a series of alleged money laundering schemes that involved international narcotics trafficking and money laundering; some through Saigon National Bank.ii One of the indictments—a sixteen-defendant, 109 page racketeering indictment—charged six individuals with violating the Federal Racketeer-Influenced and Corrupt Organizations Act by playing key roles in a series of schemes to launder drug proceeds, that revolved around former bank CEO and President Tu Chau “Bill” Lu from 2009 through January 2015. The RICO count alleges that Lu and 5 other defendants were members of a criminal organization that was involved in narcotics trafficking and international money laundering in countries that included the United States, China, Cambodia, Liechtenstein, Mexico, and Switzerland. The indictment alleges that Lu used his “insider knowledge, position as an official at Saigon National Bank, and network of connections to promote and facilitate money laundering transactions involving members and associates of the enterprise.” According to the indictment, several members of the organization engaged in separate money laundering schemes, but “all working with, through, or at the instigation of defendant Lu.” In one scheme, in the indictment it is alleged that an undercover informant delivered cash represented to be drug proceeds to defendants, who arranged for the cash to be converted to cashier’s checks made out to a company the informant allegedly owned. Other conspiracies discussed in the RICO count of the indictment allege the delivery of cash from the informant, and that money was allegedly converted into cashier’s checks. As part of the racketeering enterprise, Lu and others named in the RICO count allegedly floated a plan in which the informant and his boss (an uncover law enforcement officer) would purchase ii An indictment contains allegations that a defendant has committed a crime. Every defendant is presumed innocent until and unless proven guilty. 39 40 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM a controlling interest in Saigon National Bank so they could have a financial institution which could easily facilitate money laundering operations. In another aspect of the RICO conspiracy, Lu allegedly played a critical role in introducing to the informant, and other RICO defendants, operatives from a drug cartel who wanted to launder millions of dollars every month. According to the indictment, Lu also had conversations with cartel operatives about purchasing Saigon National Bank, and one of the operatives said the cartel had already invested $1 million in the bank. The indictment details money laundering transactions involving a total of $3.75 million. Since the arrests in December 2015, three additional defendants were charged with money laundering. Saigon National Bank was one of 12 TARP banks to reject Treasury’s request to send an observer to the bank’s board meetings. One Financial Corp: Following a SIGTARP investigation, DOJ filed a False Claims Act suit and a forfeiture action, alleging that the late Layton P. Stuart, former CEO and President of One Financial Corp., in Little Rock, Arkansas, obtained $17.3 million in TARP funds under false pretenses and diverted some of those funds for personal use including the purchase of luxury vehicles for his wife and children. Within two weeks of receiving TARP funds, Stuart also diverted $2.185 million into his personal accounts. On September 30, 2015, the case against CEO Stuart’s estate was settled, with the estate paying the Government $4 million and $6.9 million to One Financial’s subsidiary One Bank. In January 2016, the Government won a $47,905,000 default judgment against One Financial. In an unrelated scheme regarding a bank loan to borrower Alberto Solaroli, following a SIGTARP investigation, 5 One Bank officers were indicted. Senior Executive Vice President Gary Rickenbach was convicted, and sentenced to probation after testifying at a trial of 2 other bank officers who were acquitted by the jury. On March 2, 2016, Solaroli was sentenced to one year in prison and required to pay $120,000 in restitution. Broadway Bank: Following a SIGTARP investigation, on October 26, 2016, Broadway Bank Loan Officer Paul Ryan was sentenced to 18 months in prison. The bank, according to a L.A. Times story, “had long provided loans to local houses of worship, but in 2007, with Ryan’s help, it started lending to churches across the country.” Many of those loans defaulted, causing at least $5 million in loses. Ryan abused his position of trust and caused losses at TARP recipient Broadway Federal Bank by knowingly allowing borrowers to use inflated financial information in loan applications. In this mortgage scheme aimed at predominately African-American churches, he demanded more than $350,000 in bribes from brokers. One of the brokers who paid kickbacks—Chester Peggese—was sentenced in February 2016 to one year and one day in prison and was ordered to pay $4.2 million in restitution to the bank. When investigators closed, in Ryan tried to cover up his crimes by telling a conspirator to lie on his behalf. Bank CEO Wayne-Kent Bradshaw reportedly told the L.A. Times about the church loans, “It was by far the major basis for problems at the institution. It was a big and bad operation. Broadway had a large church SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 portfolio, and it fell apart. We found out it was the making of a rogue lender.” With the bank unable to repay TARP, in 2013, Treasury agreed to swap its debt for Broadway stock and remains a large shareholder in the bank. Porter Bancorp (PBI): Following a SIGTARP investigation, on May 5, 2016, Joseph Tobin Loan Officer at TARP bank Porter Bancorp was charged along with bank borrowers Daniel Sexton, Jonathan Williams, and Sheila Flynn who were also charged, with a scheme to defraud PBI and other banks from May 2006 to September 2010. The scheme allegedly resulted in PBI Bank funding millions in loans based on false information. Treasury took a loss of $31.5 million on the TARP investment along with 13 missed dividend payments totaling $6,737,500. Treasury continues to hold warrants in the bank. Harbor Bank: Following a SIGTARP investigation, on April 27, 2016, Harbor Bank employee Rodney Dunn was indicted, along with Darryl Clements, charged with a scheme to defraud the bank to secure $13 million in financing for a movie to be produced called “Season Tickets.” In 2011, Clements allegedly created false documents stating that CityScope Productions, which had contractual rights to buy the movie script, had permanent financing of $13 million held in escrow at Harbor Bank. Dunn allegedly confirmed the funds were in escrow in the bank when there were not. Based on this confirmation, that same day, lenders wired $2.5 million for the movie. SIGTARP Investigations of the Largest CPP Banks NYAG action against Bank of America, former CEO and CFO, related to TARP funds: In one of SIGTARP’s early cases, in 2010, following a SIGTARP investigation, the New York Attorney General brought a civil suit against Bank of America, its former Chairman and CEO Kenneth Lewis and CFO Joe Price for their actions during the bank’s merger with Merrill Lynch and to receive an additional $20 billion in TARP. SIGTARP’s investigation uncovered that Bank of America failed to disclose to shareholders the forecast of rapidly-escalating, mounting losses at Merrill Lynch of more than $9 billion, prior to a vote on the proposed merger. Lewis and Price misrepresented to shareholders the impact that the merger with Merrill would have on Bank of America’s future earnings. Despite concealing these forecasted losses from investors, the bank then immediately sought massive TARP financial assistance from the Government, claiming that there had been a “material adverse change” in Merrill’s financial condition over the previous three months. Bank of America continued to conceal Merrill’s forecasted losses until mid-January 2009, when disclosure of these losses led to a $50 billion sell-off in the shares of Bank of America. In 2014, the NYAG settled the case. Bank of America and its former CEO Lewis paid $25 million and former CFO Joe Price paid $7.5 million. Lewis was barred from serving as an officer or director of a public company for three years and Price was barred for 18 months. 41 42 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM DOJ civil fraud actions related to residential mortgage backed securities (RMBS): SIGTARP was the investigating agency on several Department of Justice civil fraud actions under the Financial Institutions Reform, Recovery, and Enforcement Act of 1989 (“FIRREA”) against some of the largest CPP banks. Our investigations found fraud in the packaging, securitization, marketing, and sale of residential mortgage-backed securities which contributed to the financial crisis. Despite knowing that they had engaged in this fraud, these large banks took TARP bailout funds without disclosing the fraud. FIRREA provides payment to the Government based on the amount of the loss. • Goldman Sachs: Along with the U.S. Attorney’s Office for the Eastern District of California, DOJ’s Civil Division, and others, SIGTARP’s investigation of Goldman Sachs (“Goldman”)—who received $10 billion in TARP funds— uncovered that Goldman made fraudulent representations when it packaged and sold RMBS to investors. Goldman told investors that mortgage loans in the pools that went into RMBS met the loan originator’s underwriting guidelines. However, Goldman admits that from its sampling, it knew that significant percentages of the loans reviewed in due diligence did not conform to those investor representations. çç For example, in 2007, after dropping 25% of the loans from the pool because due diligence found its sample of loans to have “extremely aggressive underwriting,” Goldman issued a subprime RMBS without reviewing an unsampled 70% of the loans to determine whether those loans had similar problems. çç In another example, in 2006, after learning that an unusually high percentage of loans had credit and compliance defects, Goldman’s committee that approved RMBS asked, “How do we know that we caught everything?,” and one transaction manager responded, “we don’t.” Another transaction manager responded, “Depends on what you mean by everything? Because of the limited sampling…we don’t catch everything.” Goldman’s committee approved this RMBS without requiring further due diligence. çç In 2006, Goldman was preparing an RMBS backed by Countrywide loans when a Goldman mortgage department manager circulated a “very bullish” equity research report that recommended the purchase of Countrywide stock. Goldman’s head of due diligence who had just overseen the due diligence on six Countrywide pools, responded, “If they only knew……….” çç Around the end of 2006, Goldman employees observed signs of uncertainty in the residential mortgage market, and by March 2007, Goldman has largely halted new purchases of subprime loan pools. çç Investors suffered billions of dollars in losses from investing in RMBS issued by Goldman from 2005 to 2007. Following these investigative findings, in 2016 DOJ announced a civil fraud action against Goldman for false and misleading representations to investors about the characteristics of the loans it securitized and the ways Goldman would SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 protect investors from harm, as described above. Goldman resolved the action by admitting to the misconduct, paying a $2.385 billion civil penalty, $1.8 billion relief to underwater homeowners, distressed borrowers and communities, for loan forgiveness and affordable housing financing, and $875 million in restitution to National Credit Union Administration ($575,000,000); Federal Home Loan Bank of Des Moines ($37,500,000); Federal Home Loan Bank of Chicago ($37,500,000); New York state ($190,000,000); Illinois state ($25,000,000); and California state ($10,000,000). • Morgan Stanley: Along with the U.S. Attorney’s Office for the Northern District of California, DOJ’s Civil Division, and others, SIGTARP’s investigation of Morgan Stanley—who received $10 billion in TARP funds— uncovered that Morgan Stanley misled investors about the subprime mortgage loans underlying the RMBS it sold. çç Morgan Stanley told investors that it did not securitize underwater loans, but did not disclose that it had expanded its risk tolerance in order to purchase and securitize “everything possible.” Morgan Stanley admits that it ignored broker’s price opinions that showed 9,000 underwater loans. A Morgan Stanley manager of valuation due diligence told an employee, “please do not mention the slightly higher risk tolerance in these communications. We are running under the radar and do not want to document these type of things.” çç Morgan Stanley told investors that it did not securitize loans that failed to meet originators’ guidelines unless they had compensating factors, despite employees knowing that this was not true. çç Morgan Stanley told investors that as part of its due diligence process, it excluded from a RMBS any loan where the broker price showed an “unacceptable negative variance from the original appraisal,” knowing that it never rejected a loan based solely on the broker price. çç Morgan Stanley was aware of problematic lending practices of subprime originators, but did not increase its sample when conducting due diligence because it did not want to harm its relationship with the subprime originators. Morgan Stanley’s manager of credit and compliance due diligence was admonished to “stop fighting and begin recognizing the point that we need monthly volume from our biggest trading partners and that … the client [the originator] does not have to sell to Morgan Stanley.” çç Investors suffered billions of dollars in losses from investing in RMBS issued by Morgan Stanley in 2006 and 2007. Following these investigative findings, in 2016 DOJ announced a civil fraud action against Morgan Stanley for failing to disclose critical information to prospective investors about the quality of the mortgage loans underlying its RMBS and about its due diligence practices. Morgan Stanley resolved the action by admitting to the misconduct, paying a $2.6 billion penalty, $225 million for credit union purchasers of RMBS, $1.25 billion for RMBS purchases by Fannie Mae and 43 44 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM Freddie Mac, and $86.95 million for purchases of RMBS by banks that later failed (through the FDIC). • Bank of America: Along with the U.S. Attorney’s Office for the Southern District of New York (USAO SDNY), SIGTARP investigated the origination of defective residential mortgage loans by Countrywide and Bank of America and the fraudulent sale of the loans to Fannie Mae and Freddie Mac. This investigation uncovered that Countrywide and Bank of America were aware that many of the residential mortgage loans they made to borrowers were defective, and that many of the representations and warranties they made to the GSEs about the quality of the loans were inaccurate. They did not self-report to the GSEs, those mortgage loans they had identified as defective. On August 20, 2014, DOJ announced Countrywide’s and Bank of America’s admission to this misconduct, and payment of $1 billion to resolve liability under the False Claims Act, as part of a broader $16.65 billion settlement agreement ($7 billion of which was a consumer relief package). A portion of the $1 billion was used to compensate Fannie and Freddie for losses they suffered as part of the misconduct. DOJ Civil Fraud Actions Related to the Origination And Resale of Loans • SDNY civil fraud action against Bank of America related to “the Hustle” scheme: SIGTARP’s investigation with the U.S. Attorney for the Southern District of New York resulted in a Federal jury trial in New York, with the jury finding that Bank of America and one of its officers Rebecca Mairone had engaged in criminal misconduct. The Federal court’s July 30, 2014 order in the original trial stated, “the essential crime found by the jury was a scheme to induce Fannie Mae and/or Freddie Mac to purchase mortgage loans originated through the High Speed Swim Lane by misrepresenting that the loans were of higher quality than they were.” The court’s opinion described the bank’s process known as the “Hustle” as, “the vehicle for a brazen fraud by the defendants, driven by hunger for profits and oblivious to the harms thereby visited, not just on the immediate victims but also on the financial system as a whole.” In ordering penalties of $1.27 billion against Bank of America and $1 million against defendant Mairone, the Federal court’s order found that the law the Government sued under, FIRREA, “predicated civil liability on the Government proving criminal violations (here mail fraud and wire fraud), by a preponderance of the evidence….In short, FIRREA seeks to impose substantial civil penalties for criminal misconduct affecting federally insured financial institutions.” The second circuit reversed this case on appeal. • Fifth Third Bank: SIGTARP investigated Fifth Third Bank employees who made false representations to HUD that residential mortgages the bank originated were of the quality HUD required. Fifth Third Bank agreed to pay approximately $85 million to cover Federal losses on approximately 500 loans that defaulted and for which HUD paid insurance claims, and indemnify HUD SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 for all losses HUD may incur on approximately 900 defective loans that have not yet defaulted. Investigations where Treasury suffered a loss in TARP: Treasury suffered a loss on the TARP investments in most banks that received TARP funds (only 37% of banks repaid TARP in full). SIGTARP Investigations Related to Failed or Bankrupt CPP Banks-Full or Near Full TARP Loss SIGTARP investigations have resulted in criminal or civil prosecutions related to 10 of 32 failed CPP banks. It is important for SIGTARP to enforce the law where crime or civil fraud occurred in a bank that later failed. For the 32 TARP banks that failed, as shown in Table 3.2, Treasury suffered a full loss of the whole TARP investment or Treasury received a small amount in the liquidation of the failed bank. Treasury also suffered losses of unpaid TARP dividends owed by banks that failed. 45 46 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM TABLE 3.2 BANKRUPT OR WITH FAILED SUBSIDIARY CPP BANKS, AS OF 12/31/2016 ($ MILLIONS) Company CIT Group Inc., New York, NY TARP Loss SIGTARP Investigation 2,330.0 UCBH Holdings Inc., San Francisco, CA 298.7 ✓ Anchor BanCorp Wisconsin Inc. 110.0 ✓ Midwest Banc Holdings, Inc., Melrose Park, IL 89.4 Integra Bank Corporation, Evansville, IN 83.6 First Place Financial Corporation 72.9 Superior Bancorp, Inc., Birmingham, AL 69.0 Tennessee Commerce Bancorp, Inc., Franklin, TN 30.0 Princeton National Bancorp 25.1 Rogers Bancshares, Inc. 25.0 TCB Holding Company 11.7 Citizens Bancorp, Nevada City, CA 10.4 ✓ ✓ ✓ Premier Bank Holding Company 9.5 Sonoma Valley Bancorp, Sonoma, CA 8.7 Syringa Bancorp 8.0 GulfSouth Private Bank 7.5 Western Community Bancshares, Inc., Palm Desert, CA 7.3 Idaho Bancorp, Boise, ID 6.9 Pierce County Bancorp, Tacoma, WA 6.8 Rising Sun Bancorp, Rising Sun, MD 6.0 FPB Bancorp, Port Saint Lucie, FL 5.8 Legacy Bancorp, Inc., Milwaukee, WI 5.5 One Georgia Bank, Atlanta, GA 5.5 Blue River Bancshares, Inc., Shelbyville, IN 5.0 Pacific Coast National Bancorp, San Clemente, CA 4.1 CB Holding Corp., Aledo, IL 4.1 Investors Financial Corporation of Pettis County, Inc. 4.0 ✓ Tifton Banking Company, Tifton, GA 3.8 ✓ Gold Canyon Bank 1.6 Fort Lee Federal Savings Bank 1.3 Indiana Bank Corp. 1.3 Gregg Bancshares, Inc. Total Notes: Numbers may not total due to rounding. Sources: Treasury, Transactions Report, 12/30/2016. 0.9 3,259.4 ✓ ✓ ✓ SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 SIGTARP investigations led to criminal charges against bank officials in 10 failed/bankrupt TARP banks (9 CPP banks and 1 CDCI bank) and against borrowers who defrauded 6 TARP banks that later failed. Also as a result of SIGTARP investigations, the SEC has brought civil securities fraud charges related to failed TARP banks. Key investigations include: UCBH Holdings Inc./United Commercial Bank, San Francisco, California: Following a SIGTARP investigation, United Commercial Bank Holdings, Inc. (“UCBH”) COO and Chief Credit Officer Ebrahim Shabudin was sentenced to 8 years and 1 month in prison. Former Senior Vice President, Thomas Yu was convicted, and sentenced to probation on DOJ’s recommendation. He testified at trial against Shabudin. CFO Craig On was convicted and awaits sentencing. DOJ deferred prosecution of two other bank officers. Both testified at trial. UCBH was the 9th largest bank to fail since 2008 and Treasury took a nearly $300 million loss on its TARP investment in UCBH. From 2004 to 2007, United Commercial Bank began aggressively expanding, nearly doubling its loans, with a goal to be a $10 billion bank so that it could become a bank in China. During the crisis, in an attempt to have the bank appear to “break even,” COO Shabudin and coconspirators manipulated the bank’s books and records, and issued false press releases, filings with examiners, and false financial statements. He fraudulently delayed downgrading the risk ratings of loans. He hid that the inventory of electronics that served as collateral for a major loan turned out to be fake even though bank officials found a warehouse of empty boxes. He hid that other loans had real property as collateral that had significantly declined in value. Then U.S. Attorney Melinda Haag, the prosecutor on the case at the time, said, “UCB is one of the largest criminal prosecutions brought by the U.S. Department of Justice of wrongdoing by bank officers arising out of the 2008 financial crisis.” Sonoma Valley Bancorp, Sonoma, California: As a result of a SIGTARP investigation, on March 31, 2014, Sean Cutting, the former bank President and CEO; Brian Melland, bank Senior Vice President; bank borrower Bijan Madjlessi (now deceased) and David Lonich (attorney for Madjlessi), were charged for their roles in an alleged bank fraud scheme. From approximately 2009 to 2012, Cutting and Melland are alleged to have defrauded the bank by loaning $9.5 million to a straw purchaser, concealing that Madjlessi and his attorney Lonich were the beneficiaries. The defendants allegedly used the proceeds of the loan to purchase from the FDIC the rights to a $30 million IndyMac Bank condominium construction loan which Madjlessi had defaulted. Trial is scheduled for March. Tifton Banking Co., Tifton, Georgia: Following a SIGTARP investigation, bank CEO Pat Hall was sentenced to 7 years in prison following a SIGTARP investigation. Beginning in 2005, CEO Hall began misleading the bank’s loan committee about loans. He later concealed when those loans went past-due. His fraudulent schemes included circumventing the loan committee to issue a new 47 48 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM loan for one property to retire an overdue loan on another property. He overdrafted accounts by more than $900,000 to make loan payments. He fraudulently prepared an application for loans from two Federal agencies for a borrower who would use that money to remove an overdue loan at Tifton Bank. He made false representations to an appraiser for bank collateral. Hall obtained $3.8 million in TARP bailout funds to fill holes in the bank’s books caused by his fraud, all of which was lost when the bank failed. Anchor BanCorp Wisconsin, Inc., Madison, Wisconsin: Following a SIGTARP investigation, on June 16, 2015, David Weimert, former Senior Vice President at TARP recipient AnchorBank, was sentenced to 18 months in prison after a jury trial. The indictment alleged that from December 2008, until March 31, 2009, Weimert, while working at Anchor BanCorp Wisconsin, Inc. (“ABCW”) as a Senior Vice President in Lending Administration and as the President of Investment Directions, Inc. (“IDI”), a wholly-owned subsidiary of ABCW, devised and participated in a scheme to defraud IDI and obtain money by means of fraudulent pretenses. In August 2013, when the bank filed for bankruptcy, Treasury lost $104 million on the TARP investment in addition to $23 million in missed dividends. The Seventh Circuit reversed his conviction on appeal. Pierce County Bancorp, Tacoma, Washington: Following a SIGTARP investigation, on January 28, 2013, Shawn Portmann, former Senior Vice President and Loan Officer at Pierce Commercial Bank was sentenced to 10 years in prison for a mortgage fraud scheme that resulted in the collapse of the bank. Loan underwriter Jeanette Salsi was sentenced to 7 months in prison, personal assistant Lorraine Barney was sentenced to two months in prison, and Pierce Commercial Vice President and Residential Lending Manager Sonja Lightfoot was sentenced to one month in prison. Between 2004 and 2008, Portmann with these co-conspirators closed over 300 loans with false and fraudulent information. They falsified information about the borrowers’ qualifications as well as their intention to reside in the homes being financed. More than half the loans defaulted or otherwise caused bank losses. Portman was compensated for each loan’s total value. Pierce Commercial Bank received $6.8 million in TARP funds in January 2009, all of which was lost when the bank failed. Superior Bancorp, Inc., Birmingham, Alabama: On January 13, 2016, 11 former high-ranking executives and board members at TARP recipient, Superior Bancorp, Inc., were charged by the SEC with defrauding shareholders in connection with various schemes to conceal the extent of loan losses as the bank was faltering in the wake of the financial crisis. As alleged in the civil complaint, the highranking officers and directors schemed to mislead investors and bank regulators by propping up Superior Bank’s financial condition through straw borrowers, bogus appraisals, and insider deals. Further, the SEC complaint alleges that the defendants extended, renewed, and rolled over bad loans to avoid the need to report ever-increasing losses in the bank’s financial accounting. As a result, Superior Bank SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 allegedly overstated its net income in public filings by approximately 99 percent for 2009 and 50 percent for 2010. Superior Bank failed, resulting in the loss of the TARP investment of $69 million with $2,587,500 in unpaid dividends. The FDIC estimated a $259.6 million loss. In a separate criminal case, Phillip Owen, a former branch manager with Superior Bancorp, was sentenced to six months in prison, and was ordered to pay $217,540 after pleading guilty to one count of conspiracy to commit bank fraud in connection with his role in a loan fraud scheme. SIGTARP Investigations Related to CPP Banks Where Treasury Suffered a Partial Loss on TARP Only about one third of TARP banks repaid TARP in full. For the remaining banks, Treasury wrote off some amount of loss on the TARP investment from sale at an auction (168 banks) or a loss in a restructuring or exchange (43 banks).5 Some banks also had unpaid TARP dividends, as listed in Appendix A on SIGTARP’s website. SIGTARP also investigates crime and civil fraud in banks where Treasury took a partial loss. Key examples include: Wilshire Bank: On January 13, 2016, Ataollah “John” Aminpour, former Chief Marketing Officer of Mirae Bank, was indicted for a $150 million loan fraud scheme that contributed to the failure of Mirae Bank and caused $33 million in losses to TARP recipient, Wilshire Bank, which acquired Mirae. SIGTARP’s investigation, revealed that, from 2005 through 2009, Aminpour allegedly created $150 million in inflated loans to gas stations and car washes, skimmed money off the top, and generated over a million dollars in commissions. Aminpour allegedly concealed the true loan amounts from the bank, arranged for fake down payments and encouraged some borrowers to stop making payments so he could purchase those distressed loans at a discount. Prior to its acquisition of Mirae in 2009, Wilshire received $62 million in TARP funds. Treasury suffered a loss of more than $3.5 million. Front Range Bank: On December 2, 2015, Candice L. White, a Senior Vice President of TARP recipient Front Range Bank, was sentenced to 3 months in prison for embezzlement from client accounts at the bank. TNBank: On February 5, 2015, Braxton L. Sadler, a former Senior Vice President and Senior Loan Officer of TARP recipient bank TNBank, was sentenced to two years probation for willfully misapplying bank funds in connection with a longrunning scheme to defraud TNBank, and ordered to pay $963,900 to TNBank. According to court documents, Sadler admitted that from 1995 through July 2009 he willfully processed loans for a borrower without investigating the borrower’s ability to repay the loan and then allowed the loan proceeds to be used for the borrower’s failed construction project, rather than for their stated purpose. Treasury suffered a loss of $531,375 in unpaid dividend payments. 49 50 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM SIGTARP Investigations of Banks that Committed Fraud By Applying For TARP with False Banks Books, But Did Not Receive TARP Funds In early years, focused on deterrning banks that would defraud TARP, SIGTARP conducted investigations that led to the convictions of 30 bankers, including 9 CEOs, whose banks applied for TARP unsuccessfully, with SIGTARP proving that the bank books supporting the TARP application were fraudulent. All but two of the banks failed, causing hundreds of millions of dollars in losses to the FDIC and one that did not fail was taken over. In the case of Colonial Bank, SIGTARP stopped the bank from receiving $550 million in TARP funds already approved by Treasury, saving the Government $550 million, all of which would have been lost to fraud. Colonial Bank (failed bank): SIGTARP uncovered an undetected 10-year $2.9 billion fraud scheme by Colonial Bank and Taylor, Bean and Whitaker Mortgage Corporation LLC (“TBW”) that contributed to the failure of Colonial Bank, the third largest bank failure since the crisis and the sixth largest bank failure in U.S. history. This 10-year fraud was undetected until Colonial Bank applied for TARP and SIGTARP discovered the fraud, stopping the TARP money just prior to disbursement. The case resulted in prison sentences for eight defendants including TBW chairman Lee Bentley Farkas, who was sentenced to 30 years in prison, TBW Treasurer Desiree Brown, who was sentenced to 6 years in prison, and two officers of Colonial Bank, Senior Vice President Catherine Kissick, who was sentenced to 8 years in prison, and operations supervisor Theresa Kelly, who was sentenced to 3 months in prison. Then-U.S. Attorney Neil H. MacBride who prosecuted the case called it one of the longest and largest bank fraud schemes in the country. Bank of the Commonwealth (failed bank): Following a SIGTARP investigation that uncovered that Bank of the Commonwealth applied for $28 million in TARP funds using false books and records, CEO and Chairman Edward Woodard was sentenced to 23 years in prison, Executive Vice President Stephen Fields was sentenced to 17 years in prison, Vice President Troy Brandon Woodard was sentenced to 8 years in prison, and Loan Officer Jeremy Churchill was convicted and sentenced to probation for a massive bank fraud that contributed to the failure of the bank. A total of 10 defendants were convicted in the case, 7 were sentenced to prison. This was the largest bank failure in Virginia since 2008. In announcing the indictment, U.S. Attorney Neil H. MacBride called the scheme “stunningly massive.” “The brazen greed and dishonesty of these four defendants toppled one of Virginia’s largest financial institutions and intensified the impact of the 2008 financial crisis on the public during the height of the fiscal storm,” said U.S. Attorney Neil H. MacBride. Starting in 2006, Woodard aggressively expanded the bank with the goal of becoming a billion dollar bank by becoming so concentrated in certain commercial real estate borrowers that he put the bank at risk. Woodard’s lawyer described one SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 loan as, “if the project failed, not only would the borrower go under, but they could have pulled the whole bank under with them, and it was Ed Woodard’s duty to try to avoid it.” Woodard took, or directed others to take, one criminal action followed by another, then another, to make past due loans appear current. He used straw borrowers, made new loans for a new stated purpose, but used those funds to make past due loans look current. He made fraudulent sweetheart deals for favored borrowers. The bank’s fraudulent books were used to apply for TARP. Tier One (failed bank) TierOne Bank CEO Gil Lundstrom was sentenced to 11 years in prison, Acting CEO, President, and COO James Laphen was sentenced to 2 years and 10 months in prison, and Chief Credit Officer Don Langford was sentenced to 1 year and 9 months in prison following a SIGTARP investigation. TierOne Bank applied for $86 million TARP funds using false books and records. Evidence at trial showed that starting in 2002, CEO Lundstrom aggressively expanded bank lending from Nebraska to riskier commercial real estate in Las Vegas and other states, nearly doubling the bank’s loan book to $3.7 billion. Chief Credit Officer Don Langford testified this was “the very riskiest level of commercial real estate lending.” Many of the loans exceeded the loan-to-value ratio limitations and the bank did not adequately analyze the financial condition of borrowers. When the crisis unfolded, the value of the collateral securing these loans dropped significantly. Loans had no appraisals, unsupported appraisals, or stale appraisals. The bank’s President James Laphen testified at trial that he, Lundstrom and Langford agreed to delay ordering new appraisals to delay taking losses. CEO Lundstrom and his co-conspirators created a second set of books to conceal more than $100 million in losses from this risky lending, in what bank officers called “smoke and mirrors” and “hiding the ball.” They understated losses and used unrealistic loan collateral values to make it appear that the bank met required capital ratios. Acting CEO and President Laphen testified that TierOne was “infinitesimally close” to blowing its core capital ratio, which was at 8.51, just 0.01 over the regulator-required 8.5 ratio. TierOne was Nebraska’s second largest bank with $3.7 billion in assets and was the largest bank failure in Nebraska’s history. NOVA Bank (failed bank): Following a SIGTARP investigation, in November 14, 2016, NOVA Bank CEO and President Brian Hartline was sentenced to 1 year and 2 months in prison after a jury found him guilty of a fraud scheme to get TARP funds. The jury also found guilty NOVA Bank’s founder and former Chairman Brian Bekkedam, who has not yet been scheduled to be sentenced. CPP was a program only for healthy banks and when NOVA Bank applied for TARP, Treasury and regulators had concerns about the bank’s capital levels. CEO Hartline told regulators that a Florida businessman George Levin was willing to invest $15 million in the bank. In June 2009, Treasury approved NOVA Bank to receive $13.5 million in TARP funds contingent on the bank raising $15 million in private capital. The defendants arranged for NOVA Bank to loan $5 million to Levin who transferred the funds back to the bank within two hours. CEO Hartline never 51 52 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM disclosed to any regulator that the $5 million of capital from Levin was financed by the bank, a fact that a regulator involved with TARP testified would be important to know in the decision about TARP. The regulators all knew that Levin filed change of control applications with the Federal Reserve. The agreement to conceal that the bank financed the $5 million investment from Levin continued with the simple question from the regulators on the source of the funds for Levin to make the investment. Bekkedam and Hartline convinced two others to make similar “investments” using loans from NOVA to make NOVA appear more financially sound than it actually was. Treasury did not distribute the TARP funds, but only because of timing, not because Hartline told the truth. FirstCity (failed bank): Following a SIGTARP investigation in August 2012, bank President Mark Conner was sentenced to 12 years in prison, Vice President and Senior Loan Officer Clayton Coe was sentenced to 7 years and 3 months in prison, and attorney Robert Maloney was sentenced to 3 years and 3 months in prison following a SIGTARP investigation. FirstCity Bank applied for TARP with false books and records. SIGTARP uncovered that beginning in 2004, Conner and Coe convinced the bank to approve multiple multi-million dollar commercial loans to borrowers who, unbeknownst to the bank, were actually purchasing the property owned by Conner or his coconspirators. They made fraudulent misrepresentations to 10 other banks who participated in these loans. They routinely misled bank examiners. To hide the bank’s declining financial position, they made loans to buyers to purchase foreclosed property off the bank’s books. The bank failed at a time when Georgia led the nation in the number of bank failures. United States Attorney Sally Quillian Yates noted that “ These failures have a ripple effect in every workplace and household in the state. This sentence should serve as a warning that regardless of your position or the complexity of your scheme, bank officers and directors who place FDIC-insured funds at risk through fraud and self-dealing will be brought to justice.”6 Orion (failed bank): Following a SIGTARP investigation, on June 13, 2012, Jerry J. Williams, former President, Chief Executive Officer, and Chairman of the Board of Directors of Orion Bank, was sentenced to 6 years in prison. Williams orchestrated a complex conspiracy to fraudulently raise capital and falsify bank records in order to mislead state and federal regulators as to the bank’s true financial condition. Orion Bancorp, Inc. unsuccessfully sought $64 million in TARP. Bank borrower Francesco Mileto was sentenced to 5 ½ years in federal prison, Bank Officer Thomas Hebble was sentenced to 2 ½ years in federal prison, and Bank Officer Angel Guerzon was sentenced to 2 years in federal prison. Williams directed his executives to conduct a roundtrip transaction by loaning money to straw borrowers on behalf of borrower and co-conspirator Frank Mileto, creating the illusion that Orion Bank’s capital position had improved by $15 million. Williams knew that banking laws prohibited the bank from financing the purchase of its own stock. Even after top bank executives discovered that Mileto had submitted fraudulent documents to support the loans, Williams directed the SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 bank to issue the loans as the only one with authority to approve loans over $2 million for submission to the loan committee.7 Appalachian Community Bank (failed bank): Following a SIGTARP investigation in April 2013, former bank Vice President Adam Teague was sentenced to 5 years and 10 months in prison and former bank Vice President William Beamon was sentenced to 3 years and 6 months in prison. Teague contributed to the failure of TARP applicant Appalachian Community Bank by fraudulently masking the bank’s true financial condition while enriching himself. As a result of Teague’s actions, Appalachian Community Bank applied for TARP using false books and records. Beamon fraudulently rented out bank-owned properties taking the rent, and he caused the bank to sell properties to his wife and company at severely discounted prices.8 Park Avenue Bank (failed bank): Following a SIGTARP investigation in August 2015, Charles Antonucci, the former President and CEO of the Park Avenue Bank was sentenced to 2 years and 6 months in prison. Antonucci was the first person convicted for trying to steal TARP bailout funds. Antonucci lied to bank examiners and took bribes from bank clients. Additionally, Antonucci and his co-conspirators orchestrated a scheme to defraud Treasury into giving the bank $11 million dollars in TARP funds by making it appear that an investor invested millions in the bank, when it was really the bank’s money.9 First Community Bank (bank had to be merged into another bank): Following a SIGTARP investigation in April 2013, Reginald Harper, former President and CEO of First Community Bank was sentenced to 2 years in prison and his coconspirator, Troy Fouquet, was sentenced to 1 year and 6 months in prison. Harper and bank customer Fouquet turned to bank fraud to hide past due loans from the bank, its regulators, and the Treasury Department in the bank’s TARP application. As a result of the fraud, when applying for TARP the bank used false books and records. The application was approved, but later withdrawn by the bank.10 Gateway Bank: Following a SIGTARP investigation in December 2015, Poppi Metaxas, the former President and CEO of Gateway Bank was sentenced to 1 year and 6 months in prison. Metaxas orchestrated an elaborate conspiracy to commit bank fraud to hide the bank’s high numbers of non-performing loans and repossessed assets during the financial crisis all while seeking TARP as a lifeline (the TARP application was later denied). As the TARP application was pending Metaxas and her co-conspirators devised an intricate criminal scheme to sell the bank’s non-performing loans and repossessed assets, hiding from the board and the bank’s books that $3.64 million of the bank’s own money funded the 25% deposit by the buyers.11 Omni Bank (failed bank): Following a SIGTARP investigation in April 2011, Jeffrey L. Levine, former Executive Vice-President, the second largest bank 53 54 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM shareholder, and head of a lending department at Omni National Bank was sentenced to 5 years in prison. Levine and others falsified the books to conceal that Omni was crumbling, including material overvaluations submitted when the bank unsuccessfully sought TARP. Levine was also ordered to pay restitution in the amount of $6.7 million. Bank borrower Delroy Oliver Davy was sentenced to 14 years in prison; Omni Bank Officer Karim Walthour Lawrence was sentenced to 1 year 9 months in prison; Christopher Benard Loving was sentenced to 3 years probation for making false statements to SIGTARP agents; and Brent Merriell was sentenced to over 3 years in prison.12 Each of these were important investigations to conduct to protect TARP against fraud, and they led to 23 bankers being sentenced to prison, along with 17 co-conspirators. Given the amount of fraud we are finding, SIGTARP has prioritized resources on banks who received TARP funds. SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 SIGTARP’S OVERSIGHT OVER COMMUNITY DEVELOPMENT CAPITAL INITIATIVE BANKS / CREDIT UNIONS SIGTARP conducts oversight over the smaller bank bailout known as Community Development Capital Initiative (“CDCI”) through audits and investigations. This program is ongoing with 30 institutions still in TARP owing $108 million. This quarter, Treasury exited its investments in 26 of the CDCI institutions, in all but 3 cases at a loss. Of the 30 institutions remaining in CDCI, 23 are in states with above average unemployment, as shown Table 3.3 below.13 55 56 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM TABLE 3.3 CDCI PARTICIPATION AND UNEMPLOYMENT RATE BY STATE State Statewide Investment Unemployment Rate Institution Name Alaska $1,600,000 6.8 Tongass Federal Credit Union $1,600,000 Louisiana $4,224,000 6.2 Carter Federal Credit Union $3,800,000 District of Columbia $500,000 Pennsylvania $100,000 Mississippi $8,742,000 5.7 Illinois $13,868,000 Tulane-Loyola Federal Credit Union $424,000 6 D.C. Federal Credit Union $500,000 5.7 Hill District Federal Credit Union $100,000 5.6 Hope Federal Credit Union $4,520,000 The Magnolia State Corporation $4,222,000 American Bancorp of Illinois, Inc. $5,457,000 IBC Bancorp, Inc. $8,086,000 North Side Community Federal Credit Union California $20,473,000 5.3 $7,462,000 5.3 $4,060,000 Cooperative Center Federal Credit Union $2,799,000 Episcopal Community Federal Credit Union Mission Valley Bancorp $36,408,000 5.1 $100,000 $10,336,000 $350,000 Santa Cruz Community Credit Union $2,828,000 Citizens Bancshares Corporation $7,462,000 Buffalo Cooperative Federal Credit Union New York $325,000 Community Bank of the Bay Northeast Community Federal Credit Union Georgia Outstanding Investment First American International Corp. Neighborhood Trust Federal Credit Union Carver Bancorp, Inc New Jersey $31,000 5 Renaissance Community Development Credit Union Tennessee $2,795,000 4.8 Tri-State Bank of Memphis Outstanding Investment in States with Above Average Unemployment $145,000 $17,000,000 $283,000 $18,980,000 $31,000 $2,795,000 $96,203,000 National Unemployment Rate (4.7%) Connecticut $7,000 4.7 Texas $174,000 4.6 East End Baptist Tabernacle Federal Credit Union Liberty County Teachers Federal Credit Union Union Baptist Church Federal Credit Union Indiana $112,450 4.2 Virginia $8,044,000 4.2 Fairfax County Federal Credit Union Vermont $1,091,000 3.2 Opportunities Credit Union Vigo County Federal Credit Union Outstanding Investment in States with Below Average Unemployment Guam $2,650,000 Total Outstanding TARP Investment Community First Guam Federal Credit Union $7,000 $174,000 $10,000 $102,450 $8,044,000 $1,091,000 $9,428,450 $2,650,000 $108,281,450 Sources: Treasury, Transaction Report, 12/30/2016, https://www.treasury.gov/initiatives/financial-stability/reports/Documents/01-04-17%20Transactions%20Report%20 as%20of%2012-30-16_INVESTMENT.pdf, accessed 1/9/2017. Bureau of Labor Statistics, Local Area Unemployment Statistics as of November 2016, https://www.bls.gov/ web/laus/laumstrk.htm, accessed 1/9/2017. SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 SIGTARP Audit Oversight Over CDCI SIGTARP’s primary audit focus is to conduct oversight over Treasury action to exit its remaining $108 million TARP investment in 30 remaining CDCI institutions. One of these institutions, Santa Cruz Community Credit Union, in Santa Cruz, California, was assessed a civil money penalty by its regulator the National Credit Union Administration on January 13, 2015.14 SIGTARP will conduct oversight of Treasury’s actions as it continues to wind-down its investment in CDCI. In November 2016, SIGTARP made the following recommendations to Treasury to protect taxpayer dollars, after Treasury proposed that CDCI institutions could repay the TARP amounts owed earlier than expected: • Treasury should not indicate what discount it will accept; this will help limit taxpayer loss and ensure that taxpayers get the highest repayment; • Treasury should fully memorialize decision-making when they take a loss; review proposals consistently and publish any losses taken on CDCI institutions; to facilitate oversight; • Treasury should consult with the primary regulator of each CDCI institution before allowing repayment at a discount; • Treasury should provide SIGTARP with the identity of any CDCI institutions reporting at a loss in case SIGTARP is performing a criminal investigation of that bank or credit union. Treasury did not agree to implement SIGTARP’s recommendations, stating that it addressed the issues SIGTARP identified. SIGTARP was well aware of Treasury’s process before making the recommendations and did not view those processes as sufficient to ensure taxpayers get the highest repayment or to facilitate oversight. SIGTARP will continue to monitor implementation of an existing SIGTARP recommendation to protect taxpayers’ investment in CDCI institutions by Treasury enforcing its right to appoint directors to the boards of CDCI institutions that failed to pay eight or more TARP payments. Tri-State Bank, in Memphis, Tennessee, has missed 10 TARP quarterly dividend payments, totaling $139,750. While Treasury has an employee observing Tri-State Bank’s board meetings, it has not appointed two independent directors to the board, which is its right.15 This loses an opportunity at a bank that is operating under a consent order issued by the FDIC. SIGTARP will also continue to monitor Community Bank of the Bay, in Oakland, California that has missed one TARP dividend payment of $20,300, as well as Carver Bancorp, Inc., in New York, New York that has missed paying TARP dividends in the past. Treasury sends an employee to observe the bank’s 57 58 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM board meetings, even though Carver Bancorp repaid all previously missed dividends of $284,700.16 SIGTARP Investigations Related to CDCI SIGTARP investigates potential criminal activity at CDCI institutions prior to or during the time the institution was in TARP. The repayment of TARP does not relieve criminal culpability. SIGTARP Investigation Led to Prison Sentence of Chairman of Premier Bank, Inc. and a Sentence of Probation for the bank’s General Counsel, who was a director. SIGTARP’s investigation into Premier Bancorp, Inc., the only CDCI institution to fail, led to two different criminal actions by the Illinois Attorney General.17 Chairman and General Council/Board Member Sentenced for Crime that led to failure of Premier Bank: On November 1, 2016, Zulfikar Esmail, the bank’s Chairman of the Board, was sentenced to five years in prison. His wife, Shamim Esmail, who was the bank’s general counsel and director, was sentenced to probation.18 SIGTARP’s investigation led to the Illinois Attorney General filing criminal charges against Zulfikar Esmail, Shamim Esmail, and two board members Robert McCarty and William Brannin, for an alleged scheme to defraud Treasury out of $6.784 million in TARP funds. Treasury lost $6.7 million in TARP funds when the bank failed, in addition to $64.1 million estimated cost to the FDIC due to the bank’s failure.19,20 On July 10, 2013, SIGTARP federal agents participated in the arrest of all four defendants, who were charged with a massive hidden sixyear bank fraud conspiracy and criminal enterprise that led to the collapse of the bank. The indictment alleges that the defendants hid the poor financial condition of Premier Bank from regulators. It is alleged that Zulfikar Esmail engaged in a criminal shakedown scheme. It is also alleged that Esmail ordered construction and improvements to his home and rental properties, including construction of an underground tunnel at his home, and directed the contractor to prepare invoices that fraudulently showed the work was done at the bank in order to bill the bank for the work. By late 2008, when the bank was near failure, the bank applied for and received the first of two payments from TARP in order to further the criminal scheme.21 The two directors await trial. SIGTARP’s investigation also resulted in the indictment of Angelica Demetropolis, the former President of Premier Bank in October 2013. The indictment alleges that Demetropolis filed or caused to be filed false and misleading financial information with the FDIC. As part of the scheme, among other actors, Demetropolis and the Esmails allegedly took a series of actions to make past due loans appear current. It also alleges that Demetropolis instructed the destruction of documents for two of these loans two weeks before the bank closed. Additionally, it is alleged that in order to obtain $6.784 million in TARP funds, Demetropolis and others caused the bank to submit documents that materially misrepresented the financial condition of the bank. Subsequently, Demetropolis and others allegedly SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 submitted documents, which materially misrepresented the financial condition of the bank in connection with an application to Treasury to exchange the debentures held by Treasury, which were received in consideration for the initial $6.784 million in TARP funds, for debentures that paid a lower interest rate. Demetropolis fled the county and currently awaits extradition. Conviction after jury trial of Premier Bank Chairman Zufikar Esmail for Defrauding TARP Recipient First Midwest Bank: On December 6, 2015, the Illinois Attorney General brought criminal charges against Zulfikar Esmail and Shamim Esmail for a scheme to defraud another TARP bank. On December 15, 2015, after a six-day trial, a jury found both guilty of defrauding First Midwest Bank by submitting false information in a workout agreement after they defaulted on an $8 million loan obtained in 2009. On March 30, 2016, the court entered a judgment notwithstanding the jury’s guilty verdict for Shamim Esmail, finding her not guilty. The court subsequently sentenced Zulfikar Esmail to two years of probation.22 59 60 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM SIGTARP’S OVERSIGHT OVER TRADING IN MORTGAGE-BACKED SECURITIES RELATED TO TARP Treasury’s original TARP proposal presented to Congress was that the Government purchase toxic assets (mortgage backed securities) held by banks. SIGTARP conducts oversight over mortgage backed securities related to TARP in two ways: (1) SIGTARP investigations of TARP institutions in the business of packaging and selling residential mortgage backed securities (RMBS); and (2) SIGTARP investigations over the Public Private Investment Program, a TARP program known as “PPIP”, that purchased and sold mortgage backed securities using TARP funds. Treasury contracted with nine investment firms (Angelo Gordon, AllianceBernstein, BlackRock, Invesco, Marathon, Oaktree, RLJ Western Asset, TCW, and Wellington Management) who managed the TARP funds, buying and selling the mortgagebacked securities through brokers (TCW withdrew after terminating its PPIP portfolio manager). Given that trading in mortgage-backed securities using TARP dollars through the PPIP program has ended, SIGTARP no longer conducts audits, but continues to investigate crime and civil fraud related to the PPIP program, as the closing of the program cannot serve as a shield to criminal or civil liability.23 SIGTARP Investigations into TARP Institutions for Misrepresentations to RMBS Investors SIGTARP investigated TARP-recipient institutions for fraud that contributed to the financial crisis. We found misrepresentations in the packaging, securitization, marketing, sale, and issuance of RMBS. The RMBS at issue also traded through the PPIP program. As a result of these investigations, DOJ brought actions under the Financial Institutions Reform, Recovery and Enforcement Act (“FIRREA”), which authorizes the Federal government to impose civil remedies against financial institutions that commit mail and wire fraud.24 SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 Along with the U.S. Attorney’s Office for the Eastern District of California, DOJ’s Civil Division, and others, SIGTARP’s investigation of Goldman Sachs (“Goldman”)—who received $10 billion in TARP funds—uncovered that Goldman made fraudulent representations when it packaged and sold RMBS to investors. Goldman told investors that mortgage loans in the pools that went into RMBS met the loan originator’s underwriting guidelines. However, Goldman admits that from its sampling, it knew that significant percentages of the loans reviewed in due diligence did not conform to those investor representations. • For example, in 2007, after dropping 25% of the loans from the pool because due diligence found its sample of loans to have “extremely aggressive underwriting,” Goldman issued a subprime RMBS without reviewing an unsampled 70% of the loans to determine whether those loans had similar problems. • In another example, in 2006, after learning that an unusually high percentage of loans had credit and compliance defects, Goldman’s committee that approved RMBS asked, “How do we know that we caught everything?,” and one transaction manager responded, “we don’t.” Another transaction manager responded, “Depends on what you mean by everything? Because of the limited sampling…we don’t catch everything.” Goldman’s committee approved this RMBS without requiring further due diligence. • In 2006, Goldman was preparing an RMBS backed by Countrywide loans when a Goldman mortgage department manager circulated a “very bullish” equity research report that recommended the purchase of Countrywide stock. Goldman’s head of due diligence who had just overseen the due diligence on six Countrywide pools, responded, “If they only knew……….” • Around the end of 2006, Goldman employees observed signs of uncertainty in the residential mortgage market, and by March 2007, Goldman has largely halted new purchases of subprime loan pools. • Investors suffered billions of dollars in losses from investing in RMBS issued by Goldman from 2005 to 2007. Following these investigative findings, in 2016 DOJ announced a civil fraud action against Goldman for false and misleading representations to investors about the characteristics of the loans it securitized and the ways Goldman would protect investors from harm, as described above. Goldman resolved the action 61 62 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM by admitting to the misconduct, paying a $2.385 billion civil penalty, $1.8 billion relief to underwater homeowners, distressed borrowers and communities, for loan forgiveness and affordable housing financing, and $875 million in restitution to the National Credit Union Administration ($575,000,000); Federal Home Loan Bank of Des Moines ($37,500,000); Federal Home Loan Bank of Chicago ($37,500,000); New York state ($190,000,000); Illinois state ($25,000,000); and California state ($10,000,000).25 Along with the U.S. Attorney’s Office for the Northern District of California, DOJ’s Civil Division, and others, SIGTARP’s investigation of Morgan Stanley— who received $10 billion in TARP funds—uncovered that Morgan Stanley misled investors about the subprime mortgage loans underlying the RMBS it sold. • Morgan Stanley told investors that it did not securitize underwater loans, but did not disclose that it had expanded its risk tolerance in order to purchase and securitize “everything possible.” Morgan Stanley admits that it ignored broker’s price opinions that showed 9,000 underwater loans. A Morgan Stanley manager of valuation due diligence told an employee, “please do not mention the slightly higher risk tolerance in these communications. We are running under the radar and do not want to document these type of things.” • Morgan Stanley told investors that it did not securitize loans that failed to meet originators’ guidelines unless they had compensating factors, despite employees knowing that this was not true. • Morgan Stanley told investors that as part of its due diligence process, it excluded from a RMBS any loan where the broker price showed an “unacceptable negative variance from the original appraisal,” knowing that it never rejected a loan based solely on the broker price. • Morgan Stanley was aware of problematic lending practices of subprime originators, but did not increase its sample when conducting due diligence because it did not want to harm its relationship with the subprime originators. Morgan Stanley’s manager of credit and compliance due diligence was admonished to “stop fighting and begin recognizing the point that we need monthly volume from our biggest trading partners and that …the client [the originator] does not have to sell to Morgan Stanley.” • Investors suffered billions of dollars in losses from investing in RMBS issued by Morgan Stanley in 2006 and 2007. Following these investigative findings, in 2016, DOJ announced a civil fraud action against Morgan Stanley for failing to disclose critical information to prospective investors about the quality of the mortgage loans underlying its RMBS and about its due diligence practices. Morgan Stanley resolved the action by admitting to the misconduct, paying a $2.6 billion penalty, $225 million for credit SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 union purchasers of RMBS, $1.25 billion for RMBS purchases by Fannie Mae and Freddie Mac, and $86.95 million for purchases of RMBS by banks that later failed (through the FDIC).26 Along with the U.S. Attorney’s Office for the Southern District of New York, SIGTARP investigated the origination of defective residential mortgage loans by Countrywide and Bank of America and the fraudulent sale of the loans to Fannie Mae and Freddie Mac. This investigation uncovered that Countrywide and Bank of America were aware that many of the residential mortgage loans they made to borrowers were defective, and that many of the representations and warranties they made to the GSEs about the quality of the loans were inaccurate. They did not self-report to the GSEs, those mortgage loans they had identified as defective. On August 20, 2014, DOJ announced Countrywide’s and Bank of America’s admission to this misconduct, and payment of $1 billion to resolve liability under the False Claims Act, as part of a broader $16.65 billion settlement agreement ($7 billion of which was a consumer relief package). A portion of the $1 billion was used to compensate Fannie and Freddie for losses they suffered as part of the misconduct.27 SIGTARP Investigation of Wall Street Traders Buying and Selling to PPIP Managers SIGTARP investigations of Wall Street traders that traded through PPIP or TARP recipients is based on the requirement of honesty and integrity in the RMBS market, where there is no exchange that lists the market price. As described by the SEC in a cease and desist order in one of the cases listed below (Edward Chin), RMBS are generally illiquid, and discovering a market price for them is difficult. In addition to fundamental valuation methods, participants in this market rely on informal sources, such as the dealer with whom they trade, for this information….It is not unusual for a customer’s information about the current market price for a security to come from the firm that is arranging the sale of the security. Because of this, there is an emphasis on establishing relationships, building trust, and having a good reputation within the industry. In part because of the opacity of the market, and because investment advisers owe fiduciary duties to their underlying clients, customers seek to avoid broker-dealers who are not honest with them. United States Attorney Deidre Daly stated about one case listed below, “Current regulations governing many fixed income products allow broker-dealers to operate in secrecy. Under the securities laws, broker-dealers do not have a license to lie to their customers.”28 63 64 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM • Jefferies, LLC: SIGTARP’s investigation of investment bank and broker-dealer Jefferies, LLC (“Jefferies”) uncovered that Jefferies’ management became aware that Jefferies employees were making misrepresentations to customers and did nothing to stop it. Six of eight PPIP managers were overcharged. As a result of Jefferies cooperation in SIGTARP’s investigation and agreement to change its culture and internal controls, in 2014, the United States Attorney Office for the District of Connecticut entered into a non-prosecution agreement with Jefferies. Jefferies paid $25 million ($11 million in restitution to victims and a $4 million penalty). Jefferies agreed to appoint an independent monitor and change its policies and procedures to detect and prevent fraud in connection with the purchase or sale of RMBS.29 • Jefferies trader Jesse Litvak: Following a SIGTARP investigation, in 2013, Jefferies trader Jesse Litvak was charged with securities fraud, TARP fraud and making false statements to the federal government, based on allegations that he defrauded customers trading in RMBS, including through the PPIP program. After a three week trial, the jury convicted Litvak on all 15 counts. The court sentenced him to two years in prison and ordered him to pay a fine of $1.75 million.30 On appeal, the Second Circuit upheld the securities fraud conviction, reversed on the TARP fraud conviction, and remanded to the lower court to hold a new trial. The trial was occurring while this report was written. In addition to the Litvak and Jefferies Case, SIGTARP and the United States Attorney’s Office for the District of Connecticut investigated other RMBS traders, including: SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 • RBS Securities trader Matthew Katke: Following a SIGTARP investigation, in March 2015, Matthew Katke, managing director at RBS Securities, Inc. (“RBS”) pled guilty to a multimillion dollar securities fraud scheme. Between 2008 and 2013, Katke admitted that he and others conspiring to increase RBS’s profits on collateral loan obligations (CLO) bond trades at the expense of customers. The conspiracy was perpetrated in two ways: In certain transactions, Katke misrepresented the seller’s asking price to the buyer (or vice versa), keeping the difference. In other transactions, Katke misrepresented to the buyer that bonds held in RBS’s inventory were being sold by a fictitious third-party, which allowed Katke to charge an extra commission. The multi-million dollar securities fraud had at least 20 customers who were victims—including TARP recipients.31 • RBS Securities supervisor Adam Siegel: Following a SIGTARP investigation, in December 2015, Adam Siegel, Matthew Katke’s boss and head mortgage backed securities trader pled guilty to a multimillion dollar securities fraud scheme. Between 2008 and 2014, Siegel admitted that he and others conspired to increase RBS’s profits on trades at the expense of customers. In certain transactions, Sigel misrepresent the seller’s asking price to the buyer (or vice versa), keeping the difference. In other transactions, Siegel misrepresented to the buyer that bonds held in RBS’s inventory were being offered for sale by a fictitious third-party seller, which allowed RBS to charge the buyer an extra, unearned commission. The multi-million dollar securities fraud had at least 35 customers who were victims, including TARP recipients.32 • Nomura Securities traders Ross Shapiro, Michael Gramins, and Tyler Peters: Following a SIGTARP investigation, in September 2015, three Nomura Securities International (“Nomura”) RMBS traders, Ross Shapiro, Michael Gramins, and Tyler Peters, who formerly worked at Lehman Brothers, were indicted for fraud. The traders allegedly conspired to overcharge their customers, which included an investment firm that was managing a PPIP fund. As alleged in the indictment, Shapiro, Gramins, and Peters fraudulently inflated the purchase price at which Nomura could buy a RMBS bond to induce their victim-customers to pay a higher price for the bond, and fraudulently deflated the price at which Nomura could sell a RMBS bond to induce their victimcustomers to sell bonds at cheaper prices, each causing Nomura and the three defendants to profit illegally. The defendants are also alleged to have created fictitious third parties in an effort to increase their profits.33 • Goldman senior trader Edwin Chin: SIGTARPs investigation of Edwin Chin, the former Goldman Sachs head trader in RMBS, found that he repeatedly misled customers and caused them to pay higher prices. Chin generated extra revenue for Goldman by concealing the prices at which the firm had bought RMBS, then reselling them at higher prices to customers, keeping 65 66 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM the difference. Chin also misled purchasers by suggesting he was negotiating between customers when he was selling RMBS out of Goldman’s inventory. This drove up the price as Chin made false statements such as, “This guy was really painful and I couldn’t get him to sell any lower.” In this one trade alone where he made these false representations, Chin obtained an extra profit of $200,000 for Goldman. In another trade, Chin made the false representation, “I’m trying not to appear too eager” and “he needs a few mins…to clear with his boss.” Through his misconduct on this trade, Chin obtained an additional $140,000 of extra profit for Goldman. In both of these cases, there was no “guy” on the other side, but instead the security was held in Goldman’s inventory. In August 2016, the Securities and Exchange Commission brought civil securities fraud charges against Chin. Chin settled the charges, disgorged $200,000, paid interest of $50,000 and a penalty of $150,000. Chin is barred from the securities industry.34 SIGTARP Investigation of PPIP Manager SIGTARP’s investigation of PPIP manager Western Asset Management Co., a subsidiary of Legg Mason, uncovered Western’s illegal trading of securities, and that Western concealed investor losses. SIGTARP proactively opened the investigation after data analysis of trades through the PPIP program. SIGTARP uncovered illegal trading known as known as “cross trading,” which favored some clients over others. Cross trading is the practice of moving a security from one client account to another without exposing the transaction to the market, which contains an inherent conflict of interest in obtaining best execution for both the buying and selling client, one of which was the PPIP account. As a PPIP fund manager participating in TARP, Western was prohibited from engaging in cross trades involving the PPIP fund. However, Western violated this prohibition, illegally using the PPIP fund to defraud its clients out of $6.2 million. As a result of SIGTARP’s investigation, in 2014, the Securities and Exchange Commission charged Western with fraud, entered a cease and desist order. Western paid $10 million to harmed clients and a $1 million penalty.35 SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 SIGTARP’S OVERSIGHT OVER THE AUTO BAILOUT Given that there are no companies remaining in TARP’s auto industry programs, SIGTARP no longer conducts audits of these programs. SIGTARP investigations do not stop solely because a company exits TARP, as that exit cannot shield criminal or civil liability for misconduct while the company was in TARP or before TARP if it impacted the company’s TARP application. SIGTARP’s investigations have led to law enforcement results against General Motors in September 2015, and Ally Financial in November 2016—two of the four auto companies in TARP – both investigations finalizing after the companies exited TARP. General Motors: SIGTARP’s investigation with the U.S. Attorney’s Office for the Southern District of New York of General Motors (“GM”) found criminal conduct by GM for criminally concealing from the National Highway Safety Administration (“NHTSA”) a safety defect in certain models of Chevrolet, Pontiac and Saturn brands manufactured and/or sold by GM and also found wire fraud. This defect resulted in vehicle crashes causing injury and death to drivers and passengers, including many young drivers.36 SIGTARP’s investigation revealed that a defective low-torque ignition switch on these vehicles caused the vehicle to move out of the “Run” position, causing the driver to lose the assistance of power steering and brakes, and also caused a failure of the vehicle’s safety airbags to deploy in vehicle crashes. Our investigation further revealed that GM failed to disclose the deadly safety defect to NHTSA, and falsely represented to consumers that vehicles containing the defect posed no safety concern. These failures and false statements occurred despite the fact that GM engineers knew the switch was prone to move out of position when it went into production and the switch did not meet GM’s own internal specifications. Other GM employees also became aware of the situation as early as 2004 and 2005, when GM employees, media representatives, and customers began to experience sudden stalls and engine shutoffs and GM failed to correct the problem with a simple improvement that would cost less than a dollar a vehicle.37 In June 2005, GM publicly stated that that the inadvertent rotation of the ignition key was not a safety issue. As late as spring of 2012, certain GM personnel knew the ignition switch posed a safety problem. GM personnel further delayed a recall, taking certain affirmative steps to keep the Defective Switch outside of the normal process. On at least two occasions while the Defective Switch condition was well known by some in GM but not disclosed to the public or NHTSA, certain GM personnel made incomplete and misleading presentations to NHTSA to assure 67 68 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM the regulator it was acting promptly, effectively and in accordance with its formal recall policy to respond to safety problems. GM acknowledged a total of 15 deaths, and an undefined number of serious injuries caused by the defective switch.38 On September 17, 2015, Loretta Lynch, the Attorney General of the United States, Preet Bharara, United States Attorney for the Southern District of New York, and Special Inspector General Christy Goldsmith Romero (SIGTARP) announced that GM was criminally charged with one count of concealing the safety defect from NHTSA and one count of wire fraud. Mr. Bharara also announced a deferred prosecution agreement with GM under which the Company admitted that it failed to disclose a safety defect to NHTSA and misled US consumers about that same defect.39 GM agreed to pay $900 million and install an independent monitor to review and assess policies, practices, and procedures relating to GM’s safety-related public statement, sharing of engineering data and recall processes. The goal of these changes is that this type of life-threatening safety defect never happens again. GM paid victims through a separate fund.40 This case had nationwide repercussions. In the wake of the GM ignition switch recall, NHTSA changed its policies and practices and reporting requirements imposed on the auto industry, stating that “It is no overstatement to say this was one of the most significant cases in NHTSA’s history, not only because of the tragic toll of deaths and injuries, or the technical challenges it presented, but because of the unprecedented steps the manufacturer took to conceal a deadly defect.”41 This case resulted in significant improvements in keeping drivers safe, even while the investigation was ongoing. The case was closely followed by the industry and the public. The case directly contributed to a quicker industry response to identify, address, and rectify automobile defects. This becomes evident in that vehicle recalls skyrocketed from approximately 20 million in 2013 to 51 million in 2014 and over 51 million in 2015.42 Our roads are safer when defective parts in cars manufactured by the largest car companies in the world are replaced before injury or loss of life. SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 Ally Financial (formerly GMAC): SIGTARP’s investigation with the Department of Justice (“DOJ”) found that Ally acted improperly in packaging, securitizing, marketing, selling, and issuing subprime residential mortgage backed securities (“RMBS”). DOJ agreed that Ally would pay $52 million and immediately discontinue operations of its broker-dealer Ally Securities, LLC, which was the lead underwriter on the subprime RMBS that we investigated. Ally received $17.2 billion in TARP funds. Treasury wrote-off a $2.47 billion loss on the principal TARP investment, based on losses when Treasury sold Ally’s common stock into the market. Special Inspector General Christy Goldsmith Romero said about the case, “With the agreement, Ally acknowledges that the underwriting and due diligence process was deficient in connection with the securitization of 40,000 toxic subprime mortgage loans by its subsidiaries – exactly the type of abuse that contributed to the financial crisis.”43 As the lead underwriter, Ally Securities recognized in 2006 and 2007 that there was a consistent trend of deterioration in the quality of the mortgage loan pools underlying 10 subprime RMBS offerings called RASC-EMX. This deterioration stemmed, at least in part, from deficiencies in the subprime mortgage loan underwriting guidelines and diligence applied to the collateral prior to securitization. All of the RASC-EMX Securities sustained losses as a result of the underlying mortgages falling delinquent. United States Attorney for the Central District of California Eileen Decker, who prosecuted the case, said, “These securities were marketed to investors with the knowledge that a significant percentage of the pooled subprime mortgages were toxic. Nevertheless, Ally Securities continued to market the RMBS, and investors lost millions of dollars as the value of the securities plummeted.”44 69 70 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM SIGTARP’S OVERSIGHT OF THE HOME AFFORDABLE MODIFICATION PROGRAM (“HAMP”) SIGTARP conducts audits and investigations of HAMP, which pays mortgage servicers and investors to lower high mortgage interest rates (permanently) for participating homeowners. Treasury is spending approximately $690 million a quarter on HAMP.45 HAMP is terminated for new homeowner applications. However, under contract between Treasury and more than 100 mortgage servicers, Treasury has TARP obligations related to the nearly one million homeowners in HAMP.46 Under the more than 100 Treasury contracts, Treasury is already obligated to pay more than $7.5 billion in TARP dollars over the next 7 years ($5.6 billion to servicers and investors and just under $2 billion to those same servicers to reduce the principal mortgage balance for homeowners) as seen in Table 3.4. Treasury may also be obligated to pay an additional $4 billion based on homeowners who applied for the program by December 31, 2016 (the application cutoff.)47 These payments do not go out all at once, and they do not go out automatically. Instead, payments are based on continuous reporting to Treasury and compliance with Treasury rules in HAMP.48 SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 TABLE 3.4 TREASURY CONTRACTS FOR TAX DOLLARS TO BE PAID TO HAMP MORTGAGE SERVICERS UNTIL 2023, AS OF 12/31/2016 $4.1 Billion + Obligated to be paid $2.7 Billion + Obligated to be paid $2.7 Billion + Obligated to be paid $2.0 Billion + Obligated to be paid $1.1 Billion + Obligated to be paid $1.0 Billion + Obligated to be paid Tax dollars paid Tax dollars paid Tax dollars paid Tax dollars paid Tax dollars paid Tax dollars paid $669 Million Tax dollars paid Other Servicers TOTAL $2.0 Billion Tax dollars paid $16.2 Billion Tax dollars paid + + $2.2 Billion $1.1 Billion $745 Million $500 Million $874 Million $747 Million $142 Million Obligated to be paid $1.3 Billion Obligated to be paid $7.5 Billion Obligated to be paid Sources: Treasury, Aggregate Cap Monitoring Report - December 2016; Treasury, TARP Housing Transaction Reports, 12/27/2016, https://www.treasury.gov/initiatives/financial-stability/reports/Pages/TARP-Housing-Transaction-Reports.aspx, accessed 1/3/2017; SIGTARP analysis of Treasury HAMP data. 71 72 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM Significant oversight is required to prevent waste, fraud, and abuse related to the $7.5 billion Treasury is already obligated to pay for the servicers, investors, and homeowners. The large bank and nonbank servicers are required to follow Treasury’s rules in HAMP, and other applicable laws and rules. Some of these servicers have already faced law enforcement action and been found to have broken Treasury’s rules in HAMP, other rules or laws, and engaged in abuse of homeowners and overcharging of Treasury. If Treasury does not make these contractual payments, it risks that servicers and investors may find a way to increase interest rates on the mortgages of nearly one million homeowners in HAMP nationwide, as shown in Figure 3.1. SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 FIGURE 3.1 ACTIVE HAMP MODIFICATIONS BY STATE AND REGION, AS OF 12/31/2016 19,288 2,588 887 125 864 3,847 12,554 9,941 56,192 8,448 268 3,059 4,674 13,624 25,063 355 22,589 2,112 1,246 21,154 18,605 48,876 6,468 11,100 226,293 21,663 2,238 9,295 1,182 21,889 8,892 33,916 2,923 31,171 1,636 3,804 17,158 10,009 2,388 29,488 2,160 9,083 3,224 3,463 28,146 5,464 32,678 5,660 122,056 409 HI 3,713 Rust Belt States Southern States Other States Note: Includes HAMP Tier 1 and Tier 2 modifications. Source: Treasury, 1MP Program Volumes - December 2016, accessed 1/19/2017. 73 74 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM With the exception of the highly populated California, and New York, the states with the highest numbers of people participating in HAMP now are generally in the rust belt and the south.49 SIGTARP Audit Oversight Over HAMP SIGTARP has already identified millions of dollars in cost savings for HAMP. Going forward, as Treasury pays approximately $690 million each quarter, SIGTARP will look to identify waste, vulnerabilities to fraud, servicer mismanagement, and inefficiencies that could lead to cost savings. Instead of meeting its goal to help 3 to 4 million homeowners, more than 4 million people were turned down by their mortgage servicer for HAMP (7 out of 10 people who applied), of the over 1.6 million homeowners in HAMP at one time, about 1 million remain in HAMP today.50 At least 150,000 of the roughly 575,000 people cancelled out of HAMP were foreclosed on or otherwise lost their home, and others were put in a less advantageous program.51 Taxpayers paid $2.3 billion mostly to servicers and investors, as well homeowners for those cancelled HAMP modifications.52 SIGTARP’s audit priorities in HAMP are to: • Identify vulnerabilities to fraud by servicers • Identify waste by servicers • Identify inefficiencies and servicer mismanagement that could lead to cost savings SIGTARP will be focused on the largest HAMP servicers that account for 87% of TARP funds, and have a known history of homeowner complaints, enforcement actions, mismanagement, and wrongdoing already identified by SIGTARP.53 HAMP should not be a federal program where a homeowner who breaks the rules gets kicked out, while large servicers who break the rules continue to be paid millions of TARP dollars and suffer no consequences for repeated violations. Treasury can save costs by temporarily (and in some cases, permanently) withholding TARP payments where servicer violations are found over more than one quarter. SIGTARP has identified the following servicer mismanagement and abuse by servicers: • Wrongfully terminating people out of HAMP • Misapplying mortgage payments made in HAMP which causes delinquency that incur late fees • Transferring the mortgage without transferring the HAMP paperwork. The new servicer does not know the person is in HAMP so only sees underpayment, or fails to honor the HAMP lowered interest rate • Failing to notify homeowners, as Treasury requires, when their interest rate and monthly payment is going to rise after 5 years SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 • Failing to notify homeowners, as Treasury requires, that after 6 years in HAMP they can lower their mortgage payment by re-amortizing the mortgage • Overcharging Treasury for extinguishing second liens when those liens were not extinguished • Failing to reduce principal on mortgages despite being paid by Treasury to do so SIGTARP has reported how servicer mismanagement led to canceling people out of HAMP. Treasury has partially implemented SIGTARP’s recommendation to determine how servicer misconduct leads to canceling people out of the program by finding that 6 of the largest 7 servicers in HAMP have wrongfully cancelled homeowners out of the program. However, Treasury’s compliance group only looks on a small sample basis of 150 homeowner files per quarter, and does not know the full extent of the problem. Treasury makes the servicer put any wrongedhomeowner found in this sample back into HAMP. This mismanagement lead to inefficiency in government payments. In order to determine the full scope of mismanagement, Treasury could start with requiring servicers found in violation to conduct an independent review and self-report to Treasury on other homeowners wrongfully cancelled out of the program. Servicer Track Records Evidence High Risk Areas 68% Homeowners denied for HAMP 325,242 People in HAMP now or before 127,342 Homeowners fell out of HAMP (39%) costing taxpayers $712 million Source: Treasury, 1MP Program Volumes - December 2016, accessed 1/19/2017; Treasury, Response to SIGTARP data call 1/17/2017; SIGTARP analysis of Treasury HAMP data. Ocwen is the largest recipient of federal funds in HAMP, but also has one of the worst track records in foreclosure mitigation, including HAMP. Ocwen had an enforcement action in December 2013 for significant and systemic “deception and shortcuts in mortgage servicing”, which included improperly denying homeowner’s a loan modification and failing to properly apply a homeowner’s payment, both of which are extremely relevant to conducting oversight over Ocwen in HAMP.54 During the last two years, Treasury has found that Ocwen wrongfully denied 75 76 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM homeowners help from HAMP and wrongfully cancelled homeowners out of HAMP.55 • Wrongfully canceling homeowners out of HAMP: Treasury continued to find in 2014 through 2016 that Ocwen wrongfully cancelled homeowners out of HAMP. More than 127,000 homeowners who were in a HAMP modification with Ocwen have fallen out of HAMP. Ocwen was paid in excess of $725 million through HAMP for these cancelled homeowners. More than 30,000 of these homeowners went into foreclosure or otherwise lost their home.56 Treasury has found that Ocwen wrongfully cancelled people out of HAMP based on Ocwen’s own misconduct similar to the conduct in Ocwen’s enforcement action. Ocwen cancelled homeowners out of HAMP finding that they had missed three payments, when in reality homeowners made the payments, but Ocwen held mortgage payments in suspense, improperly reversed and later reapplied mortgage payments, and did not timely post payments made to an Ocwen lockbox. Treasury does not know how many homeowners Ocwen has wrongfully cancelled out of HAMP. Treasury’s findings on a sample basis of some people wrongfully cancelled out of HAMP by Ocwen should be viewed in light of the December 2013 enforcement action that found, in part for Ocwen “Failing to timely and accurately apply payments made by borrowers and failing to maintain accurate account statements.”57 In order to determine the full extent of mismanagement, Treasury could start with requiring Ocwen to conduct an independent review and report on all people wrongfully cancelled out of HAMP, while also requiring additional controls to ensure that homeowner payments are timely and accurately posted. • Wrongfully denying homeowners admission in HAMP: Ocwen has until September 2017 to determine which homeowners who applied by December 30, 2016 are admitted into HAMP. Ocwen’s denial of 68% of those who applied for HAMP should be looked at through the lens of the enforcement action which found that Ocwen “improperly denied loan modifications.”58 This included: Failing to provide accurate information about loan modifications and other loss mitigation services; Failing to properly process borrowers’ applications and calculate their eligibility for loan modifications; Providing false or misleading reasons for denying loan modifications; Failing to honor previously agreed upon trial modifications with prior servicers; and Deceptively seeking to collect payments under the mortgage’s original unmodified terms after the consumer had already begun a loan modification with the prior servicer. In the last two years, Treasury found that Ocwen denied homeowners for HAMP that should have been admitted and/or failed to offer homeowners a HAMP modification.59 With Treasury contracted to pay up to another scheduled $2.2 billion and possibly an additional $941 million to Ocwen, continued oversight over these billions of dollars and this program remains critical.60 SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 60% Homeowners denied for HAMP 212,102 People in HAMP now or before 64,925 Homeowners fell out of HAMP (31%) costing taxpayers $283 million Source: Treasury, 1MP Program Volumes - December 2016, accessed 1/19/2017; Treasury, Response to SIGTARP data call 1/17/2017; SIGTARP analysis of Treasury HAMP data. Wells Fargo is the second largest receiver of TARP funds under the HAMP program. Wells Fargo has broken HAMP’s rules by canceling people out of HAMP who made their payments on time, and by failing to notify homeowners in HAMP, as Treasury requires, on a timely basis that their mortgage payment was going to increase.61 • Wrongfully canceling homeowners out of HAMP: Almost 65,000 homeowners with their mortgage serviced by Wells Fargo have cancelled out of HAMP costing taxpayers $283 million. While Treasury even in the last year found that Wells Fargo wrongfully cancelled some people out of HAMP, Treasury does not know how many total homeowners Wells Fargo wrongfully cancelled out of the program. Treasury does not know how many total homeowners Wells Fargo wrongfully cancelled out of the program. Wells Fargo cancelled people out of HAMP finding that they had missed three payments, when in reality the homeowners made the payments, but Wells Fargo did not timely and accurately apply the payments. In order to determine the full extent of mismanagement, Treasury could start with requiring Wells Fargo to conduct an independent review and report on other people wrongfully cancelled out of HAMP, while also requiring additional controls that could stop wrongful cancellations.62 • Failing to notify homeowners timely that their mortgage was increasing: Wells Fargo failed to notify homeowners of upcoming increases to their mortgage payments in accordance with HAMP rules. Treasury requires that the servicer give a 120 day notice and a 60 day notice before the payment increase giving homeowners an opportunity to find means to pay their mortgage. • Failure to notify homeowners that they can lower their mortgage payment after 6 years in HAMP: Wells Fargo also failed to notify on a timely basis homeowners that had successfully made their HAMP mortgage payment for 77 78 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM six years that the homeowner could lower their mortgage payment by reamortizing (recasting) their unpaid principal balance. Treasury reviewed 25 homeowner files during each of the past two quarters, and found problems with Wells Fargo’s handling of some of those loans. The ability of successful HAMP homeowners to re-amortize their mortgage after six years is a major push made by Treasury to keep people in HAMP based on SIGTARP’s recommendations to curb HAMP terminations. Wells Fargo’s failure to timely notify these homeowners of their right to re-amortize their loan may result in the homeowner paying a higher monthly principal and interest payment over the remaining term of the mortgage. Given that Treasury does not know how many other homeowners did not receive timely notice that their mortgage payment would increase or that they could re-amortize their mortgage given Treasury’s small sample size, Treasury could start with requiring Wells Fargo to self-report these violations. With Treasury contracted to pay up to another scheduled $1.1 billion and possibly an additional $663 million to Wells Fargo, continued oversight over these dollars and this program remains critical.63 84% Homeowners denied for HAMP 168,494 People in HAMP now or before 45,452 Homeowners fell out of HAMP (27%) costing taxpayers $194 million Source: Treasury, 1MP Program Volumes - December 2016, accessed 1/19/2017; Treasury, Response to SIGTARP data call 1/17/2017; SIGTARP analysis of Treasury HAMP data. JPMorgan denied nearly 1 million people for HAMP—84% of all who applied through this servicer.64 According to Treasury in its compliance reviews, JPMorgan went from a history of one of the worst offenders of breaking Federal rules governing HAMP, to recently improving. If this is the case, it shows that it is possible for a large bank or non-bank servicer to follow Federal rules governing HAMP. For example, Treasury did not find that JPMorgan miscalculated homeowner income over the past year, showing that it is possible for a large bank to put controls in place to calculate income correctly.65 However, JPMorgan’s extremely high rate of keeping people out of HAMP will require deeper Treasury scrutiny between now and the September 2017 deadline on whether JPMorgan properly evaluated homeowners for admission to HAMP. With a backlog of over SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 15,000 applications and a process rate of only 2,575 applications per month, JPMorgan will be rushing to review applications through the September 2017 deadline, which could lead to improper evaluation of homeowner applications.66 One rule that JPMorgan has been breaking is the Treasury rule to provide homeowners the opportunity to re-amortize their mortgage which could lower their mortgage payment after six years to bring their monthly payment goes down. Treasury has found that JPMorgan failed to notify homeowners in HAMP that they were eligible to re-amortize their mortgage and lower their payments. 79% Homeowners denied for HAMP 111,138 People in HAMP now or before 36,632 Homeowners fell out of HAMP (33%) costing taxpayers $129 million Source: Treasury, 1MP Program Volumes - December 2016, accessed 1/19/2017; Treasury, Response to SIGTARP data call 1/17/2017; SIGTARP analysis of Treasury HAMP data. Bank of America also has one of the worst track records in HAMP. SIGTARP’s investigation of Bank of America defrauding HAMP led to a 2012 Department of Justice agreement with Bank of America.67 Treasury found that Bank of America needed substantial improvement in complying with HAMP’s rules in 5 of the last 6 quarters. This should be unacceptable given that Bank of America has already received about $2 billion from Treasury for HAMP.68 • Risk of Waste — Overcharging Treasury: In 2016,Treasury found that Bank of America has overcharged Treasury by hundreds of thousands of dollars found in Treasury’s sample. Bank of America reported incorrect information about the delinquency status of several second liens that were extinguished through the HAMP Second Lien program, resulting in more than $400,000 in wasted tax dollars, including almost $150,000 on a single loan. Treasury requested that Bank of America perform a lookback analysis to determine whether there were other instances of misreporting. • Wrongfully denying homeowners admission into HAMP: Bank of America denied 79% of all who applied for HAMP, which requires deeper Treasury scrutiny on whether Bank of America is properly evaluating homeowners. In the second quarter 2016, Treasury found more instances of Bank of America wrongfully denying homeowners for HAMP. With a backlog of 29,075 79 80 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM applications and a process rate of only 3,285 applications per month, Bank of America will be rushing to review applications through the September 2017 deadline, which could lead to improper evaluation of homeowner applications.69 • Miscalculation of income: Bank of America has one of the worst track records of any large servicer on miscalculating homeowner income. Miscalculation can lead to Bank of America denying a qualified homeowner for HAMP or set a higher mortgage payment for people in HAMP. • Risk of waste—Failing to reduce principal despite being paid by Treasury to do so: In the HAMP principal reduction program, Treasury pays servicers typically several thousand tax dollars per loan to reduce the outstanding balance of underwater mortgages. Treasury found that Bank of America failed to reduce the principal despite being paid by Treasury about $4,500 on average to do so. Bank of America did not reduce these homeowners’ underwater balances until Treasury later inquired about the status of these loans, showing the risk of waste, and the power of oversight. 53% Homeowners denied for HAMP 209,262 People in HAMP now or before 58,133 Homeowners fell out of HAMP (28%) costing taxpayers $168 million Source: Treasury, 1MP Program Volumes - December 2016, accessed 1/19/2017; Treasury, Response to SIGTARP data call 1/17/2017; SIGTARP analysis of Treasury HAMP data. Nationstar also has one of the worst track record in HAMP. Nationstar’s violations of Treasury rules have been widespread spanning multiple quarters. Nationstar has shown little improvement and, even appears to be getting worse. • Wrongful denying or failing to offer homeowners HAMP admission: Of all large HAMP servicers, Nationstar has the worst recent track record in wrongfully denying or failing to offer homeowners admission into HAMP. • Wrongful cancellation of homeowners out of HAMP: More than 58,000 homeowners whose mortgages are serviced by Nationstar have fallen out of HAMP, representing taxpayer payments of $168 million to Nationstar. Nationstar has wrongfully cancelled homeowners out of HAMP. This has serious consequences, as 47% of homeowners who have fallen out of HAMP through Nationstar have gone into foreclosure or otherwise lost their homes SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 • • • • • (33% through foreclosure and 15% through short sales or deed-in-lieu foreclosure).70 Nationstar incorrectly claimed that some homeowners in HAMP had missed three payments. Treasury does not know how many homeowners Nationstar wrongfully terminated out of HAMP given their small sample size of 100 HAMP terminations each quarter. In order to determine the full extent of mismanagement, Treasury could require Nationstar to conduct an independent review and report on all people wrongfully cancelled out of HAMP, while also requiring additional controls to ensure that homeowner payments are timely and accurately posted. Misreporting of homeowner payments: Nationstar has, on numerous occasions, misreported homeowner payment information to Treasury that resulted in homeowner harm of lost TARP payments or wasted tax dollars. In some cases, Nationstar reported homeowners as delinquent when they had not missed payments. Risk of Waste -- Overcharging Treasury: Treasury found, even recently, that it overpaid Nationstar due to Nationstar’s faulty reporting. Failure to notify homeowners on timely basis about increase in mortgage payment: Quarter after quarter Nationstar has also failed to timely notify homeowners in HAMP, as Treasury requires, that their interest rate was rising and therefore their mortgage payment was also rising. Failure to notify homeowners in their 6th year of HAMP about opportunity to re-amortize and lower their monthly payment: Nationstar has not followed Treasury rules to provide timely notification to homeowners of their ability to re-amortize their loan, and lower their payment. Miscalculation of income: Nationstar has miscalculated homeowner income quarter after quarter. 44% Homeowners denied for HAMP 142,003 People in HAMP now or before 55,498 Homeowners fell out of HAMP (39%) costing taxpayers $377 million Source: Treasury, 1MP Program Volumes - December 2016, accessed 1/19/2017; Treasury, Response to SIGTARP data call 1/17/2017; SIGTARP analysis of Treasury HAMP data. Select Portfolio is the fifth largest HAMP servicer.71 Select Portfolio is the only servicer out of the largest 7 servicers in HAMP that Treasury has not found to have wrongfully terminated homeowners out of HAMP. It also is the only one 81 82 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM of the 7 servicers who denied admission to less than half of all homeowners that applied to HAMP.72 Previously, Treasury has found that some instances where SPS misreported information that impacts the TARP funds that investors receive for current homeowners. Fixing that could represent a cost savings. However, that would require Treasury to determine the full extent of misreporting and TARP funds involved. 88% Homeowners denied for HAMP 36,665 People in HAMP now or before 12,978 Homeowners fell out of HAMP (35%) costing taxpayers $45 million Source: Treasury, 1MP Program Volumes - December 2016, accessed 1/19/2017; Treasury, Response to SIGTARP data call 1/17/2017; SIGTARP analysis of Treasury HAMP data. CitiMortgage has had a track record of not following the Federal rules governing HAMP. HAMP is at risk of waste by CitiMortgage. • Risk of waste--Late reporting homeowners who fell out of HAMP/ overcharging TARP: CitiMortgage has wrongfully terminated homeowners out of HAMP. However, Treasury is not aware of the full extent of the problem, given its small sample size. Treasury found that in some instances CitiMortgage delayed reporting the termination to Treasury, delaying sometimes more than 100 days, in one case delaying reporting to Treasury for more than 2 years and in another case more than 5 years. During this time, CitiMortgage would have received “pay for success” TARP payments, including $1,000 each year to put towards principal, servicer payments (if the HAMP modification was in its first three years), and investor payments. These payments represent waste. Treasury also found other instances where CitiMortgage received TARP funds based on inaccurate reporting. Treasury is requiring CitiMortgage to identify the total population of loans that were part of misreporting related to termination of HAMP modifications. • Misapplication of investor payments: One year ago, CitiMortgage misapplied payments causing 9 out of 10 (tested) loans to be reported as 30 days delinquent when they were not. This abuse of HAMP raises concerns about other times CitiMortgage may have misapplied payments. • Denied 88% of homeowners seeking help in HAMP: CitiMortgage has the highest rate of denying homeowners for admission to HAMP – 88%, which SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 are 341,625 homeowners. CitiMortgage has the lengthiest delays of any major servicer in reviewing HAMP applications –up to 16 months, which could cause it to rush and wrongfully deny others for HAMP. This requires deeper Treasury scrutiny by the September 2017 deadline on whether CitiMortgage is properly evaluating homeowners for admission to HAMP. • Failure to notify homeowners in their 6th year of HAMP about opportunity to re-amortize and lower their monthly payment: CitiMortgage has continued to fail to provide homeowners the required notice about their ability to reamortize their loan to reduce their mortgage payment. SIGTARP Investigations Related to HAMP SIGTARP’s investigations related to HAMP have: (1) shut down scams, bringing justice to scammers stealing homeowners’ money on a false promise that they can get a homeowner into HAMP, and then do little to nothing; and (2) led to DOJ actions against HAMP servicers related to misconduct and false representations to Treasury and/or homeowners. Going forward, our priority for investigations related to HAMP will be any investigation involving a mortgage servicer being paid with TARP dollars to administer HAMP. Supporting Convictions for Mortgage Modification Scams SIGTARP’s investigations of mortgage modification scams that relate to HAMP have netted 88 convicted defendants (65 already sentenced to prison with others awaiting sentencing). These scams targeted at least 40,353 victim homeowners who were seeking help to apply to HAMP in all states, as shown in Figure 3.2, although the number of actual victims may be even higher. This includes over 7,900 victims in Florida, more than 7,500 victims in California, almost 2,800 homeowners in Georgia, more than 2,500 victims in Virginia, almost 1,700 in Maryland, almost 1,400 homeowners in Arizona, more than 1,300 in North Carolina, and more than 1,000 victims in Illinois. 83 84 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM FIGURE 3.2 VICTIMS OF THE HAMP FRAUDSTERS SIGTARP STOPPED, AS OF 12/31/2016 895 101 74 12 73 274 82 436 50 138 1,047 439 644 39 674 142 58 839 909 1,039 525 631 7,534 136 404 139 196 535 2,512 99 (DC) 186 308 1,308 505 79 134 824 59 142 1,689 (MD) 80 714 1,395 620 311 282 2,795 221 7,933 24 HI 63 Notes: Victims represented on the map were identified during SIGTARP investigations and were provided to United States attorney's to assist in charging, trial or determining restitution. There may be additional victims. Source: SIGTARP analysis of investigation data. SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 With the expiration of the HAMP application period, new scams are not likely to be related to HAMP. SIGTARP’s strong law enforcement actions against fraud related to HAMP also served to deter fraud. Investigations of HAMP Mortgage Servicers SIGTARP’s investigations resulted into three DOJ actions against mortgage servicers, SunTrust Bank, JP Morgan and Bank of America. Criminal conduct by SunTrust Bank: SIGTARP’s investigation of HAMP mortgage servicer SunTrust Mortgage, Inc., a subsidiary of TARP recipient SunTrust Bank, uncovered criminal conduct by SunTrust including that SunTrust made misrepresentations to homeowners seeking help from HAMP. SunTrust failed to process HAMP applications timely, instead piling so many unopened fed ex packages of HAMP applications and homeowner documents in a room that the floor eventually buckled. SunTrust mass denied homeowners for HAMP, and then lied to Treasury about the reason why those homeowners were denied. The U. S. Attorney for the Western District of Virginia entered into a non-prosecution agreement of charges of mail fraud, wire fraud, and false statements to Treasury, with SunTrust Bank who paid $225 million in restitution to victims and made significant corporate changes to prevent fraud. Investigation into JP Morgan Chase’s Misconduct in HAMP: As part of the $25 billion robosigning agreement with the five largest mortgage servicers, DOJ resolved allegations investigated by SIGTARP related to JP Morgan Chase’s failure to engage in adequate loss mitigation efforts (HAMP) for past due homeowners, none of which was a fine. Of this $6,187,500 was attributed to SIGTARP’s investigation. Investigation into Bank of America’s Misconduct in HAMP: As part of the $25 billion robosigning agreement with the five largest mortgage servicers, DOJ resolved allegations investigated by SIGTARP related to Bank of America defrauding HAMP. Of this amount, $6.5 million was attributed to SIGTARP’s investigation. SIGTARP will continue to investigate mortgage servicers participating in HAMP. 85 86 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM SIGTARP’S OVERSIGHT OVER THE HARDEST HIT FUND SIGTARP conducts oversight through audits and investigations of the Hardest Hit Fund (“HHF”), a $9.6 billion program. In February 2016, Members of Congress worked across the aisle to convince Congress to add $2 billion to HHF, and Treasury extended the program to year-end 2020.73 This $2 billion has not yet been spent. HHF has $2.56 billion remaining.74 Treasury is spending approximately $300 million a quarter on HHF. HHF has two primary purposes: 1. H HF Unemployment Bridge: HHF provides a temporary safety net to save the homes of unemployed or underemployed working class Americans in Rust Belt States (Ohio, Michigan, Indiana and Illinois), Southern states (North Carolina, South Carolina, Alabama, Tennessee and Georgia) and 10 other states across the country. TARP funds pay part of the mortgages of American workers who lost their jobs through no fault of their own (or saw their paycheck cut), generally for no more than a year, while they look for a full-time job. 2. HHF Blight Demolition: Abandoned houses and near empty factories became eyesores to suffering communities, dragging down property values, and contributing to crime. In response, Treasury allowed seven rust belt and southern states (Ohio, Michigan, Indiana, Illinois, Alabama, South Carolina, and Tennessee) to shift some existing HHF funds to demolish blighted abandoned houses with the goal of the neighborhood stabilization. It may also lead to work for local demolition companies and jobs.75 An approximately $10 billion program requires significant federal oversight on both the money already spent, and the approximately $300 million that will be spent each quarter. SIGTARP Investigations Related to HHF SIGTARP is actively conducting criminal investigations related to the Hardest Hit Fund. In fiscal year 2017, two homeowners who received HHF dollars were indicted for false statements. Michael Reynolds allegedly falsified his HHF application saying he was single when his wife worked at the state agency in charge of HHF. Tannis Brazil allegedly under reported cash savings to qualify for HHF. SIGTARP Prioritizes Investigations in the More Than $800 Million TARP-Funded Demolition Program.76 TARP-funded demolitions did not begin until April 2014, but already there are nearly 400 cities or other local partners, each of which can hire multiple contractors and subcontractors. Only a small number of these local partners are cities/counties (3) or other public agencies (35). In this TARP program, 147 of the SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 local partners are individuals, 8 are for-profit companies, 158 non-profit entities, and 39 land banks.77 See Figure 3.3. Right now, we are analyzing data and conducting trend analysis to find crime proactively in the $811 million blight demolition program, rather than solely relying on tips and referrals. SIGTARP’s audits identified vulnerabilities to unfair competitive practices, fraud, and waste. SIGTARP’s investigations root out these and other crimes, or civil fraud. FIGURE 3.3 HHF BLIGHT ELIMINATION PROGRAM PARTNERS WHO RECEIVE TARP FUNDS 2.1% 9.7% 40.5% SIGTARP Audit Oversight of HHF HHF has helped more than a quarter of a million homeowners, but even good programs can be better, more efficient, and can have cost savings, and must be protected from fraud, waste and abuse.78 The majority of SIGTARP’s current audit work is in response to concerns raised by members of Congress after SIGTARP identified waste, abuse or risks of fraud. SIGTARP works to identify cost savings through recommendations. SIGTARP also identified previously spent federal funds that were wasted or abused, so that Treasury can seek repayment of those dollars. However, Treasury has not sought repayment. SIGTARP forensic auditors also refer potential fraud to SIGTARP agents. SIGTARP’s audit priorities in the Hardest Hit Fund are to: • Identify vulnerabilities to fraud in the HHF demolition programs • Identify possible fraud by contractors, city or state agencies, or other local partners • Identify waste by demolition contractors, city or state agencies, or other local partners • Identify wasteful spending by state agencies paid with HHF dollars or their contractors • Identify abuse by city or state agencies, or other local partners • Identify mismanagement or inefficiency by state agencies paid with TARP dollars • Identify potential cost savings and make recommendations 37.7% 10.0% Governments (38) Individuals (147) Land Banks (39) Non-Profit Entities (158) For Profit Entities (8) Source: State HFA responses to SIGTARP request. 87 88 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM SIGTARP Identified Abuse in HHF Demolition Program $246,490 COST SAVINGS FROM SIGTARP RECOMMENDATIONS SIGTARP alert: In December 2015, SIGTARP identified abuse by a city and state agency using TARP dollars to demolish occupied homes, rather than abandoned homes. SIGTARP uncovered that in Evansville, Indiana; people in 18 houses were being evicted or asked to move so that the house would qualify as vacant so that TARP could fund Occupied house in Evansville, Indiana, demolished using TARP the demolition and a car dealership funds, photo provided to SIGTARP. could move to the site. The Indiana agency administering HHF was aware that people lived in the homes. City inspection reports presented to the Indiana agency listed the homes as occupied. Photographs of the homes submitted to the Indiana agency (one of which is above) showed that people lived in the homes as evidenced by children’s bicycles, a baby stroller, a child’s tree swing, barbecue grills, front porch chairs, wind chimes, decorations, and several American flags. And there were television stories showing the people living in their house. Despite Treasury’s contract with the Indiana agency limiting HHF funds to vacant and abandoned houses, the Indiana agency approved the use of TARP funds to demolish the houses, all so that the city could move D. Patrick Ford’s auto dealer car lot to those streets. SIGTARP recommended that Treasury direct state agencies to limit HHF to demolish abandoned properties only in line with their contract, and claw back $246,490 used to demolish the January 8, 2016 – Hearing to lived-in residences.79 examine Treasury’s oversight of the After SIGTARP’s report: After notifying Hardest Hit Fund, Treasury’s policies Treasury of this abuse, Chairman Jason Chaffetz of the House Oversight to ensure accountability and measure Committee scheduled a hearing on the effectiveness of the HHF January 8, 2016.iii program, and Treasury’s policies to On January 15, 2016, Treasury prevent misuse of program funds. issued state agencies a directive that the Chairman Jason Chaffetz house must have been abandoned prior to initiating a demolition, the hearing did iii United States House of Representatives, Hearing: Treasury Oversight of TARP’s Hardest Hit Fund, www.house.gov/legislative/ date/2016-01-08, accessed 1/4/2017. SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 not go forward.80 Treasury has not clawed back the $246,490. Treasury should not allow the Indiana agency to keep funds that have been misused. SIGTARP Identified Vulnerabilities in HHF Demolition Program to Unfair Competitive Practices and Overcharging, Potentially Leading to Fraud and Waste $161 MILLION COST SAVINGS FROM SIGTARP RECOMMENDATIONS SIGTARP’s June 2016 Report: SIGTARP identified that this program, which, at the time of the report, had spent $192.4 million out of almost $800 million to demolish 12,980 houses, is significantly vulnerable to the substantial risks of unfair competitive practices and overcharging than the similar, but Blighted house used in PowerPoint for Evansville, Indiana, public much smaller HUD demolition meeting about HHF demolitions, photo provided to SIGTARP. program. The HUD program requires entities seeking these Federal dollars to adhere to federal requirements that limit reimbursement to only necessary and reasonable costs, and requirements that ensure full and open competition. The TARP program does not have similar protections which risks fraud, and waste.81 SIGTARP raised concerns that the HHF demolition program is vulnerable to fraud, waste, and overcharging because unlike HUD, Treasury does not limit federal payments to costs that are necessary and reasonable—the normal standard in demolition contracts. Instead, Treasury set a worst-case-scenario maximum allowable cost of $25,000 or $35,000 per house, depending on the state. SIGTARP reported that the TARP program leaves decisions about what costs are necessary and reasonable, and about whether and in what form to have competition in the solicitation and award of contracts, to the recipients of Federal funds. Demolition costs have been rising in this program, but Treasury has no way of knowing whether this rise in costs reflect costs that are necessary and reasonable, or instead reflect overcharging. Federal requirements for competition are critically important to keep programs fair, drive down costs, motivate better contractor performance, and help curb fraud, waste, abuse, favoritism, undue influence, contract steering, bid rigging, and other closed-door contract processes. SIGTARP identified that TARP’s demolition program is vulnerable to the risk of these backroom unfair competitive 89 90 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM practices. The TARP program has no federal requirements for competition in the awarding of contracts, and 5 of 7 state agencies do not have their own competition requirements. HUD’s federal program for blight elimination has significant requirements for competition that could easily be applied to this TARP program. The TARP program is even more at risk than HUD’s program because in HUD’s program, the nearly local partners receiving the money are municipalities, compared to only 4 cities/counties in the TARP program.82 After SIGTARP’s report: In July 2016, members of the House Committee on “Approximately $458 million remains Oversight and Government Reform to be spent in the Blight Elimination including Chairman Jason Chaffetz, Program. Treasury can still take Chairman of Subcommittee Jim Jordan, action to implement SIGTARP’s Representative John J. Duncan, Jr., and Representative Mick Mulvaney, sent a recommendations and create letter to Treasury Secretary Lew citing federal requirements to protect to SIGTARP’s audit findings, and their against waste, fraud, and abuse, concerns. These members of Congress while allowing for locally-tailored requested documents and information, solutions and flexibility.” including Treasury’s timeline for fully responding to SIGTARP’s Chairman Jason Chaffetz, Chairman Jim recommendations. Jordan, Representative John J. Duncan, Jr., After SIGTARP’s report, the Representative Mick Mulvaney Michigan state agency added a requirement that all of the work be bid. Treasury is now implementing SIGTARP’s recommendation to: (1) limit TARP reimbursement to necessary and reasonable costs, and (2) require full and open competition. Implementation of these two recommendations will save the government up to $161 million. SIGTARP has additional unimplemented recommendations in its audit that state agencies use best practices to determine necessary and reasonable costs and additional unimplemented recommendations that mirror HUD requirements, requirements designed to ensure full and open competition. SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 SIGTARP Identified $8.2 Million in Wasteful Spending of HHF Dollars in Nevada $8.2 MILLION COST SAVINGS FROM SIGTARP RECOMMENDATIONS SIGTARP’s September 2016 Report: SIGTARP identified $8.2 million in wasted TARP dollars and abuse by the Nevada Affordable Housing Assistance Corporation (NAHAC), the contractor selected by the Nevada Housing Division to administer HHF—the worst SIGTARP has seen in the Hardest Hit Fund. SIGTARP found a deliberate attempt to use the TARP program as a cash cow for every expense imaginable, while NAHAC all but stopped admitting new homeowners. That is the textbook definition of waste and abuse. SIGTARP recommended Treasury seek repayment of the following waste: • $11,000 for the CEO’s car allowance for a Mercedes Benz • $20,000 for severance to the terminated CEO • $10,963.68 spent on employee bonuses, employee gifts, employee outings, staff lunches and other employee perks. çç SIGTARP found that NAHAC used TARP funds to treat their employees to extravagant gifts and perks, all of which was charged to the HHF. NAHAC spent these funds at restaurants, a casino, a country club, on catering and employee gifts, and on an executive’s bonus. Establishments where funds were spent include Herbs & Rye, named the nation’s best “high volume cocktail bar,” and the Dragon Ridge Country Club and Golf Course, which provides “championship golf, luxurious amenities and elegant service.” • $5,811.27 spent for holiday parties and gifts • $100,385.20 wasted on excessive rent, relocation and related costs • $184,319.21 spent on legal expenses to defend violations and alleged violations of the law çç HHF funds were used to pay lawyers to settle a federal investigation by the Department of Labor who found that NAHAC violated Federal law: employee discrimination lawsuits (block‐billed at $123,217), and for an ethics investigation (block‐billed at $18,160). • $26,395.70 to pay for forensic auditors to reconcile its books • $10,812.00 for the independent auditor to reconcile non-HHF bank accounts • $19,874.75 paid for the terminated CEO’s severance package • $10,840.18 spent on non-HHF expenses identified by Treasury • $23,838.25 identified by Treasury for unsupported and non-HHF expenses • $2,241,396 in wasted excessive administrative expenses during 2015, which exceeded the per-homeowner-cost in 2013, and 91 92 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM • $7,459,626.22 in overhead as NAHAC charged 100% of its overhead to HHF. Taxpayers should not pay for non-performance under a government contract or pay for wasteful spending. In 2015, NAHAC kept one TARP dollar for every TARP dollar it gave to a homeowner. It kept for itself more than $1.4 million of the $2.4 million in TARP dollars spent. SIGTARP found that NAHAC dropped homeowner admissions to HHF to only 6% of admissions at its peak year, but still sought 100% of their overhead from TARP, while the number of homeowners admitted to the program plummeted 94 percent.83 See Figure 3.4. FIGURE 3.4 SPENDING BY HARDEST HIT FUND NEVADA COMPARED TO HOMEOWNERS APPROVED FOR HHF $, Homeowners 3,000 HHF Dollars Spent on Gifts, Pizza, Cakes, Picnic & Office Refreshments 2,500 2,000 1,500 1,000 Homeowners Admitted to HHF 500 - 2013 2014 2015 Source: SIGTARP, Audit Report: “Waste and Abuse in the Hardest Hit Fund in Nevada”, 9/9/2016, https://www.sigtarp.gov/ Audit%20Reports/HHF%20Nevada_090916.pdf, accessed 1/13/2017. SIGTARP recommended that Treasury prohibit this contractor from HHF. The Nevada Housing Division outsourced this work to this contractor, which is rare in HHF. SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 After SIGTARP’s Report: No Money Has Been Repaid and NAHAC Continues to Administer HHF After the report, Senator Chuck Grassley sent a letter to Treasury expressing concerns about Treasury’s oversight to prevent waste.84 After receiving Treasury’s response, Senator Grassley issued the following comment on Treasury’s response: “The Treasury Department tiptoes around its responsibility to ensure that $9.6 billion in taxpayer funding is used effectively to help vulnerable homeowners stay in their homes. Treasury writes the checks and relies on states to spend the money. If states don’t pay attention to whether the money is spent properly, abuse can and does occur, as we saw in Nevada. This is unacceptable for both homeowners who were supposed to be helped by this program and the taxpayers. SIGTARP and the Government Accountability Office are right to conduct oversight and fill the void left by the Treasury Department.”85 Senator Chuck Grassley There has been no acceptance of responsibility and instead the Nevada Housing Division is keeping money from Treasury and Nevada homeowners. The Nevada Housing Division defends keeping the money despite asking the Nevada Attorney General to investigate, and releasing to the press an October 2015 letter sent to Treasury one year before SIGTARP’s report where it suggested removing NAHAC from HHF based on a “List of State of Nevada Concerns” about NAHAC including: • Lack of transparency, including private board decisions that led to the contraction of the program and the inability to disburse Treasury funding • Poor customer service, including that NAHAC had an unpublished phone number, does not publish their office location, and does not encourage face-toface communication with borrowers • Complicated intake process compared to other states in HHF • NAHAC has alienated prior working relationships with counseling agencies • NAHAC’s leadership is more concerned with funding than its customers and programs • Key staff turnover • The Nevada Housing Division is frustrated with the lack of communication with NAHAC • NAHAC has not demonstrated it can meet its mission, goals, and timelines86 The Nevada Housing Division’s representative told the press after SIGTARP’s audit that he warned Treasury about NAHAC and “from that point forward [two 93 94 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM TABLE 3.5 TREASURY PAYMENTS TO STATE AGENCIES, AS OF 9/30/2016 State Agency Administrative Expenses Alabama $10,228,238 Arizona 22,787,601 California 153,816,892 Florida 68,642,020 Georgia 29,418,205 Illinois 36,608,993 Indiana 29,432,302 Kentucky 15,516,694 Michigan 36,509,749 Mississippi 11,988,041 Nevada 17,479,651 New Jersey 25,831,308 North Carolina 65,768,901 Ohio 51,628,473 Oregon 36,796,694 Rhode Island 9,724,815 South Carolina 33,352,844 Tennessee 19,658,680 Washington, DC Total 3,686,091 $678,876,192 Note: Administrative expenses are as reported on the states Quarterly Financial Reports. Source: Treasury, response to SIGTARP data call, 1/17/2017. years ago] the money stopped flowing and the housing division’s attempts to try to intervene were blocked. We’ve been working with Treasury for two years to get NAHAC to change its ways.” The Nevada Housing Division admits that NAHAC stopped flowing the TARP money out to homeowners, but still claims that NAHAC should be entitled to expenses, despite the fact that Treasury’s contract only allows those expenses that are necessary for the purpose of the program.87 If Treasury had taken action to remove NAHAC after being warned by the state agency in October 2015, taxpayers could have saved one year of abused and wasted TARP dollars. In that year, Treasury paid NAHAC $1.66 million while NAHAC only admitted a very small number of homeowners.88 NAHAC issued a statement to the press saying, “[T]he new leadership team have been shifting the organization’s culture into one of accountability and transparency like never before to prevent such abuse and bad judgment from ever occurring again.”89 NAHAC admits abuse (abuse that happened over a large timeframe with multiple CEOs), but refuses to pay back the money. And even with NAHAC’s admitted abuse, it continues administering HHF in Nevada, putting this program and these dollars at significant risk of waste and abuse. Any entity that has shown itself willing to waste Federal dollars should be removed from receiving more Federal dollars. Ongoing Priority Audit In October 2016, at the request of Senator Grassley, SIGTARP opened an audit into $678 million in expenses of 19 state agencies that were reimbursed with TARP funds: Having already found substantial waste in HHF Nevada, SIGTARP has honed its expertise to find any additional wasteful spending or spending by state agencies that is not “necessary to carry out the purpose” of HHF, which is the requirement in the contract with Treasury. Treasury has paid state agencies $678 million as shown in Table 3.5. SIGTARP Identified Inefficient State Agencies in HHF $54 MILLION COST SAVINGS FROM SIGTARP RECOMMENDATIONS After finding that the Nevada state agency contractor kept $1 for its expenses for every $1 it distributed to homeowners in 2015; SIGTARP recommended that Treasury disallow any administrative expenses claimed by state agencies that are disproportionate to the dollars provided to homeowners (and other recipients). On average, state agencies had spent approximately $1 on their own administrative expenses for every $10 in HHF assistance (10%), some spent more, and some less. If Treasury limits state agency administrative expenses reimbursed by TARP to only 10%, the Government would save up to $54 million until 2020, based on current spending patterns. SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 October 2015 report on HHF Florida: At the request of Senator Bill Nelson, SIGTARP audited the Florida agency in HHF. Despite being paid more than $60 million to distribute Federal dollars; SIGTARP reported in October 2015, that only 20% of the people who applied in Florida received assistance, the lowest of any state. SIGTARP also reported that the state agency takes a median of nearly 6 months to get assistance to an applying homeowner. After SIGTARP’s October 2015 report on HHF in Florida, the state agency has increased its admission rate to 29%.90 While the admission rate in Florida still remains one of the lowest of all the HHF states, it shows that increased oversight over inefficient or mismanaged state agencies can lead to change.91 January 2017 report on people denied for HHF: SIGTARP makes recommendations to increase effectiveness of federal TARP programs. Some state agencies have struggled to distribute the funds to homeowners. In order to increase effectiveness, SIGTARP analyzed those people who were turned down by state agencies for HHF to identify trends. SIGTARP used data analytics to find that most of the people denied Hardest Hit funds earned less than $30,000 per year. SIGTARP found that state agencies turned down 84,965 people who earned less than $30,000 per year, including 64,979 people who made less than $20,000 per year. In 12 of the 19 participating states, nearly three out of four people turned down earned less than $30,000 per year. Rust belt states Michigan and Ohio are among the states that have the most TARP dollars set aside, but also have some of the highest percentages of people turned down for the Hardest Hit Fund who earned less than $30,000 per year. As shown in Figure 3.5 in cities where General Motors—which received $50 billion in TARP funds—or its suppliers closed plants or laid off workers, denial rates are even higher for those who made less than $30,000 per year. 95 96 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM FIGURE 3.5 HHF DENIALS FOR HOMEOWNERS MAKING LESS THAN $30,000 PER YEAR *Dayton OH includes nearby cities of Moraine and Vandalia. Source: SIGTARP, Audit Report “Improving TARP’s Investment in American Workers”, 1/11/2017, https://www.sigtarp.gov/Audit%20Reports/SIGTARP_HHF_Florida_Report.pdf, accessed 1/13/2017. Despite returning to profitability, GM and other auto companies closed plants and laid off workers, even in the last year. GM announced that 2,000 additional workers in Michigan and Ohio face layoffs early in the coming year. The findings uncovered by this evaluation indicate that there may be eligibility criteria that are too stringent. There may be valid reasons why these people were turned down, but it is impossible to know because SIGTARP found that state agencies’ records were non-existent, missing, or incomplete regarding why the agencies turned down people making less than $30,000 per year. State agencies should unlock the full potential of the program by eliminating unnecessary criteria that do not exist in other states or that do not reflect the reality of the working class in that state. This program has a lot more potential to provide a safety net in certain communities until jobs return to these towns, but that potential needs to be unlocked. Treasury and state agencies should: (1) eliminate unnecessary program criteria; and (2) open up eligibility to workers facing layoffs so that they do not have to first fall behind on their mortgage. State agencies should keep detailed records on why the state denied each person.92 State Agencies Inefficiency and/or Mismanagement in Providing HHF Assistance to American Workers SIGTARP Quarterly Reports to Congress October 2015 through Present: HHF dollars have been slow to flow in many states and more than 160,000 people were denied HHF assistance. Therefore, beginning in quarterly reports to Congress starting October 2015, SIGTARP reported on low performing state agencies in SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 homeowner admission rates, homeowner denial rates, and withdrawn homeowner application rates. That information is updated each quarter and appears below. Fewer than half (43%) (269,712) of all 632,032 homeowners who sought HHF assistance were admitted to the program. Table 3.6 shows those state agencies who admitted less than 43% of applying homeowners. TABLE 3.6 INEFFICIENT HHF STATE AGENCIES – LOW PERCENTAGE OF APPROVED APPLICATIONS, AS OF 9/30/2016 State Agency Florida Homeowners That Applied Homeowners That Received Assistance Homeowner Admission Rate 126,819 27,086 21.4% Alabama 21,660 5,057 23.3% Arizona 18,606 4,608 24.8% Georgia 27,876 8,415 30.2% Nevada 14,725 5,417 36.8% Oregon 28,790 11,809 41.0% 153,577 63,657 41.4% California Sources: Treasury’s Q3 2016 Quarterly Performance Reports, accessed from Treasury’s Hardest Hit Fund – State by State Information website, www.treasury.gov/initiatives/financial-stability/TARP-Programs/housing/Pages/Program-Documents.aspx, accessed 1/5/2017; Treasury, “HFA Aggregate Quarterly Report Q3 2016,” no date, www.treasury.gov/initiatives/financial-stability/ reports/Documents/HFA%20Aggregate%20Q32016%20Report_v2.pdf, accessed 1/3/2017. On a cumulative basis, HHF Florida, HHF Alabama, HHF Arizona were the most inefficient, with their expenses being paid by TARP, with each admitting less than one in every four American workers who applied. HHF Georgia and HHF Nevada were also inefficient in comparison to the national average. Some state agencies are letting into the program far fewer than they had in the past. In 2016, HHF in Alabama only helped 19% of unemployed and underemployed workers whose applications were processed, nearly half of the admission rate in 2014. Treasury paid the Alabama state agency nearly $10.2 million, but this state agency whose role is to serve workers in one of the hardest hit areas in the country is inefficient in distributing these dollars. The New Jersey state agency that was providing this unemployment bridge and other assistance to 58% of people who applied in 2014, only provided it to 10% and 18% of those applying in 2015 and 2016, respectively. After SIGTARP’s October 2015 report on HHF Florida, HHF Florida helped 22% of unemployed and underemployed workers who applied, which is progress from 13% last year, but could open up even more. HHF Georgia admitted more unemployed and underemployed homeowners this year after a letter from their Congressman John Lewis, but is still very low at helping only one-third of Georgia workers who apply.93 97 98 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM State Agencies Inefficiency and/or Mismanagement – Denying High Numbers of Homeowners for HHF Throughout the nation, state agencies denied 165,083 people – 26% of all who applied. Another 175,535 people applied but withdrew their application, perhaps because they did not meet the state agency’s criteria. Some state agencies denied higher rates of people, as listed in Table 3.7. TABLE 3.7 INEFFICIENT STATE AGENCIES – HIGH PERCENTAGE OF DENIED HOMEOWNERS, AS OF 9/30/2016 Homeowners That Applied Homeowners Denied Assistance Homeowner Denial Rate Arizona 18,606 12,618 67.8% New Jersey 14,163 7,765 54.8% Georgia 27,876 11,084 39.8% South Carolina 26,432 8,954 33.9% State Agency Rhode Island 4,921 1,447 29.4% Michigan 64,936 19,022 29.3% California 153,577 43,046 28.0% Sources: Treasury’s Q3 2016 Quarterly Performance Reports, accessed from Treasury’s Hardest Hit Fund – State by State Information website, www.treasury.gov/initiatives/financial-stability/TARP-Programs/housing/Pages/Program-Documents.aspx, accessed 1/5/2017; Treasury, “HFA Aggregate Quarterly Report Q3 2016,” no date, www.treasury.gov/initiatives/financial-stability/ reports/Documents/HFA%20Aggregate%20Q32016%20Report_v2.pdf, accessed 1/3/2017. HHF Arizona, HHF New Jersey and HHF Georgia were the most inefficient. Despite their expenses being paid by Treasury, they each denied high rates of workers in their state who applied, at nearly 70% for HHF Arizona, 55% for HHF New Jersey, and almost 40% for HHF Georgia. Some state agencies have recently started turning down more and more American workers seeking this temporary safety net. In 2016, HHF New Jersey turned down 81% of all people who applied, much higher than 47% in 2013. HHF DC turned down 70% of all people who applied in 2016, far higher than 18% in 2014, and 53% in 2015.94 SIGTARP recommended in its January 2017 audit that state agencies eliminate unnecessary criteria for applicants. The state agencies should start with eliminating criteria that does not match the reality of workers in that state (such as a criteria that the person make enough now to pay their mortgage in the future) or do not exist in other states for these same dollars. SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 State Agencies Seeing High Numbers of Withdrawn Applications There were 175,535 people saw their application withdrawn – 28% of all who applied to HHF. Some state agencies had an even higher amount of withdrawn applications, as shown in Table 3.8. TABLES 3.8 INEFFICIENT STATE AGENCIES – HIGH PERCENTAGE OF WITHDRAWN APPLICATIONS, AS OF 9/30/2016 Homeowners That Applied Homeowner Applications Withdrawn Homeowner Withdrawal Rate Alabama 21,660 14,192 65.5% Oregon 28,790 14,399 50.0% Florida 126,819 54,231 42.8% Nevada 14,725 5,831 39.6% 153,577 43,293 28.2% 27,876 7,785 27.9% State Agency California Georgia Sources: Treasury’s Q3 2016 Quarterly Performance Reports, accessed from Treasury’s Hardest Hit Fund – State by State Information website, www.treasury.gov/initiatives/financial-stability/TARP-Programs/housing/Pages/Program-Documents.aspx, accessed 1/5/2017; Treasury, “HFA Aggregate Quarterly Report Q3 2016,” no date, www.treasury.gov/initiatives/financial-stability/ reports/Documents/HFA%20Aggregate%20Q32016%20Report_v2.pdf, accessed 1/3/2017. “Resources are unused and SIGTARP’s negative audits and recommendations for HHF improvement have been disregarded.” Representatives John Lewis, John Coyers, David Scott, Marcy Kaptur, Dina Titus, Brenda Lawrence, Henry C. Johnson, Jr., Alan Grayson, Mike Thompson, Corrine Brown, and Terri Sewell The percentage of homeowners who withdrew their applications or had their applications withdrawn, were the highest in Alabama, Oregon, Florida and Nevada –66% in Alabama, 50% in Oregon, 43% in Florida, and 40% in Nevada. This has gotten worse in Alabama, Ohio, and Florida. This could signal inefficiency or mismanagement. High numbers of people withdrawing their application could indicate lengthy wait times or program criteria that do not match the reality of workers in that state.95 After SIGTARP’s reports: In March 2016, 11 Congressmen led by Representative John Lewis, sent a letter to President Obama saying that the results presented by SIGTARP were “very troubling.” These Members of Congress expressed concern that that: (1) fewer than half of homeowners who applied received help, and far fewer than that in certain states; (2) there were long waiting periods to receive assistance, and (3) that more than half of homeowners were ultimately denied help or had their applications withdrawn. Those Congressmen included Representatives John Lewis, John 99 100 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM Coyers, David Scott, Marcy Kaptur, Dina Titus, Brenda Lawrence, Henry C. Johnson, Jr., Alan Grayson, Mike Thompson, Corrine Brown, and Terri Sewell.96 The 11 Congressmen asked for executive action for Treasury to amend their HHF contracts with state agencies to implement SIGTARP’s recommendations. However, SIGTARP’s recommendations can be implemented without amending contracts, as long as Treasury issues guidance to the state agencies, just as it did related to houses being abandoned or related to blight. Ongoing Priority Audit At the request of Congressman John Lewis, SIGTARP opened an audit of HHF in three counties in Georgia: In September 2016, SIGTARP opened an audit of HHF in DeKalb, Fulton, and Clayton Counties in Georgia, at the request of Congressman John Lewis. Preventing Fraud, Waste, and Abuse in HHF Homebuyer Assistance Programs $48 MILLION COST SAVINGS FROM SIGTARP RECOMMENDATIONS HHF also provides $480 million in down payment assistance, ranging from $7,500 to $20,000 to homebuyers, and in 2015, SIGTARP made recommendations to Treasury to prevent fraud, waste, and abuse in homebuyer programs. Among these were recommendations to prevent fraud, such as requiring detailed reporting on who was receiving these dollars, whether they were buying the house in a nonarms-length transaction, whether there was commingling with state down payment assistance dollars, and the buyer certifying that they met the eligibility requirements. We also recommended that the state agency conduct background checks to determine if an applicant was convicted of a crime of dishonesty.97 These unimplemented recommendations can save the Government $48 million based on the average 10% fraud found in Government programs. SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 HHF in Alabama There remains a critical need for HHF’s stop-gap unemployment bridge to help save the homes of Alabama workers who lost their job or saw their paycheck cut, while they look for a full time job in Alabama. Last year 8,867 Alabama homeowners lost their home to foreclosure, another 44,561 Alabama homeowners are behind on their mortgage, and 21,267 owe more than their home is worth.98 The unemployment rate in Alabama is 5.9%, making it one of the states with the highest unemployment.99 Despite this critical need for HHF, SIGTARP has repeatedly identified the Alabama state agency as one of the most inefficient state agencies in the program. Despite being paid $10.2 million by Treasury as its conduit to distribute these Federal dollars, the Alabama state agency has not been effective in distributing these Federal dollars to Alabama workers (for the unemployment bridge) or to Alabama neighborhoods (to demolish abandoned blight houses). For example: • In 6 years, HHF has helped only 5,057 Alabama homeowners • 68% of the TARP set aside for Alabama homeowners has not been spent • The Alabama state agency lowered the number of workers it estimated helping with HHF (13,500) by half, despite more than 20,000 homeowners applying • The Alabama state agency admitted only 790 new Alabama homeowners last year to HHF • Alabama’s HHF program has an application withdrawal rate of 66%, among the highest of all 19 HHF states, with 14,192 of the 21,660 homeowners who applied for HHF assistance in Alabama either withdrawing their application or having their application withdrawn by the state agency • The Alabama state agency has only admitted 23% of all people who applied (5,057 out of 21,660)—the second lowest of any state agency in HHF100 • The state agency never admitted a single worker to an HHF program to help unemployed workers with a short sale, despite 180 people applying and only admitted 3% (116 of 3,572) of workers applying to an HHF program to modify mortgages since March 2013 • More than three out of four (78%)iv people who were denied assistance earned less than $30,000 per year101 • After more than two years, only 3 abandoned houses have been demolished102 Hardest Hit Fund – Use of Funds in Alabama and Status of Alabama Workers Most of Alabama’s spending went to help homeowners. However, only 5,057 workers were actually helped by the program.103 See Figures 3.6 and 3.7 for more details. iv Data as of June 30, 2016. See SIGTARP’s January 11, 2017, evaluation “Improving TARP’s Investment in American Workers”. 101 102 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM FIGURE 3.6 FIGURE 3.7 HARDEST HIT FUND – USE OF FUNDS IN ALABAMA, STATUS OF ALABAMA WORKERS THAT APPLIED TO HHF, AS OF 9/30/2016 6.26% AS OF 9/30/2016 0.02% 26.21% 1% 23% 10% 66% 67.50% TARP Dollars to State Agency ($10,228,238) Workers Helped (5,057) Demolition ($38,714) Workers Denied (2,091) Unspent ($110,293,370) Workers with Withdrawn Applications (14,192) Unemployment Bridge and Related Assistance ($42,826,301) Workers In Process (320) Note: Funds include $162.5 million allocated from Treasury plus remittances of $865,278. Sources: Treasury, HFA Aggregate Report Q3 2016; Alabama Housing Finance Authority, Treasury Reports, Quarterly Performance Report Q3 2016, no date. Source: Treasury, response to SIGTARP data call, 1/17/2017. HIGH RISK AREAS Concerns about HHF raised by Representative Sewell: In March, 2016, Representative Terri Sewell from the 7th District of Alabama sent a letter to President Obama, along with 10 other Congressmen, expressing concerns that HHF dollars were not being distributed effectively in their states. In July 2016, SIGTARP reported that in Dallas County, Alabama, in Congresswoman Sewell’s district, unemployment was 9%- almost twice the national rate. With more than 1,400 people unemployed in that county, only 2 people were approved for HHF in the prior year.104 After the report SIGTARP continues to find that Congresswoman Sewell’s concerns are still not being addressed by Alabama’s state agency administering HHF. For instance, as of September 30, 2016, 128,787 remain unemployed in the state of Alabama, but only 715 people were approved for HHF unemployment assistance in the 12 months prior to that.105 Highest rate of withdrawn HHF applications than any other state agency in HHF should be lowered: In July 2016, SIGTARP reported that the Alabama state agency has the highest rate of withdrawn HHF applications, more than any other state agency. Rather than deny Alabama workers who applied, 64% of people who applied and did not get admitted to the program saw their application withdrawn—12,435 people— a problem that SIGTARP raised in the July 2016 report. Since that report, this number grew by nearly 800 people, so as of SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 September 30, 2016, 14,192 people saw their application withdrawn. This is evidence of a root problem that needs improvement.106 Consequently, SIGTARP made the following recommendations, which remain unimplemented, that address this priority problem: PRIORITY SIGTARP RECOMMENDATION Report separately people who withdraw their HHF application from applications withdrawn by the state agency Streamline the lengthy application process: The state agency withdraws a person’s application if it has taken too much time to complete, which may be evidence of an inefficient process (such as overly complex or confusing process or burdensome document requirements) that can be improved, or mismanagement.107 85 to 94 days TO PROCESS HHF APPLICATION AND PROVIDE ASSISTANCE Many cannot withstand a lengthy delay PRIORITY SIGTARP RECOMMENDATION Reduce percentage of withdrawn HHF applications to a targeted level and measure progress Eliminate unnecessary criteria: In its January 2017 report, SIGTARP recommended that state agencies eliminate unnecessary program criteria. This includes: (1) criteria that does not exist for homeowners in other states for these same Federal dollars, and (2) criteria that does not reflect the reality of Alabama workers.108 103 104 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM TARP-Funded Demolition of Abandoned Houses in Alabama Communities The $35 million TARP-funded demolition program has not gotten off the ground in Alabama. After more than two years (since September 2014), the Alabama state agency has only demolished 3 abandoned houses using $38,713.109 PRIORITY SIGTARP RECOMMENDATIONS Limit TARP reimbursement to demolition costs that are necessary and reasonable as exist in similar HUD and state-funded programs Require full and open competition and other competition requirements that exist in similar HUD program Risk of Overcharging, Waste and Fraud: In January 2017 Treasury implemented SIGTARP’s recommendation to limit TARP reimbursement to necessary and reasonable costs. This is necessary because before Treasury paid up to $25,000 per demolished house (not limited to necessary and reasonable costs), which far exceeds the median cost of HHF demolition at $9,610 for demolition + $70 for greening the land. The average demolition cost per property in the state is $12,904.110 Implementation of this recommendation could save thousands of dollars per house, up to $161 million program wide. SIGTARP has additional unimplemented recommendations that state agencies use best practices to determine necessary and reasonable costs. Risk of Unfair Competitive Practices that can drive up costs: In January 2017, Treasury implemented SIGTARP’s recommendation to require full and open competition.111 However, SIGTARP has additional unimplemented recommendations that mirror HUD requirements to ensure full and open competition in the solicitation and award of contracts. The Alabama state agency differs from other HHF states in management of its demolition program, by contracting with non-profit Habitat for Humanity organizations to receive TARP dollars (as shown in Table 3.9), to receive TARP funds, choose neighborhoods and specific houses for TARP-funded demolitions, and hire contractors and subcontractors. HHF Alabama’s partner Habitat for Humanity organizations include an Alabama state-wide Habitat for Humanity, as well as: Habitats for Autauga and Chilton Counties, Habitat for Hale County and Habitat for Greater Birmingham, which also provides services for Jefferson County. Treasury does not conduct oversight over these Habitat for Humanity organizations or their contractors.112 105 SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 TABLE 3.9 ALABAMA HHF BLIGHT ELIMINATION PROGRAM PARTNERS AND DEMOLITION ACTIVITY AS OF 9/30/2016** Most Recent Quarter Cumulative Applications Submitted 4 16 Properties Demolished/Removed 0 3 Disbursements to Partners, Program to Dateb Demolished in Most Demolished, Recent Quarter Cumulative City/County Partnera Alabama (Statewide) Alabama Association of Habitat for Humanity $— 0 0 Autauga County Habitat for Humanity of Autauga and Chilton County $— 0 0 Birmingham Greater Birmingham Habitat for Humanity $— 0 0 Chilton County Habitat for Humanity of Autauga and Chilton County $— 0 0 Hale County Habitat for Humanity of Hale County $— 0 0 Jefferson Greater Birmingham Habitat for Humanity $38,714 3 3 Alabama Housing Finance Authority. b Alabama HFA response to SIGTARP data call. Due to reporting date differences, disbursement amounts may be mor recent than demolition data. a ** Alabama Housing Finance Authority, Treasury Reports, Quarterly Performance Report, Q3 2016, no date. Each Habitat for Humanity local partner hires contractors and subcontractors for demolition, site inspection, asbestos removal, greening and other activities. It is critical to ensure full and open competition in these contracts. Making oversight difficult is that there is no one source to identify contractors and subcontractors. SIGTARP is in the process of identifying contractors and subcontractors who receive TARP dollars for demolition. Identifying all participating in a TARP program and benefitting from TARP funds is crucial to protecting these Federal dollars from fraud, waste, and abuse. Program Performance Figures 3.8 and 3.9 show the performance of HHF Alabama Unemployment and Related Programs, as of September 30, 2016. 106 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM FIGURE 3.8 HHF ALABAMA HOMEOWNER PROGRAMS’ PERFORMANCE, UNEMPLOYMENT AND RELATED PROGRAMS, AS OF 9/30/2016 25,000 As of 9/30/2016: Homeowner Applications: 21,660 Homeowners Helped: 5,057 Homeowner Admission Rate: 23% 20,000 15,000 10,000 5,000 0 Q1 Q2 Q3 Q4 Q1 2010 Q2 Q3 Q4 Q1 2011 Q2 Q3 Q4 Q1 Q2 2012 Estimated Homeowners to be Helped Q3 Q4 Q1 2013 Q2 Q3 Q4 Q1 Q2 2014 Q3 Q4 Q1 2015 Q2 2016 Homeowners Helped Applying Homeowners Notes: Estimated includes highest estimate of a range. Applications are the total number of applicant homeowners, which Treasury began reporting as of Q3 2012. Homeowner Admission Rate is cumulative Homeowners Assisted as a percent of homeowners who applied. Sources: Treasury and Alabama Housing Finance Authority, Commitment to Purchase Financial Instrument and HFA Participation Agreement, 9/23/2010, and Amendments to Agreement one through eleven, as of 9/30/2016; Alabama Housing Finance Authority, Quarterly Performance Reports Q1 2011 – Q3 2016, no date; Treasury, HFA Aggregate Reports Q3 2012 – Q3 2016, no date. FIGURE 3.9 HHF ALABAMA PROGRAM PERFORMANCE, AS OF 9/30/2016 HARDEST HIT FOR ALABAMA'S UNEMPLOYED HOMEOWNERS (UNEMPLOYMENT) – SEPTEMBER 2010 As of 9/30/2016: Estimate: 5,500 (Peak: 13,500) Homeowner Applications: 18,653 Homeowners Helped: 4,947 Homeowner Admission Rate: 27% 20,000 16,000 12,000 LOAN MODIFICATION ASSISTANCE PROGRAM (MODIFICATION) – MARCH 2013 4,000 3,000 2,000 8,000 As of 9/30/2016: Estimate: 1,200 (Peak: 1,200) Homeowner Applications: 3,572 Homeowners Helped: 116 Homeowner Admission Rate: 3% 1,000 4,000 0 0 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 2010 2011 2012 2013 Estimated Homeowners to be Helped Homeowner Applications 2014 2015 Homeowners Helped 2016 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 2010 2011 2012 2013 Estimated Homeowners to be Helped 2014 2015 2016 Homeowners Helped Homeowner Applications Notes: Programs may have been started or ended at different times. Estimated includes highest estimate of a range. Homeowner Admission Rate is cumulative Homeowners Assisted as a percent of reported Homeowner Applications. Sources: Treasury and Alabama Housing Finance Authority, Commitment to Purchase Financial Instrument and HFA Participation Agreement, 9/23/2010, and Amendments to Agreement one through eleven, as of 9/30/2016; Alabama Housing Finance Authority, Quarterly Performance Reports Q1 2011 – Q3 2016, no date. Q3 SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 HHF in Arizona There remains a critical need for the Hardest Hit Fund’s stop-gap unemployment bridge to help save the homes of Arizona workers who have lost their job or saw their paycheck cut while they look for a full-time job in Arizona. Last year 8,817 Arizona homeowners lost their home to foreclosure, another 42,180 Arizona homeowners are behind on their mortgage, and 143,690 owe more than their home is worth.113 Arizona was one of the first states to receive HHF funds because Treasury decided Arizona was one of the harderst hit states at the beginning of HHF.114 The unemployment rate in Arizona is 5%, continuing the difficulties homeowners face in this state.115 SIGTARP has repeatedly identified the Arizona state agency as one of the most inefficient state agencies in the program in distributing TARP funds to Arizona workers for the unemployment bridge or related programs. For example, despite being paid $22.8 million by Treasury to distribute these Federal dollars to Arizona workers, the Arizona state agency only provided Federal dollars to 25% of all people who applied. In contrast, the Arizona state agency provided Federal dollars to 100% of Arizona homebuyers seeking downpayment assistance.116 Some of the major issues at the Arizona state agency identified by SIGTARP include: • In 6 years, the Arizona state agency has helped only 4,608 Arizona homeowners • The Arizona state agency has not helped 12,618 or 68% of all workers who have applied for help. In contrast, every home buyer who applied for assistance from the Arizona state agency to purchase a home received assistance • 36% of the TARP funds set aside for HHF in Arizona has not been spent • The Arizona state agency estimated helping 11,959 people, and nearly 19,000 applied for assistance, but now the state agency estimates helping just 6,589 people • The Arizona state agency has only provided Federal dollars to 25% of all people who applied (4,608 out of 18,606 people)—the third lowest performance of any state agency in HHF • The Arizona state agency denied more than 6,800 homeowners earning less than $30,000v • It takes 51-131 days to process an application and many cannot withstand such a lengthy delay.117 Hardest Hit Fund – Use of Funds in Arizona and Status of Arizona Workers Most of Arizona’s spending went to help homeowners.118 However, only 4,608 workers were actually helped by the program.119 See Figures 3.10 and 3.11 for more details. v Data as of June 30, 2016. See SIGTARP’s January 11, 2017, evaluation “Improving TARP’s Investment in American Workers”. 107 108 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM FIGURE 3.10 FIGURE 3.11 HARDEST HIT FUND – USE OF FUNDS IN ARIZONA, STATUS OF ARIZONA WORKERS THAT APPLIED TO HHF, AS OF 9/30/2016 AS OF 9/30/2016 1% 6% 6% 8% 36% 25% 50% 68% TARP Dollars to State Agency ($22,787,601) Workers Helped (4,608) Homebuyer Assistance ($19,303,003) Workers Denied (12,618) Unspent ($107,129,885) Workers with Withdrawn Applications (1,206) Unemployment Bridge and Related Assistance ($149,091,399) Workers In Process (174) Note: Funds include $296 million allocated from Treasury plus remittances of $2.3 million. Source: Treasury, response to SIGTARP data call, 1/17/2017. Sources: Treasury, HFA Aggregate Report Q3 2016; Arizona (Home) Foreclosure Prevention Funding Corporation, Hardest Hit Fund Reporting (quarterly performance reports), Quarterly Performance Report Q3 2016, no date. HIGH RISK AREAS High rate of workers denied HHF help in Arizona should be lowered: As of September 30, 2016, since the start of HHF in Arizona, 12,618 workers saw their application denied, which is 68% of all workers who applied for help in Arizona. After SIGTARP began reporting on this very high rate of denying homeowners, the Arizona state agency improved its homeowner denial rate. Over the last year another 1,251 workers were denied assistance out of 1,912 workers who applied – a 65% denial rate, which can show the impact of oversight.120 However, greater improvement is needed, as a 65% denial rate is extremely high. Streamline the lengthy application process: A person seeking help from the Arizona state agency administering HHF may face lengthy wait times to determine if they are eligible to receive that help. Some people cannot withstand lengthy delays.121 51 to 131 days TO PROCESS HHF APPLICATION AND PROVIDE ASSISTANCE Many cannot withstand a lengthy delay SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 Eliminate unnecessary criteria: A person is denied because they do not qualify. In its January 2017 report, SIGTARP recommended that state agencies eliminate unnecessary program criteria. This includes: (1) criteria that does not exist for homeowners in other states for these same Federal dollars, and (2) criteria that does not reflect the reality of Arizona workers.122 Protect TARP-Funded Homebuyer Assistance Program from Fraud, Waste and Abuse While the state agency in Arizona had among the worst performance in denying 68% of homeowners for HHF; it has provided assistance to 100% of all homebuyers who applied for an HHF down payment assistance program. The state agency pays up to $20,000 to a homebuyer, spending $19.3 million (out of $71.4 million), as of September 30, 2016.123 In 2015, SIGTARP made a series of recommendations to prevent fraud that remain unimplemented. Among these were requiring detailed reporting on who was receiving these dollars, whether they were buying the house in a non-arms-length transaction, whether there was commingling with state down payment assistance dollars and the buyer certifying that they meet the eligibility requirements. We also recommended that state agencies conduct background checks to determine if an applicant was convicted of a crime of dishonesty. Implementing these recommendations can save the government $48 million program wide, based on the average 10% of fraud in Government programs.124 Program Performance Figures 3.12 and 3.13 show the performance of HHF Arizona Unemployment and Related Programs, as of September 30, 2016. 109 110 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM FIGURE 3.12 HHF ARIZONA HOMEOWNER PROGRAMS’ PERFORMANCE, UNEMPLOYMENT AND RELATED PROGRAMS, AS OF 9/30/2016 20,000 As of 9/30/2016: Homeowner Applications: 18,606 Homeowners Helped: 4,608 Homeowner Admission Rate: 25% 15,000 10,000 5,000 0 Q1 Q2 Q3 Q4 Q1 2010 Q2 Q3 Q4 2011 Estimated Homeowners to be Helped Q1 Q2 Q3 Q4 Q1 Q2 2012 Q3 2013 Q4 Q1 Q2 Q3 2014 Q4 Q1 Q2 Q3 2015 Q4 Q1 Q2 2016 Homeowners Helped Applying Homeowners Notes: Estimated includes highest estimate of a range. Applications are the total number of applicant homeowners, which Treasury began reporting as of Q3 2012. Homeowner Admission Rate is cumulative Homeowners Assisted as a percent of homeowners who applied. Sources: Treasury and Arizona (Home) Foreclosure Prevention Funding Corporation, Commitment to Purchase Financial Instrument and HFA Participation Agreement, 6/23/2010, and Amendments to Agreement one through eighteen, as of 9/30/2016; Arizona (Home) Foreclosure Prevention Funding Corporation, Quarterly Performance Reports Q3 2010 – Q3 2016, no date; Treasury, HFA Aggregate Reports Q3 2012 – Q3 2016, no date. Q3 SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 FIGURE 3.13 HHF ARIZONA PROGRAM PERFORMANCE, AS OF 9/30/2016 PRINCIPAL REDUCTION ASSISTANCE (MODIFICATION) – JUNE 2010 SECOND MORTGAGE ASSISTANCE COMPONENT (SECOND-LIEN REDUCTION) – JUNE 2010 As of 9/30/2016: Estimate: 1,808 (Peak: 7,227) Homeowners Helped:1,323 Homeowner Admission Rate: N/A* 8,000 6,000 1,500 4,000 1,000 2,000 500 0 0 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 2010 2011 2012 2013 Estimated Homeowners to be Helped 2014 2015 4,000 3,000 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 2016 2010 2011 2012 2013 Estimated Homeowners to be Helped Homeowners Helped UNEMPLOYMENT/UNDEREMPLOYMENT/ REINSTATEMENT MORTGAGE ASSISTANCE COMPONENT (UNEMPLOYMENT) – JUNE 2010 5,000 As of 9/30/2016: Estimate: 407 (Peak: 1,875) Homeowners Helped: 310 Homeowner Admission Rate: N/A* 2,000 2014 2015 2016 Homeowners Helped SHORT SALE ASSISTANCE COMPONENT (TRANSITION) – MAY 2011 1,200 As of 9/30/2016: Estimate: 4,211 (Peak: 4,211) Homeowners Helped: 3,255 Homeowner Admission Rate: N/A* As of 9/30/2016: Estimate: 163 (Peak: 1,200) Homeowners Helped: 146 Homeowner Admission Rate: N/A* 900 600 2,000 300 1,000 0 0 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 2010 2011 2012 2013 Estimated Homeowners to be Helped 2014 2015 Homeowners Helped 2016 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 2010 2011 2012 2013 Estimated Homeowners to be Helped 2014 2015 2016 Homeowners Helped Notes: Programs may have been started or ended at different times. Estimated includes highest estimate of a range. Homeowner Admission Rate is cumulative Homeowners Assisted as a percent of reported Homeowner Applications. *Arizona does not report program by program application numbers. Sources: Treasury and Arizona (Home) Foreclosure Prevention Funding Corporation, Commitment to Purchase Financial Instrument and HFA Participation Agreement, 6/23/2010; and Amendments to Agreement one through eighteen, as of 9/30/2016; Arizona (Home) Foreclosure Prevention Funding Corporation, Quarterly Performance Reports Q3 2010 – Q3 2016, no date. 111 112 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM HHF in California California has the largest amount of TARP dollars set aside by Treasury than any other HHF state. There remains a critical need for the Hardest Hit Fund’s stop-gap unemployment bridge to help save the homes of California workers who have lost their job or saw their paycheck cut. Last year 20,406 California homeowners lost their home to foreclosure, another 185,683 California homeowners are behind on their mortgage, and 325,730 owe more than their home is worth.125 As of September 30, 2016, more than 1 million California workers are unemployed.126 The California agency was paid $154 million by Treasury as its conduit to distribute $2,358,590,320 in TARP funds, SIGTARP has identified issues at the California state agency that could be improved to help unemployed or underemployed workers gain access to the funds.127 For example: • 43,293 of the 153,577 homeowners who applied to the Californian state agency for HHF assistance in California either have withdrawn or been withdrawn by the state agency – 28% – one of the highest rates for HHF states. • 6,244 of the 23,144 homeowners whose HHF applications have been processed during the past year by the California state agency have withdrawn or had their applications withdrawn by the state agency. • The state agency closed and defunded two programs – one to help homeowners short sell their home and the other to help workers get principal reduction on their mortgage – neither program helped a single California homeowner.128 Hardest Hit Fund – Use of Funds in California and Status of California Workers Most of California’s spending went to help homeowners.129 See Figures 3.14 and 3.15 for more details. SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 FIGURE 3.14 FIGURE 3.15 HARDEST HIT FUND – USE OF FUNDS IN CALIFORNIA, STATUS OF CALIFORNIA WORKERS THAT APPLIED TO HHF, 6.4% 2.3% AS OF 9/30/2016 31.2% 62.4% AS OF 9/30/2016 41.5% 28.2% 28.0% TARP Dollars to State Agency ($153,816,892) Workers Helped (63,657) Unspent ($752,514,782) Workers Denied (43,046) Unemployment Bridge and Related Assistance ($1,502,141,334) Workers with Withdrawn Applications (43,293) Note: Funds include $2,358.6 million allocated from Treasury plus remittances of $49.9 million. Source: Treasury, response to SIGTARP data call, 1/17/2017. Workers In Process (3,581) Sources: Treasury, HFA Aggregate Report Q3 2016; CalHFA Mortgage Assistance Corporation, “Keep Your Home California, Reports & Statistics, Quarterly Reports,” Quarterly Performance Reports Q3 2016, no date. HIGH RISK AREAS Concerns about HHF raised by Representative Mike Thompson: In March, 2016, Representative Thompson from the 5th District of California sent a letter to President Obama, along with 10 other Congressmen, expressing concerns that HHF dollars were not being distributed effectively in their states. In July 2016, SIGTARP reported that in Lake County, California, in Congressman Thompson’s district, unemployment was at 7.3% with 2,117 workers unemployed. However, only 10 workers received HHF assistance over the past year.130 Since the start of HHF, 2,966 homeowners lost their homes to foreclosure in the county while only 104 homeowners were approved for HHF in California.131 After the report, SIGTARP continues to find that Congressman Thompson’s concerns are still not being addressed by California’s state agency administering HHF. For instance, as of November 30, 2016, 1,950 people remain unemployed in Lake County, and only 8 homeowners have been approved for HHF over the last year in Lake County.132 High rate of withdrawn HHF applications: As of September 30, 2016, the California state agency had one of the highest rates of withdrawn HHF applications, with 28% of all homeowners who applied for help either withdrawing or having their application withdrawn by the California state agency.133 SIGTARP made the following recommendations that address this priority problem:134 113 114 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM PRIORITY SIGTARP RECOMMENDATIONS Report separately people who withdraw their HHF application from applications withdrawn by the state agency Reduce percentage of withdrawn HHF applications to a targeted level and measure progress Program Performance Figures 3.16 and 3.17 show the performance of HHF California Unemployment and Related Programs, as of September 30, 2016. FIGURE 3.16 HHF CALIFORNIA HOMEOWNER PROGRAMS’ PERFORMANCE, UNEMPLOYMENT AND RELATED PROGRAMS, AS OF 9/30/2016 200,000 As of 9/30/2016: Homeowner Applications: 153,577 Homeowners Helped: 63,657 Homeowner Admission Rate: 41% 150,000 100,000 50,000 0 Q1 Q2 Q3 Q4 Q1 2010 Q2 Q3 Q4 2011 Estimated Homeowners to be Helped Q1 Q2 Q3 Q4 Q1 2012 Q2 Q3 2013 Q4 Q1 Q2 Q3 2014 Q4 Q1 Q2 Q3 2015 Q4 Q1 Q2 2016 Homeowners Helped Applying Homeowners Notes: Estimated includes highest estimate of a range. Applications are the total number of applicant homeowners, which Treasury began reporting as of Q3 2012. Homeowner Admission Rate is cumulative Homeowners Assisted as a percent of homeowners who applied. Sources: Treasury and CalHFA Mortgage Assistance Corporation, Commitment to Purchase Financial Instrument and HFA Participation Agreement, 6/23/2010; and Amendments to Agreement one through twenty-one, as of 9/30/2016; CalHFA Mortgage Assistance Corporation, Quarterly Performance Reports Q4 2010 – Q3 2016, no date; Treasury, HFA Aggregate Reports Q3 2012 – Q3 2016, no date. Q3 SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 FIGURE 3.17 HHF CALIFORNIA PROGRAM PERFORMANCE, AS OF 9/30/2016 UNEMPLOYMENT MORTGAGE ASSISTANCE PROGRAM of 9/30/2016: (UNEMPLOYMENT) – JUNE 2010 As Estimate: 58,300 (Peak: 60,531) Homeowner Applications: 86,849 Homeowners Helped: 50,780 Homeowner Admission Rate: 58% 90,000 75,000 60,000 MORTGAGE REINSTATEMENT ASSISTANCE PROGRAM (PAST-DUE PAYMENT) – JUNE 2010 60,000 45,000 45,000 30,000 30,000 15,000 15,000 0 0 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 2010 2011 2012 2013 Estimated Homeowners to be Helped 2014 2015 2010 2016 As of 9/30/2016: Estimate: 12,200 (Peak: 25,135) Homeowner Applications: 67,980 Homeowners Helped: 9,752 Homeowner Admission Rate: 14% 50,000 40,000 2013 2014 2015 2016 Homeowners Helped TRANSITION ASSISTANCE PROGRAM (TRANSITION) – JUNE 2010 As of 9/30/2016: Estimate: 1,100 (Peak: 6,471) Homeowner Applications: 2,343 Homeowners Helped: 1,003 Homeowner Admission Rate: 43% 10,000 8,000 6,000 30,000 4,000 20,000 2,000 10,000 0 0 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 2010 2011 2012 2013 Estimated Homeowners to be Helped 2014 2015 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 2016 2010 2011 2012 2013 Estimated Homeowners to be Helped Homeowners Helped Homeowner Applications 2014 2015 2016 Homeowners Helped Homeowner Applications COMMUNITY SECOND MORTGAGE PRINCIPAL REDUCTION PROGRAM (SECOND-LIEN REDUCTION) – AUGUST 2011 500 REVERSE MORTGAGE ASSISTANCE PILOT PROGRAM (PAST-DUE PAYMENT) – SEPTEMBER 2014 2,500 2,000 375 125 2012 Homeowner Applications PRINCIPAL REDUCTION PROGRAM (MODIFICATION) – JUNE 2010 60,000 2011 Estimated Homeowners to be Helped Homeowners Helped Homeowner Applications 250 As of 9/30/2016: Estimate: 13,800 (Peak: 17,293) Homeowner Applications: 66,272 Homeowners Helped: 11,665 Homeowner Admission Rate: 18% 75,000 As of 9/30/2016: Estimate: 830 (Peak: 2,100) Homeowner Applications: 1,789 Homeowners Helped: 474 Homeowner Admission Rate: 26% 1,500 As of 9/30/2016: Estimate: 370 (Peak: 370) Homeowner Applications: 42 Homeowners Helped: 34 Homeowner Admission Rate: 81% 1,000 500 0 0 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 2010 2011 2012 2013 Estimated Homeowners to be Helped Homeowner Applications 2014 2015 Homeowners Helped 2016 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 2010 2011 2012 2013 Estimated Homeowners to be Helped 2014 2015 2016 Homeowners Helped Homeowner Applications Notes: Programs may have been started or ended at different times. Estimated includes highest estimate of a range. Homeowner Admission Rate is cumulative Homeowners Assisted as a percent of reported Homeowner Applications. Sources: Treasury and CalHFA Mortgage Assistance Corporation, Commitment to Purchase Financial Instrument and HFA Participation Agreement, 6/23/2010; and Amendments to Agreement one through twenty-one, as of 9/30/2016; CalHFA Mortgage Assistance Corporation, Quarterly Performance Reports Q4 2010 – Q3 2016, no date. 115 116 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM HHF in Florida After California, Florida has the highest amount of HHF dollars set aside by Treasury than any other HHF state. There remains a critical need for HHF’s stopgap unemployment bridge to help save the homes of Florida workers who lost their job or saw their paycheck cut, while they look for a full time job in Florida. Last year 52,569 homeowners in Florida lost their homes to foreclosure, 201,220 are behind on their mortgages, and 496,051 owe more than their homes are worth, which is evidence of a need for HHF in Florida.135 Notwithstanding this acute need for HHF in Florida, SIGTARP has repeatedly found that the Florida state agency is one of the most inefficient state agencies. Despite being paid $68.6 million by Treasury as its conduit to distribute these Federal dollars, in October, 2015, SIGTARP issued an audit report making findings about problems at the state agency.136 Some of the problems with HHF in Florida include: • Only 21% of workers seeking unemployment help from the Florida state agency actually received that help – 27,086 of 126,819, while 97% of homebuyers received help • 16,706 workers who made less than $30,000 per year were denied assistance by the Florida state agencyvi • The Florida state agency had the third highest amount (43%) of all the HHF states of homeowners who withdrew or had their application withdrawn for HHF help – over the last year that number has drastically increased to 57% • Florida homeowners had to wait between 160 and 238 days to get HHF assistance (depending on the specific program the homeowner applied for) • Florida approved just 1,584 homeowners for the unemployed bridge program in the past year, while Florida currently has 481,763 unemployed workers • The Florida state agency has only helped 26% of the estimated number of homeowners that Florida would help137 Hardest Hit Fund – Use of Funds in Florida and Status of Florida Workers Most of Florida’s spending went to help homeowners.138 See Figures 3.18 and 3.19 for more detail. vi Data as of June 30, 2016. See SIGTARP’s January 11, 2017, evaluation “Improving TARP’s Investment in American Workers”. SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 FIGURE 3.18 FIGURE 3.19 HARDEST HIT FUND – USE OF FUNDS IN FLORIDA, AS OF 9/30/2016 STATUS OF FLORIDA WORKERS THAT APPLIED TO HHF, AS OF 9/30/2016 6% 6% 21% 34% 11% 54% 25% 43% TARP Dollars to State Agency ($68,642,020) Workers Helped (27,086) Homebuyer Assistance ($65,932,857) Workers Denied (32,172) Unspent ($394,332,739) Workers with Withdrawn Applications (54,231) Unemployment Bridge and Related Assistance ($616,100,271) Workers In Process (13,330) Note: Funds include $1,135.7 million allocated from Treasury plus remittances of $9.3 million. Sources: Treasury, HFA Aggregate Report Q3 2016; Florida Housing Finance Corporation, Florida Hardest Hit Fund (HHF) Information, Quarterly Reports, Quarterly Performance Report Q3 2016, no date. Source: Treasury, response to SIGTARP data call, 1/17/2017. HIGH RISK AREAS Concerns about HHF raised by former Representative Corrine Brown and former Representative Alan Grayson: On March 25, 2016, Representative Alan Grayson from the 9th District of Florida and Congresswoman Corrine Brown from the 5th District of Florida sent a letter to President Obama, along with 9 other Congressmen, expressing concerns that HHF dollars were not being distributed effectively in their states. In July 2016, SIGTARP reported that in Orange and Alachua Counties, in Congresswoman Brown’s and Congressman Grayson’s districts, foreclosures were double the national rate.139 After the report SIGTARP continues to find that former Congresswoman Brown’s and former Congressman Grayson’s concerns are still not being addressed by Florida’s state agency administering HHF. For instance in Orange County, Florida, 36,3121 residents owe more than their home is worth, and over the last year, in Orange County, Florida, 2,793 homeowners lost their homes to foreclosure, while only 190 received HHF help. In Alachua County, Florida, 471 homeowners lost homes to foreclosure, while only 25 received HHF help.140 117 118 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM Lowest percentage of workers helped of all HHF states: SIGTARP reported that the Florida state agency had the lowest rate of workers helped through HHF than any other state agency. At that time, of the Florida workers who applied for help, 80% (87,374 people) did not get admitted into the program or had not received a decision on their application.141 As of September 30, 2016, the number of Florida worker’s seeking help and not receiving it continues to be high, at 79% (99,733 workers). This low percentage of workers being helped is evidence of a core problem of inefficiency and mismanagement. SIGTARP identified the low number of workers helped, who were seeking help in Florida, and in October 2015 made several recommendations, which remain unimplemented. After SIGTARP’s October 2015 report on HHF Florida, HHF Florida has increased its admission rate from 21% to 29% (applications processed during the past year). While its overall admission rate of 21% since the start of the program remains the lowest of all HHF states, it shows that increased oversight over inefficient or mismanaged agencies can lead to change. However, incremental change will not be sufficient, more drastic change is needed to bring this state agency in line with other states. PRIORITY SIGTARP RECOMMENDATION Improve the homeowner admission rate in HHF Florida to a targeted level and measure progress.142 High numbers of workers denied and workers with withdrawn applications should be improved: After identifying a high percentage of workers with withdrawn applications by the Florida state agency, in its January, 2017 report, SIGTARP found that most people the Florida state agency turned down made less than $30,000 per year. SIGTARP has made numerous recommendations to Treasury, including recommendations to set numeric targets and milestones for Florida in action memos to reduce the number of workers who had their application withdrawn or denied, recommendations that remain unimplemented. PRIORITY SIGTARP RECOMMENDATION Prevent fraud, waste and abuse, through background checks, including searching public records of contractors as well as homeowners who may have been convicted of mortgage related or other crimes of dishonesty.143 vii SIGTARP Audit Report,“Factors Impacting the Effectiveness of Hardest Hit Fund Florida, October 2015, accessed 1/13/2017. SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 PRIORITY SIGTARP RECOMMENDATION Report separately people who withdraw their HHF application from applications withdrawn by the state agency PRIORITY SIGTARP RECOMMENDATION Reduce percentage of denied or withdrawn HHF applications to a targeted level and measure progress. Report reasons for denials. Streamline lengthy application process: The state agency withdraws a person’s application if it has taken too much time to complete, which may be evidence of an inefficient process (such as overly complex or confusing process or burdensome document requirements) that can be improved or mismanagement.144 160 to 238 days TO PROCESS HHF APPLICATION AND PROVIDE ASSISTANCE Many cannot withstand a lengthy delay Eliminate unnecessary criteria: In its January 2017 report, SIGTARP recommended that state agencies eliminate unnecessary program criteria to help HHF programs reach more unemployed and underemployed homeowners seeking help. This includes: (1) criteria that does not exist for homeowners in other states for these same Federal dollars, and (2) criteria that does not reflect the reality of Florida workers.145 Protect TARP-Funded Homebuyer Assistance Program from Fraud, Waste and Abuse Florida, moved millions in funding away from homeowners to homebuyers even while the Florida state agency administering HHF had the worst performance helping workers get help. As of September 30, 2016, the Florida state agency has provided assistance to 98% of all homebuyers who applied for an HHF down payment assistance program, paying up to $15,000 to a homebuyer, spending $65.9 million out of $108.4 million.146 In 2015, SIGTARP made a series of recommendations to prevent fraud, waste and abuse in homebuyer assistance programs that remain unimplemented. Among these were requiring detailed reporting on who was receiving these dollars, whether they were buying the house in a non-arms-length transaction, and whether there was commingling with 119 120 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM state down payment assistance dollars and the buyer certifying that they meet the eligibility requirements. We also recommend that state agencies conduct background checks to determine if an applicant was convicted of a crime of dishonesty. Implementing these recommendations can save the government $48 million program wide, based on the average 10% of fraud in government programs.147 Program Performance Figures 3.20 and 3.21 show the performance of HHF Florida Unemployment and Related Programs, as of September 30, 2016. FIGURE 3.20 HHF FLORIDA HOMEOWNER PROGRAMS’ PERFORMANCE, UNEMPLOYMENT AND RELATED PROGRAMS, AS OF 9/30/2016 150,000 120,000 90,000 As of 9/30/2016: Homeowner Applications: 126,819 Homeowners Helped: 27,086 Homeowner Admission Rate: 21% 60,000 30,000 0 Q1 Q2 Q3 Q4 Q1 2010 Q2 Q3 Q4 2011 Estimated Homeowners to be Helped Q1 Q2 Q3 Q4 Q1 2012 Q2 Q3 2013 Q4 Q1 Q2 Q3 2014 Q4 Q1 Q2 Q3 2015 Q4 Q1 Q2 2016 Homeowners Helped Applying Homeowners Notes: Estimated includes highest estimate of a range. Applications are the total number of applicant homeowners, which Treasury began reporting as of Q3 2012. Homeowner Admission Rate is cumulative Homeowners Assisted as a percent of homeowners who applied. Sources: Treasury and Florida Housing Finance Corporation, Commitment to Purchase Financial Instrument and HFA Participation Agreement, 6/23/2010; and Amendments to Agreement one through fourteen, as of 9/30/2016; Florida Housing Finance Corporation, Quarterly Performance Reports Q3 2010 – Q3 2016, no date; Treasury, HFA Aggregate Reports Q3 2012 – Q3 2016, no date. Q3 SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 FIGURE 3.21 HHF FLORIDA PROGRAM PERFORMANCE, AS OF 9/30/2016 UNEMPLOYMENT MORTGAGE ASSISTANCE PROGRAM of 9/30/2016: (UNEMPLOYMENT) – JUNE 2010 As Estimate: 25,000* (Peak: 53,000) Homeowner Applications: 84,248 Homeowners Helped: 17,315 Homeowner Admission Rate: 21% 80,000 70,000 60,000 50,000 40,000 30,000 20,000 10,000 0 MORTGAGE LOAN REINSTATEMENT PROGRAM (PAST-DUE PAYMENT) – DECEMBER 2010 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 2010 2011 2012 2013 Estimated Homeowners to be Helped 2014 2015 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 2016 2010 2013 2014 2015 2016 Homeowners Helped PRINCIPAL REDUCTION PROGRAM (MODIFICATION) – SEPTEMBER 2013 2,000 500 2012 Homeowner Applications MODIFICATION ENABLING PILOT PROGRAM (MODIFICATION) – APRIL 2013 1,000 2011 Estimated Homeowners to be Helped Homeowners Helped Homeowner Applications 1,500 As of 9/30/2016: Estimate: 25,000* (Peak: 53,000) Homeowner Applications: 84,810 Homeowners Helped: 16,988 Homeowner Admission Rate: 20% 80,000 70,000 60,000 50,000 40,000 30,000 20,000 10,000 0 40,000 32,000 As of 9/30/2016: Estimate: 925 (Peak: 1,500) Homeowner Applications: 358 Homeowners Helped: 253 Homeowner Admission Rate: 71% 24,000 16,000 8,000 0 As of 9/30/2016: Estimate: 10,000 (Peak: 10,000) Homeowner Applications: 40,285 Homeowners Helped: 6,082 Homeowner Admission Rate: 15% 0 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 2010 2011 2012 2013 Estimated Homeowners to be Helped 2014 2015 2016 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 2010 2011 2012 2013 Estimated Homeowners to be Helped Homeowners Helped Homeowner Applications 2014 2015 2016 Homeowners Helped Homeowner Applications ELDERLY MORTGAGE ASSISTANCE PROGRAM (PAST-DUE PAYMENT) – SEPTEMBER 2013 4,000 3,000 As of 9/30/2016: Estimate: 2,000 (Peak: 2,500) Homeowner Applications: 4,786 Homeowners Helped: 1,276 Homeowner Admission Rate: 27% 2,000 1,000 0 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 2010 2011 2012 2013 Estimated Homeowners to be Helped 2014 2015 2016 Homeowners Helped Homeowner Applications Notes: Programs may have been started or ended at different times. Estimated includes highest estimate of a range. Homeowner Admission Rate is cumulative Homeowners Assisted as a percent of reported Homeowner Applications. *Florida estimates that it will serve approximately 25,000 homeowners in the aggregate between its Unemployment Mortgage Assistance Program and its Mortgage Loan Reinstatement Program. Sources: Treasury and Florida Housing Finance Corporation, Commitment to Purchase Financial Instrument and HFA Participation Agreement, 6/23/2010; and Amendments to Agreement one through fourteen, as of 9/30/2016; Florida Housing Finance Corporation, Quarterly Performance Reports Q3 2010 – Q3 2016, no date. 121 122 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM HHF in Georgia There remains a critical need for HHF’s stop-gap unemployment bridge to help save the homes of Georgia workers who lost their job or saw their paycheck cut, while they look for a full time job in Georgia. Last year 19,965 Georgia homeowners lost their home to foreclosure, another 104,518 Georgia homeowners are behind on their mortgage, and 109,266 owe more than their home is worth.148 The Georgia state agency has not been efficient in distributing these Federal dollars to Georgia’s workers. Despite this acute need for help and despite being paid $29.4 million by Treasury as its conduit to distribute these Federal dollars, Georgia’s state agency did not provide assistance to more than two-thirds (68%) or 18,869 homeowners who have applied for HHF.149 For example: • In 6 years, HHF in Georgia has helped only 8,415 homeowners 30% of the 27,876 homeowners who applied, which is among the lowest rate of any state agency in the HHF • 40% of workers who sought assistance were denied by the state agency, among the highest in of all the HHF states, with 11,084 of the 27,876 workers denied assistance • Nearly three out of four (73%) of the 10,789 people who were denied assistance earned less than $30,000 per yearviii • Over the last year only 1,332 workers were approved for the unemployment bridge and related programs • Almost half of the TARP funds set aside for Georgia have not been spent • The Georgia state agency lowered the number of workers it estimated helping by 31%, from 18,300 workers to 12,625 workers, despite more than 27,000 homeowners applying • Georgia workers have had to wait up to 6 months to receive that help150 Hardest Hit Fund – Use of Funds in Georgia and Status of Georgia Workers Most of Georgia’s spending went to help homeowners. See Figures 3.22 and 3.23 for more detail. viii Data as of June 30, 2016. See SIGTARP’s January 11, 2017, evaluation “Improving TARP’s Investment in American Workers”. SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 FIGURE 3.22 FIGURE 3.23 HARDEST HIT FUND – USE OF FUNDS IN GEORGIA, AS OF 9/30/2016 STATUS OF GEORGIA WORKERS THAT APPLIED TO HHF, AS OF 9/30/2016 2% 8% 30% 28% 43% 49% 40% TARP Dollars to State Agency ($29,418,205) Workers Helped (8,415) Unspent ($183,727,158) Workers Denied (11,084) Unemployment Bridge and Related Assistance ($159,508,047) Workers with Withdrawn Applications (7,785) Note: Funds include $370.1 million allocated from Treasury plus remittances of $2.5 million. Workers In Process (592) Sources: Treasury, HFA Aggregate Report Q3 2016; GHFA Affordable Housing Inc., HomeSafe Georgia, US Treasury Reports, Quarterly Performance Report Q3 2016, no date. Source: Treasury, response to SIGTARP data call, 1/17/2017. HIGH RISK AREAS Concerns raised by Representatives John Lewis (5th District), David Scott (13th District) and Hank C. Johnson, Jr. (4th District): In March, 2016, Georgia Congressmen John Lewis, Hank Johnson, Jr., and David Scott sent a letter to President Obama, along with 8 other Congressmen, expressing concerns that HHF dollars were not being distributed effectively in their states. In July, 2016, SIGTARP reported that in Fulton County, Georgia (within the 5th and 13th Districts) 27,720 homeowners had lost their home to foreclosure since HHF began, but just 1,057 were approved for HHF assistance during that time. In DeKalb County, 26,229 homeowners lost their homes to foreclosure since HHF began, but only 1,189 were approved for HHF help during that time. In DeKalb County, nearly 20,000 homeowners owed more than their home is worth, while in Fulton more than 27,000 faced the same negative equity.151 After the report 123 124 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM SIGTARP continues to find that Congressmen Lewis’, Scott’s, and Johnson’s concerns are still not being addressed by Georgia’s state agency administering HHF. For instance more than 22,048 Fulton County Georgia residents owe more than their home is worth, and over the last year in Fulton County, Georgia, 1,734 homeowners lost their homes to foreclosure, while only 193 received HHF help. In DeKalb County, Georgia, 1,671 homeowners lost homes to foreclosure, while only 174 received HHF help. Representative Lewis asked SIGTARP to audit the state agency. On September, 2016, SIGTARP initiated an audit. High rate of denied HHF applications should be improved: In October 2016, SIGTARP reported that the Georgia state agency denied a high number of workers seeking HHF help, denying 40% of Georgia workers.152 Over the last quarter the state agency’s denial rate has not changed, further evidence of inefficiency and/or mismanagement that needs improvement.153 Lengthy application process: Such a low rate of helping workers who apply may be evidence of an inefficient process (such as overly complex or confusing process or burdensome document requirements) that can be improved, or mismanagement. 156 to 187 days TO PROCESS HHF APPLICATION AND PROVIDE ASSISTANCE154 Many cannot withstand a lengthy delay Unnecessary criteria: In its January 2017 report, SIGTARP recommended that state agencies eliminate unnecessary program criteria to help HHF programs reach more unemployed and underemployed homeowners seeking help. This includes: (1) criteria that does not exist for homeowners in other states for these same Federal dollars, and (2) criteria that does not reflect the reality of Georgia workers.155 Program Performance Figures 3.24 and 3.25 show the performance of HHF Georgia Unemployment and Related Programs, as of September 30, 2016. SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 FIGURE 3.24 HHF GEORGIA HOMEOWNER PROGRAMS’ PERFORMANCE, UNEMPLOYMENT AND RELATED PROGRAMS, AS OF 9/30/2016 30,000 25,000 20,000 15,000 As of 9/30/2016: Homeowner Applications: 27,876 Homeowners Helped: 8,415 Homeowner Admission Rate: 30% 10,000 5,000 0 Q1 Q2 Q3 Q4 Q1 2010 Q2 Q3 Q4 2011 Estimated Homeowners to be Helped Q1 Q2 Q3 Q4 Q1 2012 Q2 Q3 2013 Q4 Q1 Q2 Q3 2014 Q4 Q1 Q2 Q3 2015 Q4 Q1 Q2 2016 Homeowners Helped Applying Homeowners Notes: Estimated includes highest estimate of a range. Applications are the total number of applicant homeowners, which Treasury began reporting as of Q3 2012. Homeowner Admission Rate is cumulative Homeowners Assisted as a percent of homeowners who applied. Sources: Treasury and GHFA Affordable Housing Inc., Commitment to Purchase Financial Instrument and HFA Participation Agreement, 9/23/2010, and Amendments to Agreement one through ten as of 9/30/2016; GHFA Affordable Housing Inc., Quarterly Performance Reports Q4 2010 – Q3 2016, no date; Treasury, HFA Aggregate Reports Q3 2012 – Q3 2016, no date. Q3 125 126 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM FIGURE 3.25 HHF GEORGIA PROGRAM PERFORMANCE, AS OF 9/30/2016 MORTGAGE PAYMENT ASSISTANCE (UNEMPLOYMENT) – SEPTEMBER 2010 50,000 MORTGAGE REINSTATEMENT PROGRAM (PAST-DUE PAYMENT) – DECEMBER 2013 5,000 As of 9/30/2016: Estimate: 9,100 (Peak: 18,300) Homeowner Applications: 27,232 Homeowners Helped: 7,930 Homeowner Admission Rate: 29% 40,000 30,000 4,000 As of 9/30/2016: Estimate: 700 (Peak: 5,000) Homeowner Applications: 534 Homeowners Helped: 436 Homeowner Admission Rate: 82% 3,000 20,000 2,000 10,000 1,000 0 0 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 2010 2011 2012 2013 Estimated Homeowners to be Helped 2014 2015 2016 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 2010 2011 2012 2013 Estimated Homeowners to be Helped Homeowners Helped Homeowner Applications 2014 2015 2016 Homeowners Helped Homeowner Applications RECAST/MODIFICATION (MODIFICATION) – DECEMBER 2013 3,000 2,500 As of 9/30/2016: Estimate: 2,825 (Peak: 2,825) Homeowner Applications: 113 Homeowners Helped: 52 Homeowner Admission Rate: 46% 2,000 1,500 1,000 500 0 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 2010 2011 2012 2013 Estimated Homeowners to be Helped 2014 2015 2016 Homeowners Helped Homeowner Applications Notes: Programs may have been started or ended at different times. Estimated includes highest estimate of a range. Homeowner Admission Rate is cumulative Homeowners Assisted as a percent of reported Homeowner Applications. Sources: Treasury and GHFA Affordable Housing Inc., Commitment to Purchase Financial Instrument and HFA Participation Agreement, 9/23/2010, and Amendments to Agreement one through ten as of 9/30/2016; GHFA Affordable Housing Inc., Quarterly Performance Reports Q4 2010 – Q3 2016, no date. SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 HHF in Illinois After California, Florida, Ohio and Michigan, Illinois has the most TARP funds set aside by Treasury for HHF.156 There remains a critical need for HHF’s stop-gap unemployment bridge to help save the homes of Illinois workers who lost their job or saw their paycheck cut, while they look for a full time job in Illinois. Last year 13,824 Illinois homeowners lost their home to foreclosure, another 108,738 Illinois homeowners are behind on their mortgage, and 237,864 owe more than their home is worth.157 The unemployment rate in Illinois is 5.6%, continuing the difficulties homeowners face in this state. SIGTARP has identified issues at the Illinois state agency that could be improved to help unemployed or underemployed workers gain access to the funds for unemployment assistance. For example: • In 6 years, HHF has helped only 14,008 Illinois homeowners • The Illinois state agency has not helped nearly 6,657 or 31% of all workers who have applied for assistance • Nearly three out of four (70%) of the people denied assistance earned less than $30,000 per yearix • Illinois homeowners who received HHF assistance had to wait between 67 to 165 days (depending on the program they applied for) to receive assistance • Over the last year, the Illinois state agency only approved 80 workers for HHF assistance, while 368,458 workers are unemployed in Illinois • TARP funded demolition in Illinois has only demolished 47 properties since the program started 2 years ago158 Hardest Hit Fund – Use of Funds in Illinois and Status of Illinois Workers Most of Illinois’s spending went to help homeowners.159 See Figures 3.26 and 3.27 for more detail. ix Data as of June 30, 2016. See SIGTARP’s January 11, 2017, evaluation “Improving TARP’s Investment in American Workers”. 127 128 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM FIGURE 3.26 FIGURE 3.27 HARDEST HIT FUND – USE OF FUNDS IN ILLINOIS, AS OF 9/30/2016 STATUS OF ILLINOIS WORKERS THAT APPLIED TO HHF, 3.8% .2% AS OF 9/30/2016 5% 4% 11% 44.5% 46.5% 65% 20% TARP Dollars to State Agency ($36,608,993) Workers Helped (14,008) Homebuyer Assistance ($28,072,500) Workers Denied (4,382) Demolition ($1,318,692) Workers with Withdrawn Applications (2,275) Unspent ($324,684,792) Workers In Process (927) Unemployment Bridge and Related Assistance ($338,888,738) Note: Funds include $715.1 million allocated from Treasury plus remittances of $14.5 million. Sources: Treasury, HFA Aggregate Report Q3 2016; Illinois Housing Development Authority, Illinois Hardest Hit Program, Reporting, Quarterly Performance Report Q3 2016, no date. Source: Treasury, response to SIGTARP data call, 1/17/2017. HIGH RISK AREAS High rate of rejected HHF applications: Since the beginning of HHF in Illinois, 32% of workers seeking help did not receive it. The lack of improvement in denied or withdrawn applications in Illinois is evidence of inefficiency and/or mismanagement that needs improvement.160 Streamline lengthy application process: A lengthy application process may be evidence of an inefficient process (such as overly complex or confusing process or burdensome document requirements) that can be improved, or mismanagement. 67 to 165 days TO PROCESS HHF APPLICATION AND PROVIDE ASSISTANCE161 Many cannot withstand a lengthy delay Eliminate unnecessary criteria: In its January 2017 report, SIGTARP recommended that state agencies eliminate unnecessary program criteria to help HHF programs reach more unemployed and underemployed homeowners seeking help. This includes: (1) criteria that does not exist for homeowners in other states SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 for these same Federal dollars, and (2) criteria that does not reflect the reality of Illinois workers.162 TARP-Funded Demolition of Abandoned Houses in Illinois Communities The $17 million TARP-funded demolition program has not gotten off the ground in Illinois. After more than two years, the Illinois state agency has only demolished 47 abandoned houses using $1.3 million.163 PRIORITY SIGTARP RECOMMENDATIONS Limit TARP reimbursement to demolition costs that are necessary and reasonable as exist in similar HUD and state-funded programs Require full and open competition and other competition requirements that exist in similar HUD program Risk of Overcharging, Waste and Fraud: In January, 2017, Treasury implemented SIGTARP’s recommendation to limit TARP reimbursement to necessary and reasonable costs.164 This is necessary because before Treasury paid up to $35,000 per demolished house (not limited to necessary and reasonable costs), which far exceeds the median cost of HHF demolition at $17,011 for demolition + $1,438 for greening the land. The average cost spent by the Illinois state agency to demolish a property is $28,057.165 Implementation of this recommendation could save thousands of dollars per house, up to $161 million program wide. SIGTARP has additional unimplemented recommendations that state agencies use best practices to determine necessary and reasonable costs. Risk of Unfair Competitive Practices that can drive up costs: In January, 2017, Treasury implemented SIGTARP’s recommendation to require full and open competition. However, SIGTARP has additional unimplemented recommendations that mirror HUD requirements to ensure full and open competition in the solicitation of contract awards. The Illinois state agency contracts with local partners who to receive TARP dollars (as shown in Table 3.10) and choose neighborhoods and specific houses for TARP-funded demolitions, and then hire contractors and subcontractors. Treasury does not conduct oversight over these local partners or their contractors. 129 130 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM TABLE 3.10 ILLINOIS HHF BLIGHT ELIMINATION PROGRAM PARTNERS AND DEMOLITION ACTIVITY AS OF 9/30/2016** Applications Submitted Properties Demolished/Removed City/County Aurora Centralia Chicago Partnera Disbursements to Partners, Program to Dateb Fox Valley Habitat for Humanity $— Joseph Corporation $— Northern Lights Development $— BCMW Community $— Services, Inc. $— Greater Englewood CDC $— Sunshine Gospel Ministries $— Most Recent Quarter Cumulative 0 455 29 47 Demolished in Most Recent Quarter Demolished, Cumulative 0 0 0 0 0 0 0 Chicago Heights Cook County Land Bank Authority $— 0 Danville Habitat for Humanity Danville $— 0 0 Evanston Community Partners for Affordable Housing $— 0 0 11 11 Freeport Northwestern Illinois Community Action Agency NW Homestart, Inc. $— $341,197 Joliet South Suburban Land Bank and Devt. Authority $— 0 3 Macomb Western Illinois Regional Council Community Action Agency $— 0 0 Moline Moline Community Development Corporation $124,871 4 4 Ottawa Starved Rock Homes Development Corp $86,020 4 4 Park Forest South Suburban Land Bank and Devt. Authority $— 0 0 Peoria Peoria Citizens Community for Economic Opportunity $— 0 0 0 Riverdale Cook County Land Bank Authority $— 0 Rock Island Rock Island Economic Growth Corp. $81,825 3 9 Rockford Rockford Corridor Improvement, Inc. $— 4 6 0 0 0 0 7 Round Lake Beach Springfield The Fuller Center for Housing–Hero Project Lake County $— Enos Park Neighborhood Improvement Association $— Nehemiah Expansion $— The Springfield Project $— Sterling Rock Island Economic Growth Corp. $84,778 3 Urbana Habitat for Humanity of Champaign County $— 0 3 Winnebago County Comprehensive Community Solutions, Inc. $100,651 0 0 a b Illinois Housing Development Authority. Illinois HFA response to SIGTARP data call. Due to reporting date differences, disbursement amounts may be more recent than demolition data. **Illinois Housing Development Authority, Illinois Hardest Hit Program, Reporting, Quarterly Performance Report, Q3 2016, no date. SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 Each local partner hires contractors and subcontractors for demolition, site inspection, asbestos removal, greening and other activities. It is critical to ensure full and open competition in these contracts. Making oversight difficult is that there is no one source to identify contractors and subcontractors. SIGTARP is in the process of identifying contractors and subcontractors who receive TARP dollars for demolition. Identifying all participating in a TARP program and benefitting from TARP funds is crucial to protecting these Federal dollars from fraud, waste, and abuse, and transparency for taxpayers. Protect TARP-Funded Homebuyer Assistance Program in Illinois from Fraud, Waste and Abuse As of September 30, 2016, the Illinois state agency has assisted 3,743 first-time homebuyers, paying up to $7,500 to a homebuyer, moving millions of dollars away from helping homeowners to helping homebuyers.166 In 2015, SIGTARP made a series of recommendations to prevent fraud that remain unimplemented. Among these were requiring detailed reporting on who was receiving these dollars, whether they were buying the house in a non-arms-length transaction, whether there was commingling with state down payment assistance dollars and the buyer certifying that they meet the eligibility requirements. We also recommend that state agencies conduct background checks to determine if an applicant was convicted of a crime of dishonesty. Implementing these recommendations can save the government $48 million program wide, based on the average 10% of fraud in government programs.167 Program Performance Figures 3.28 and 3.29 show the performance of HHF Illinois Unemployment and Related Programs, as of September 30, 2016. 131 132 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM FIGURE 3.28 HHF ILLINOIS HOMEOWNER PROGRAMS’ PERFORMANCE, UNEMPLOYMENT AND RELATED PROGRAMS, AS OF 9/30/2016 30,000 25,000 20,000 15,000 As of 9/30/2016: Homeowner Applications: 21,592 Homeowners Helped: 14,008 Homeowner Admission Rate: 65% 10,000 5000 0 Q1 Q2 Q3 Q4 Q1 2010 Q2 Q3 Q4 2011 Estimated Homeowners to be Helped Q1 Q2 Q3 Q4 Q1 2012 Q2 Q3 2013 Q4 Q1 Q2 Q3 2014 Q4 Q1 Q2 Q3 2015 Q4 Q1 Q2 2016 Homeowners Helped Applying Homeowners Notes: Estimated includes highest estimate of a range. Applications are the total number of applicant homeowners, which Treasury began reporting as of Q3 2012. Homeowner Admission Rate is cumulative Homeowners Assisted as a percent of homeowners who applied. Sources: Treasury and Illinois Housing Development Authority, Commitment to Purchase Financial Instrument and HFA Participation Agreement, 9/23/2010, and Amendments to Agreement one through twelve, as of 9/30/2016; Illinois Housing Development Authority, Quarterly Performance Reports Q1 2011 – Q3 2016, no date; Treasury, HFA Aggregate Reports Q3 2012 – Q3 2016, no date. Q3 SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 FIGURE 3.29 HHF ILLINOIS PROGRAM PERFORMANCE, AS OF 9/30/2016 MORTGAGE RESOLUTION FUND PROGRAM (MODIFICATION) – AUGUST 2011 HARDEST HIT FUND HOMEOWNER EMERGENCY LOAN PROGRAM (UNEMPLOYMENT) – As of 9/30/2016: SEPTEMBER 2010 Estimate: 20,000 (Peak: 27,000) Homeowner Applications: 19,563 Homeowners Helped: 13,442 Homeowner Admission Rate: 69% 30,000 25,000 20,000 2,000 As of 9/30/2016: Estimate: 1,000 (Peak: 2,000) Homeowner Applications: 441 Homeowners Helped: 107 Homeowner Admission Rate: 24% 1,500 15,000 1,000 10,000 500 5,000 0 0 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 2010 2011 2012 2013 Estimated Homeowners to be Helped 2014 2015 2016 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 2010 2011 2012 2013 Estimated Homeowners to be Helped Homeowners Helped 2014 2015 2016 Homeowners Helped Homeowner Applications Homeowner Applications HARDEST HIT FUND HOME PRESERVATION PROGRAM (MODIFICATION) – SEPTEMBER 2012 3,000 2,500 2,000 1,500 1,000 As of 9/30/2016: Estimate: 2,500 (Peak: 2,500) Homeowner Applications: 622 Homeowners Helped: 528 Homeowner Admission Rate: 85% 500 0 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 2010 2011 2012 2013 Estimated Homeowners to be Helped 2014 2015 2016 Homeowners Helped Homeowner Applications Notes: Programs may have been started or ended at different times. Estimated includes highest estimate of a range. Homeowner Admission Rate is cumulative Homeowners Assisted as a percent of reported Homeowner Applications. Sources: Treasury and Illinois Housing Development Authority, Commitment to Purchase Financial Instrument and HFA Participation Agreement, 9/23/2010, and Amendments to Agreement one through twelve, as of 9/30/2016; Illinois Housing Development Authority, Quarterly Performance Reports Q1 2011 – Q3 2016, no date. 133 134 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM HHF in Indiana There remains a critical need for HHF’s stop-gap unemployment bridge to help save the homes of Indiana workers who lost their job or saw their paycheck cut, while they look for a full time job in Indiana. Last year 13,213, Indiana homeowners lost their home to foreclosure, another 53,495 Indiana homeowners are behind on their mortgage, and 25,620 owe more than their home is worth.168 Indiana has admitted 82% of homeowners who applied to HHF.169 However, there can still be improvement as SIGTARP has identified improvements to the efficiency of the Indiana state agency’s administration of HHF. For example: • In 6 years, HHF has helped 8,344 Indiana workers • 41% of the TARP funds allocated to Indiana has not been spent • The Indiana state agency has spent over $29 million in TARP dollars for its own expenses • The Indiana state agency estimated helping 16,257 people, but has lowered that estimate to only 11,335 workers, as it shifted more TARP funds to demolition • More than three out of four (76%) of the homeowners denied assistance by the Indiana state agency made less than $30,000 per yearx,170 Hardest Hit Fund – Use of Funds in Indiana and Status of Indiana Workers Most of Indiana’s spending went to help homeowners.171 See Figures 3.30 and 3.31 for more information. x Data as of June 30, 2016. See SIGTARP’s January 11, 2017, evaluation “Improving TARP’s Investment in American Workers”. SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 FIGURE 3.30 FIGURE 3.31 HARDEST HIT FUND – USE OF FUNDS IN INDIANA, AS OF 9/30/2016 STATUS OF INDIANA WORKERS THAT APPLIED TO HHF, 6% AS OF 9/30/2016 3% 9% 10% 6% 43% 41% 82% TARP Dollars to State Agency ($29,432,302) Workers Helped (8,344) Demolition ($16,720,464) Workers Denied (621) Unspent ($116,393,171) Workers with Withdrawn Applications (963) Unemployment Bridge and Related Assistance ($122,752,568) Workers In Process (278) Note: Funds include $283.7 million allocated from Treasury plus remittances of $1.6 million. Source: Treasury, response to SIGTARP data call, 1/17/2017. Sources: Treasury, HFA Aggregate Report Q3 2016; Indiana Housing and Community Development Authority, Indiana’s Hardest Hit Fund, Quarterly Reports to the U.S. Treasury, Quarterly Performance Report Q3 2016, no date. HIGH RISK AREAS Streamline lengthy application process: A lengthy delay may be evidence of an inefficient process (such as overly complex or confusing process or burdensome document requirements) that can be improved, or mismanagement. 134 to 345 days TO PROCESS HHF APPLICATION AND PROVIDE ASSISTANCE172 Many cannot withstand a lengthy delay Eliminate unnecessary criteria: In its January 2017 report, SIGTARP recommended that state agencies eliminate unnecessary program criteria to help HHF programs reach more unemployed and underemployed homeowners seeking help. This includes: (1) criteria that does not exist for homeowners in other states for these same Federal dollars, and (2) criteria that does not reflect the reality of Indiana workers.173 135 136 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM TARP-Funded Demolition of Abandoned Houses in Indiana Communities The $75 million TARP-funded demolition program in Indiana has demolished 1,217 properties.174 The Indiana state agency has an opportunity to prevent overcharging, waste, and fraud, as well as unfair competitive practices such as bid rigging that drive up costs, if it implements SIGTARP’s recommendations in its June 2016 audit.175 PRIORITY SIGTARP RECOMMENDATIONS Limit TARP reimbursement to demolition costs that are necessary and reasonable as exist in similar HUD and state-funded programs Require full and open competition and other competition requirements that exist in similar HUD program Risk of Overcharging, Waste and Fraud: In January, 2017, Treasury implemented SIGTARP’s recommendation to limit TARP reimbursement to necessary and reasonable costs.176 This is necessary because before Treasury will pay up to $25,000 per demolished house (not limited to necessary and reasonable costs), which far exceeds the median cost of HHF demolition at $6,390 for demolition + $1,500 for greening the land. The average cost for the Indiana state agency to demolish a property is $13,739.177 Implementation of this recommendation could save thousands of dollars per house, up to $161 million program wide. SIGTARP has additional unimplemented recommendations that state agencies use best practices to determine necessary and reasonable costs. Risk of Unfair Competitive Practices that can drive up costs: In January, 2017, Treasury implemented SIGTARP’s recommendation to require full and open competition. However, SIGTARP has additional unimplemented recommendations that mirror HUD requirements to ensure full and open competition in the solicitation of contract awards. The Indiana state agency contracts with local partners who receive TARP dollars (as shown in Table 3.11) and choose neighborhoods and specific houses for TARP-funded demolitions, and then hire contractors and subcontractors. Treasury does not conduct oversight over these local partners or their contractors. 137 SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 TABLE 3.11 INDIANA HHF BLIGHT ELIMINATION PROGRAM PARTNERS AND DEMOLITION ACTIVITY AS OF 9/30/2016** Applications Submitted Properties Demolished/Removed City/County City of Alexandria City of Anderson Partner a Alexandria Redevelopment Commission Madison County Council of Governments City of Auburn City of Austin Cumulative 0 3,078b 207 1,217c Disbursements to Partners, Program to Dated Demolished in Most Recent Quarter Demolished, Cumulative 9 19 6 28 1 1 0 1 $272,586 $— Anderson Community Development Corporation $220,219 Anderson Redevelopment Commission $265,231 Bethesda Missionary Baptist Church $21,734 Habitat for Humanity of Madison County $— Operation MOVE-In, LLC $— South Meridian Church of God City of Arcadia Most Recent Quarter Curtis and Mary Parr City of Auburn Redevelopment Commission $— $21,015 $— Habitat for Humanity of Northeast Indiana $21,341 Austin Redevelopment Commission (ARC) $— Southern Indiana Housing & Community Development Corp. $— 0 0 City of Bicknell Bicknell Bulldog Development Corp. $— 0 0 City of Brazil Clay County Economic Redevelopment Commission $79,520 0 0 National Road Heritage Trail $14,736 0 1 0 0 0 8 0 City of Coatesville City of Columbus South Meridian Church of God ARA (Administrative Resources Association) $— Southern Indiana Housing & Community Development Corporation $— Thrive Alliance, Inc. $— Connersville Urban Enterprise Association U.E.A. City of Connersville House of Ruth Whole Family Community Initiative, Inc City of Delphi Habitat for Humanity of Lafayette, Inc. City of Dunkirk Dunkirk Industrial Development Corp. City of East Chicago City of Elwood $99,499 $— $69,531 $— 0 $96,959 0 9 East Chicago Department of Redevelopment $582,961 12 43 Elwood Redevelopment Commission $271,282 0 20 18 64 Amanda Hanna Comfort Homes Community One, Inc. David Clark $— $— $25,000 $— ECHO Housing Corporation $102,876 Evansville Brownfields Corp. $529,890 Evansville Housing Authority City of Evansville $— $— Full Gospel Mission $19,572 Gethsemane Church $27,941 Gloria Peek Habitat for Humanity of Evansville, Inc. $— $83,574 HOPE of Evansville $— James Bradley $— JBELL Properties, LLC $— Jonathan Page Memorial Community Development Corporation New Odyssey Investments, LLC Ozanam Family Shelter Corp. $— $26,279 $384,383 $17,738 Rose Products, LLC dba as Comfort Homes $— City of Fort Wayne Housing and Neighborhood Devt. Svcs, Inc. $3,461,014 25 136 City of Garrett Garrett State Bank $— 0 0 49 289 8 15 Broadway Area Community Development Corp. City of Gary City of Hammond Fuller Center for Housing of Gary The Gary Redevelopment Commission $97,808 $182,011 $2,803,489 The Sojourner Truth House $107,083 United Neighborhoods, Inc. $346,412 Hammond Redevelopment Commission $— Continued on next page 138 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM INDIANA HHF BLIGHT ELIMINATION PROGRAM PARTNERS AND DEMOLITION ACTIVITY AS OF 9/30/2016** City/County City of Hartford Partnera Blackford Development Corp. $176,337 Community & Family Services $— Jay Dawson $— Rosalie Adkins $— Community Alliance of Far Eastside Mapleton Fall Creek Development Corporation City of Indianapolis Near East Area Renewal Near North Development Corporation Renew Indianapolis Riley Area Development Corporation City of Knox Starke County Economic Devt. Foundation, Inc. City of Kokomo Kokomo Community Development Corp. City of Lawrence Lawrence Community Development Corporation Lawrence/Fort Harrison Development Corporation dba City of Lebanon Lebanon Community Development Corporation City of Logansport Logansport Municipal Building Corporation City of Marion Marion Redevelopment Commission City of Montpelier City of Muncie City of New Castle Blackford Development Corp City of Richmond City of Rising Sun City of Rushville City of South Bend City of Terre Haute 4 4 74 0 5 $57,351 $— $38,550 1 1 $565,552 16 33 $1,070,751 0 63 0 3 0 0 4 24 0 0 0 0 0 103 0 5 0 6 2 60 0 16 $30,578 $78,623 $20,012 Interlocal Community Action Program, Inc. $72,074 Neighborhood Services Clearinghouse Redevelopment Commission of City of Rising Sun RSOC Senior Citizen Housing Inc. $— $69,998 $— $20,643 $— $— $42,588 $203,478 $1,370,777 $116,536 $— Southern Indiana Housing & Community Development Corp $151,916 Near Northwest Neighborhood Inc. $153,522 South Bend Heritage Foundation, Inc. $174,675 Urban Enterprise Assoc. of South Bend, Inc. $699,216 Terre Haute Department of Redevelopment $192,693 West Terre Haute Redevelopment Commission 53 14 Henry County Redevelopment Commission Habitat for Humanity of Greater Richmond 7 $53,273 Healthy Communities of Henry County Community & Family Services 19 $869,565 $— Miami County Master Gardener Association 1 $28,496 $— Miami County Economic Development Authority Demolished, Cumulative $1,043,556 Faith Builders Scratching Post Cat Rescue City of Portland $95,704 $109,580 Muncie Redevelopment Commission Habitat for Humanity of Miami County, Inc. Demolished in Most Recent Quarter $— $— Westminster Community Center (CONTINUED) $57,639 Community & Family Services New Castle Housing Authority City of Peru Disbursements to Partners, Program to Dated $— Continued on next page 139 SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 INDIANA HHF BLIGHT ELIMINATION PROGRAM PARTNERS AND DEMOLITION ACTIVITY AS OF 9/30/2016** City/County City of Vincennes City of Washington Partnera Carol Anderson $— Chris Case $— Dan Vories $— Forest Davis and Charity Davis $— Jack Stilwell $— Karen Evans $— Larry Stuckman $— Leonard Stevenson $— Marc Loveman $— Matt McCoy $— Priscilla Wissell $— Randall E. Madison $— Rick Szudy $— Spiritwoman Greywolfe $— Steven Kramer $— Thursday Church $— United Pentecostal Tabernacle $— William Ridge $— Davies County Economic Development Foundation, Inc. $— Habitat for Humanity of Daviess County, Inc. $— Washington Housing Authority $— Casey Kaiser $11,109 City of Aurora Redevelopment Commission $19,403 John & Darlene Albright Joseph Fette County of Dearborn Laura Williams Linda Ketterman Revocable Trust Robert & Janice Fehrman Revocable Trust Town of Moores Hill Redevelopment Commission Victor C. Fay, III County of Elkhart Disbursements to Partners, Program to Dated LaCasa Inc. (CONTINUED) Demolished in Most Recent Quarter Demolished, Cumulative 0 0 0 0 0 7 3 7 $8,672 $— $11,666 $— $8,963 $30,612 $14,328 $255,455 Continued on next page 140 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM INDIANA HHF BLIGHT ELIMINATION PROGRAM PARTNERS AND DEMOLITION ACTIVITY AS OF 9/30/2016** City/County Partnera Anna Marie Kiel $10,842 Barnaby Knoll $58,808 Billy Ray Walden $22,473 Brandon Taylor $10,775 Brenda Boyer $18,000 Brian Dawson $16,388 Chris Schmidt $14,720 $18,756 David O. Hill $13,700 Elizabeth Schlacks Gloria and Jose Garcia $— $18,540 Joseph H. Gardner $17,062 $12,575 Leslie T. Marshall $16,869 Nancy Carsey, Jay and Richard Stevens Nicholas Burns Princeton Redevelopment Commission $15,425 Richard Ellis $16,899 Richard Kolb $— County of Howard $19,793 Sheryl Walker-Isakson/Allen Isakson $12,204 Steve & Brian Dyson $17,887 Thomas R. Johnstone, Sr. $30,250 Tim Thompson $31,675 Howard County Redevelopment Commission Jessee Trine 1 1 $— $9,942 Sheiln J. Besing Greene Redevelopment Commission 4 $29,656 $158,806 $13,220 Timothy A. Beadles 0 $— $14,831 Randall A. Scales Scott & Kathryn St. Clair County of Greene $— Ralph B DeBord Rick and Elaine Sides 27 $— Kenneth L. Wolf Mark A. Tooley 8 $— $14,495 John D. Young Lillie E. Gardner Wheelhouse, Joseph H. Gardner, and Judith L.Gardner Demolished, Cumulative $9,811 Jason Spindler Keith Perkins Demolished in Most Recent Quarter $— Daniel R. Engler and Sherry L. Engler Donald & Wilma Newcome (CONTINUED) $— Brandon Taylor and Jane E. Taylor Daniel R. Engler County of Gibson Disbursements to Partners, Program to Dated $— $51,085 $— $19,569 Continued on next page 141 SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 INDIANA HHF BLIGHT ELIMINATION PROGRAM PARTNERS AND DEMOLITION ACTIVITY AS OF 9/30/2016** City/County Partnera Allen and Erma Roedel Beverly Stone/Katrina Wagner Brett Newman Bruce and Kathy Martin County of Posey Dale Reuter James C. Welch, Jr Karen Baker Mt. Vernon Redevelopment County of Pulaski County of Sullivan County of Vigo $— $— $135,760 West Terre Haute Redevelopment Commission $— Alan, Daryl & Elizabeth (Griggs) Saltzman $— 1 0 0 7 25 $— $259,008 $12,070 $— Christopher Lunn $25,000 Clifford Hayden $12,108 Habitat for Humanity of Warrick County $20,282 James B. Decker, II $13,579 Josh Barnett $22,166 Larry & Karen Willis $15,487 Lori Lamar $15,618 Ronald & Annis M. Marshall $10,057 $— Scott Speicher $14,336 Terry D. Cline and Kathy J. Cline $11,966 $0 Tim A. McKinney $11,364 Wesley B. Hack and Maureen L. Hack $13,916 Zachary Lee Bailey 0 $13,466 Brian Hendrickson Thomas Key 0 $15,012 Boonville Now, Inc. Ronald Evans 0 $— $— Charles L. Allen 16 $165,668 Sullivan County Redevelopment Commission Bettye Lee 7 $— $22,382 $— Barbara & Kenneth Klippel Demolished, Cumulative $— $— Sullivan City Redevelopment Commission Demolished in Most Recent Quarter $— Sherriell Thompson White’s General Contracting (CONTINUED) $13,645 Randall Yeida and Susan Marshall Andy R & Donna VanWinkle County of Warrick Disbursements to Partners, Program to Dated $— Kendallville Campbell and Fetter Bank $— 0 0 Richland City The Friends of Richland $61,670 0 4 Shelby County/City of Shelbyville Habitat for Humanity For Shelby Co. $85,635 0 5 0 0 0 0 0 0 Town of Brookville Town of Cambridge City Town of Daleville Brookville Redevelopment Commission $— Kara Knapp $— Thomas G. and Tammy Davis III $— Carla Boyles $— Jonathan Winchester $— Robert Fortman $— Daleville Parks, Inc. $— Continued on next page 142 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM INDIANA HHF BLIGHT ELIMINATION PROGRAM PARTNERS AND DEMOLITION ACTIVITY AS OF 9/30/2016** City/County Disbursements to Partners, Program to Dated Partnera Cathy Griffith Town of Edwardsport Town of Lagro 0 0 3 0 0 0 0 $— 0 0 $29,252 0 3 0 0 2 2 2 9 $— Kathy Hartigan $— William Beamon $— Keith Martin $— $7,265 David Mosier and Dianna Mosier and Danielle Virgil Mendy Rose $0 $8,265 $14,765 Edward Nugent $— Joe Smith, Jefferson Township Trustee $— Randy Moles $— David Pefley $— Kevin Campbell $— Knox County Housing Authority Silver Lake Educational Foundation Town of Waterloo 0 $— Doug Deyoe Town of Silver Lake Town of Sweetser 0 Decker Community Center Town of Oaktown Town of St. Joe 0 $— $6,442 Monty and Mary York Town of Hagerstown Demolished, Cumulative David & Bonnie Wehmeirer David Mosier and Dianna Mosier Town of Greens Fork Demolished in Most Recent Quarter $— Darrell & Robin Lindsay Town of Decker (CONTINUED) Habitat for Humanity of Northeast Indiana $— Larry Griffin $— Michael Mills $— Sweetser Redevelopment Commission $24,898 Habitat for Humanity of Northeast Indiana $50,428 RP Wakefield Co. $15,699 Waterloo Redevelopment Commission $106,317 Indiana Housing and Community Development Authority. Indiana Quarterly Performance Report, 9/30/2016, cumulative data did not change, quarter to quarter. From Indiana’s Quarterly Performance Report: “Due to human error, the cumulative demolished/removed value in the Q1-2016 report was understated by 234 properties.” d Indiana HFA response to SIGTARP data call. Due to reporting date differences, disbursement amounts may be more recent than demolition data. a b c **Indiana Housing and Community Development Authority, Indiana’s Hardest Hit Fund, Quarterly Reports to the U.S. Treasury, Quarterly Performance Report, Q3 2016, no date. Each local partner hires contractors and subcontractors for demolition, site inspection, asbestos removal, greening and other activities. Treasury and the Indiana state agency have no requirements for full and open competition in these contracts. Making oversight even more difficult is that there is no one source to identify contractors and subcontractors. SIGTARP is in the process of identifying contractors and subcontractors who receive TARP dollars for demolition. Identifying all participating in a TARP program and benefitting from TARP funds is crucial to protecting these Federal dollars from fraud, waste, and abuse, and transparency for taxpayers. SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 Program Performance Figures 3.32 and 3.33 show the performance of HHF Indiana Unemployment and Related Programs, as of September 30, 2016. FIGURE 3.32 HHF INDIANA HOMEOWNER PROGRAMS’ PERFORMANCE, UNEMPLOYMENT AND RELATED PROGRAMS, AS OF 9/30/2016 20,000 15,000 10,000 As of 9/30/2016: Homeowner Applications: 10,206 Homeowners Helped: 8,344 Homeowner Admission Rate: 82% 5,000 0 Q1 Q2 Q3 Q4 Q1 2010 Q2 Q3 Q4 2011 Estimated Homeowners to be Helped Q1 Q2 Q3 Q4 Q1 2012 Q2 Q3 2013 Q4 Q1 Q2 Q3 2014 Q4 Q1 Q2 Q3 Q4 Q1 2015 Q2 2016 Homeowners Helped Applying Homeowners Notes: Estimated includes highest estimate of a range. Applications are the total number of applicant homeowners, which Treasury began reporting as of Q3 2012. Homeowner Admission Rate is cumulative Homeowners Assisted as a percent of homeowners who applied. Sources: Treasury and Indiana Housing and Community Development Authority, Commitment to Purchase Financial Instrument and HFA Participation Agreement, 9/23/2010, and Amendments to Agreement one through eleven, as of 9/30/2016; Indiana Housing and Community Development Authority, Quarterly Performance Reports Q2 2011 – Q3 2016, no date; Treasury, HFA Aggregate Reports Q3 2012 – Q3 2016, no date. Q3 143 144 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM FIGURE 3.33 HHF INDIANA PROGRAM PERFORMANCE, AS OF 9/30/2016 HARDEST HIT FUND UNEMPLOYMENT BRIDGE PROGRAM (UNEMPLOYMENT) – SEPTEMBER 2010 As of 9/30/2016: Estimate: 11,000 (Peak: 16,257) Homeowner Applications: 9,765 Homeowners Helped: 8,164 Homeowner Admission Rate: 84% 20,000 15,000 HARDEST HIT FUND RECAST/MODIFICATION PROGRAM (MODIFICATION) – MARCH 2013 2,000 1,500 10,000 1,000 5,000 500 0 As of 9/30/2016: Estimate: 265 (Peak: 2,000) Homeowner Applications: 577 Homeowners Helped: 163 Homeowner Admission Rate: 28% 0 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 2010 2011 2012 2013 Estimated Homeowners to be Helped 2014 2015 2016 Homeowners Helped Homeowner Applications Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 2010 2011 2012 2013 Estimated Homeowners to be Helped 2014 2015 2016 Homeowners Helped Homeowner Applications HARDEST HIT FUND TRANSITION ASSISTANCE PROGRAM (TRANSITION) – MARCH 2013 200 150 100 50 As of 9/30/2016: Estimate: 70 (Peak: 184) Homeowner Applications: 53 Homeowners Helped: 17 Homeowner Admission Rate: 32% 0 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 2010 2011 2012 2013 Estimated Homeowners to be Helped 2014 2015 2016 Homeowners Helped Homeowner Applications Notes: Programs may have been started or ended at different times. Estimated includes highest estimate of a range. Homeowner Admission Rate is cumulative Homeowners Assisted as a percent of reported Homeowner Applications. Sources: Treasury and Indiana Housing and Community Development Authority, Commitment to Purchase Financial Instrument and HFA Participation Agreement, 9/23/2010 and Amendments to Agreement one through eleven, as of 9/30/2016; Indiana Housing and Community Development Authority, Quarterly Performance Reports Q2 2011 – Q3 2016, no date. SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 HHF in Kentucky There remains a critical need for HHF’s stop-gap unemployment bridge to help save the homes of Kentucky workers who lost their job or saw their paycheck cut, while they look for a full time job in Kentucky. More than 12,000 Kentucky homeowners who have lost jobs or suffered reductions in income have sought help from Kentucky’s HHF unemployment bridge or related programs to help save their home.178 Last year 3,545 Kentucky homeowners lost their home to foreclosure, another 27,246 Kentucky homeowners are behind on their mortgage, and 17,573 owe more than their home is worth, showing a critical need for HHF in Kentucky.179 The Kentucky state agency has admitted 69% of all homeowners who have applied, which is one of the higher rates of state agencies in HHF.180 SIGTARP has identified improvements to the efficiency of the Kentucky state agency’s administration of HHF. For example: • N early three out of four (72%) of the 2,110 people denied earned less than $30,000 per yearxi • Over the past year, only 1,247 Kentucky workers were helped by the Kentucky state agency through its unemployment program • The Kentucky state agency has approved 55% (540 of 983) homebuyers, but denied 17% of homeowners and 12% of homeowners saw their applications withdrawn • Kentucky homeowners have had to wait 51 days to receive help.181 Hardest Hit Fund – Use of Funds in Kentucky and Status of Kentucky Workers Most of Kentucky’s spending went to help homeowners.182 See Figures 3.34 and 3.35 for more information. xi Data as of June 30, 2016. See SIGTARP’s January 11, 2017, evaluation “Improving TARP’s Investment in American Workers”. 145 146 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM FIGURE 3.34 FIGURE 3.35 HARDEST HIT FUND – USE OF FUNDS IN KENTUCKY, STATUS OF KENTUCKY WORKERS THAT APPLIED TO HHF, AS OF 9/30/2016 AS OF 9/30/2016 7% 4% 2% 12% 34% 17% 55% 69% TARP Dollars to State Agency ($15,516,694) Workers Helped (8,543) Homebuyer Assistance ($7,644,824) Workers Denied (2,143) Unspent ($70,992,002) Workers with Withdrawn Applications (1,483) Unemployment Bridge and Related Assistance ($115,489,469) Workers In Process (256) Note: Funds include $207 million allocated from Treasury plus remittances of $2.6 million. Sources: Treasury, HFA Aggregate Report Q3 2016; Kentucky Housing Corporation, Quarterly Performance Report Q3 2016. Source: Treasury, response to SIGTARP data call, 1/17/2017. HIGH RISK AREAS Streamline lengthy application process: A lengthy delay in applications reviewed may be evidence of an inefficient process (such as overly complex or confusing process or burdensome document requirements) that can be improved, or mismanagement. 51 days TO PROCESS HHF APPLICATION AND PROVIDE ASSISTANCE183 Many cannot withstand a lengthy delay Eliminate unnecessary criteria: In its January, 2017, report, SIGTARP recommended that state agencies eliminate unnecessary program criteria to help HHF programs reach more unemployed and underemployed homeowners seeking help. This includes: (1) criteria that does not exist for homeowners in other states for these same Federal dollars, and (2) criteria that does not reflect the reality of Kentucky workers.184 SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 Protect TARP-Funded Homebuyer Assistance Program from Fraud, Waste and Abuse As of September 30, 2016, the Kentucky state agency has assisted 540 first-time homebuyers, paying up to $10,000 to a homebuyer.185 In 2015, SIGTARP made a series of recommendations to prevent fraud, which remain umimplemented. Among these were requiring detailed reporting on who was receiving these dollars, whether they were buying the house in a non-arms-length transaction, whether there was commingling with state down payment assistance dollars and the buyer certifying that they meet the eligibility requirements. We also recommend that state agencies conduct background checks to determine if an applicant was convicted of a crime of dishonesty. Implementing these recommendations can save the government $48 million program wide, based on the average 10% of fraud in government programs.186 Program Performance Figure 3.36 shows the performance of HHF Kentucky Unemployment Program, as of September 30, 2016. FIGURE 3.36 HHF KENTUCKY HOMEOWNER PROGRAM PERFORMANCE, UNEMPLOYMENT PROGRAM, AS OF 9/30/2016 15,000 12,000 9,000 As of 9/30/2016: Homeowner Applications: 12,425 Homeowners Helped: 8,543 Homeowner Admission Rate: 69% 6,000 3,000 0 Q1 Q2 Q3 Q4 Q1 2010 Q2 Q3 Q4 2011 Estimated Homeowners to be Helped Q1 Q2 Q3 Q4 Q1 2012 Q2 Q3 2013 Q4 Q1 Q2 Q3 2014 Q4 Q1 Q2 Q3 2015 Q4 Q1 Q2 2016 Homeowners Helped Applying Homeowners Notes: Estimated includes highest estimate of a range. Applications are the total number of applicant homeowners, which Treasury began reporting as of Q3 2012. Homeowner Admission Rate is cumulative Homeowners Assisted as a percent of homeowners who applied. Sources: Treasury and Kentucky Housing Corporation, Commitment to Purchase Financial Instrument and HFA Participation Agreement, 9/23/2010, and Amendments to Agreement one through ten, as of 9/30/2016; Kentucky Housing Corporation, Quarterly Performance Reports Q4 2010 – Q3 2016, no date; Treasury, HFA Aggregate Reports Q3 2012 – Q3 2016, no date. Q3 147 148 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM HHF in Michigan With the exception of the highly populated California and Florida, Ohio and Michigan have the most dollars set aside by Treasury for HHF.187 There remains a critical need for HHF’s stop-gap unemployment bridge to help save the homes of Michigan workers who lost their job or saw their paycheck cut, while they look for a full time job in Michigan. Last year 28,676 Michigan homeowners lost their home to foreclosure, another 65,726 Michigan homeowners are behind on their mortgage, and 126,783 owe more than their home is worth.188 Michigan had 239,884 unemployed workers, as of November 2016.189 General Motors recently announced additional layoffs of workers in Michigan.190 The Michigan state agency has done a better job than many state agencies distributing these funds to homeowners. However, there can still be improvments. Given the critical need in Michigan, SIGTARP has identified some improvements to the efficiency of the Michigan state agency’s administration of HHF who was paid $36.5 million by Treasury as the conduit to distribute these Federal funds.191 For example: • In 6 years, HHF has helped only 32,612 Michigan homeowners • Almost half (49%) of all workers seeking help from the state agency were not helped • The state agency denied assistance to 12,653 people who earned less than $30,000 per year, which is about three out of four (71%) of those who were denied, but provided HHF funds to 1,176 people earning more than $90,000 per year, and 1,884 people making between $70-$89,999 per yearxii,192 Hardest Hit Fund – Use of Funds in Michigan and Status of Michigan Workers Most of Michigan’s spending went to help homeowners.193 See Figures 3.37 and 3.38 for more information. xii Data as of June 30, 2016. See SIGTARP’s January 11, 2017, evaluation “Improving TARP’s Investment in American Workers”. SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 FIGURE 3.37 FIGURE 3.38 HARDEST HIT FUND – USE OF FUNDS IN MICHIGAN, STATUS OF MICHIGAN WORKERS THAT APPLIED TO HHF, AS OF 9/30/2016 AS OF 9/30/2016 5% 1% 20% 20% 33% 42% 50% 29% TARP Dollars to State Agency ($36,509,749) Workers Helped (32,612) Demolition ($152,761,656) Workers Denied (19,022) Unspent ($320,252,603) Workers with Withdrawn Applications (12,811) Unemployment Bridge and Related Assistance ($257,527,759) Workers In Process (491) Note: Funds include $761.2 million allocated from Treasury plus remittances of $5.8 million. Sources: Treasury, HFA Aggregate Report Q3 2016; Michigan Homeowner Assistance Nonprofit Housing Corporation, Hardest Hit U.S. Treasury Reports, Quarterly Performance Report Q3 2016, no date. Source: Treasury, response to SIGTARP data call, 1/17/2017. HIGH RISK AREAS Concerns raised by Representative John Conyers and Representative Brenda Lawrence: In March, 2016, Representatives John Conyers (13th District) and Brenda Lawrence (14th District) of Michigan sent a letter to President Obama, along with 9 other Congressmen, expressing concerns that HHF dollars were not being distributed effectively in their states. In July 2016, SIGTARP reported that in Wayne County, Michigan parts of which are in the 13th and 14th districts, unemployment was 6.4%, higher than the national (5.4%) rate. At that time 49,082 people unemployed in that county, and 159,514 county residents lost homes to foreclosure over the prior year, while only 1,781 people were approved for HHF help.194 As of November 30, 2016, there are 46,904 unemployed people in Wayne County and during the 12 months ended September 30, 2016, 16,196 lost their homes to foreclosure, while only 1,524 people were approved for HHF over that period.195 SIGTARP January 2017 Report: SIGTARP has reported that Michigan has one of the highest percentages of people turned down for HHF who earned less than $30,000 per year. As shown in Figure 3.39, in cities where General Motors or its suppliers closed plants or laid off workers, denial rates were even higher for those who made less than $30,000 per year.196 149 150 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM FIGURE 3.39 HHF DENIALS FOR HOMEOWNERS MAKING LESS THAN $30,000 PER YEAR *Dayton OH includes nearby cities of Moraine and Vandalia. Source: SIGTARP, Audit Report “Improving TARP’s Investment in American Workers”, 1/11/2017, https://www.sigtarp.gov/Audit%20Reports/SIGTARP_HHF_Florida_Report.pdf, accessed 1/13/2017. Eliminate unnecessary criteria: In its January, 2017, report, SIGTARP recommended that state agencies eliminate unnecessary program criteria. This includes: (1) criteria that does not exist for homeowners in other states for these same Federal dollars, and (2) criteria that does not reflect the reality of Michigan workers.197 TARP-Funded Demolition of Abandoned Houses in Michigan Communities The $381.2 million TARP-funded demolition program has demolished 9,849 homes in Michigan, after more than three years, spending $152.8 million on demolition.198 In a June, 2016, audit, SIGTARP identified that the HHF demolition program, which has spent $217.5 million out of more than $800 million to demolish 14,598 houses nationwide, is significantly vulnerable to the substantial risks of unfair competitive practices and overcharging and is vulnerable to bid rigging, contract steering, and other closed-door contracting processes. In the report, SIGTARP made several recommendations to Treasury to address the issues found in the HHF demolition program.199 SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 PRIORITY SIGTARP RECOMMENDATIONS Limit TARP reimbursement to demolition costs that are necessary and reasonable as exist in similar HUD and state-funded programs Require full and open competition and other competition requirements that exist in similar HUD program After SIGTARP’s report, in August, 2016, Treasury suspended funding for HHF demolition acitivities in Detroit. The Michigan state agency began a review of Hardest Hit Fund expenditures in Detroit. In light of this review, Treasury directed MSHDA to temporarily suspend HHF-blight-related activities in Detroit and stopped funding the program for two months. In October, 2016, after the Michigan state agency agreed to operational improvements, including requiring competition, and a limit on the size of demolition bid packages, partially implementing SIGTARP’s recommendations, Treasury released the suspension and allowed Michigan to continue the HHF demolition program.200 Risk of Overcharging, Waste and Fraud: In January, 2017, Treasury implemented SIGTARP’s recommendation to limit TARP reimbursement to necessary and reasonable costs.201 This is necessary because before Treasury paid up to $25,000 per demolished house (not limited to necessary and reasonable costs), which far exceeds the median cost of HHF demolition at $9,978 for demolition + $2,700 for greening the land. The average cost for the Michigan state agency to demolish a property is $15,510.202 Implementation of this recommendation could save thousands of dollars per house, up to $161 million program wide. SIGTARP has additional unimplemented recommendations that state agencies use best practices to determine necessary and reasonable costs. Risk of Unfair Competitive Practices that can drive up costs: In January 2017, Treasury implemented SIGTARP’s recommendation to require full and open competition. However, SIGTARP has additional unimplemented recommendations that mirror HUD requirements to ensure full and open competition.203 The Michigan state agency contracts with local partners who receive TARP dollars (as shown in Table 3.12) and choose neighborhoods and specific houses for TARPfunded demolitions, and then hire contractors and subcontractors. Treasury does not conduct oversight over these local partners or their contractors. 151 152 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM TABLE 3.12 MICHIGAN HHF BLIGHT ELIMINATION PROGRAM PARTNERS AND DEMOLITION ACTIVITY AS OF 9/30/2016** Most Recent Quarter Cumulative Applications Submitted 102 13,729b Properties Demolished/Removed 616 9,849 Demolished in Most Recent Quarter Demolished, Cumulative City/County Partner Adrian Lenawee County Land Bank Detroit Detroit Land Bank Ecorse Wayne Metro Community Action Agency (Ecorse) Flint Genesee County Land Bank Authority Grand Rapids a Habitat for Humanity of Kent County Kent County Land Bank Hamtramck Michigan Land Bank (Hamtramck) Highland Park Michigan Land Bank (Highland Park) Inkster Ironwood Jackson Lansing Disbursements to Partners, Program to Datec $160,257 0 8 $99,921,307 238 6,096 $911,416 35 68 $24,562,219 84 1,909 15 117 $631,744 $1,720,383 $— 0 0 $1,845,936 83 83 Michigan Land Bank (Inkster) $229,111 11 11 Gogebic County Land Bank $522,003 11 27 John George Home (Jackson) $3,959,861 53 180 Ingham County Land Bank $2,726,323 4 190 Muskegon Muskegon County Land Bank $1,008,042 38 103 Pontiac Michigan Land Bank (Pontiac) $1,945,828 9 135 Port Huron Port Huron Neighborhood Housing Corporation $724,950 8 33 River Rouge Wayne Metro Community Action Agency (River Rouge) $700,580 27 47 Saginaw Saginaw County Land Bank Authority $11,196,003 0 842 Notes: a Michigan Homeowner Assistance Nonprofit Housing Corporation (MHA). b Michigan reported in their QPR 13,900 applications received as of 3/31/2016, 171 more applications than reported received as of 9/30/2016. c Michigan HFA response to SIGTARP data call. Due to reporting date differences, disbursement amounts may be more recent than demolition data. ** Michigan Homeowner Assistance Nonprofit Housing Corporation, Hardest Hit U.S. Treasury Reports, Quarterly Performance Report Q3 2016, no date. SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 Each local partner hires contractors and subcontractors for demolition, site inspection, asbestos removal, greening and other activities. Treasury and the Michigan state agency have no requirements for full and open competition in these contracts. Making oversight even more difficult is that there is no one source to identify contractors and subcontractors. SIGTARP is in the process of identifying contractors and subcontractors who receive TARP dollars for demolition. Identifying all participating in a TARP program and benefitting from TARP funds is crucial to protecting these Federal dollars from fraud, waste, and abuse, and transparency for taxpayers. Program Performance Figures 3.40 and 3.41 show the performance of HHF Michigan Unemployment and Related Programs, as of September 30, 2016. FIGURE 3.40 HHF MICHIGAN HOMEOWNER PROGRAMS’ PERFORMANCE, UNEMPLOYMENT AND RELATED PROGRAMS, AS OF 9/30/2016 80,000 As of 9/30/2016: Homeowner Applications: 64,936 Homeowners Helped: 32,612 Homeowner Admission Rate: 50% 70,000 60,000 50,000 40,000 30,000 20,000 10,000 0 Q1 Q2 Q3 Q4 Q1 2010 Q2 Q3 Q4 2011 Estimated Homeowners to be Helped Q1 Q2 Q3 Q4 Q1 2012 Q2 Q3 2013 Q4 Q1 Q2 Q3 2014 Q4 Q1 Q2 Q3 2015 Q4 Q1 Q2 2016 Homeowners Helped Applying Homeowners Notes: Estimated includes highest estimate of a range. Applications are the total number of applicant homeowners, which Treasury began reporting as of Q3 2012. Homeowner Admission Rate is cumulative Homeowners Assisted as a percent of homeowners who applied. Sources: Treasury and Michigan Homeowner Assistance Nonprofit Housing Corporation, Commitment to Purchase Financial Instrument and HFA Participation Agreement, 6/23/2010, and Amendments to Agreement one through thirteen, as of 9/30/2016; Michigan Homeowner Assistance Nonprofit Housing Corporation, Quarterly Performance Reports Q3 2010 – Q3 2016, no date; Treasury, HFA Aggregate Reports Q3 2012 – Q3 2016, no date. Q3 153 154 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM FIGURE 3.41 HHF MICHIGAN PROGRAM PERFORMANCE, AS OF 9/30/2016 PRINCIPAL CURTAILMENT PROGRAM (MODIFICATION) – JUNE 2010 As of 9/30/2016: Estimate: 300 (Peak: 3,044) Homeowner Applications: 1,487 Homeowners Helped: 305 Homeowner Admission Rate: 21% 4,000 3,000 2,000 LOAN RESCUE PROGRAM (PAST-DUE PAYMENT) – JUNE 2010 As of 9/30/2016: Estimate: 7,218 (Peak: 21,760) Homeowner Applications: 49,659 Homeowners Helped: 22,258 Homeowner Admission Rate: 45% 45,000 37,500 30,000 22,500 15,000 1,000 7,500 0 0 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 2010 2011 2012 2013 Estimated Homeowners to be Helped 2014 2015 2010 2016 2011 2012 2013 Estimated Homeowners to be Helped Homeowners Helped 2014 2015 2016 Homeowners Helped Homeowner Applications Homeowner Applications UNEMPLOYMENT MORTGAGE SUBSIDY PROGRAM (UNEMPLOYMENT) – JUNE 2010 MODIFICATION PLAN PROGRAM (MODIFICATION) – JUNE 2013 As of 9/30/2016: Estimate: 2,728 (Peak: 24,618) Homeowner Applications: 12,633 Homeowners Helped: 9,686 Homeowner Admission Rate: 77% 25,000 20,000 15,000 1,250 1,000 750 10,000 500 5,000 250 0 As of 9/30/2016: Estimate: 294 (Peak: 825) Homeowner Applications: 1,157 Homeowners Helped: 363 Homeowner Admission Rate: 31% 0 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 2010 2011 2012 2013 Estimated Homeowners to be Helped Homeowner Applications 2014 2015 Homeowners Helped 2016 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 2010 2011 2012 2013 Estimated Homeowners to be Helped 2014 2015 2016 Homeowners Helped Homeowner Applications Notes: Programs may have been started or ended at different times. Estimated includes highest estimate of a range. Homeowner Admission Rate is cumulative Homeowners Assisted as a percent of reported Homeowner Applications. Sources: Treasury and Michigan Homeowner Assistance Nonprofit Housing Corporation, Commitment to Purchase Financial Instrument and HFA Participation Agreement, 6/23/2010, and Amendments to Agreement one through thirteen, as of 9/30/2016; Michigan Homeowner Assistance Nonprofit Housing Corporation, Quarterly Performance Reports Q3 2010 – Q3 2016, no date. SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 HHF in Mississippi There remains a critical need for HHF’s stop-gap unemployment bridge to help save the homes of Mississippi workers who lost their job or saw their paycheck cut, while they look for a full time job in Mississippi. Last year 844 Mississippi homeowners lost their home to foreclosure, another 27,719 Mississippi homeowners are behind on their mortgage, and 7,071 owe more than their home is worth.204 The unemployment rate in Mississippi is 5.7% making it one of the states with the highest unemployment.205 After being paid $12 million by Treasury as its conduit to distribute these Federal dollars, SIGTARP has identified issues at the Mississippi state agency that could be improved to help unemployed or underemployed workers gain access to the funds.206 For example: • In 6 years, HHF has helped only 3,973 Mississippi homeowners • 42% of the funds set aside for Mississippi has not been spent. • The Mississippi state agency has helped 65% (3,973) of homeowners who applied (an above average admission rate in HHF), however, 80% of homeowners denied assistance made less than $30,000 per yearxiii • Mississippi homeowners typically had to wait about 100 days to get HHF assistance • The Mississippi state agency admitted only 501 new Mississippi homeowners last year to HHF. • The state agency did not help 33% (2,012) of 6,125 Mississippi workers who applied for HHF help.207 Hardest Hit Fund – Use of Funds in Mississippi and Status of Mississippi Workers Most of Mississippi’s spending went to help homeowners. However, only 3,973 workers were actually helped by the program.208 xiii Data as of June 30, 2016. See SIGTARP’s January 11, 2017, evaluation “Improving TARP’s Investment in American Workers”. 155 156 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM FIGURE 3.42 FIGURE 3.43 HARDEST HIT FUND – USE OF FUNDS IN MISSISSIPPI, STATUS OF MISSISSIPPI WORKERS THAT APPLIED TO HHF, AS OF 9/30/2016 AS OF 9/30/2016 2% 9% 8% 42% 65% 50% 24% TARP Dollars to State Agency ($11,988,041) Workers Helped (3,973) Unspent ($60,086,605) Workers Denied (1,457) Unemployment Bridge and Related Assistance ($72,686,580) Workers with Withdrawn Applications (555) Note: Funds include $144.3 million allocated from Treasury plus remittances of $469,526. Source: Treasury, response to SIGTARP data call, 1/17/2017. Workers In Process (140) Sources: Treasury, HFA Aggregate Report Q3 2016; Mississippi Home Corporation, Hardest Hit Fund Performance Data Report, Quarterly Performance Report Q3 2016, no date. HIGH RISK AREAS Streamline lengthy application process: The state agency takes 110 days to process HHF applications, which may be evidence of an inefficient process (such as overly complex or confusing process or burdensome document requirements) that can be improved, or mismanagement.209 110 days TO PROCESS HHF APPLICATION AND PROVIDE ASSISTANCE Many cannot withstand a lengthy delay Eliminate unnecessary criteria: In its January 2017 report, SIGTARP found more than 80% of homeowners denied HHF assistance made less than $30,000 per year. In that report, SIGTARP recommended that state agencies eliminate unnecessary program criteria. This includes: (1) criteria that does not exist for homeowners in other states for these same Federal dollars, and (2) criteria that does not reflect the reality of Mississippi workers.210 SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 TARP-Funded Demolition of Abandoned Houses in Mississippi Communities The Mississippi state agency’s $20 million TARP-funded demolition program is brand new, as of December 19, 2016, and has not yet gotten off the ground.211 PRIORITY SIGTARP RECOMMENDATIONS Limit TARP reimbursement to demolition costs that are necessary and reasonable as exist in similar HUD and state-funded programs Require full and open competition and other competition requirements that exist in similar HUD program Risk of Overcharging, Waste and Fraud: In January, 2017, Treasury implemented SIGTARP’s recommendation to limit TARP reimbursement to necessary and reasonable costs.212 Implementation of this recommendation could save thousands of dollars per house, up to $161 million program wide. SIGTARP has additional unimplemented recommendations related to state agencies using best practices to determine necessary and reasonable costs. Risk of Unfair Competitive Practices that can drive up costs: In January, 2017, Treasury implemented SIGTARP’s recommendation to require full and open competition. However, SIGTARP has additional unimplemented recommendations that mirror HUD requirements to ensure full and open competition in the solicitation of contract awards. State agencies manage their demolition programs, by contracting with non-profits or for profit contractors and subcontractors to receive TARP dollars. To receive TARP funds, state agencies choose neighborhoods and specific houses for TARP-funded demolitions, and hire contractors and subcontractors. Treasury does not conduct oversight over these organizations or their contractors. Program Performance Figure 3.44 shows the performance of HHF Mississippi’s Unemployment Program, as of September 30, 2016. 157 158 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM FIGURE 3.44 HHF MISSISSIPPI HOMEOWNER PROGRAM PERFORMANCE, UNEMPLOYMENT PROGRAM, AS OF 9/30/2016 As of 9/30/2016: Homeowner Applications: 6,125 Homeowners Helped: 3,973 Homeowner Admission Rate: 65% 8,000 7,000 6,000 5,000 4,000 3,000 2,000 1,000 0 Q1 Q2 Q3 Q4 Q1 2010 Q2 Q3 Q4 2011 Estimated Homeowners to be Helped Q1 Q2 Q3 Q4 Q1 2012 Q2 Q3 2013 Q4 Q1 Q2 Q3 2014 Q4 Q1 Q2 Q3 2015 Q4 Q1 Q2 2016 Homeowners Helped Applying Homeowners Notes: Estimated includes highest estimate of a range. Applications are the total number of applicant homeowners, which Treasury began reporting as of Q3 2012. Homeowner Admission Rate is cumulative Homeowners Assisted as a percent of homeowners who applied. Sources: Treasury and Mississippi Home Corporation, Commitment to Purchase Financial Instrument and HFA Participation Agreement, 9/23/2010, and Amendments to Agreement one through eleven, as of 9/30/2016; Mississippi Home Corporation, Quarterly Performance Reports Q4 2010 – Q3 2016, no date; Treasury, HFA Aggregate Reports Q3 2012 – Q3 2016, no date. Q3 SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 HHF in Nevada There are serious risks of Treasury continuing to have the state agency’s contractor NAHAC administer HHF, and SIGTARP recommends NAHAC’s removal from the program. There remains a critical need for HHF’s stop-gap unemployment bridge to help save the homes of Nevada workers who lost their job or saw their paycheck cut, while they look for a full time job in Nevada. Last year, 6,156 Nevada homeowners lost their home to foreclosure, another 24,177 Nevada homeowners are behind on their mortgage, and 77,744 owe more than their home is worth.213 The unemployment rate in Nevada is 5.2%, making it one of the states with high unemployment.214 Despite the critical need for HHF, SIGTARP has found waste and abuse by NAHAC. SIGTARP repeatedly identified the Nevada state agency as one of the most inefficient state agencies in the program, despite being paid $17.5 million by Treasury as its conduit to distribute these Federal dollars. • Nevada had a 94% drop in number of homeowners helped from 2013-2015, see Figure 3.45. This has not improved in 2016. The Nevada state agency has not been effective and, in the second quarter of last year, only 97 homeowners in the entire state received help from HHF215 • Almost half of the TARP funds being distributed by the Nevada agency have not been spent FIGURE 3.45 NEVADA HOMEOWNERS APPROVED FOR HHF, BY QUARTER 1,200 1,000 964 1,015 800 600 556 400 372 333 300 234 200 550 246 209 212 119 114 0 122 88 1 Q1 Q2 Q3 2011 Q4 Q1 Q2 Q3 2012 Q4 Q1 Q2 Q3 2013 Q4 Q1 Q2 Q3 2014 Q4 55 Q1 24 14 24 38 Q2 Q3 Q4 Q1 2015 Homeowners Approved for HHF Source: SIGTARP Audit Report, “Waste and Abuse in the Hardest Hit Fund in Nevada”, 9/9/2016, https://www.sigtarp. gov/Audit%20Reports/HHF%20Nevada_090916.pdf, accessed 1/25/2017. 2016 159 160 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM • The Nevada state agency estimated helping 23,556 people, and nearly 15,000 applied, but the state agency lowered its estimate by 65% and now estimates helping only 8,259 or about a third of its original estimate • Since 2013 spending by the Nevada state agency has increased while the number of homeowners helped has decreased, see Figure 3.46 FIGURE 3.46 SPENDING BY HARDEST HIT FUND NEVADA COMPARED TO HOMEOWNERS APPROVED FOR HHF $, Homeowners 3,000 HHF Dollars Spent on Gifts, Pizza, Cakes, Picnic & Office Refreshments 2,500 2,000 1,500 1,000 Homeowners Admitted to HHF 500 - 2013 2014 2015 Source: SIGTARP, Audit Report: “Waste and Abuse in the Hardest Hit Fund in Nevada”, 9/9/2016, https://www.sigtarp.gov/ Audit%20Reports/HHF%20Nevada_090916.pdf, accessed 1/13/2017. • The Nevada state agency has only admitted 37% (5,417) of all people who applied, (nearly 15,000) despite the state’s persistently high mortgage delinquencies, foreclosures and unemployment • Nearly nine out of ten people (89%) did not receive help (766 of 862) who applied for assistance in the last year • The Nevada state agency turned down 1,293 homeowners who earned less than $30,000 per yearxiv • The Nevada state agency has one of the worst rates of withdrawn HHF applications (39%) from any other state • The state agency never admitted a single worker to an HHF program to help unemployed workers recast and refinance their mortgage or helped a single worker with a home retention program216 xiv Data as of June 30, 2016. See SIGTARP’s January 11, 2017, evaluation “Improving TARP’s Investment in American Workers”. SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 Hardest Hit Fund – Use of Funds in Nevada and Status of Nevada Workers Most of Nevada’s spending went to help homeowners.217 See Figures 3.47 and 3.48 for more details. FIGURE 3.47 FIGURE 3.48 HARDEST HIT FUND – USE OF FUNDS IN NEVADA, STATUS OF NEVADA WORKERS THAT APPLIED TO HHF, AS OF 9/30/2016 AS OF 9/30/2016 8.56% 0.1% 44.88% 36.8% 39.6% 46.56% 23.5% TARP Dollars to State Agency ($17,479,651) Workers Helped (5,417) Unspent ($95,113,269) Workers Denied (3,456) Unemployment Bridge and Related Assistance ($91,684,311) Workers with Withdrawn Applications (5,831) Workers Process (21) Source: Treasury, HFA Aggregate Report Q3 2016. Note: Funds include $202.9 million allocated from Treasury plus remittances of $1.4 million. Source: Treasury, response to SIGTARP data call, 1/17/2017. HIGH RISK AREAS Concerns about HHF raised by Representative Titus: On March 25, 2016, Representative Dina Titus from the 1st District of Nevada sent a letter to President Obama, along with 10 other Congressmen, expressing concerns that HHF dollars were not being distributed effectively in their states. In July 2016, SIGTARP reported that in Clark County, Nevada, in Congresswoman Titus’ district, nearly 80,000 homeowners owed more than their home was worth and 62,539 people were unemployed in the county, yet only 9 homeowners in the entire state received HHF unemployment bridge help during the second quarter of 2016.218 With 65,670 homeowners in Clark County owing more than their homes are worth and 4,889 homeowners having lost their homes to foreclosure in the 12 months ended September 30, 2016, while only 75 Clark County workers being helped by the Nevada state agency between September 2015 and June 2016 (the most recent data available), there remains a critical need for the Nevada state agency to provide fair access to workers struggling to keep their homes in Nevada. 161 162 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM Waste and Abuse by the Nevada State Agency: In September, 2016, SIGTARP issued an audit report finding that the Nevada Affordable Housing Assistance Corporation (NAHAC), the contractor the Nevada state agency chose to run its HHF program wasted $8.2 million. SIGTARP found that NAHAC deliberately attempted to use the TARP program as a cash cow for every expense imaginable, while NAHAC all but stopped admitting new homeowners.219 SIGTARP recommended that Treasury fire NAHAC and seek repayment of the $8.2 million in wasted and abused funds. Neither has happened. See Section 2 of this Report for more detail. PRIORITY SIGTARP RECOMMENDATIONS Require Nevada to repay $8.2 million in unnecessary costs for gifts, employee parties, car payments, unneeded office space, etc. Remove Nevada contractor that wasted and abused $8.2 m in HHF (Potential cost savings of millions of dollars) PRIORITY SIGTARP RECOMMENDATIONS Prohibit state agencies from spending more of HHF funds to themselves than to homeowners in any one quarter Prohibit state agencies from spending HHF funds to pay themselves one dollar for every dollar they provide to homeowners in any one quarter High rate of withdrawn HHF applications: In July 2016, SIGTARP reported that the Nevada state agency had one of the worst rates of withdrawn HHF applications than any other state agency. Rather than deny Nevada workers who applied, 40% of people who applied and did not get admitted to the program saw their application withdrawn - a problem that SIGTARP raised in the July 2016 report.220 As of September 30, 2016, 5,831 (40% of those that applied for HHF help) people saw their application withdrawn, which is further evidence of inefficiency and mismanagement that needs improvement.221 Consequently, SIGTARP made the following recommendations that address this priority problem:222 SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 PRIORITY SIGTARP RECOMMENDATIONS Report separately people who withdraw their HHF application from applications withdrawn by the state agency Reduce percentage of withdrawn HHF applications to a targeted level and measure progress Streamline lengthy application processing times: The state agency withdraws a person’s application if it has taken too much time to complete, which may be evidence of an inefficient process (such as overly complex or confusing process or burdensome document requirements) that can be improved, or mismanagement.223 66 to 128 days TO PROCESS HHF APPLICATION AND PROVIDE ASSISTANCE Many cannot withstand a lengthy delay Eliminate unnecessary criteria: In its January 2017 report, SIGTARP recommended that state agencies eliminate unnecessary program criteria. This includes: (1) criteria that does not exist for homeowners in other states for these same Federal dollars, and (2) criteria that does not reflect the reality of Nevada workers.224 Ongoing audit work on HHF in Nevada: Based on concerns raised by Congressman Dina Titus, in October 2016, SIGTARP initiated a second audit into spending at HHF Nevada. Program Performance Figures 3.49 and 3.50 show the performance of HHF Nevada Unemployment and Related Programs, as of September 30, 2016. 163 164 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM FIGURE 3.49 HHF NEVADA HOMEOWNER PROGRAMS’ PERFORMANCE, UNEMPLOYMENT AND RELATED PROGRAMS, AS OF 6/30/2016 25,000 As of 6/30/2016: Homeowner Applications: 14,591 Homeowners Helped: 5,397 Homeowner Admission Rate: 37% 20,000 15,000 10,000 5,000 0 Q1 Q2 Q3 Q4 Q1 2010 Q2 Q3 Q4 2011 Estimated Homeowners to be Helped Q1 Q2 Q3 Q4 Q1 2012 Q2 Q3 2013 Q4 Q1 Q2 Q3 2014 Q4 Q1 Q2 Q3 Q4 2015 Q1 Q2 2016 Homeowners Assisted Applying Homeowner Notes: Nevada data is as of 6/30/2016, as the third quarter performance report is not yet available. Estimated includes highest estimate of a range. Applications are the total number of applicant homeowners, which Treasury began reporting as of Q3 2012. Homeowner Admission Rate is cumulative Homeowners Assisted as a percent of homeowners who applied. Sources: Treasury and Nevada Affordable Housing Assistance Corporation, Commitment to Purchase Financial Instrument and HFA Participation Agreement, 6/23/2010, and Amendments to Agreement one through seventeen, as of 6/30/2016; Nevada Affordable Housing Assistance Corporation, Quarterly Performance Reports Q1 2011 – Q2 2016, no date; Treasury, HFA Aggregate Reports Q3 2012 – Q2 2016, no date. 165 SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 FIGURE 3.50 HHF NEVADA PROGRAM PERFORMANCE, AS OF 6/30/2016 SECOND MORTGAGE REDUCTION PLAN (SECOND-LIEN REDUCTION)–JUNE 2010 PRINCIPAL REDUCTION PROGRAM (MODIFICATION)– As of 6/30/2016: JUNE 2010 Estimate: 2,783 (Peak: 3,016) Homeowner Applications: 3,237 Homeowners Helped: 1,263 Homeowner Admission Rate: 39% 4,000 3,000 As of 6/30/2016: Estimate: 1,300 (Peak: 2,200) Homeowner Applications: 1,780 Homeowners Helped: 437 Homeowner Admission Rate: 25% 3,000 2,500 2,000 1,500 2,000 1,000 1,000 500 0 0 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 2010 2011 2012 2013 Estimated Homeowners to be Helped 2014 2015 2010 2016 2011 2012 2013 Estimated Homeowners to be Helped Homeowners Helped 2014 2015 2016 Homeowners Helped Homeowner Applications Homeowner Applications SHORT-SALE ACCELERATION PROGRAM (TRANSITION)–JUNE 2010 2,000 MORTGAGE ASSISTANCE PROGRAM (UNEMPLOYMENT)–SEPTEMBER 2010 20,000 As of 6/30/2016: Estimate: 100 (Peak: 1,713) Homeowner Applications: 394 Homeowners Helped: 104 Homeowner Admission Rate: 26% 1,500 1,000 As of 6/30/2016: Estimate: 3,900 (Peak: 16,969) Homeowner Applications: 9,911 Homeowners Helped: 3,711 Homeowner Admission Rate: 37% 15,000 10,000 500 5,000 0 0 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 2010 2011 2012 2013 Estimated Homeowners to be Helped 2014 2015 2016 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 2010 2011 2012 2013 Estimated Homeowners to be Helped Homeowners Helped Homeowner Applications 2014 2015 2016 Homeowners Helped Homeowner Applications MORTGAGE ASSISTANCE PROGRAM ALTERNATIVE (UNEMPLOYMENT)–FEBRUARY 2012 500 375 250 125 As of 6/30/2016: Estimate: 176 (Peak: 416) Homeowner Applications: 236 Homeowners Helped: 226 Homeowner Admission Rate: 96% 0 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 2010 2011 2012 2013 Estimated Homeowners to be Helped 2014 2015 2016 Homeowners Helped Homeowner Applications Notes: Nevada data is as of 6/30/2016, as the third quarter performance report is not yet available. Estimated includes highest estimate of a range. Applications are the total number of applicant homeowners, which Treasury began reporting as of Q3 2012. Homeowner Admission Rate is cumulative Homeowners Assisted as a percent of homeowners who applied. Sources: Treasury and Nevada Affordable Housing Assistance Corporation, Commitment to Purchase Financial Instrument and HFA Participation Agreement, 6/23/2010, and Amendments to Agreement one through seventeen, as of 6/30/2016; Nevada Affordable Housing Assistance Corporation, Quarterly Performance Reports Q1 2011 – Q2 2016, no date. 166 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM HHF in New Jersey There remains a critical need for HHF’s stop-gap unemployment bridge to help save the homes of New Jersey workers who lost their job or saw their paycheck cut, while they look for a full time job in New Jersey. Last year 16,305 New Jersey homeowners lost their home to foreclosure, another 104,641 New Jersey homeowners are behind on their mortgage, and 170,392 owe more than their home is worth.225 The unemployment rate in New Jersey is 5% making it one of states with above average unemployment.226 Despite this critical need for HHF, SIGTARP has repeatedly identified the New Jersey state agency as inefficient, despite being paid $25.8 million by Treasury as its conduit to distribute these Federal dollars.227 The New Jersey state agency has not been effective in distributing these Federal dollars to New Jersey workers for the Unemployment Bridge and related programs. For example: • In 6 years, HHF has helped only 6,156 New Jersey homeowners, fewer than half who applied • 37% of the TARP funds set aside for New Jersey has not been spent • The state agency denied 55% of workers who sought help in New Jersey – (7,765 of 14,163) workers – one of highest denial rates in HHF states as of September 30, 2016 • The state agency only admitted 15% (151 of the 976) who applied for help over the last year, among the very lowest of the HHF states during that period • The state agency denied more than 8 out of 10 workers (82%) (800 of 976) workers seeking help last year, the highest denial rate of all 19 states. • New Jersey workers had to wait 163 days to get HHF assistance228 Hardest Hit Fund – Use of Funds in New Jersey and Status of New Jersey Workers Most of New Jersey’s spending went to help homeowners. However, only 6,156 workers were actually helped by the program.229 See Figures 3.51 and 3.52 for more details. SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 FIGURE 3.51 FIGURE 3.52 HARDEST HIT FUND – USE OF FUNDS IN NEW JERSEY, STATUS OF NEW JERSEY WORKERS THAT APPLIED TO HHF, AS OF 9/30/2016 6% 37% AS OF 9/30/2016 1% 57% 43% 1% 55% TARP Dollars to State Agency ($25,831,308) Workers Helped (6,156) Unspent ($153,967,283) Workers Denied (7,765) Unemployment Bridge and Related Assistance ($239,954,893) Workers with Withdrawn Applications (146) Note: Funds include $415.1 million allocated from Treasury plus remittances of $4.6 million. Workers In Process (96) Sources: Treasury, HFA Aggregate Report Q3 2016; New Jersey Housing and Mortgage Finance Agency, Quarterly Performance Report Q3 2016, no date. Source: Treasury, response to SIGTARP data call, 1/17/2017. HIGH RISK AREAS Low number of workers admitted to the HHF in New Jersey: In July 2016, SIGTARP reported that the New Jersey state agency only admitted 44% of the workers who applied.230 In the past year, that number dropped as only 15% of workers whose applications were processed over the past year were admitted.231 SIGTARP made several recommendations that, if implemented, would help ensure effective distribution of HHF dollars. Eliminate unnecessary program criteria: With more than half of all workers seeking help from the New Jersey state agency being denied assistance, there is room to improve the HHF program in New Jersey.232 In its January, 2017 audit report, SIGTARP recommended that state agencies eliminate unnecessary program criteria. This includes: (1) criteria that does not exist for homeowners in other states for these same Federal dollars, and (2) criteria that does not reflect the reality of New Jersey workers.233 Streamline lengthy application process: A person seeking help from the New Jersey agency administering HHF may face lengthy wait times to determine if they are eligible to receive that help. Some people cannot withstand such delays.234 167 168 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM 188 days TO PROCESS HHF APPLICATION AND PROVIDE ASSISTANCE Many cannot withstand a lengthy delay Program Performance Figures 3.53 and 3.54 show the performance of HHF New Jersey Unemployment and Related Programs, as of September 30, 2016. FIGURE 3.53 HHF NEW JERSEY HOMEOWNER PROGRAMS’ PERFORMANCE, UNEMPLOYMENT AND RELATED PROGRAMS, AS OF 9/30/2016 15,000 As of 9/30/2016: Homeowner Applications: 14,163 Homeowners Helped: 6,156 Homeowner Admission Rate: 43% 12,000 9,000 6,000 3,000 0 Q1 Q2 Q3 Q4 Q1 2010 Q2 Q3 Q4 2011 Estimated Homeowners to be Helped Q1 Q2 Q3 Q4 Q1 2012 Q2 Q3 2013 Q4 Q1 Q2 Q3 2014 Q4 Q1 Q2 Q3 2015 Q4 Q1 Q2 2016 Homeowners Helped Applying Homeowners Notes: Estimated includes highest estimate of a range. Applications are the total number of application homeowners, which Treasury began reporting as of Q3 2012. Homeowner Admission Rate is cumulative Homeowners Assisted as a percent of homeowners who applied. Sources: Treasury and New Jersey Housing and Mortgage Finance Agency, Commitment to Purchase Financial Instrument and HFA Participation Agreement, 9/23/2010, Amendments to Agreement one through nine, as of 9/30/2016; New Jersey Housing and Mortgage Finance Agency, Quarterly Performance Reports Q3 2011 – Q3 2016, no date; Treasury, HFA Aggregate Reports Q3 2012 – Q3 2016, no date. Q3 SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 FIGURE 3.54 HHF NEW JERSEY PROGRAM PERFORMANCE, AS OF 9/30/2016 NEW JERSEY HOMEKEEPER PROGRAM (UNEMPLOYMENT ASSISTANCE) – SEPTMEBER 2010 14,000 12,000 10,000 8,000 6,000 4,000 2,000 0 As of 9/30/2016: Estimate: 8,600 (Peak: 8,600) Homeowner Applications: 13,093 Homeowners Helped: 6,005 Homeowner Admission Rate: 46% NEW JERSEY HOME SAVER PROGRAM (MODIFICATION) – MAY 2015 1,800 1,500 1,200 As of 9/30/2016: Estimate: 345 (Peak: 345) Homeowner Applications: 1,631 Homeowners Helped: 215 Homeowner Admission Rate: 13% 900 600 300 0 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 2010 2011 2012 2013 Estimated Homeowners to be Helped Homeowner Applications 2014 2015 Homeowners Helped 2016 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 2010 2011 2012 2013 Estimated Homeowners to be Helped 2014 2015 2016 Homeowners Helped Homeowner Applications Notes: Programs may have been started or ended at different times. Estimated includes highest estimate of a range. Homeowner Admission Rate is cumulative Homeowners Assisted as a percent of reported Homeowner Applications. Sources: Treasury and New Jersey Housing and Mortgage Finance Agency, Commitment to Purchase Financial Instrument and HFA Participation Agreement, 9/23/2010, Amendments to Agreement one through nine, as of 9/30/2016; New Jersey Housing and Mortgage Finance Agency, Quarterly Performance Reports Q3 2011 – Q3 2016, no date. 169 170 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM HHF in North Carolina There remains a critical need for HHF’s stop-gap unemployment bridge to help save the homes of North Carolina workers who lost their job or saw their paycheck cut, while they look for a full time job in North Carolina. Last year 14,698 North Carolina homeowners lost their home to foreclosure, another 84,567 North Carolina homeowners are behind on their mortgage, and 77,877 owe more than their home is worth, and 242,990 workers in North Carolina are currently unemployed.235 Despite this critical need for HHF, SIGTARP has identified issues with the North Carolina state agency’s administration of HHF, even after being paid more than $65.8 million by Treasury as its conduit to distribute these Federal dollars.236 The North Carolina state agency has not been the most efficient in distributing these Federal dollars to North Carolina workers. For example: • In 6 years, HHF has helped 22,897 North Carolina homeowners • Nearly one-third (10,754 people) of North Carolina workers who sought help did not receive it • 80% of the (6,559) homeowners denied help by the North Carolina state agency administering HHF made less than $30,000 per yearxv • Two programs designed to help homeowners modify their loans and recast their monthly payments were closed without helping a single homeowner • One program, designed to help modify homeowners’ loans has only helped 4% of people it originally estimated to help – rather that help 800 people, the state agency estimates helping 50 people • Workers seeking help in North Carolina had to wait from 62 to 112 days to receive assistance237 Hardest Hit Fund – Use of Funds in North Carolina and Status of North Carolina Workers Most of North Carolina’s spending went to help homeowners. See Figures 3.55 and 3.56 for more details. xv Data as of June 30, 2016. See SIGTARP’s January 11, 2017, evaluation “Improving TARP’s Investment in American Workers”. SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 FIGURE 3.55 FIGURE 3.56 HARDEST HIT FUND – USE OF FUNDS IN NORTH CAROLINA, STATUS OF NORTH CAROLINA WORKERS THAT APPLIED TO HHF, AS OF 9/30/2016 AS OF 9/30/2016 1% 2% 13% 9% 34% 55% 67% 18% TARP Dollars to State Agency ($65,768,901) Workers Helped (22,897) Homebuyer Assistance ($14,790,000) Workers Denied (6,310) Unspent ($242,936,031) Workers with Withdrawn Applications (4,444) Unemployment Bridge and Related Assistance ($394,822,317) Workers In Process (502) Note: Funds include $706.5 million allocated from Treasury plus remittances of $11.8 million. Sources: Treasury, HFA Aggregate Report Q3 2016; North Carolina Housing Finance Agency, Quarterly Performance Report Q3 2016, no date. Source: Treasury, response to SIGTARP data call, 1/17/2017. HIGH RISK AREAS Eliminate unnecessary criteria: In its January 2017 report, SIGTARP recommended that state agencies eliminate unnecessary program criteria. This includes: (1) criteria that does not exist for homeowners in other states for these same Federal dollars, and (2) criteria that does not reflect the reality of North Carolina workers.238 Protect TARP-Funded Homebuyer Assistance Program from Fraud, Waste and Abuse The North Carolina state agency has provided assistance to 77% (979) first-time homebuyers who applied for HHF down payment assistance, paying up to $15,000 to a homebuyer.239 In 2015, SIGTARP made a series of recommendations to prevent fraud that remain unimplemented. Among these were requiring detailed reporting on who was receiving these dollars, whether they were buying the house in a non-arms-length transaction, and whether there was commingling with state down payment assistance dollars and the buyer certifying that they meet the eligibility requirements. We also recommend that state agencies conduct background checks to determine if an applicant was convicted of a crime of dishonesty. Implementing these recommendations can save the government $48 million program wide, based on the average 10% of fraud in government programs.240 171 172 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM Program Performance Figures 3.57and 3.58 show the performance of HHF North Carolina Unemployment and Related Programs, as of September 30, 2016. FIGURE 3.57 HHF NORTH CAROLINA HOMEOWNER PROGRAMS’ PERFORMANCE, UNEMPLOYMENT AND RELATED PROGRAMS, AS OF 9/30/2016 35,000 As of 9/30/2016: Homeowner Applications: 34,153 Homeowners Helped: 22,897 Homeowner Admission Rate: 67% 30,000 25,000 20,000 15,000 10,000 5,000 0 Q1 Q2 Q3 Q4 Q1 2010 Q2 Q3 Q4 2011 Estimated Homeowners to be Helped Q1 Q2 Q3 Q4 Q1 2012 Q2 Q3 2013 Q4 Q1 Q2 Q3 2014 Q4 Q1 Q2 Q3 2015 Q4 Q1 Q2 2016 Homeowners Helped Applying Homeowners Notes: Estimated includes highest estimate of a range. Applications are the total number of applicant homeowners, which Treasury began reporting as of Q3 2012. Homeowner Admission Rate is cumulative Homeowners Assisted as a percent of homeowners who applied. Sources: Treasury and North Carolina Housing Finance Agency, Commitment to Purchase Financial Instrument and HFA Participation Agreement, 8/23/2010, and Amendments to Agreement one through fourteen, as of 9/30/2016; North Carolina Housing Finance Agency, Quarterly Performance Reports Q3 2010 – Q3 2016, no date; Treasury, HFA Aggregate Reports Q3 2012 – Q3 2016, no date. Q3 SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 FIGURE 3.58 HHF NORTH CAROLINA PROGRAM PERFORMANCE, AS OF 9/30/2016 MORTGAGE PAYMENT PROGRAM-2 (UNEMPLOYMENT) – SEPTEMBER 2010 MORTGAGE PAYMENT PROGRAM-1 (UNEMPLOYMENT) – SEPTEMBER 2010 12,000 10,000 8,000 As of 9/30/2016: Estimate: 8,868 (Peak: 8,868) Homeowner Applications: 13,749 Homeowners Helped: 7,198 Homeowner Admission Rate: 52% As of 9/30/2016: Estimate: 13,869 (Peak: 14,100) Homeowner Applications: 23,642 Homeowners Helped: 15,470 Homeowner Admission Rate: 65% 24,000 20,000 16,000 6,000 12,000 4,000 8,000 2,000 4,000 0 0 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 2010 2011 2012 2013 Estimated Homeowners to be Helped 2014 2015 2010 2016 SECOND MORTGAGE REFINANCE PROGRAM (SECOND-LIEN REDUCTION) – SEPTEMBER 2010 2,000 2013 2014 2015 2016 Homeowners Helped MODIFICATION ENABLING PILOT PROJECT (MODIFICATION) – DECEMBER 2013 As of 9/30/2016: Estimate: 282 (Peak: 2,000) Homeowner Applications: 411 Homeowners Helped: 198 Homeowner Admission Rate: 48% 3,000 2012 Homeowner Applications Homeowner Applications 4,000 2011 Estimated Homeowners to be Helped Homeowners Helped 1,000 As of 9/30/2016: Estimate: 50 (Peak: 800) Homeowner Applications: 52 Homeowners Helped: 32 Homeowner Admission Rate: 62% 750 500 1,000 250 0 0 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 2010 2011 2012 2013 Estimated Homeowners to be Helped 2014 2015 2016 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 2010 2011 2012 2013 Estimated Homeowners to be Helped Homeowners Helped Homeowner Applications 2014 2015 2016 Homeowners Helped Homeowner Applications PRINCIPAL REDUCTION RECAST/LIEN EXTINGUISHMENT FOR UNAFFORDABLE MORTGAGES (MODIFICATION) – JUNE 2015 2,000 1,500 As of 9/30/2016: Estimate: 1,878 (Peak: 1,878) Homeowner Applications: 1,171 Homeowners Helped: 296 Homeowner Admission Rate: 25% 1,000 500 0 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 2010 2011 2012 2013 Estimated Homeowners to be Helped 2014 2015 2016 Homeowners Helped Homeowner Applications Notes: Programs may have been started or ended at different times. Estimated includes highest estimate of a range. Homeowner Admission Rate is cumulative Homeowners Assisted as a percent of reported Homeowner Applications. Sources: Treasury and North Carolina Housing Finance Agency, Commitment to Purchase Financial Instrument and HFA Participation Agreement, 8/23/2010, and Amendments to Agreement one through fourteen, as of 9/30/2016; North Carolina Housing Finance Agency, Quarterly Performance Reports Q3 2010 – Q3 2016, no date. 173 174 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM HHF in Ohio With the exception of the highly populated California and Florida, Ohio has the most dollars set aside by Treasury for HHF.241 There remains a critical need for HHF’s stop-gap unemployment bridge to help save the homes of Ohio workers who lost their job or saw their paycheck cut, while they look for a full time job in Ohio. GM recently announced layoffs of workers in Ohio. Last year 22,888 Ohio homeowners lost their home to foreclosure, another 90,205 Ohio homeowners are behind on their mortgage, and 201,750 owe more than their home is worth, while 278,216 workers are unemployed in Ohio.xvi,242 The Ohio state agency has done a better job than many other state agencies distributing these funds to homeowners, with Ohio homeowners exhausting all of the funds before additional money was allocated from Congress.243 However, even effective state agencies can improve. Give the critical need in Ohio, SIGTARP has identified some improvements to the efficiency of the Ohio state agency, who has been paid $51.6 million by Treasury as its conduit to distribute these Federal dollars.244 For example: • W hile the Ohio state agency assisted 24,533 Ohio homeowners with HHF, it has not helped nearly one out of every three people who applied • Of those not helped, 86% (4,133 workers) earned less than $30,000 per yearxvii • An HHF program to help homeowners refinance their homes ended without helping a single person; while another program designed to help homeowners with transition assistance only helped 75 homeowners over the last five years • Ohio workers seeking help from HHF had to wait up to 233 to 366 days before receiving assistance Hardest Hit Fund – Use of Funds in Ohio and Status of Ohio Workers Most of Ohio’s spending went to help homeowners.245 See Figures 3.59 and 3.60 for more details. xvi Ohio closed many of its homeowner support programs, as it transferred funds to demolition, but since then has begun to reopen these programs. xvii Data as of June 30, 2016. See SIGTARP’s January 11, 2017, evaluation “Improving TARP’s Investment in American Workers”. SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 FIGURE 3.59 FIGURE 3.60 HARDEST HIT FUND – USE OF FUNDS IN OHIO, AS OF 9/30/2016 STATUS OF OHIO WORKERS THAT APPLIED TO HHF, AS OF 9/30/2016 5.92% 6.73% 15% 31.64% 55.71% 14% 71% TARP Dollars to State Agency ($51,628,473) Workers Helped (24,533) Demolition ($45,459,801) Workers Denied (4,881) Unspent ($242,805,408) Workers with Withdrawn Applications (5,365) Unemployment Bridge and Related Assistance ($427,518,121) Workers In Process (0) Note: Funds include $762.3 million allocated from Treasury plus remittances of $5.1 million. Sources: Treasury, HFA Aggregate Report Q3 2016; Ohio Homeowner Assistance LLC, Quarterly Performance Report Q3 2016, no date. Source: Treasury, response to SIGTARP data call, 1/17/2017. Concerns raised by Representative Kaptur: In March, 2016, Representative Marcy Kaptur of Ohio’s 9th District sent a letter to President Obama, along with 10 other Congressmen, expressing concerns that HHF dollars were not being distributed effectively in their states. In July 2016, SIGTARP reported that in Lorain County, Ohio, part of which makes up the 9th District of Ohio, in the prior year 484 homeowners lost their home to foreclosure and 10,683 homeowners owe more than their home is worth, however, only 2 homeowners received HHF assistance during that same period.246 Congresswoman Kaptur’s concerns highlight the need for HHF in Ohio.247 SIGTARP January 2017 Report: SIGTARP reported that Ohio has one of the highest percentages or people turned down for HHF who earned less than $30,000 per year. In cities where General Motors or its suppliers closed plants or laid off workers, denial rates are even higher for those who made less than $30,000.248 175 176 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM FIGURE 3.61 HHF DENIALS FOR HOMEOWNERS MAKING LESS THAN $30,000 PER YEAR *Dayton OH includes nearby cities of Moraine and Vandalia. Source: SIGTARP, Audit Report “Improving TARP’s Investment in American Workers”, 1/11/2017, https://www.sigtarp.gov/Audit%20Reports/SIGTARP_HHF_Florida_Report.pdf, accessed 1/13/2017. In Cleveland and Dayton (including Moraine and Vandalia) 90% of workers who earned less than $30,000 per year were turned down for HHF help.249 Eliminate unnecessary program criteria: In its January, 2017, report, SIGTARP found that in Cleveland and Dayton, 90% of workers turned down for HHF earned less than $30,000 per year. In that report, SIGTARP recommended that state agencies eliminate unnecessary program criteria. This includes: (1) criteria that does not exist for homeowners in other states for these same Federal dollars, and (2) criteria that does not reflect the reality of Ohio workers.250 Streamline lengthy application process: A person seeking help from the Ohio agency administering HHF may face lengthy wait times to determine if they are eligible to receive that help. Some people cannot withstand such delays. Some of this delay may be applicable to exhausting the funds. SIGTARP will monitor wait times. 233 to 366 days TO PROCESS HHF APPLICATION AND PROVIDE ASSISTANCE251 Many cannot withstand a lengthy delay SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 TARP-Funded Demolition of Abandoned Houses in Ohio Communities The $238 million TARP-funded demolition program in Ohio, has demolished 3,422 abandoned houses using $45.5 million, since August 2013. This is the second highest number of demolitions in the HHF program.252 PRIORITY SIGTARP RECOMMENDATION Limit TARP reimbursement to demolition costs that are necessary and reasonable as exist in similar HUD and state-funded programs Risk of Overcharging, Waste and Fraud: In January, 2017, Treasury implemented SIGTARP’s recommendation to limit TARP reimbursement to necessary and reasonable costs.253 This is necessary because before Treasury paid up to $25,000 per demolished house (not limited to necessary and reasonable costs), which far exceeds the median cost of HHF demolition at $8,500 for demolition + $500 for greening the land. The average cost for the Ohio state agency to demolish a property is $13,285.254 Implementation of this recommendation could save thousands of dollars per house, up to $161 million program wide. SIGTARP has additional unimplemented recommendations that state agencies use best practices to determine necessary and reasonable costs. Risk of Unfair Competitive Practices that can drive up costs: In January, 2017, Treasury implemented SIGTARP’s recommendation to require full and open competition.255 However, SIGTARP has additional unimplemented recommendations that mirror HUD requirements to ensure full and open competition. The Ohio state agency contracts with local partners who receive TARP dollars (as shown in Table 3.13) and choose neighborhoods and specific houses for TARP-funded demolitions, and then hire contractors and subcontractors. Treasury does not conduct oversight over these local partners or their contractors. 177 178 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM TABLE 3.13 OHIO HHF BLIGHT ELIMINATION PROGRAM PARTNERS AND DEMOLITION ACTIVITY AS OF 9/3O/2016** Most Recent Quarter Cumulative Applications Submitted 703 3,591 Properties Demolished/Removed 699 3,422 Disbursements to Partners, Program to Dateb Demolished in Most Recent Quarter Demolished, Cumulative $876,794 18 51 $— 0 0 City/County Partner Ashtabula Ashtabula County Land Reutilization Corporation Belmont Belmont County Land Reutilization Corporation Butler Butler County Land Reutilization Corporation $530,574 23 31 Clark Clark County Land Reutilization Corporation $396,177 10 25 Columbiana Columbiana County Land Reutilization Corp. Cuyahoga Cuyahoga County Land Reutilization Corp. a $420,882 7 20 $18,769,811 198 1,426 Erie Erie County Land Reutilization Corporation $114,488 0 7 Fairfield Fairfield County Land Reutilization Corp. $294,245 4 17 Franklin Central Ohio Community Improvement Corporation $4,957,190 53 287 Hamilton Hamilton County Land Reutilization Corporation $1,996,200 46 90 Jefferson Jefferson County Land Reutilization Corporation $202,132 0 14 Lake Lake County Land Reutilization Corp. $396,866 2 22 Lorain Lorain County Land Reutilization Corporation $1,756,085 77 77 Lucas Lucas County Land Reutilization Corporation $6,580,764 106 666 Mahoning Mahoning County Land Reutilization Corp. $1,817,558 12 123 Montgomery Montgomery County Land Reutilization Corp. $3,017,265 51 145 Portage Portage County Land Reutilization Corporation $139,418 8 10 Richland Richland County Land Reutilization Corp. $624,790 14 41 Stark Stark County Land Reutilization Corp. $2,449,580 50 159 Summit Summit County Land Reutilization Corp. $1,439,083 5 73 Trumbull Trumbull County Land Reutilization Corp. $1,574,739 15 138 Ohio Homeowner Assistance LLC. b Ohio HFA response to SIGTARP data call. Due to reporting date differences, disbursement amounts may be more recent than demolition data. a ** Ohio Homeowner Assistance LLC, Save the Dream Ohio: Quarterly Reports, Quarterly Performance Report, Q3 2016, no date. SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 Each local partner hires contractors and subcontractors for demolition, site inspection, asbestos removal, greening and other activities. It is critical to ensure full and open competition in these contracts. Making oversight difficult is that there is no one source to identify contractors and subcontractors. SIGTARP is in the process of identifying contractors and subcontractors who receive TARP dollars for demolition. Identifying all participating in a TARP program and benefitting from TARP funds is crucial to protecting these Federal dollars from fraud, waste, and abuse. Program Performance Figures 3.62 and 3.63 show the performance of HHF Ohio Unemployment and Related Programs, as of September 30, 2016. FIGURE 3.62 HHF OHIO HOMEOWNER PROGRAMS’ PERFORMANCE, UNEMPLOYMENT AND RELATED PROGRAMS, AS OF 9/30/2016 80,000 70,000 60,000 50,000 As of 9/30/2016: Homeowner Applications: 34,779 Homeowners Helped: 24,533 Homeowner Admission Rate: 71% 40,000 30,000 20,000 10,000 0 Q1 Q2 Q3 Q4 Q1 2010 Q2 Q3 Q4 2011 Estimated Homeowners to be Helped Q1 Q2 Q3 Q4 Q1 2012 Q2 Q3 2013 Q4 Q1 Q2 Q3 2014 Q4 Q1 Q2 Q3 2015 Q4 Q1 Q2 2016 Homeowners Helped Applying Homeowners Notes: Estimated includes highest estimate of a range. Applications are the total number of applicant homeowners, which Treasury began reporting as of Q3 2012. Homeowner Admission Rate is cumulative Homeowners Assisted as a percent of homeowners who applied. Sources: Treasury and Ohio Homeowner Assistance LLC, Commitment to Purchase Financial Instrument and HFA Participation Agreement, 9/23/2010, and Amendments to Agreement one through twelve as of 9/30/2016; Ohio Homeowner Assistance LLC, Quarterly Performance Reports Q4 2010 – Q3 2016, no date; Treasury, HFA Aggregate Reports Q3 2012 – Q3 2016, no date. Q3 179 180 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM FIGURE 3.63 HHF OHIO PROGRAM PERFORMANCE, AS OF 9/30/2016 RESCUE PAYMENT ASSISTANCE PROGRAM (PAST-DUE PAYMENT) – SEPTEMBER 2010 MORTGAGE PAYMENT ASSISTANCE PROGRAM (UNEMPLOYMENT) – SEPTEMBER 2010 As of 9/30/2016: 30,000 Estimate: 23,000 (Peak: 23,000) Homeowner Applications: 27,624 25,000 Homeowners Helped: 20,256 20,000 Homeowner Admission Rate: 73% 30,000 15,000 20,000 10,000 10,000 5,000 0 0 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 2010 2011 2012 2013 Estimated Homeowners to be Helped 2014 2015 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 2016 2010 2,500 2,000 As of 9/30/2016: Estimate: 1,300 (Peak: 6,400) Homeowner Applications: 2,465 Homeowners Helped: 1,569 Homeowner Admission Rate: 64% 2015 2016 Homeowners Helped 1,500 1,000 500 0 0 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 2010 2011 2012 2013 Estimated Homeowners to be Helped 2014 2015 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 2016 2010 2011 2012 2013 Estimated Homeowners to be Helped Homeowners Helped Homeowner Applications 2014 2015 2016 Homeowners Helped Homeowner Applications HOMEOWNERSHIP RETENTION ASSISTANCE (PAST-DUE PAYMENT)–DECEMBER 2012 HOMEOWNERSHIP RETENTION ASSISTANCE (PAST-DUE PAYMENT)–DECEMBER 2012 4,000 2,000 2014 As of 9/30/2016: Estimate: 1,150 (Peak: 2,350) Homeowner Application: 1,662 Homeowners Helped: 1,210 Homeowner Admission Rate: 73% 3,000 6,000 3,000 2013 LIEN ELIMINATION ASSISTANCE (MODIFICATION) – SEPTEMBER 2010 7,500 1,500 2012 Homeowner Applications MODIFICATION WITH CONTRIBUTION ASSISTANCE PROGRAM (MODIFICATION) – DECEMBER 2011 3,000 2011 Estimated Homeowners to be Helped Homeowners Helped Homeowner Applications 4,500 As of 9/30/2016: Estimate: 17,000 (Peak: 31,900) Homeowner Applications: 18,461 Homeowners Helped: 14,882 Homeowner Admission Rate: 81% 40,000 4,000 As of 9/30/2016: Estimate: 1,738 (Peak: 3,100) Homeowner Applications: 2,380 Homeowners Helped: 1,929 Homeowner Admission Rate: 81% 3,000 2,000 1,000 As of 9/30/2016: Estimate: 1,738 (Peak: 3,100) Homeowner Applications: 2,380 Homeowners Helped: 1,929 Homeowner Admission Rate: 81% 1,000 0 0 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 2010 2011 2012 2013 Estimated Homeowners to be Helped Homeowner Applications 2014 2015 Homeowners Helped 2016 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 2010 2011 2012 2013 Estimated Homeowners to be Helped 2014 2015 2016 Homeowners Helped Homeowner Applications Notes: Programs may have been started or ended at different times. Estimated includes highest estimate of a range. Homeowner Admission Rate is cumulative Homeowners Assisted as a percent of reported Homeowner Applications. Sources: Treasury and Ohio Homeowner Assistance LLC, Commitment to Purchase Financial Instrument and HFA Participation Agreement, 9/23/2010, and Amendments to Agreement one through twelve as of 9/30/2016; Ohio Homeowner Assistance LLC, Quarterly Performance Reports Q4 2010 – Q3 2016, no date. SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 HHF in Oregon There remains a critical need for HHF’s stop-gap unemployment bridge to help save the homes of Oregon workers who lost their job or saw their paycheck cut, while they look for a full time job in Oregon. Last year 7,228 Oregon homeowners lost their home to foreclosure, another 22,290 Oregon homeowners are behind on their mortgage, and 16,612 owe more than their home is worth.256 The unemployment rate in Oregon is 5% making it one of the states with above average unemployment.257 Despite this critical need for HHF, SIGTARP has identified issues with HHF in Oregon, despite that the state agency was paid $36.8 million by Treasury as its conduit to distribute these Federal dollars.258 For example: • The Oregon state agency has admitted one in four (24%) of workers seeking assistance – (39 of the 164 workers whose applications were processed), in the past year • The Oregon state agency did not approve a single homeowner for the unemployment bridge program in the last year – while 103,994 people remain unemployed in Oregon • The Oregon state agency has not helped over 3 out of 4 (76%) of the 164 workers who’s applications were processed over the past year • 14,399 of the workers seeking help from HHF in Oregon’s have had their application withdrawn - 50% of all applications • Oregon homeowners receiving HHF assistance waited 135 to 162 days from application till receiving assistance, over the life of the program259 Hardest Hit Fund – Use of Funds in Oregon and Status of Oregon Workers Most of Oregon’s spending went to help homeowners.260 See Figures 3.64 and 3.65 for more details. 181 182 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM FIGURE 3.64 FIGURE 3.65 HARDEST HIT FUND – USE OF FUNDS IN OREGON, AS OF 9/30/2016 STATUS OF OREGON WORKERS THAT APPLIED TO HHF, AS OF 9/30/2016 1% 11% 30% 59% 41% 50% 8% TARP Dollars to State Agency ($36,796,694) Workers Helped (11,809) Unspent ($105,316,548) Workers Denied (2,196) Unemployment Bridge and Related Assistance ($204,158,734) Workers with Withdrawn Applications (14,399) Note: Funds include $314.6 million allocated from Treasury plus remittances of $31.7 million. Workers In Process (386) Sources: Treasury, HFA Aggregate Report Q3 2016; Oregon Affordable Housing Assistance Corporation, Quarterly Performance Report Q3 2016, no date. Source: Treasury, response to SIGTARP data call, 1/17/2017. HIGH RISK AREAS High rate of withdrawn HHF applications should be lowered: Oregon has second highest rate of withdrawn applications of 19 states. Rather than deny Oregon workers who applied and did not get admitted into the program saw their application withdrawn–14,391, (51%) a problem that SIGTARP raised in July 2016. As of September 30, 2016, 14,399, (50%) saw their application withdrawn, which may be further evidence of inefficiency that needs improvement. SIGTARP made the following recommendations to address this priority problem:261 PRIORITY SIGTARP RECOMMENDATIONS Report separately people who withdraw their HHF application from applications withdrawn by the state agency Reduce percentage of withdrawn HHF applications to a targeted level262 SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 135 to 162 days TO PROCESS HHF APPLICATION AND PROVIDE ASSISTANCE Many cannot withstand a lengthy delay Streamline lengthy application process: The state agency withdraws a person’s application if it has taken too much time to complete, which may be evidence of an inefficient process (such as overly complex or confusing process or burdensome document requirements) that can be improved, or mismanagement. Eliminate unnecessary criteria: In its January 2017 report, SIGTARP recommended that state agencies eliminate unnecessary program criteria. This includes: (1) criteria that does not exist for homeowners in other states for these same Federal dollars, and (2) criteria that does not reflect the reality of Oregon workers.263 Program Performance Figures 3.66 and 3.67 show the performance of HHF Oregon Unemployment and Related Programs, as of September 30, 2016. 183 184 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM FIGURE 3.66 HHF OREGON HOMEOWNER PROGRAMS’ PERFORMANCE, UNEMPLOYMENT AND RELATED PROGRAMS, AS OF 9/30/2016 30,000 As of 9/30/2016: Homeowner Applications: 28,790 Homeowners Helped: 11,809 Homeowner Admission Rate: 41% 25,000 20,000 15,000 10,000 5,000 0 Q1 Q2 Q3 Q4 Q1 2010 Q2 Q3 Q4 2011 Estimated Homeowners to be Helped Q1 Q2 Q3 Q4 Q1 2012 Q2 Q3 2013 Q4 Q1 Q2 Q3 2014 Q4 Q1 Q2 Q3 2015 Q4 Q1 Q2 2016 Homeowners Helped Applying Homeowners Notes: Estimated includes highest estimate of a range. Applications are the total number of applicant homeowners, which Treasury began reporting as of Q3 2012. Homeowner Admission Rate is cumulative Homeowners Assisted as a percent of homeowners who applied. Sources: Treasury and Oregon Affordable Housing Assistance Corporation, Commitment to Purchase Financial Instrument and HFA Participation Agreement, 8/3/2010, and Amendments to Agreement one through eighteen, as of 9/30/2016; Oregon Affordable Housing Assistance Corporation, Quarterly Performance Reports Q2 2011 – Q3 2016, no date; Treasury, HFA Aggregate Reports Q3 2012 – Q3 2016, no date. Q3 SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 FIGURE 3.67 HHF OREGON PROGRAM PERFORMANCE, AS OF 9/30/2016 MORTGAGE PAYMENT ASSISTANCE PROGRAM (UNEMPLOYMENT) – SEPTEMBER 2010 30,000 24,000 LOAN PRESERVATION ASSISTANCE PROGRAM (PAST-DUE PAYMENT) – SEPTEMBER 2010 As of 9/30/2016: Estimate: 13,400 (Peak: 13,400) Homeowner Applications: 26,499 Homeowners Helped: 11,262 Homeowner Admission Rate: 42% 15,000 12,000 18,000 9,000 12,000 6,000 6,000 3,000 0 0 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 2010 2011 2012 2013 Estimated Homeowners to be Helped 2014 2015 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 2016 2010 600 2012 2013 2014 2015 2016 Homeowners Helped Homeowner Applications LOAN REFINANCE ASSISTANCE PROGRAM (MODIFICATION) – MARCH 2011 800 2011 Estimated Homeowners to be Helped Homeowners Helped Homeowner Applications 1,000 As of 9/30/2016: Estimate: 8,900 (Peak: 8,900) Homeowner Applications: 13,785 Homeowners Helped: 4,341 Homeowner Admission Rate: 31% REBUILDING AMERICAN HOMEOWNERSHIP ASSISTANCE PILOT PROJECT (MODIFICATION) – FEBRUARY 2013 As of 9/30/2016: Estimate: 200 (Peak: 330) Homeowner Applications: 859 Homeowners Helped: 225 Homeowner Admission Rate: 26% 300 250 200 150 400 100 200 50 0 As of 9/30/2016: Estimate: 50 (Peak: 50) Homeowner Applications: 289 Homeowners Helped: 73 Homeowner Admission Rate: 25% 0 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 2010 2011 2012 2013 Estimated Homeowners to be Helped Homeowner Applications 2014 2015 Homeowners Helped 2016 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 2010 2011 2012 2013 Estimated Homeowners to be Helped 2014 2015 2016 Homeowners Helped Homeowner Applications Notes: Programs may have been started or ended at different times. Estimated includes highest estimate of a range. Homeowner Admission Rate is cumulative Homeowners Assisted as a percent of reported Homeowner Applications. Sources: Treasury and Oregon Affordable Housing Assistance Corporation, Commitment to Purchase Financial Instrument and HFA Participation Agreement, 8/3/2010, and Amendments to Agreement one through eighteen, as of 9/30/2016; Oregon Affordable Housing Assistance Corporation, Quarterly Performance Reports Q2 2011 – Q3 2016, no date. 185 186 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM HHF in Rhode Island There remains a critical need for HHF’s stop-gap unemployment bridge to help save the homes of Rhode Island workers who lost their job or saw their paycheck cut, while they look for a full time job in Rhode Island. Last year 1,622 Rhode Island homeowners lost their home to foreclosure, another 8,404 Rhode Island homeowners are behind on their mortgage, and 24,109 owe more than their home is worth.264 The unemployment rate in Rhode Island is 5.3% making it one of the states with above average unemployment.265 Despite this critical need for HHF, SIGTARP has identified issues with the administration of HHF in Rhode Island, despite that the Rhode Island state agency was paid almost $10 million by Treasury as its conduit to distribute these Federal dollars.266 For example: • In 6 years, HHF, has helped only 3,075 Rhode Island homeowners • The Rhode Island state agency lowered the number of workers it estimated helping with HHF by 68%, from 13,125 at the start of the program to just 4,164 as of September 30, 2016 • The Rhode Island state agency did not approve a single worker for unemployment bridge assistance in the past year, while there are currently 29,231 unemployed Rhode Island workers • Rhode Island homeowners receiving HHF assistance waited 118 to 223 days from application to receive that assistance • The state agency did not help more than a third (35.9%) of workers seeking assistance • A transition assistance program only helped 65 people • The Rhode Island state agency only helped one in three (32%) workers seeking assistance to buy a home267 Hardest Hit Fund – Use of Funds in Rhode Island and Status of Rhode Island Workers Most of Rhode Island’s spending went to help homeowners.268 See Figures 3.68 and 3.69 for more details. SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 FIGURE 3.68 FIGURE 3.69 HARDEST HIT FUND – USE OF FUNDS IN RHODE ISLAND, STATUS OF RHODE ISLAND WORKERS THAT APPLIED TO HHF, AS OF 9/30/2016 AS OF 9/30/2016 2% 2% 7% 8% 35% 29% 55% 62% TARP Dollars to State Agency ($9,724,815) Workers Helped (3,075) Homebuyer Assistance ($1,960,000) Workers Denied (1,447) Unspent ($40,929,946) Workers with Withdrawn Applications (322) Unemployment Bridge and Related Assistance ($64,804,828) Workers In Process (77) Note: Funds include $116 million allocated from Treasury plus remittances of $1.4 million. Source: Treasury, response to SIGTARP data call, 1/17/2017. Sources: Treasury, HFA Aggregate Report Q3 2016; Rhode Island Housing and Mortgage Finance Corporation, Quarterly Performance Report Q3 2016, no date. HIGH RISK AREAS Streamline the lengthy application process: A lengthy wait period may be evidence of an inefficient process (such as overly complex or confusing process or burdensome document requirements) that can be improved, or mismanagement. 118 to 223 days TO PROCESS HHF APPLICATION AND PROVIDE ASSISTANCE269 Many cannot withstand a lengthy delay Eliminate unnecessary criteria: In its January 2017 report, SIGTARP recommended that state agencies eliminate unnecessary program criteria. This includes: (1) criteria that does not exist for homeowners in other states for these same Federal dollars, and (2) criteria that does not reflect the reality of Rhode Island workers.270 Protect TARP-Funded Homebuyer Assistance Program from Fraud, Waste and Abuse The Rhode Island state agency has the lowest rate of all HHF states that provide assistance to homebuyers, with just 32% of first-time homebuyers receiving 187 188 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM help. The Rhode Island state agency paid up to $20,000 to a homebuyer.271 In 2015, SIGTARP made a series of recommendations to prevent fraud that remain unimplemented. Among these were requiring detailed reporting on who was receiving these dollars, whether they were buying the house in a nonarms-length transaction, and whether there was commingling with state down payment assistance dollars, and the buyer certifying that they meet the eligibility requirements. We also recommend that state agencies conduct background checks to determine if an applicant was convicted of a crime of dishonesty. Implementing these recommendations can save the government $48 million program wide, based on the average 10% of fraud in government programs.272 Program Performance Figures 3.70 and 3.71 show the performance of HHF Rhode Island Unemployment and Related Programs, as of September 30, 2016. FIGURE 3.70 HHF RHODE ISLAND HOMEOWNER PROGRAMS’ PERFORMANCE, UNEMPLOYMENT AND RELATED PROGRAMS, AS OF 9/30/2016 15,000 As of 9/30/2016: Homeowner Applications: 4,921 Homeowners Helped: 3,075 Homeowner Admission Rate: 62% 12,000 9,000 6,000 3,000 0 Q1 Q2 Q3 Q4 Q1 2010 Q2 Q3 Q4 2011 Estimated Homeowners to be Helped Q1 Q2 Q3 Q4 Q1 2012 Q2 Q3 2013 Q4 Q1 Q2 Q3 2014 Q4 Q1 Q2 Q3 2015 Q4 Q1 Q2 2016 Homeowners Helped Applying Homeowners Notes: Estimated includes highest estimate of a range. Applications are the total number of applicant homeowners, which Treasury began reporting as of Q3 2012. Homeowner Admission Rate is cumulative Homeowners Assisted as a percent of Homeowners who applied. Sources: Treasury and Rhode Island Housing and Mortgage Finance Corporation, Commitment to Purchase Financial Instrument and HFA Participation Agreement, 8/3/2010, and Amendments to Agreement one through eleven, as of 9/30/2016; Rhode Island Housing and Mortgage Finance Corporation, Quarterly Performance Reports Q4 2010 – Q3 2016, no date; Treasury, HFA Aggregate Reports Q3 2012 – Q3 2016, no date. Q3 SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 FIGURE 3.71 HHF RHODE ISLAND PROGRAM PERFORMANCE, AS OF 9/30/2016 LOAN MODIFICATION ASSISTANCE PROGRAM (MODIFICATION) – SEPTEMBER 2010 3,500 TEMPORARY AND IMMEDIATE HOMEOWNER ASSISTANCE (PAST-DUE PAYMENT) – SEPTEMBER 2010 3,000 As of 9/30/2016: Estimate: 711 (Peak: 3,500) Homeowner Applications: 884 Homeowners Helped: 497 Homeowner Admission Rate: 56% 3,000 2,500 2,000 1,500 2,000 1,500 1,000 1,000 500 500 0 0 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 2010 2011 2012 2013 Estimated Homeowners to be Helped 2014 2015 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 2016 2010 100 25 2012 2013 2014 2015 2016 Homeowners Helped Homeowner Applications PRINCIPAL REDUCTION PROGRAM (MODIFICATION) – MAY 2011 50 2011 Estimated Homeowners to be Helped Homeowners Helped Homeowner Applications 75 As of 9/30/2016: Estimate: 879 (Peak: 2,750) Homeowner Applications: 1,170 Homeowners Helped: 667 Homeowner Admission Rate: 57% 2,500 MORTGAGE PAYMENT ASSISTANCE – UNEMPLOYMENT (UNEMPLOYMENT) – SEPTEMBER 2010 As of 9/30/2016: Estimate: 2,454 (Peak: 6,000) Homeowner Applications: 3,143 Homeowners Helped: 2112 Homeowner Admission Rate: 67% 6,000 5,000 As of 9/30/2016: Estimate: 32 (Peak: 100) Homeowner Applications: 42 Homeowners Helped: 28 Homeowner Admission Rate: 67% 4,000 3,000 2,000 1,000 0 0 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 2010 2011 2012 2013 Estimated Homeowners to be Helped Homeowner Applications 2014 2015 Homeowners Helped 2016 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 2010 2011 2012 2013 Estimated Homeowners to be Helped 2014 2015 2016 Homeowners Helped Homeowner Applications Notes: Programs may have been started or ended at different times. Estimated includes highest estimate of a range. Homeowner Admission Rate is cumulative Homeowners Assisted as a percent of reported Homeowner Applications. Sources: Treasury and Rhode Island Housing and Mortgage Finance Corporation, Commitment to Purchase Financial Instrument and HFA Participation Agreement, 8/3/2010, and Amendments to Agreement one through eleven, as of 9/30/2016; Rhode Island Housing and Mortgage Finance Corporation, Quarterly Performance Reports Q4 2010 – Q3 2016, no date. 189 190 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM HHF in South Carolina There remains a critical need for HHF’s stop-gap unemployment bridge to help save the homes of South Carolina workers who lost their job or saw their paycheck cut, while they look for a full time job in South Carolina. Last year 7,162 South Carolina homeowners lost their home to foreclosure, another 44,515 South Carolina homeowners are behind on their mortgage, and 37,310 owe more than their home is worth.273 South Carolina has more than 102,075 unemployed workers, evidence that there is a critical need for HHF in South Carolina.274 SIGTARP has identified several issues with the efficiency of the South Carolina state agency, despite the South Carolina agency being paid $33 million by Treasury.275 For example: • In 6 years, HHF in South Carolina has not helped more than half (55%) 14,464 of the 26,432, South Carolina homeowners seeking assistance • The state agency denied one of three (34%) 8,954 workers of the 26,432 seeking help, the 4th highest rate of denying homeowners of all 19 HHF states, in the past year • The state agency withdrew another 21% of the 5,510 workers who sought help through HHF • South Carolina homeowners waited 139 to 288 days from application to receiving assistance • Through September 2016, the state agency has helped just one in three people (34%) 11,458 homeowners, of the state’s peak estimate of helping 34,100 homeowners • Two HHF programs did not help a single homeowner, the Second Mortgage Assistance Program, and the HAMP Assistance Program, before closing in 2011 and 2013, respectively • A transition program only helped 326 people despite a peak estimate of 6,000 • After more than two years, only 60 abandoned houses have been demolished276 Hardest Hit Fund – Use of Funds in South Carolina and Status of South Carolina Workers Most of South Carolina’s spending went to help homeowners.277 See Figures 3.72 and 3.73 for more details. SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 FIGURE 3.72 FIGURE 3.73 HARDEST HIT FUND – USE OF FUNDS IN SOUTH CAROLINA, STATUS OF SOUTH CAROLINA WORKERS THAT APPLIED TO HHF, AS OF 9/30/2016 AS OF 9/30/2016 10.4% 2% 0.4% 21% 32.1% 43% 57.1% 34% TARP Dollars to State Agency ($33,352,844) Workers Helped (11,458) Demolition ($1,246,297) Workers Denied (8,954) Unspent ($102,613,671) Workers with Withdrawn Applications (5,510) Unemployment Bridge and Related Assistance ($182,480,600) Workers In Process (510) Note: Funds include $317.5 million allocated from Treasury plus remittances of $2.2 million. Sources: Treasury, HFA Aggregate Report Q3 2016; SC Housing Corp., Quarterly Performance Report Q3 2016, no date. Source: Treasury, response to SIGTARP data call, 1/17/2017. HIGH RISK AREAS Streamline lengthy application process: A lengthy delay may be evidence of an inefficient process (such as overly complex or confusing process or burdensome document requirements) that can be improved, or mismanagement. 139 to 288 days TO PROCESS HHF APPLICATION AND PROVIDE ASSISTANCE278 Many cannot withstand a lengthy delay Eliminate unnecessary criteria: In its January 2017 report, SIGTARP recommended that state agencies eliminate unnecessary program criteria. This includes: (1) criteria that does not exist for homeowners in other states for these same Federal dollars, and (2) criteria that does not reflect the reality of South Carolina workers.279 191 192 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM TARP-Funded Demolition of Abandoned Houses in South Carolina Communities The $35 million TARP-funded demolition program has not gotten off the ground in South Carolina. In more than two years, it has only demolished 60 abandoned houses, the second lowest rate of states in the blight demolition program using $1.2 million.280 PRIORITY SIGTARP RECOMMENDATION Limit TARP reimbursement to demolition costs that are necessary and reasonable as exist in similar HUD and state-funded programs281 Risk of Overcharging, Waste and Fraud: In January, 2017, Treasury implemented SIGTARP’s recommendation to require full and open competition.282 However, SIGTARP has additional unimplemented recommendations that mirror HUD requirements to ensure full and open competition. Treasury paid up to $35,000 per demolished house, which far exceeds the median cost of HHF demolition at $10,319 for demolition + $2,500 for greening the land. The average cost for the South Carolina state agency to demolish a property is $20,772.283 Implementation of this recommendation could save thousands of dollars per house, up to $161 million program wide. SIGTARP has made additional unimplemented recommendations that state agencies use best practices to determine necessary and reasonable costs. Risk of Unfair Competitive Practices that can drive up costs: In January 2017, Treasury implemented SIGTARP’s recommendation to require full and open competition.284 However, SIGTARP has additional unimplemented recommendations that mirror HUD requirements to ensure full and open competition in the execution of solicitation of contract awards. The South Carolina state agency contracts with local partners who to receive TARP dollars (as shown in Table 3.14) and choose neighborhoods and specific houses for TARP-funded demolitions, and then hire contractors and subcontractors. Treasury does not conduct oversight over these local partners or their contractors. 193 SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 TABLE 3.14 SOUTH CAROLINA HHF BLIGHT ELIMINATION PROGRAM PARTNERS AND DEMOLITION ACTIVITY AS OF 9/30/2016** Most Recent Quarter Cumulative 125 781 20 60 Demolished in Most Recent Quarter Demolished, Cumulative 0 0 0 0 0 0 1 3 0 3 0 0 Applications Submitted Properties Demolished/Removed City/County Aiken County Allendale County Anderson County Bamberg County Partnera Nehemiah Community Revitalization Corp. $— Second Baptist CDC $— Allendale County Alive $— Southeastern Housing Foundation $— Anderson Community Development Corp. $— Nehemiah Community Revitalization Corp. $— Pelzer Heritage Commission $— Southeastern Housing Foundation (Bamberg Co.) Blackville, CDC Barnwell County Charleston County $174,016 $— Southeastern Housing Foundation (Blackville) $82,155 Southeastern Housing Foundation (Williston) $40,984 City of North Charleston $— PASTORS, Inc. $— Sea Island Habitat for Humanity $— Chester County Not Available Chesterfield County Town of Cheraw Community Development Corp. Florence County $— 0 0 $420,060 12 12 Downtown Development Corporation $— 0 0 Allen Temple Community Economic Devt. Corp. $— 4 4 Genesis Homes Greenville County Disbursements to Partners, Program to Dateb $201,394 Greenville Revitalization Corp. $— Habitat for Humanity of Greenville County $— Homes of Hope, Inc. $— Nehemiah Community Revitalization Corp. Neighborhood Housing Corp. of Greenville, Inc. $— $33,178 United Housing Connections $— Greenwood County Greenwood Area Habitat for Humanity $— 0 0 Hampton County Southeastern Housing Foundation $— 0 0 Myrtle Beach Community Land Trust $— Grand Strand Housing & CDC $— 0 0 Habitat for Humanity of Horry County $— Kershaw County Santee-Lynches Regional Development Corp. $— 0 0 Lancaster County Not Available $— 0 0 Columbia Development Corporation $— 0 2 0 0 0 20 Horry County Richland County Columbia Housing Development Corporation Eau Claire Development Corporation Saluda County Christ Central Habitat for Humanity of Spartanburg, Inc Homes of Hope Spartanburg County Nehemiah Community Revitalization Corp. $141,226 $98,717 $— $14,229 $— $— Northside Development Group $235,043 Upstate Housing Partnership $117,239 Sumter County Santee-Lynches Regional Development Corp $607,298 2 14 Union County Not Available $— 0 0 Catawba Regional Development Corp. $— 1 2 York County a b Housing Development Corporation of Rock Hill $46,685 SC Housing Corp. South Carolina HFA response to SIGTARP data call. Due to reporting date differences, disbursement amounts may be more recent than demolition data. **SC Housing Corp., SC HELP, Reports, Quarterly Performance Reports, Q3 2016, no date. 194 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM Each local partner hires contractors and subcontractors for demolition, site inspection, asbestos removal, greening and other activities. It is critial to ensure competition in these contracts. Making oversight difficult is that there is no one source to identify contractors and subcontractors. SIGTARP is in the process of identifying contractors and subcontractors who receive TARP dollars for demolition. Identifying all participating in a TARP program and benefitting from TARP funds is crucial to protecting these Federal dollars from fraud, waste, and abuse. Program Performance Figures 3.74 and 3.75 show the performance of HHF South Carolina Unemployment and Related Programs, as of September 30, 2016. FIGURE 3.74 HHF SOUTH CAROLINA HOMEOWNER PROGRAMS’ PERFORMANCE, UNEMPLOYMENT AND RELATED PROGRAMS, AS OF 9/30/2016 35,000 As of 9/30/2016: Homeowner Applications: 26,432 Homeowners Helped: 11,458 Homeowner Admission Rate: 43% 30,000 25,000 20,000 15,000 10,000 5,000 0 Q1 Q2 Q3 Q4 Q1 2010 Q2 Q3 Q4 2011 Estimated Homeowners to be Helped Q1 Q2 Q3 Q4 Q1 2012 Q2 Q3 2013 Q4 Q1 Q2 Q3 2014 Q4 Q1 Q2 Q3 2015 Q4 Q1 Q2 2016 Homeowners Helped Applying Homeowners Notes: Estimated includes highest estimate of a range. Applications are the total number of applicant homeowners, which Treasury began reporting as of Q3 2012. Homeowner Admission Rate is cumulative Homeowners Assisted as a percent of homeowners who applied. Sources: Treasury and SC Housing Corp., Commitment to Purchase Financial Instrument and HFA Participation Agreement, 8/3/2010, Amendments to Agreement one through ten, as of 9/30/2016; SC Housing Corp., Quarterly Performance Reports Q1 2011 – Q3 2016, no date; Treasury, HFA Aggregate Reports Q3 2012 – Q3 2016, no date. Q3 SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 FIGURE 3.75 HHF SOUTH CAROLINA PROGRAM PERFORMANCE, AS OF 9/30/2016 MONTHLY PAYMENT ASSISTANCE PROGRAM (UNEMPLOYMENT) – SEPTEMBER 2010 18,000 15,000 12,000 9,000 DIRECT LOAN ASSISTANCE PROGRAM (PAST-DUE PAYMENT) – SEPTEMBER 2010 As of 9/30/2016: Estimate: 7,000 (Peak: 14,000) Homeowner Applications: 19,252 Homeowners Helped: 6,419 Homeowner Admission Rate: 33% 25,000 As of 9/30/2016: Estimate: 12,500 (Peak: 12,500) Homeowner Applications: 22,768 Homeowners Helped: 10,796 Homeowner Admission Rate: 47% 20,000 15,000 10,000 6,000 5,000 3,000 0 0 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 2010 2011 2012 2013 Estimated Homeowners to be Helped 2014 2015 2016 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 2010 2011 2012 2013 Estimated Homeowners to be Helped Homeowners Helped Homeowner Applications 2014 2015 2016 Homeowners Helped Homeowner Applications MODIFICATION ASSISTANCE PROGRAM (MODIFICATION) – OCTOBER 2013 4,000 As of 9/30/2016: Estimate: 550 (Peak: 3,500) Homeowner Applications: 267 Homeowners Helped: 249 Homeowner Admission Rate: 93% 3,000 2,000 1,000 0 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 2010 2011 2012 2013 Estimated Homeowners to be Helped 2014 2015 2016 Homeowners Helped Homeowner Applications Notes: Programs may have been started or ended at different times. Estimated includes highest estimate of a range. Homeowner Admission Rate is cumulative Homeowners Assisted as a percent of reported Homeowner Applications. Sources: Treasury and SC Housing Corp., Commitment to Purchase Financial Instrument and HFA Participation Agreement, 8/3/2010, Amendments to Agreement one through ten, as of 9/30/2016; SC Housing Corp., Quarterly Performance Reports Q1 2011 – Q3 2016, no date; Treasury, HFA Aggregate Reports Q3 2012 – Q3 2016, no date. 195 196 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM HHF in Tennessee There remains a critical need for HHF’s stop-gap unemployment bridge to help save the homes of Tennessee workers who lost their job or saw their paycheck cut, while they look for a full time job in Tennessee. Last year 11,592 Tennessee homeowners lost their home to foreclosure, another 55,140 Tennessee homeowners are behind on their mortgage, and 47,007 owe more than their home is worth.285 Tennessee has 151,907 unemployed people as of November 2016.286 Despite being paid almost $20 million by Treasury as its conduit to distribute these Federal dollars, the Tennessee state agency can improve efficiency.287 For example: • In 6 years, HHF has helped only 7,355 Tennessee homeowners • The state agency did not approve a single homeowner to help for the unemployment bridge program in the past year • The state agency has not helped one in five of those who applied (21.4%) • Three out of four (73%) of the 1,300 people denied assistance made less than $30,000 per yearxviii • The state agency stopped accepting applications, even though the state agency had only spent 65% of the TARP funds allocated to Tennessee, as of September 30, 2016 • The state agency estimates helping only half of the 13,500 homeowners, it originally estimated helping288 Hardest Hit Fund – Use of Funds in Tennessee and Status of Tennessee Workers Most of Tennessee’s spending went to help homeowners.289 See Figures 3.76 and 3.77 for more details. xviii Data as of June 30, 2016. See SIGTARP’s January 11, 2017, evaluation “Improving TARP’s Investment in American Workers”. SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 FIGURE 3.76 FIGURE 3.77 HARDEST HIT FUND – USE OF FUNDS IN TENNESSEE, STATUS OF TENNESSEE WORKERS THAT APPLIED TO HHF, AS OF 9/30/2016 AS OF 9/30/2016 6% 7% 14% 35% 59% 79% TARP Dollars to State Agency ($19,658,680) Workers Helped (7,355) Demolition ($0) Workers Denied (1,300) Unspent ($105,302,678) Workers with Withdrawn Applications (697) Unemployment Bridge and Related Assistance ($179,487,513) Workers In Process (0) Note: Funds include $302.1 million allocated from Treasury plus remittances of $2.4 million. Sources: Treasury, HFA Aggregate Report Q3 2016; Tennessee Housing Development Agency, Quarterly Performance Report Q3 2016, no date. Source: Treasury, response to SIGTARP data call, 1/17/2017. HIGH RISK AREAS Streamline the lengthy application process: The state agency withdraws a person’s application if it has taken too much time to complete, which may be evidence of an inefficient process (such as overly complex or confusing process or burdensome document requirements) that can be improved, and/or mismanagement. 121 days TO PROCESS HHF APPLICATION AND PROVIDE ASSISTANCE290 Many cannot withstand a lengthy delay TARP-Funded Demolition of Abandoned Houses in Tennessee Communities The $10 million TARP-funded demolition program has not gotten off the ground in Tennessee.291 After more than one year, the Tennessee state agency has not demolished any vacant and abandoned houses. 197 198 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM PRIORITY SIGTARP RECOMMENDATIONS Limit TARP reimbursement to demolition costs that are necessary and reasonable as exist in similar HUD and state-funded programs Require full and open competition and other competition requirements that exist in similar HUD program 292 Risk of Overcharging, Waste and Fraud: In January 2017, Treasury implemented SIGTARP’s recommendation to require full and open competition.293 However, SIGTARP has additional unimplemented recommendations that mirror HUD requirements to ensure full and open competition. While Tennessee has not demolished any properties yet, Treasury will pay up to $25,000 per demolished house, which far exceeds the median cost of HHF demolitions in most states of under $14,000. Implementation of this recommendation could save thousands of dollars per house, up to $161 million program wide.294 SIGTARP has made additional unimplemented recommendations that state agencies use best practices to determine necessary and reasonable costs. Risk of Unfair Competitive Practices that can drive up costs: In January 2017, Treasury implemented SIGTARP’s recommendation to require full and open competition.295 However, SIGTARP has additional unimplemented recommendations that mirror HUD requirements to ensure full and open competition in the execution of solicitation of contract awards. The Tennessee state agency has contracted with several local partners that receive TARP dollars, as shown in Table 3.15, to receive TARP funds, choose neighborhoods and specific houses for TARP-funded demolitions, and hire contractors and subcontractors. Treasury does not conduct oversight over these partners or their contractors. 199 SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 TABLE 3.15 TENNESSEE HHF BLIGHT ELIMINATION PROGRAM PARTNERS AND DEMOLITION ACTIVITY AS OF 9/30/2016** Most Recent Quarter Cumulative Applications Submitted 0 8 Properties Demolished/Removed 0 0 Disbursements to Partners, Program to Dateb Demolished in Most Demolished, Recent Quarter Cumulative City/County Partnera Anderson County Oak Ridge Land Bank $— 0 0 Davidson County — $— 0 0 Hamilton County Chattanooga Neighborhood Enterprise $14,975 0 0 Knox County — $— 0 0 Montgomery County — $— 0 0 Rutherford County — $— 0 0 0 0 Shelby County Jacobs Ladder CDC $42,538 United Housing, Inc. $14,702 Healthy Transitions Development Group, Inc. a b $— Tennessee Housing Development Agency. Tennessee HFA response to SIGTARP data call. Due to reporting date differences, disbursement amounts may be more recent than demolition data. ** Tennessee Housing Development Agency, Treasury Reports, Quarterly Performance Report, Q3 2016, no date. Each local partner hires contractors and subcontractors for demolition, site inspection, asbestos removal, greening and other activities. It is critical to ensure full and open competition in these contracts. Making oversight difficult is that there is no one source to identify contractors and subcontractors. SIGTARP is in the process of identifying contractors and subcontractors. Identifying all participating in a TARP program and benefitting from TARP funds is crucial to protecting these Federal dollars from fraud, waste, and abuse. Tennessee Home Buyer Assistance Program Tennessee has recently shifted $60 million in HHF funds from homeowners to homebuyers.296 Program Performance Figure 3.78 shows the performance of HHF Tennessee’s Unemployment Program, as of September 30, 2016. 200 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM FIGURE 3.78 HHF TENNESSEE HOMEOWNER PROGRAM PERFORMANCE, UNEMPLOYMENT PROGRAM, AS OF 9/30/2016 15,000 12,000 9,000 As of 9/30/2016: Homeowner Applications: 9,352 Homeowners Helped: 7,355 Homeowner Admission Rate: 79% 6,000 3,000 0 Q1 Q2 Q3 Q4 Q1 2010 Q2 Q3 Q4 2011 Estimated Homeowners to be Helped Q1 Q2 Q3 Q4 Q1 2012 Q2 Q3 2013 Q4 Q1 Q2 Q3 2014 Q4 Q1 Q2 Q3 Q4 Q1 2015 Q2 2016 Homeowners Helped Homeowner Applications Notes: Estimated includes highest estimate of a range. Applications are the total number of applicant homeowners, which Treasury began reporting as of Q3 2012. Homeowner Admission Rate is cumulative Homeowners Assisted as a percent of homeowners who applied. Sources: Treasury and Tennessee Housing Development Agency, Commitment to Purchase Financial Instrument and HFA Participation Agreement, 9/23/2010, and Amendments to Agreement one through eleven, as of 9/30/2016; Tennessee Housing Development Agency, Quarterly Performance Reports Q1 2011 – Q3 2016, no date; Treasury, HFA Aggregate Reports Q3 2012 – Q3 2016, no date. Q3 SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 HHF in Washington, DC There is a critical need for HHF’s unemployment bridge to help struggling workers in Washington, DC who lost their job or saw their paycheck cut, while they look for a full-time job in Washington, DC. Last year in Washington, DC, 226 homeowners lost their home to foreclosure, another 5,157 Washington, DC homeowners are behind on their mortgage, and 3,834 currently owe more than their home is worth.297 However, Washington, DC has an unemployment rate of 6%, one of the states with the highest unemployment.298 The District of Columbia state agency has not been as efficient in distributing these Federal dollars, despite being paid $3.7 million by Treasury. For example: • In 6 years, HHF has helped only 709 homeowners299 • The state agency only admitted 4 homeowners for HHF assistance last year, despite that 23,843 Washington, DC residents were unemployed as of November 2016 • 77% of the 138 homeowners denied assistance made less than $30,000 per yearxix • 41% of the TARP funds provided to the state agency have not been spent300 Hardest Hit Fund – Use of Funds in Washington, DC and Status of Washington, DC Workers Most of Washington, DC’s spending, (79%) went to help homeowners.301 See Figures 3.79 and 3.80 for more details. xix Data as of June 30, 2016. See SIGTARP’s January 11, 2017, evaluation “Improving TARP’s Investment in American Workers”. 201 202 SPECIAL INSPECTOR GENERAL I TROUBLED ASSET RELIEF PROGRAM FIGURE 3.79 FIGURE 3.80 HARDEST HIT FUND – USE OF FUNDS IN WASHINGTON, DC, STATUS OF WASHINGTON D.C. WORKERS THAT APPLIED TO HHF, AS OF 9/30/2016 AS OF 9/30/2016 2.4% 12% 41% 3.0% 15.4% 47% 79.2% TARP Dollars to State Agency ($3,686,091) Workers Helped (709) Unspent ($12,037,483) Workers Denied (138) Unemployment Bridge and Related Assistance ($13,816,841) Workers with Withdrawn Applications (27) Note: Funds include $28.7 million allocated from Treasury plus remittances of $795,284. Workers In Process (21) Sources: Treasury, HFA Aggregate Report Q3 2016; District of Columbia’s Housing Finance Agency, Quarterly Performance Report Q3 2016, no date. Source: Treasury, response to SIGTARP data call, 1/17/2017. HIGH RISK AREAS Streamline the lengthy application process: A lengthy wait time may be evidence of an inefficient process (such as overly complex or confusing process or burdensome document requirements) that can be improved, or mismanagement. 145 days TO PROCESS HHF APPLICATION AND PROVIDE ASSISTANCE302 Many cannot withstand a lengthy delay Eliminate unnecessary criteria: In its January 2017 report, SIGTARP recommended that state agencies eliminate unnecessary program criteria. This includes: (1) criteria that does not exist for homeowners in other states for these same Federal dollars, and (2) criteria that does not reflect the reality of Washington, DC, workers.303 Program Performance Figure 3.81 shows the performance of HHF Washington, DC’s Unemployment Program, as of September 30, 2016. SIGTARP QUARTERLY REPORT TO CONGRESS I JANUARY 27, 2017 FIGURE 3.81 HHF WASHINGTON, DC HOMEOWNER PROGRAM PERFORMANCE, UNEMPLOYMENT PROGRAM, AS OF 9/30/2016 1,500 As of 9/30/2016: Homeowner Applications: 895 Homeowners Helped: 709 Homeowner Admission Rate: 79% 1,200 900 600 300 0 Q1 Q2 Q3 Q4 Q1 2010 Q2 Q3 Q4 2011 Estimated Homeowners to be Helped Q1 Q2 Q3 Q4 Q1 2012 Q2 Q3 2013 Q4 Q1 Q2 Q3 2014 Q4 Q1 Q2 Q3 2015 Q4 Q1 Q2 2016 Homeowners Helped Applying Homeowners Notes: Estimated includes highest estimate of a range. Applications are the total number of applicant homeowners, which Treasury began reporting as of Q3 2012. Homeowner Admission Rate is cumulative Homeowners Assisted as a percent of homeowners who applied. Sources: Treasury and District of Columbia Housing Finance Agency, Commitment to Purchase Financial Instrument and HFA Participation Agreement, 9/23/2010, and Amendments to Agreement one through eleven, as of 9/30/2016; District of Columbia’s Housing Finance Agency, Quarterly Performance Reports Q1 2011 – Q3 2016, no date; Treasury, HFA Aggregate Reports Q3 2012 – Q3 2016, no date. Q3 203 ENDNOTES 204 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. Treasury, Transaction Report, 12/30/2016, https://www.treasury.gov/initiatives/financial-stability/reports/Documents/01-04-17%20 Transactions%20Report%20as%20of%2012-30-16_INVESTMENT.pdf, accessed 1/9/2017. SIGTARP Press Release, “FIRST TARP RECIPIENT INSTITUTION INDICTED”, January 6, 2016 https://www.sigtarp.gov/Press%20Releases/ First_TARP_Recipient_Institution_Indicted.pdf, accessed 1/13/2017. SIGTARP Press Release, “FORMER OFFICER AT TARP BANK WILMINGTON TRUST PLEADS GUILTY TO CONSPIRACY CHARGES”, August 4, 2014 https://www.sigtarp.gov/Press%20Releases/Bailey_Plea_Press_Release.pdf, accessed 1/13/2017. SIGTARP Press Release, “DELAWARE DEVELOPER INDICTED FOR DEFRAUDING A TARP BANK AND FOR MONEY LAUNDERING”, January 30, 2013 https://www.sigtarp.gov/Press%20Releases/Bailey_Plea_Press_Release.pdf, accessed 1/13/2017. Treasury, response to SIGTARP data call, 1/5/2017. SIGTARP Press Release, “PRESIDENT OF FIRSTCITY BANK SENTENCED TO TWELVE YEARS IN FEDERAL PRISON FOR BANK FRAUD CONSPIRACY AND PERJURY”, August 10, 2012, https://www.sigtarp.gov/Press%20Releases/Zimmerman_Indictment_Press_Release. pdf, accessed 1/9/2017. 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SIGTARP analysis of Treasury, Hardest Hit Fund “Most Recent Quarterly Performance Report”, accessed through https://www.treasury.gov/ initiatives/financial-stability/TARP-Programs/housing/Pages/Program-Documents.aspx, accessed 1/12/2017. SIGTARP Audit Report, “Improving TARP’s Investment in American Workers”, January 11, 2017, https://www.sigtarp.gov/Audit%20 Engagement%20Memorandums/Engagement%20Memo%20-%20Improving%20TARP's%20Investment%20in%20American%20Workers%20 1.11.2017.pdf, accessed 1/12/2017. 213 104 8,14 8,14,44 8,11,14 11 102 8,14, 18,44 11 NC JUNEAU JUNEAU JUNEAU DALTON DALTON ALASKA PACIFIC BANCSHARES, INC. ALASKA PACIFIC BANCSHARES, INC. ALASKA PACIFIC BANCSHARES, INC. ALLIANCE BANCSHARES, INC. ALLIANCE BANCSHARES, INC. JUNEAU ALASKA PACIFIC BANCSHARES, INC. JUNEAU OCALA ALARION FINANCIAL SERVICES, INC. JUNEAU OCALA ALARION FINANCIAL SERVICES, INC. ALASKA PACIFIC BANCSHARES, INC. OCALA ALARION FINANCIAL SERVICES, INC. ALASKA PACIFIC BANCSHARES, INC. OGALLALA OCALA ADBANC, INC. ALARION FINANCIAL SERVICES, INC. GA GA AK AK AK AK AK AK FL FL FL FL NE NC NE AB&T FINANCIAL CORPORATION NC NC OGALLALA GASTONIA GASTONIA AB&T FINANCIAL CORPORATION ADBANC, INC. GASTONIA GASTONIA NC GASTONIA AB&T FINANCIAL CORPORATION AB&T FINANCIAL CORPORATION FL 1ST UNITED BANCORP, INC. BOCA RATON AB&T FINANCIAL CORPORATION FL 1ST UNITED BANCORP, INC. BOCA RATON IN 1ST SOURCE CORPORATION SOUTH BEND NC IN HENDERSONVILLE 1ST FINANCIAL SERVICES CORPORATION NC IN HENDERSONVILLE 1ST FINANCIAL SERVICES CORPORATION CA CA 1ST SOURCE CORPORATION SOUTH BEND LOS ANGELES 1ST ENTERPRISE BANK CA NJ NJ NJ State 1ST SOURCE CORPORATION SOUTH BEND LOS ANGELES 1ST ENTERPRISE BANK CRANBURY 1ST CONSTITUTION BANCORP LOS ANGELES CRANBURY 1ST CONSTITUTION BANCORP 1ST ENTERPRISE BANK CRANBURY 1ST CONSTITUTION BANCORP City 3/27/2013 6/26/2009 4/1/2014 3/26/2013 1/11/2013 11/29/2012 11/28/2012 2/6/2009 9/12/2013 7/22/2013 7/19/2013 1/23/2009 7/21/2011 1/30/2009 3/19/2014 2/10/2014 1/6/2014 11/19/2013 1/23/2009 11/18/2009 3/13/2009 3/9/2011 12/29/2010 1/23/2009 12/31/2013 11/14/2008 9/1/2011 12/11/2009 2/13/2009 11/22/2011 10/27/2010 12/23/2008 Date $2,986,000.00 $4,781,000.00 $6,514,000.00 $12,720,000.00 $3,500,000.00 $10,000,000.00 $111,000,000.00 $16,369,000.00 $6,000,000.00 $4,400,000.00 $12,000,000.00 Original Investment Amount $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Outstanding Investment Sold, in full; $3,581,397.27 warrants not outstanding Sold, in full; $7,501,881.70 warrants not outstanding Sold, in full; $7,674,004.73 warrants not outstanding Redeemed, in $15,071,769.00 full; warrants not outstanding Sold, in full; $1,274,909.59 warrants outstanding Redeemed, in $10,870,902.67 full; warrants not outstanding Redeemed, in $125,480,000.00 full; warrants not outstanding Sold, in full; $9,229,948.97 warrants not outstanding Redeemed, in $11,748,156.44 full; warrants not outstanding Redeemed, in $13,433,242.67 full; warrants not outstanding Investment Total Cash Back2 Status* $4,058,697.67 $208,870.74 $5,524,880.90 $877,729.70 $12,720,000.00 $150,621.36 $815,100.00 $10,000,000.00 $111,000,000.00 $8,000,000.00 $10,400,000.00 $12,000,000.00 Amount ($7,324.33) ($42,675.67) ($64,026.11) ($1,506.21) ($50,000.00) (Fee)4 4,547 234 5,621 893 12,720 536 2,964 10,000 111,000 16,369 10,400 12,000 Shares Capital Repayment / Disposition / Auction3,5 $892.61 $892.61 $982.90 $982.90 $1,000.00 $281.01 $275.00 $1,000.00 $1,000.00 $488.73 $1,000.00 $1,000.00 Avg. Price ($488,302.33) ($25,129.26) ($96,119.10) ($15,270.30) ($385,378.64) ($2,148,900.00) ($8,369,000.00) (Realized Loss) / (Write-off) Gain5 $94,153.69 $2,370,908.26 $337,363.35 $636,000.00 $500,000.00 $3,750,000.00 $220,000.00 $326,576.00 Wt Amount 101 175,772 326 636 500 837,947 220 231,782 Wt Shares Warrant Proceeds $611,059.81 $913,405.03 $998,056.89 $1,715,769.00 $360,694.44 $370,902.67 $10,730,000.00 $1,229,948.97 $1,128,156.44 $1,106,666.67 0 0 6 0 11 0 0 14 0 0 Continued on next page $0.00 $0.00 $532,560.00 $0.00 $481,250.00 $0.00 $0.00 $2,864,575.00 $0.00 $0.00 Amount Dividends Paid Number of Missed of Missed to Date Dividends Dividend Dividends and Interest 214 Footnote Institution Name CPP TRANSACTIONS DETAIL, AS OF 12/31/2016 TABLE A.1 TRANSACTIONS DETAIL APPENDIX A I TRANSACTION DETAIL I JANUARY 27, 2017 45 8,11,14 8,11,14 11 8,14,44 8,14,45 8,14 8,137 14,15 11 SAINT PAUL SAINT PAUL SAINT PAUL SAINT PAUL OSWEGO OSWEGO GLENWOOD SPRINGS CO ALLIANCE FINANCIAL SERVICES, INC. ALLIANCE FINANCIAL SERVICES, INC. ALLIANCE FINANCIAL SERVICES, INC. ALLIANCE FINANCIAL SERVICES, INC. ALLIED FIRST BANCORP, INC. ALLIED FIRST BANCORP, INC. ALPINE BANKS OF COLORADO NY GREAT BEND MOULTRIE MOULTRIE MOULTRIE AMERICAN STATE BANCSHARES, INC. AMERIS BANCORP AMERIS BANCORP AMERIS BANCORP GA GA GA KS KS PA GREAT BEND AMERICAN STATE BANCSHARES, INC. CA PA ARCADIA AMERICAN PREMIER BANCORP CA AMERISERV FINANCIAL, INC. JOHNSTOWN ARCADIA AMERICAN PREMIER BANCORP NY NY AMERISERV FINANCIAL, INC. JOHNSTOWN NEW YORK NEW YORK NY NEW YORK AMERICAN EXPRESS COMPANY AMERICAN EXPRESS COMPANY OK AMERIBANK HOLDING COMPANY, INC. / AMERICAN COLLINSVILLE BANK OF OKLAHOMA AMERICAN EXPRESS COMPANY OK 8/11/2011 12/19/2008 8/22/2012 6/19/2012 11/21/2008 11/2/2011 1/9/2009 1/26/2011 5/29/2009 7/29/2009 6/17/2009 1/9/2009 9/15/2011 3/6/2009 9/22/2011 IN MUNSTER AMB FINANCIAL CORPORATION AMERIBANK HOLDING COMPANY, INC. / AMERICAN COLLINSVILLE BANK OF OKLAHOMA 1/30/2009 MUNSTER AMB FINANCIAL CORPORATION 11/16/2012 9/20/2012 9/19/2012 9/18/2012 3/27/2009 12/28/2016 4/24/2009 3/26/2013 2/7/2013 2/6/2013 6/26/2009 6/17/2009 5/13/2009 12/19/2008 4/9/2013 3/28/2013 IN GLENWOOD SPRINGS CO GLENWOOD SPRINGS CO ALPINE BANKS OF COLORADO ALPINE BANKS OF COLORADO ALPINE BANKS OF COLORADO GLENWOOD SPRINGS CO GLENWOOD SPRINGS CO ALPINE BANKS OF COLORADO IL IL MN MN MN MN NY SYRACUSE NY GA SYRACUSE SYRACUSE ALLIANCE FINANCIAL CORPORATION ALLIANCE FINANCIAL CORPORATION DALTON ALLIANCE BANCSHARES, INC. GA State ALLIANCE FINANCIAL CORPORATION DALTON City ALLIANCE BANCSHARES, INC. Footnote Institution Name $21,000,000.00 $52,000,000.00 $6,000,000.00 $1,800,000.00 $3,388,890,000.00 $2,492,000.00 $3,674,000.00 $70,000,000.00 $3,652,000.00 $12,000,000.00 $26,918,000.00 Original Investment Date Amount $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Outstanding Investment Investment Status* Redeemed, in $24,601,666.66 full; warrants not outstanding Sold, in full; $59,637,438.67 warrants not outstanding Redeemed, in $7,220,141.67 full; warrants not outstanding Redeemed, in $2,052,682.49 full; warrants not outstanding Redeemed, in $3,803,257,308.33 full; warrants not outstanding Redeemed, in $2,960,021.33 full; warrants not outstanding Redeemed, in $4,387,576.45 full; warrants not outstanding Sold, in full; $73,129,160.69 warrants not outstanding Sold, in full; $1,453,753.00 warrants not outstanding Sold, in full; $9,806,136.60 warrants not outstanding Redeemed, in $28,356,360.00 full; warrants not outstanding Total Cash Back2 CPP TRANSACTIONS DETAIL, AS OF 12/31/2016 (CONTINUED) $21,000,000.00 $48,391,200.00 $6,000,000.00 $1,800,000.00 $3,388,890,000.00 $2,492,000.00 $3,674,000.00 $50,160,264.00 $6,559,920.24 $280,115.76 $1,044,000.00 $5,626,575.00 $3,375,945.00 $26,918,000.00 $2,856,437.46 Amount ($725,868.00) ($570,003.00) ($90,025.20) ($25,000.00) (Fee)4 21,000 52,000 6,000 1,800 3,388,890 2,492 3,674 61,600 8,056 344 3,652 7,500,000 4,500,000 26,918 2,986 Shares Capital Repayment / Disposition / Auction3,5 $1,000.00 $930.60 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $814.29 $814.29 $814.29 $285.87 $0.75 $0.75 $1,000.00 $956.61 Avg. Price ($3,608,800.00) ($11,439,736.00) ($1,496,079.76) ($63,884.24) ($2,608,000.00) ($1,873,425.00) ($1,124,055.00) ($129,562.54) (Realized Loss) / (Write-off) Gain5 $2,670,000.00 $300,000.00 $90,000.00 $340,000,000.00 $125,000.00 $184,000.00 $3,291,750.00 $504,900.00 $900,000.00 $44,746.31 Wt Amount 698,554 300 90 24,264,129 125 184 3,500 600,000 173,069 48 Wt Shares Warrant Proceeds Dividends and Interest $2,776,666.66 $9,302,106.67 $920,141.67 $162,682.49 $74,367,308.33 $343,021.33 $529,576.45 $13,407,113.69 $409,753.00 $388,741.80 $538,360.00 0 0 0 0 0 0 0 0 22 12 0 Continued on next page $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $5,317,600.00 $3,020,400.00 $0.00 Amount Dividends Paid Number of Missed of Missed to Date Dividends Dividend TRANSACTION DETAIL I APPENDIX A I JANUARY 27, 2017 215 11 8,17,44 8,44 11 8,14,44 8,17 11 11,90 94 14,15 TN TN BLUFFTON BLUFFTON BLUFFTON BLUFFTON NASHVILLE NASHVILLE PALO ALTO PALO ALTO PALO ALTO SHEFFIELD SHEFFIELD ATLANTIC BANCSHARES, INC. ATLANTIC BANCSHARES, INC. ATLANTIC BANCSHARES, INC. ATLANTIC BANCSHARES, INC. AVENUE FINANCIAL HOLDINGS AVENUE FINANCIAL HOLDINGS AVIDBANK HOLDING, INC. / PENINSULA BANK HOLDING CO. AVIDBANK HOLDING, INC. / PENINSULA BANK HOLDING CO. AVIDBANK HOLDING, INC. / PENINSULA BANK HOLDING CO. BANCINDEPENDENT, INCORPORATED BANCINDEPENDENT, INCORPORATED WI IL RI BANCORP FINANCIAL, INC. OAK BROOK PROVIDENCE PROVIDENCE PROVIDENCE BANCORP RHODE ISLAND, INC. BANCORP RHODE ISLAND, INC. BANCORP RHODE ISLAND, INC. RI RI IL BANCORP FINANCIAL, INC. OAK BROOK AL AL CA CA CA SC SC SC SC WI GREEN BAY GREEN BAY WI WI ASSOCIATED BANC-CORP GREEN BAY ASSOCIATED BANC-CORP GREEN BAY MD ANNAPOLIS BANCORP, INC. ANNAPOLIS / F.N.B. CORPORATION ASSOCIATED BANC-CORP MD ASSOCIATED BANC-CORP MD WI ANNAPOLIS BANCORP, INC. ANNAPOLIS / F.N.B. CORPORATION ANCHOR BANCORP WISCONSIN, INC. WI MD MADISON ANCHOR BANCORP WISCONSIN, INC. NE NE ANNAPOLIS BANCORP, INC. ANNAPOLIS / F.N.B. CORPORATION MADISON AMFIRST FINANCIAL SERVICES, INC NE NE ANNAPOLIS BANCORP, INC. ANNAPOLIS / F.N.B. CORPORATION MCCOOK MCCOOK AMFIRST FINANCIAL SERVICES, INC MCCOOK MCCOOK AMFIRST FINANCIAL SERVICES, INC NE MCCOOK AMFIRST FINANCIAL SERVICES, INC PA State AMFIRST FINANCIAL SERVICES, INC City AMERISERV FINANCIAL, INC. JOHNSTOWN Footnote Institution Name 9/30/2009 8/5/2009 12/19/2008 8/18/2011 7/10/2009 7/14/2011 3/13/2009 8/28/2013 7/31/2013 1/30/2009 9/15/2011 2/27/2009 3/19/2014 2/10/2014 2/7/2014 12/29/2009 12/6/2011 9/14/2011 4/6/2011 11/21/2008 5/28/2015 3/6/2013 4/18/2012 1/30/2009 9/27/2013 1/30/2009 4/9/2013 3/28/2013 3/27/2013 3/26/2013 8/21/2009 11/2/2011 Date $30,000,000.00 $13,669,000.00 $21,100,000.00 $6,000,000.00 $7,400,000.00 $2,000,000.00 $525,000,000.00 $8,152,000.00 $110,000,000.00 $5,000,000.00 Original Investment Amount $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Outstanding Investment Redeemed, in $32,341,666.66 full; warrants not outstanding Redeemed, in $15,595,736.93 full; warrants not outstanding Redeemed, in $24,841,411.03 full; warrants not outstanding Redeemed, in $7,563,057.15 full; warrants not outstanding Redeemed, in $8,798,415.33 full; warrants not outstanding Sold, in full; $2,503,554.78 warrants not outstanding Redeemed, in $596,539,172.32 full; warrants not outstanding Redeemed, in $13,378,714.00 full; warrants not outstanding Sold, in full; $6,000,000.00 warrants not outstanding Sold, in full; $6,523,255.00 warrants not outstanding Investment Total Cash Back2 Status* CPP TRANSACTIONS DETAIL, AS OF 12/31/2016 (CONTINUED) $30,000,000.00 $13,669,000.00 $21,100,000.00 $6,000,000.00 $7,400,000.00 $50,000.00 $1,950,000.00 $262,500,000.00 $262,500,000.00 $4,076,000.00 $4,076,000.00 $6,000,000.00 $2,328,960.00 $2,112,000.00 $359,040.00 Amount ($25,000.00) ($48,000.00) (Fee)4 30,000 13,669 21,100 6,000 7,400 50 1,950 262,500 262,500 4,076 4,076 60,000,000 2,426,000 2,200,000 374,000 Shares Capital Repayment / Disposition / Auction3,5 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,150.00 $1,150.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $0.10 $0.96 $0.96 $0.96 Avg. Price ($104,000,000.00) ($97,040.00) ($88,000.00) ($14,960.00) (Realized Loss) / (Write-off) $7,500.00 $292,500.00 Gain5 $1,400,000.00 $410,000.00 $1,055,000.00 $190,781.12 $370,000.00 $10,798.98 $95,031.02 $3,435,005.65 $3,735,577.67 $259,875.00 $825,000.00 Wt Amount 192,967 410 1,055 81,670 370 10 88 3,983,308 367,916 250,000 1,312,500 Wt Shares Warrant Proceeds $941,666.66 $1,516,736.93 $2,686,411.03 $1,372,276.03 $1,028,415.33 $122,724.78 $68,104,166.67 $1,511,380.00 0 0 0 0 0 0 11 0 17 0 Continued on next page $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $299,255.00 $0.00 $23,604,167.00 $0.00 Amount Dividends Paid Number of Missed of Missed to Date Dividends Dividend Dividends and Interest 216 APPENDIX A I TRANSACTION DETAIL I JANUARY 27, 2017 11 105 11 11 8 44 8,14 6,7,11 8,14 83 CHARLOTTE CHARLOTTE BANK OF AMERICA BANK OF AMERICA MOCKSVILLE MOCKSVILLE BANK OF THE CAROLINAS CORPORATION BANK OF THE CAROLINAS CORPORATION BANK OF THE OZARKS, INC. LITTLE ROCK NEW YORK NEW YORK AR NC NC NY NY NY NEW YORK BANK OF NEW YORK MELLON BANK OF NEW YORK MELLON CA BANK OF MARIN BANCORP NOVATO BANK OF NEW YORK MELLON CA BANK OF MARIN BANCORP NOVATO NV NV CA LAS VEGAS NV CA CA CA NC NC NC NC NC NC NC BANK OF MARIN BANCORP NOVATO LAS VEGAS BANK OF GEORGE REDDING BANK OF COMMERCE HOLDINGS BANK OF GEORGE REDDING BANK OF COMMERCE HOLDINGS LAS VEGAS REDDING BANK OF COMMERCE HOLDINGS BANK OF GEORGE CHARLOTTE CHARLOTTE BANK OF COMMERCE BANK OF COMMERCE CHARLOTTE CHARLOTTE BANK OF COMMERCE CHARLOTTE MN BANK FINANCIAL SERVICES, EDEN PRAIRIE INC. BANK OF AMERICA MN BANK OF AMERICA MN AL BANK FINANCIAL SERVICES, EDEN PRAIRIE INC. MOBILE BANCTRUST FINANCIAL GROUP, INC. AL MN MOBILE BANCTRUST FINANCIAL GROUP, INC. MO MO BANK FINANCIAL SERVICES, EDEN PRAIRIE INC. FESTUS BANCSTAR, INC. BANK FINANCIAL SERVICES, EDEN PRAIRIE INC. FESTUS BANCSTAR, INC. MO MN FESTUS BANCSTAR, INC. MO MS MS State BANK FINANCIAL SERVICES, EDEN PRAIRIE INC. FESTUS RIDGELAND BANCPLUS CORPORATION BANCSTAR, INC. RIDGELAND BANCPLUS CORPORATION 8,11,14 8,14 City Footnote Institution Name $1,004,000.00 $50,000,000.00 $8,600,000.00 $48,000,000.00 12/12/2008 7/16/2014 4/17/2009 8/5/2009 6/17/2009 10/28/2008 11/23/2011 3/31/2009 12/5/2008 1/6/2014 10/21/2013 3/13/2009 10/26/2011 9/27/2011 11/14/2008 1/11/2013 11/30/2012 1/16/2009 3/9/2010 12/9/2009 $75,000,000.00 $13,179,000.00 $3,000,000,000.00 $28,000,000.00 $2,672,000.00 $17,000,000.00 $3,000,000.00 1/9/2009 $10,000,000,000.00 10/28/2008 $15,000,000,000.00 3/26/2013 1/11/2013 12/20/2012 12/19/2012 8/14/2009 2/15/2013 12/19/2008 5/31/2013 4/29/2013 4/26/2013 4/3/2009 9/29/2010 2/20/2009 Original Investment Date Amount $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Outstanding Investment Investment Status* Redeemed, in $81,004,166.67 full; warrants not outstanding Sold, in full; $4,334,427.00 warrants not outstanding Redeemed, in $3,231,416,666.67 full; warrants not outstanding Redeemed, in $30,155,095.11 full; warrants not outstanding Sold, in full; $1,233,940.00 warrants not outstanding Redeemed, in $19,564,027.78 full; warrants not outstanding Sold, in full; $3,087,573.33 warrants not outstanding Redeemed, in $26,599,663,040.28 full; warrants not outstanding Sold, in full; $1,114,680.76 warrants not outstanding Redeemed, in $60,451,155.74 full; warrants not outstanding Sold, in full; $10,701,460.58 warrants not outstanding Redeemed, in $54,607,399.33 full; warrants not outstanding Total Cash Back2 CPP TRANSACTIONS DETAIL, AS OF 12/31/2016 (CONTINUED) $3,294,750.00 $3,000,000,000.00 $28,000,000.00 $955,240.00 $17,000,000.00 $2,502,000.00 $25,000,000,000.00 $481,335.96 $451,600.92 $50,000,000.00 $8,352,695.00 $98,267.00 $48,000,000.00 Amount ($25,000.00) ($25,000.00) ($15,670.63) ($9,329.37) ($84,509.62) (Fee)4 13,179 3,000,000 28,000 2,672 17,000 3,000 1,000,000 518 486 50,000 8,500 100 48,000 Shares Capital Repayment / Disposition / Auction3,5 $250.00 $1,000.00 $1,000.00 $357.50 $1,000.00 $834.00 $25,000.00 $929.22 $929.22 $1,000.00 $982.67 $982.67 $1,000.00 Avg. Price ($9,884,250.00) ($1,716,760.00) ($498,000.00) ($36,664.04) ($34,399.08) ($147,305.00) ($1,733.00) (Realized Loss) / (Write-off) Gain5 $136,000,000.00 $1,703,984.00 $23,709.00 $125,000.00 $100,100.00 $305,913,040.28 $23,500.00 $15,000.00 $426,338.55 $2,400,000.00 Wt Amount 14,516,129 154,908 134 405,405 150 121,792,790 50 730,994 430 2,400 Wt Shares Warrant Proceeds Dividends and Interest $3,354,166.67 $1,039,677.00 $95,416,666.67 $451,111.11 $279,991.00 $2,439,027.78 $510,473.33 $1,293,750,000.00 $183,243.88 $10,436,155.74 $1,908,669.65 $4,207,399.33 0 14 0 0 10 0 3 0 0 0 0 Continued on next page $0.00 $2,306,325.00 $0.00 $0.00 $364,150.00 $0.00 $122,625.00 $0.00 $0.00 $0.00 $0.00 Amount Dividends Paid Number of Missed of Missed to Date Dividends Dividend TRANSACTION DETAIL I APPENDIX A I JANUARY 27, 2017 217 8,11,14 8,11,14 11 8,112 11 12,16 8,14,44 8,14 8,14,44 8,106 AR CO DENVER DENVER MACON MACON GREENVILLE GREENVILLE GREENVILLE GREENVILLE WALLA WALLA WALLA WALLA WALLA WALLA HARRISBURG HARRISBURG BANKERS’ BANK OF THE WEST BANCORP, INC. BANKERS’ BANK OF THE WEST BANCORP, INC. BANKFIRST CAPITAL CORPORATION BANKFIRST CAPITAL CORPORATION BANKGREENVILLE FINANCIAL CORPORATION BANKGREENVILLE FINANCIAL CORPORATION BANKGREENVILLE FINANCIAL CORPORATION BANKGREENVILLE FINANCIAL CORPORATION BANNER CORPORATION/ BANNER BANK BANNER CORPORATION/ BANNER BANK BANNER CORPORATION/ BANNER BANK BANNER COUNTY BAN CORPORATION BANNER COUNTY BAN CORPORATION MANHATTAN BEACH MANHATTAN BEACH MANHATTAN BEACH MANHATTAN BEACH MANHATTAN BEACH MANHATTAN BEACH PHOENIXVILLE PHOENIXVILLE BEACH BUSINESS BANK BEACH BUSINESS BANK BEACH BUSINESS BANK BEACH BUSINESS BANK BEACH BUSINESS BANK BERKSHIRE BANCORP, INC. / CUSTOMERS BANCORP, INC. BERKSHIRE BANCORP, INC. / CUSTOMERS BANCORP, INC. BALTIMORE BEACH BUSINESS BANK BCSB BANCORP, INC. THEODORE BCB HOLDING COMPANY, INC. BALTIMORE THEODORE BCB HOLDING COMPANY, INC. BALTIMORE WINSTON-SALEM BB&T CORP. BCSB BANCORP, INC. WINSTON-SALEM BCSB BANCORP, INC. WINSTON-SALEM PA PA CA CA CA CA CA CA MD MD MD AL AL NC NC NC ME BAR HARBOR BANKSHARES BAR HARBOR BB&T CORP. ME BAR HARBOR BANKSHARES BAR HARBOR BB&T CORP. ME BAR HARBOR BANKSHARES BAR HARBOR NE NE WA WA WA SC SC SC SC MS MS CO AR State BANK OF THE OZARKS, INC. LITTLE ROCK City BANK OF THE OZARKS, INC. LITTLE ROCK Footnote Institution Name 12/28/2011 6/12/2009 6/27/2012 6/6/2012 3/7/2012 10/19/2011 7/6/2011 1/30/2009 4/19/2013 1/26/2011 12/23/2008 7/1/2014 4/3/2009 7/22/2009 6/17/2009 11/14/2008 7/28/2010 2/24/2010 1/16/2009 7/28/2011 2/6/2009 6/12/2013 4/3/2012 11/21/2008 3/26/2013 1/11/2013 11/9/2012 2/13/2009 9/8/2011 1/23/2009 4/24/2014 1/30/2009 11/24/2009 11/4/2009 Date $2,892,000.00 $6,000,000.00 $10,800,000.00 $1,706,000.00 $3,133,640,000.00 $18,751,000.00 $795,000.00 $124,000,000.00 $1,000,000.00 $15,500,000.00 $12,639,000.00 Original Investment Amount $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Outstanding Investment Redeemed, in $3,444,478.21 full; warrants not outstanding Redeemed, in $7,263,316.66 full; warrants not outstanding Redeemed, in $13,371,500.00 full; warrants not outstanding Redeemed, in $2,315,853.14 full; warrants not outstanding Redeemed, in $3,293,353,918.53 full; warrants not outstanding Redeemed, in $20,037,514.11 full; warrants not outstanding Redeemed, in $942,411.42 full; warrants not outstanding Sold, in full; $129,079,862.47 warrants not outstanding Sold, in full; $1,100,653.50 warrants not outstanding Redeemed, in $18,492,469.25 full; warrants not outstanding Redeemed, in $17,097,990.60 full; warrants not outstanding Investment Total Cash Back2 Status* CPP TRANSACTIONS DETAIL, AS OF 12/31/2016 (CONTINUED) $2,892,000.00 $300,000.00 $1,200,000.00 $1,500,000.00 $1,500,000.00 $1,500,000.00 $10,800,000.00 $1,706,000.00 $3,133,640,000.00 $18,751,000.00 $795,000.00 $109,717,680.00 $900,000.00 $15,500,000.00 $12,639,000.00 $75,000,000.00 Amount ($1,645,765.20) ($16,000.00) ($9,000.00) (Fee)4 2,892 300 1,200 1,500 1,500 1,500 10,800 1,706 3,134 18,751 795 124,000 1,000 15,500 12,639 75,000 Shares Capital Repayment / Disposition / Auction3,5 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,000,000.00 $1,000.00 $1,000.00 $884.82 $900.00 $1,000.00 $1,000.00 $1,000.00 Avg. Price ($14,282,320.00) ($100,000.00) (Realized Loss) / (Write-off) Gain5 $145,000.00 $300,000.00 $1,442,000.00 $85,000.00 $67,010,401.86 $250,000.00 $40,000.00 $134,201.00 $21,880.50 $775,000.00 $632,000.00 $2,650,000.00 Wt Amount 145 300 183,465 85 13,902,573 52,455 4 243,998 50 775 632 379,811 Wt Shares Warrant Proceeds $407,478.21 $963,316.66 $1,129,500.00 $524,853.14 $92,703,516.67 $1,036,514.11 $107,411.42 $20,873,746.67 $203,773.00 $2,217,469.25 $3,826,990.60 0 0 0 0 0 0 0 0 0 0 0 Continued on next page $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Amount Dividends Paid Number of Missed of Missed to Date Dividends Dividend Dividends and Interest 218 APPENDIX A I TRANSACTION DETAIL I JANUARY 27, 2017 8 8,64,97 8,14 8,14 8 15,17 8,14,18 8,14,44 11 OVERLAND PARK NEW YORK NEW YORK BNB FINANCIAL SERVICES CORPORATION OVERLAND PARK BLUE VALLEY BAN CORP BNB FINANCIAL SERVICES CORPORATION KS OVERLAND PARK BLUE VALLEY BAN CORP BLUE VALLEY BAN CORP IN BLUE RIVER BANCSHARES, SHELBYVILLE INC. OVERLAND PARK IN BLUE RIVER BANCSHARES, SHELBYVILLE INC. OVERLAND PARK MO BLUE RIDGE BANCSHARES, INDEPENDENCE INC. BLUE VALLEY BAN CORP MO BLUE VALLEY BAN CORP MO BLUE RIDGE BANCSHARES, INDEPENDENCE INC. NY NY KS KS KS KS MO ND BLUE RIDGE BANCSHARES, INDEPENDENCE INC. FARGO ND ND WI WI WI WI FL FL BLUE RIDGE BANCSHARES, INDEPENDENCE INC. FARGO BLACKRIDGE FINANCIAL, INC. BLACKRIDGE FINANCIAL, INC. BELOIT BLACKHAWK BANCORP, INC. FARGO BELOIT BLACKHAWK BANCORP, INC. BLACKRIDGE FINANCIAL, INC. COCONUT GROVE BISCAYNE BANCSHARES, INC. BELOIT COCONUT GROVE BISCAYNE BANCSHARES, INC. BELOIT COCONUT GROVE BISCAYNE BANCSHARES, INC. BLACKHAWK BANCORP, INC. FL COCONUT GROVE BISCAYNE BANCSHARES, INC. BLACKHAWK BANCORP, INC. MI BIRMINGHAM BLOOMFIELD BIRMINGHAM BANCSHARES, INC. FL MI BIRMINGHAM BLOOMFIELD BIRMINGHAM BANCSHARES, INC. 9/1/2011 8/30/2013 4/17/2009 1/7/2015 1/6/2014 10/21/2013 10/18/2013 12/5/2008 2/10/2012 3/6/2009 1/11/2013 10/31/2012 10/29/2012 3/6/2009 9/12/2012 6/27/2012 5/22/2009 1/11/2013 10/31/2012 10/29/2012 3/13/2009 3/26/2013 2/8/2013 2/7/2013 6/19/2009 7/28/2011 12/18/2009 4/24/2009 KS MI BERN BERN BANCSHARES, INC. 2/13/2009 6/24/2009 5/27/2009 12/19/2008 KS MA MA MA State BIRMINGHAM BLOOMFIELD BIRMINGHAM BANCSHARES, INC. BERN PITTSFIELD PITTSFIELD BERKSHIRE HILLS BANCORP, INC. BERN BANCSHARES, INC. PITTSFIELD BERKSHIRE HILLS BANCORP, INC. City BERKSHIRE HILLS BANCORP, INC. Footnote Institution Name $7,500,000.00 $21,750,000.00 $5,000,000.00 $12,000,000.00 $5,000,000.00 $10,000,000.00 $6,400,000.00 $1,744,000.00 $1,635,000.00 $985,000.00 $40,000,000.00 Original Investment Date Amount $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Outstanding Investment Investment Status* Currently Not Collectible Redeemed, in $9,776,051.62 full; warrants not outstanding Sold, in full; $21,264,901.65 warrants not outstanding $529,105.00 Sold, in full; $11,938,437.34 warrants not outstanding Redeemed, in $6,127,326.35 full; warrants not outstanding Sold, in full; $11,459,461.11 warrants not outstanding Sold, in full; $8,271,975.28 warrants not outstanding Redeemed, in $3,803,022.67 full; warrants not outstanding Redeemed, in $1,172,062.50 full; warrants not outstanding Redeemed, in $41,917,777.78 full; warrants not outstanding Total Cash Back2 CPP TRANSACTIONS DETAIL, AS OF 12/31/2016 (CONTINUED) $7,500,000.00 $18,085,785.00 $3,177,232.50 $9,040,370.00 $19,630.00 $2,750,000.00 $2,250,000.00 $8,913,450.00 $186,550.00 $3,700,820.00 $2,532,140.00 $3,379,000.00 $985,000.00 $40,000,000.00 Amount ($212,630.18) ($90,600.00) ($91,000.00) ($62,329.60) (Fee)4 7,500 18,500 3,250 11,974 26 2,750 2,250 9,795 205 3,800,000 2,600,000 3,379 985 40,000 Shares Capital Repayment / Disposition / Auction3,5 $1,000.00 $977.61 $977.61 $755.00 $755.00 $1,000.00 $1,000.00 $910.00 $910.00 $0.97 $0.97 $1,000.00 $1,000.00 $1,000.00 Avg. Price ($414,215.00) ($72,767.50) ($5,000,000.00) ($2,933,630.00) ($6,370.00) ($881,550.00) ($18,450.00) ($99,180.00) ($67,860.00) (Realized Loss) / (Write-off) Gain5 $375,000.00 $3,056.00 $541,793.34 $250,000.00 $470,250.00 $140,347.75 $64,158.97 $82,000.00 $50,000.00 $1,040,000.00 Wt Amount 375 130,977 600 250 500 140,000 64,000 82 5 226,330 Wt Shares Warrant Proceeds Dividends and Interest $1,901,051.62 $211,458.33 $529,105.00 $2,427,244.00 $877,326.35 $1,980,211.11 $1,896,838.16 $342,022.67 $137,062.50 $877,777.78 18 3 0 0 0 0 0 0 0 Continued on next page $4,893,750.00 $204,375.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Amount Dividends Paid Number of Missed of Missed to Date Dividends Dividend TRANSACTION DETAIL I APPENDIX A I JANUARY 27, 2017 219 8,14,44 14,15 9,10, 18,65, 96,99, 136 8 11 11 14,15 8,14,44 8 8,14,44 KAUKAUNA KAUKAUNA KANSAS CITY KANSAS CITY BROGAN BANKSHARES, INC. BROTHERHOOD BANCSHARES, INC. BROTHERHOOD BANCSHARES, INC. KAUKAUNA BROGAN BANKSHARES, INC. KAUKAUNA LOS ANGELES BROADWAY FINANCIAL CORPORATION BROGAN BANKSHARES, INC. LOS ANGELES BROADWAY FINANCIAL CORPORATION BROGAN BANKSHARES, INC. LOS ANGELES KS KS WI WI WI WI CA CA CA IL BRIDGEVIEW BANCORP, INC. BRIDGEVIEW BROADWAY FINANCIAL CORPORATION IL CA BRIDGE CAPITAL HOLDINGS SAN JOSE IL CA BRIDGE CAPITAL HOLDINGS SAN JOSE BRIDGEVIEW BANCORP, INC. BRIDGEVIEW CA BRIDGE CAPITAL HOLDINGS SAN JOSE BRIDGEVIEW BANCORP, INC. BRIDGEVIEW CA MA BOSTON PRIVATE BOSTON FINANCIAL HOLDINGS INC. BRIDGE CAPITAL HOLDINGS SAN JOSE MA MA BOSTON PRIVATE BOSTON FINANCIAL HOLDINGS INC. MA WI BOSCOBEL BANCORP, INC. BOSCOBEL BOSTON PRIVATE BOSTON FINANCIAL HOLDINGS INC. WI BOSCOBEL BANCORP, INC. BOSCOBEL BOSTON PRIVATE BOSTON FINANCIAL HOLDINGS INC. WI BOSCOBEL BANCORP, INC. BOSCOBEL TX WI HOUSTON BOH HOLDINGS, INC. TX ND ND ND ND CT CT NC NC NC State BOSCOBEL BANCORP, INC. BOSCOBEL HOUSTON BOH HOLDINGS, INC. BISMARCK BISMARCK BNCCORP, INC. BNCCORP, INC. NEW CANAAN BNC FINANCIAL GROUP, INC. BISMARCK NEW CANAAN BNC FINANCIAL GROUP, INC. BISMARCK THOMASVILLE BNC BANCORP BNCCORP, INC. THOMASVILLE BNC BANCORP BNCCORP, INC. THOMASVILLE City BNC BANCORP Footnote Institution Name 9/15/2011 7/17/2009 5/31/2013 4/29/2013 4/26/2013 5/15/2009 12/22/2016 12/4/2009 11/14/2008 1/6/2014 11/19/2013 12/19/2008 4/20/2011 3/16/2011 2/23/2011 12/23/2008 2/7/2011 6/16/2010 1/13/2010 11/21/2008 4/9/2013 3/11/2013 3/8/2013 5/15/2009 7/14/2011 3/6/2009 4/25/2014 3/17/2014 3/14/2014 1/16/2009 8/4/2011 2/27/2009 9/19/2012 8/29/2012 12/5/2008 Date $11,000,000.00 $2,400,000.00 $6,000,000.00 $9,000,000.00 $38,000,000.00 $23,864,000.00 $154,000,000.00 $5,586,000.00 $10,000,000.00 $20,093,000.00 $4,797,000.00 $31,260,000.00 Original Investment Amount $0.00 $0.00 $8,047,220.58 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Outstanding Investment Redeemed, in $12,845,586.01 full; warrants not outstanding Sold, in full; $3,022,879.60 warrants not outstanding Sold, in part; $8,287,964.07 warrants not outstanding Sold, in full; $13,447,811.37 warrants not outstanding Redeemed, in $27,872,582.22 full; warrants not outstanding Redeemed, in $171,224,745.48 full; warrants not outstanding Sold, in full; $6,947,457.50 warrants not outstanding Redeemed, in $11,783,777.44 full; warrants not outstanding Sold, in full; $26,941,865.35 warrants not outstanding Redeemed, in $5,673,920.75 full; warrants not outstanding Sold, in full; $35,140,666.12 warrants not outstanding Investment Total Cash Back2 Status* CPP TRANSACTIONS DETAIL, AS OF 12/31/2016 (CONTINUED) $11,000,000.00 $2,340,000.00 $60,000.00 $6,952,779.42 $10,450,000.00 $8,864,000.00 $15,000,000.00 $104,000,000.00 $50,000,000.00 $5,586,000.00 $10,000,000.00 $19,950,000.00 $143,000.00 $4,797,000.00 $28,797,649.80 Amount ($25,000.00) ($104,500.00) ($61,787.30) ($201,147.00) ($431,964.75) (Fee)4 11,000 2,340,000 60,000 4,702,860 38,000 8,864 15,000 104,000 50,000 5,586,000 10,000 19,950 143 4,797 31,260 Shares Capital Repayment / Disposition / Auction3,5 $1,000.00 $1.05 $1.05 $1.59 $275.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1.11 $1,000.00 $1,001.08 $1,001.08 $1,000.00 $921.23 Avg. Price ($27,550,000.00) ($2,462,350.20) (Realized Loss) / (Write-off) $117,023.40 $3,000.60 $524,767.98 $592,730.46 $21,546.00 $154.44 Gain5 $550,000.00 $125,135.60 $709,155.81 $1,395,000.00 $6,202,523.25 $129,709.80 $232,180.54 $500,000.00 $966,456.56 $29,737.13 $240,000.00 $939,920.00 Wt Amount 550 120,000 1,900 396,412 2,887,500 100,000 179,000 500 975 30 240 543,337 Wt Shares Warrant Proceeds $1,295,586.01 $402,720.00 $810,416.67 $2,393,155.56 $2,613,582.22 $11,022,222.23 $468,624.00 $1,283,777.44 $6,032,118.22 $636,920.75 $5,835,061.07 0 7 0 15 0 0 11 0 0 0 0 Continued on next page $0.00 $352,380.00 $0.00 $7,766,250.00 $0.00 $0.00 $1,288,716.00 $0.00 $0.00 $0.00 $0.00 Amount Dividends Paid Number of Missed of Missed to Date Dividends Dividend Dividends and Interest 220 APPENDIX A I TRANSACTION DETAIL I JANUARY 27, 2017 11 8,128 39 8,11,14 8,130 8 8,11,14 8,14,44 125 8,14, 18,44 11 8,11,14 8,11,14 MILWAUKEE MILWAUKEE MCLEAN MCLEAN CAPITAL COMMERCE BANCORP, INC. CAPITAL ONE FINANCIAL CORP CAPITAL ONE FINANCIAL CORP RANCHO SANTA MARGARITA CALWEST BANCORP CAPITAL COMMERCE BANCORP, INC. RANCHO SANTA MARGARITA CALWEST BANCORP RALEIGH ASHLAND CALVERT FINANCIAL CORPORATION CAPITAL BANK CORPORATION ASHLAND CALVERT FINANCIAL CORPORATION RALEIGH THOUSAND OAKS CALIFORNIA OAKS STATE BANK ROCKVILLE THOUSAND OAKS CALIFORNIA OAKS STATE BANK CAPITAL BANK CORPORATION LAFAYETTE CALIFORNIA BANK OF COMMERCE CAPITAL BANCORP, INC. CA LAFAYETTE CALIFORNIA BANK OF COMMERCE ROCKVILLE CA STARKVILLE CADENCE FINANCIAL CORPORATION CAPITAL BANCORP, INC. MO STARKVILLE CADENCE FINANCIAL CORPORATION VA VA WI WI NC NC MD MD MO CA CA CA CA MS MS UT UT LOGAN UT VA LOGAN WEST POINT C&F FINANCIAL CORPORATION VA VA CACHE VALLEY BANKING COMPANY WEST POINT C&F FINANCIAL CORPORATION LOGAN WEST POINT C&F FINANCIAL CORPORATION VA CACHE VALLEY BANKING COMPANY WEST POINT C&F FINANCIAL CORPORATION IL IL MO MO MO MO State CACHE VALLEY BANKING COMPANY CATLIN CLAYTON BUSINESS BANCSHARES, INC. CATLIN CLAYTON BUTLER POINT, INC. CLAYTON BUSINESS BANCSHARES, INC. BUTLER POINT, INC. CLAYTON BUSINESS BANCSHARES, INC. City BUSINESS BANCSHARES, INC. Footnote Institution Name 6/17/2009 11/14/2008 10/2/2015 4/10/2009 1/28/2011 12/12/2008 12/30/2010 12/23/2008 12/23/2015 1/23/2009 2/17/2016 1/23/2009 12/8/2010 1/23/2009 9/15/2011 2/27/2009 3/4/2011 1/9/2009 7/14/2011 12/18/2009 12/23/2008 5/14/2014 4/11/2012 7/27/2011 1/9/2009 11/2/2011 3/13/2009 4/24/2013 1/9/2013 5/23/2012 4/24/2009 $3,555,199,000.00 $5,100,000.00 $41,279,000.00 $4,700,000.00 $4,656,000.00 $1,037,000.00 $3,300,000.00 $4,000,000.00 $44,000,000.00 $4,640,000.00 $4,767,000.00 $20,000,000.00 $607,000.00 $15,000,000.00 Original Investment Date Amount $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Outstanding Investment Investment Status* Redeemed, in $3,806,873,702.13 full; warrants not outstanding Sold, in full; $2,764,934.40 warrants not outstanding Redeemed, in $45,252,104.25 full; warrants not outstanding Redeemed, in $5,452,281.19 full; warrants not outstanding Sold, in full; $5,285,163.67 warrants not outstanding Redeemed, in $1,604,019.48 full; warrants not outstanding Redeemed, in $3,802,219.25 full; warrants not outstanding Redeemed, in $4,755,899.67 full; warrants not outstanding Sold, in full; $41,984,062.50 warrants not outstanding Redeemed, in $10,674,333.80 full; warrants not outstanding Redeemed, in $25,205,957.78 full; warrants not outstanding Redeemed, in $724,123.53 full; warrants not outstanding Redeemed, in $18,707,708.84 full; warrants not outstanding Total Cash Back2 CPP TRANSACTIONS DETAIL, AS OF 12/31/2016 (CONTINUED) $3,555,199,000.00 $2,455,328.00 $41,279,000.00 $4,700,000.00 $4,656,000.00 $1,037,000.00 $3,300,000.00 $4,000,000.00 $38,000,000.00 $9,407,000.00 $10,000,000.00 $10,000,000.00 $607,000.00 $6,500,000.00 $2,500,000.00 $6,000,000.00 Amount (Fee)4 3,555,199 1,227,664 41,279 4,700 24,445,000 1,037 3,300 4,000 44,000 9,407 10,000 10,000 607 6,500 2,500 6,000 Shares Capital Repayment / Disposition / Auction3,5 $1,000.00 $2.00 $1,000.00 $1,000.00 $0.20 $1,000.00 $1,000.00 $1,000.00 $863.64 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 Avg. Price ($2,644,672.00) ($6,000,000.00) (Realized Loss) / (Write-off) $233,000.00 Gain5 $235,000.00 $52,000.00 $165,000.00 $200,000.00 $238,000.00 $2,303,180.00 $30,000.00 $750,000.00 Wt Amount 235 52 165 200 238 167,504 30 750 Wt Shares Warrant Proceeds Dividends and Interest $105,174,637.58 $309,606.40 $3,973,104.25 $517,281.19 $396,163.67 $515,019.48 $337,219.25 $555,899.67 $3,984,062.50 $1,029,333.80 $2,902,777.78 $87,123.53 $2,957,708.84 0 0 0 0 21 0 0 0 0 0 0 0 0 Continued on next page $0.00 $0.00 $0.00 $0.00 $1,658,213.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Amount Dividends Paid Number of Missed of Missed to Date Dividends Dividend TRANSACTION DETAIL I APPENDIX A I JANUARY 27, 2017 221 8,18 8,57,97 8,14, 18,44 11 9,11,36 11 14,15, 45 8,14 OR OR CAPITAL PACIFIC BANCORP PORTLAND CAPITAL PACIFIC BANCORP PORTLAND LOS ANGELES LOS ANGELES CATHAY GENERAL BANCORP CATHAY GENERAL BANCORP CARTERSVILLE CARTERSVILLE CARTERSVILLE CBB BANCORP CBB BANCORP ALEDO CB HOLDING CORP. CBB BANCORP ALEDO CB HOLDING CORP. ROCK HILL LOS ANGELES CATHAY GENERAL BANCORP ROCK HILL LOS ANGELES CATHAY GENERAL BANCORP CATSKILL HUDSON BANCORP, INC. EVERETT CASCADE FINANCIAL CORPORATION ROCK HILL EVERETT CASCADE FINANCIAL CORPORATION CATSKILL HUDSON BANCORP, INC. NEW YORK CARVER BANCORP, INC. CATSKILL HUDSON BANCORP, INC. NEW YORK BALTIMORE CARVER BANCORP, INC. BALTIMORE CARROLLTON BANCORP LINCOLNTON LINCOLNTON CAROLINA TRUST BANK CAROLINA TRUST BANK CARROLLTON BANCORP LINCOLNTON LINCOLNTON CAROLINA TRUST BANK LINCOLNTON GREENSBORO CAROLINA BANK HOLDINGS, INC. CAROLINA TRUST BANK GREENSBORO CAROLINA BANK HOLDINGS, INC. CAROLINA TRUST BANK GREENSBORO GREENSBORO CAROLINA BANK HOLDINGS, INC. GA GA GA IL IL NY NY NY CA CA CA CA WA WA NY NY MD MD NC NC NC NC NC NC NC NC NC NC GREENSBORO CAROLINA BANK HOLDINGS, INC. CAROLINA BANK HOLDINGS, INC. MO CARDINAL BANCORP II, INC. WASHINGTON MO OR CARDINAL BANCORP II, INC. WASHINGTON OR VA State CAPITAL PACIFIC BANCORP PORTLAND MCLEAN City CAPITAL PACIFIC BANCORP PORTLAND CAPITAL ONE FINANCIAL CORP Footnote Institution Name 11/28/2012 12/29/2009 2/20/2009 10/14/2011 5/29/2009 7/21/2011 12/22/2009 2/27/2009 12/9/2013 9/30/2013 3/20/2013 12/5/2008 6/30/2011 11/21/2008 8/27/2010 1/16/2009 4/19/2013 2/13/2009 6/11/2013 3/26/2013 1/11/2013 11/30/2012 2/6/2009 4/19/2013 3/26/2013 2/21/2013 2/20/2013 1/9/2009 9/8/2011 10/23/2009 1/11/2013 11/9/2012 11/8/2012 12/23/2008 12/9/2009 Date $1,753,000.00 $2,644,000.00 $4,114,000.00 $3,500,000.00 $3,000,000.00 $258,000,000.00 $38,970,000.00 $18,980,000.00 $9,201,000.00 $4,000,000.00 $16,000,000.00 $6,251,000.00 $4,000,000.00 Original Investment Amount $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Outstanding Investment Currently Not Collectible Sold, in full; $4,982,141.86 warrants not outstanding $271,579.53 Redeemed, in $7,448,071.47 full; warrants not outstanding Redeemed, in $329,874,444.96 full; warrants not outstanding Sold, in full; $17,678,900.00 warrants not outstanding Redeemed, in $20,511,580.55 full; warrants not outstanding Redeemed, in $11,388,958.51 full; warrants not outstanding Sold, in full; $3,994,452.00 warrants not outstanding Sold, in full; $19,941,788.94 warrants not outstanding Redeemed, in $7,547,479.56 full; warrants not outstanding Sold, in full; $4,742,850.89 warrants not outstanding Investment Total Cash Back2 Status* CPP TRANSACTIONS DETAIL, AS OF 12/31/2016 (CONTINUED) $1,268,825.60 $6,500,000.00 $129,000,000.00 $129,000,000.00 $16,250,000.00 $18,980,000.00 $9,201,000.00 $3,412,000.00 $435,756.60 $14,525,843.40 $6,251,000.00 $3,505,712.96 $247,727.04 Amount ($15,880.00) ($34,120.00) ($149,616.00) ($25,000.00) (Fee)4 1,360 6,500 129,000 129,000 38,970 18,980 9,201 4,000 466 15,534 6,251,000 3,736 264 Shares Capital Repayment / Disposition / Auction3,5 $932.96 $1,000.00 $1,000.00 $1,000.00 $416.99 $1,000.00 $1,000.00 $853.00 $935.10 $935.10 $1.00 $938.36 $938.36 Avg. Price ($91,174.40) ($4,114,000.00) ($22,720,000.00) ($588,000.00) ($30,243.40) ($1,008,156.60) ($230,287.04) ($16,272.96) (Realized Loss) / (Write-off) Gain5 $263,000.00 $13,107,778.30 $213,594.16 $19,132.00 $1,800,000.00 $313,000.00 $169,042.00 $146,500,064.55 Wt Amount 263 1,846,374 205,379 86,957 357,675 313,000 200 12,657,960 Wt Shares Warrant Proceeds $799,528.40 $271,579.53 $685,071.47 $58,766,666.66 $1,428,900.00 $1,531,580.55 $1,974,364.35 $613,320.00 $3,329,804.94 $983,479.56 $845,368.89 0 4 0 7 0 0 3 0 0 0 Continued on next page $0.00 $224,240.00 $0.00 $3,409,875.00 $0.00 $0.00 $150,000.00 $0.00 $0.00 $0.00 Amount Dividends Paid Number of Missed of Missed to Date Dividends Dividend Dividends and Interest 222 APPENDIX A I TRANSACTION DETAIL I JANUARY 27, 2017 8,11,14 8,113 45 8,11,14 12,16 8,14 11,59 44 8 8,14 LOS ANGELES LOS ANGELES LOS ANGELES CENTER FINANCIAL CORPORATION / BBCN BANCORP, INC. CENTER FINANCIAL CORPORATION / BBCN BANCORP, INC. CENTER FINANCIAL CORPORATION / BBCN BANCORP, INC. HOUSTON SOMERVILLE CENTRAL BANCORP, INC. (MA) CENTRAL BANCSHARES, INC. MORGANTOWN CENTRA FINANCIAL HOLDINGS, INC. GARLAND MORGANTOWN CENTRA FINANCIAL HOLDINGS, INC. CENTRAL BANCORP, INC. (TX) MORGANTOWN CENTRA FINANCIAL HOLDINGS, INC. GARLAND DAVENPORT CENTERSTATE BANKS OF FLORIDA INC. CENTRAL BANCORP, INC. (TX) DAVENPORT CENTERSTATE BANKS OF FLORIDA INC. SOMERVILLE DAVENPORT CENTERSTATE BANKS OF FLORIDA INC. SOMERVILLE MILFORD CENTERBANK CENTRAL BANCORP, INC. (MA) MILFORD CENTERBANK CENTRAL BANCORP, INC. (MA) MILFORD MILFORD CENTERBANK CENTERBANK MILFORD UNION CENTER BANCORP, INC. CENTERBANK UNION CENTER BANCORP, INC. LEBANON UNION CENTER BANCORP, INC. CEDARSTONE BANK ELKTON CECIL BANCORP, INC. LEBANON RUSSELLVILLE CBS BANC-CORP. CEDARSTONE BANK RUSSELLVILLE RUSSELLVILLE CBS BANC-CORP. RUSSELLVILLE CBS BANC-CORP. RUSSELLVILLE CARTERSVILLE CBB BANCORP CBS BANC-CORP. CARTERSVILLE CBB BANCORP CBS BANC-CORP. CARTERSVILLE City CBB BANCORP Footnote Institution Name TX TX TX MA MA MA WV WV WV FL FL FL OH OH OH OH OH CA CA CA NJ NJ NJ TN TN MD AL AL AL AL AL GA GA GA State 1/30/2009 8/29/2014 2/27/2009 10/19/2011 8/25/2011 12/5/2008 4/15/2009 3/31/2009 1/16/2009 10/28/2009 9/30/2009 11/21/2008 3/26/2013 1/11/2013 11/1/2012 10/29/2012 5/1/2009 5/27/2015 6/27/2012 12/12/2008 12/7/2011 9/15/2011 1/9/2009 11/20/2013 2/6/2009 12/23/2008 9/11/2012 8/10/2012 8/9/2012 8/7/2012 3/27/2009 3/26/2013 1/11/2013 11/29/2012 $5,800,000.00 $22,500,000.00 $10,000,000.00 $15,000,000.00 $27,875,000.00 $2,250,000.00 $55,000,000.00 $10,000,000.00 $3,564,000.00 $11,560,000.00 $24,300,000.00 Original Investment Date Amount $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $11,560,000.00 $0.00 Outstanding Investment Investment Status* Redeemed, in $6,859,176.83 full; warrants not outstanding Redeemed, in $31,086,221.13 full; warrants not outstanding Redeemed, in $13,886,111.11 full; warrants not outstanding Redeemed, in $15,922,937.50 full; warrants not outstanding Redeemed, in $29,283,302.58 full; warrants not outstanding Sold, in full; $2,344,662.43 warrants not outstanding Redeemed, in $65,855,083.33 full; warrants not outstanding Redeemed, in $11,586,666.67 full; warrants not outstanding $22,500,000.00 $10,000,000.00 $15,000,000.00 $27,875,000.00 $1,831,500.00 $24,750.00 $55,000,000.00 $10,000,000.00 ($6,437.50) ($18,562.50) $1,000.00 $905.20 $905.20 $932.26 Avg. Price ($5,250.00) ($2,206,944.00) ($96,696.00) ($205,740.14) Gain5 Wt Amount $178,000.00 $131,297.76 $689,313.24 $287,213.85 $115,861.34 178 144 756 315 132 Wt Shares Dividends and Interest $4,548,136.70 22,500 10,000 15,000 27,875 2,220 30 55,000 10,000 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $825.00 $825.00 $1,000.00 $1,000.00 ($388,500.00) $1,125,000.00 $2,525,000.00 $750,000.00 $212,000.00 $84,057.43 $1,115,500.00 $245,000.00 1,125 234,742 750 125,413 113 350,767 86,705 $769,176.83 $7,461,221.13 $1,361,111.11 $172,937.50 $1,196,302.58 $429,355.00 $1,341,666.67 0 0 0 0 0 0 0 0 0 28 0 Continued on next page $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $5,317,600.00 $0.00 Amount Dividends Paid Number of Missed of Missed to Date Dividends Dividend $930,098.50 3,564 23,280 1,020 3,037 Shares Warrant Proceeds Redeemed, in $4,672,098.50 full; warrants not outstanding ($219,963.60) ($363.42) ($32,969.92) (Fee)4 (Realized Loss) / (Write-off) $516,988.89 $3,564,000.00 $21,073,056.00 $923,304.00 $2,831,259.86 Amount Capital Repayment / Disposition / Auction3,5 Full investment outstanding; $516,988.89 warrants outstanding Sold, in full; $27,432,357.95 warrants not outstanding Total Cash Back2 CPP TRANSACTIONS DETAIL, AS OF 12/31/2016 (CONTINUED) TRANSACTION DETAIL I APPENDIX A I JANUARY 27, 2017 223 14,15 8,14,44 8,17,44 93 45 40 11 8,14 OTTAWA OTTAWA OTTAWA OTTAWA OTTAWA OTTAWA OTTAWA SANTA FE CENTRUE FINANCIAL CORPORATION CENTRUE FINANCIAL CORPORATION CENTRUE FINANCIAL CORPORATION CENTRUE FINANCIAL CORPORATION CENTRUE FINANCIAL CORPORATION CENTURY FINANCIAL SERVICES CORPORATION HARRISBURG CENTRIC FINANCIAL CORPORATION CENTRUE FINANCIAL CORPORATION HARRISBURG CENTRIC FINANCIAL CORPORATION CENTRUE FINANCIAL CORPORATION POWHATAN CENTRAL VIRGINIA BANKSHARES, INC. OTTAWA POWHATAN CENTRAL VIRGINIA BANKSHARES, INC. CENTRUE FINANCIAL CORPORATION FRESNO CENTRAL VALLEY COMMUNITY BANCORP BEDFORD FRESNO CENTRAL VALLEY COMMUNITY BANCORP BEDFORD FRESNO CENTRAL VALLEY COMMUNITY BANCORP CENTRIX BANK & TRUST HONOLULU CENTRAL PACIFIC FINANCIAL CORP. CENTRIX BANK & TRUST HONOLULU HONOLULU NM IL IL IL IL IL IL IL IL NH NH PA PA VA VA CA CA CA HI HI HI HI HONOLULU CENTRAL PACIFIC FINANCIAL CORP. CENTRAL PACIFIC FINANCIAL CORP. NJ CENTRAL PACIFIC FINANCIAL CORP. NJ CENTRAL JERSEY BANCORP OAKHURST OH CENTRAL JERSEY BANCORP OAKHURST FAIRLAWN CENTRAL FEDERAL CORPORATION OH NJ FAIRLAWN CENTRAL FEDERAL CORPORATION TX TX TX TX TX State CENTRAL JERSEY BANCORP OAKHURST TEMPLE TEMPLE TEMPLE CENTRAL COMMUNITY CORPORATION TEMPLE CENTRAL COMMUNITY CORPORATION CENTRAL COMMUNITY CORPORATION HOUSTON CENTRAL COMMUNITY CORPORATION City CENTRAL BANCSHARES, INC. Footnote Institution Name 6/19/2009 10/15/2014 3/19/2014 2/10/2014 1/6/2014 10/29/2013 10/18/2013 9/25/2013 1/9/2009 7/28/2011 2/6/2009 7/14/2011 12/18/2009 10/1/2013 1/30/2009 9/28/2011 8/18/2011 1/30/2009 6/11/2013 4/4/2012 6/22/2011 1/9/2009 12/1/2010 11/24/2010 12/23/2008 9/26/2012 12/5/2008 1/11/2013 12/11/2012 12/10/2012 2/20/2009 7/6/2011 Date $10,000,000.00 $32,668,000.00 $7,500,000.00 $6,056,000.00 $11,385,000.00 $7,000,000.00 $135,000,000.00 $11,300,000.00 $7,225,000.00 $22,000,000.00 Original Investment Amount $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Outstanding Investment Sold, in full; $13,186,960.25 warrants not outstanding Sold, in full; $11,205,387.14 warrants not outstanding Redeemed, in $8,887,791.42 full; warrants not outstanding Redeemed, in $6,739,821.89 full; warrants not outstanding Sold, in full; $3,800,656.00 warrants not outstanding Redeemed, in $8,077,516.47 full; warrants not outstanding Sold, in full; $75,036,891.42 warrants not outstanding Redeemed, in $12,704,145.10 full; warrants not outstanding Sold, in full; $3,612,118.06 warrants not outstanding Sold, in full; $25,797,528.80 warrants not outstanding Investment Total Cash Back2 Status* CPP TRANSACTIONS DETAIL, AS OF 12/31/2016 (CONTINUED) $577,638.02 $1,950,000.00 $8,211,450.00 $7,500,000.00 $6,056,000.00 $3,350,000.00 $7,000,000.00 $36,427,038.55 $36,337,500.00 $11,300,000.00 $3,000,000.00 $15,043,340.40 $5,333,059.60 $5,800,000.00 Amount ($5,776.38) ($19,500.00) ($82,114.50) ($387,816.38) ($454,218.75) ($203,764.00) (Fee)4 1,402 6,000 25,266 7,500 6,056 11,385 7,000 2,770,117 2,850,000 11,300 7,225 16,242 5,758 5,800 Shares Capital Repayment / Disposition / Auction3,5 $412.01 $325.00 $325.00 $1,000.00 $1,000.00 $294.25 $1,000.00 $13.15 $12.75 $1,000.00 $415.22 $926.20 $926.20 $1,000.00 Avg. Price ($824,361.98) ($4,050,000.00) ($17,054,550.00) ($8,035,000.00) ($30,113,532.58) ($32,121,928.87) ($4,225,000.00) ($1,198,659.60) ($424,940.40) (Realized Loss) / (Write-off) Gain5 $2,000.00 $375,000.00 $182,000.00 $185,016.80 $751,888.00 $319,658.99 $1,058,725.80 $290,000.00 Wt Amount 508,320 375 182 79,067 79,288 268,621 1,100 290 Wt Shares Warrant Proceeds $2,938,871.30 $571,690.00 $1,012,791.42 $501,821.89 $450,656.00 $892,499.67 $2,362,500.00 $1,084,486.11 $612,118.06 $4,566,167.00 0 18 0 0 15 0 0 0 8 0 Continued on next page $0.00 $6,959,475.00 $0.00 $0.00 $2,134,688.00 $0.00 $0.00 $0.00 $722,500.00 $0.00 Amount Dividends Paid Number of Missed of Missed to Date Dividends Dividend Dividends and Interest 224 APPENDIX A I TRANSACTION DETAIL I JANUARY 27, 2017 CHICAGO CHICAGO CHICAGO SHORE CORPORATION CHICAGO SHORE CORPORATION MO GA CITIZENS BANCSHARES CO. CHILLICOTHE ATLANTA ATLANTA COVINGTON COVINGTON COVINGTON VERSAILLES SOUTH HILL SOUTH HILL CITIZENS BANCSHARES CORPORATION CITIZENS BANCSHARES CORPORATION CITIZENS BANK & TRUST COMPANY, ESTABLISHED 1945 CITIZENS BANK & TRUST COMPANY, ESTABLISHED 1945 CITIZENS BANK & TRUST COMPANY, ESTABLISHED 1945 CITIZENS COMMERCE BANCSHARES, INC. CITIZENS COMMUNITY BANK CITIZENS COMMUNITY BANK 8 8,14,44 8 VA VA KY LA LA LA GA MO CITIZENS BANCSHARES CO. CHILLICOTHE 9,11,36 MO CITIZENS BANCSHARES CO. CHILLICOTHE CA CA PA PA PA NY NY NY NY NY IL IL IL MO NEVADA CITY WELLSBORO CITIZENS & NORTHERN CORPORATION NEVADA CITY WELLSBORO CITIZENS & NORTHERN CORPORATION CITIZENS BANCORP WELLSBORO CITIZENS & NORTHERN CORPORATION CITIZENS BANCORP NEW YORK NEW YORK CITIGROUP INC. CITIGROUP INC. NEW YORK CITIGROUP INC. NEW YORK CHICAGO CHICAGO SHORE CORPORATION CIT GROUP INC. IL CHICAGO CHICAGO SHORE CORPORATION NEW YORK AR CHAMBERS BANCSHARES, DANVILLE INC. CIT GROUP INC. AR CHAMBERS BANCSHARES, DANVILLE INC. CITIZENS BANCSHARES CO. CHILLICOTHE 8,14 8,55,97 11 19,30 23 8 15 NM SANTA FE CENTURY FINANCIAL SERVICES CORPORATION NM SANTA FE CENTURY FINANCIAL SERVICES CORPORATION NM State SANTA FE City CENTURY FINANCIAL SERVICES CORPORATION Footnote Institution Name $2,330,000,000.00 $7,000,000.00 $19,817,000.00 7/28/2011 12/23/2008 2/6/2009 8/6/2015 6/29/2015 3/20/2009 8/13/2010 3/6/2009 3/26/2013 2/8/2013 2/7/2013 5/29/2009 9/23/2011 12/23/2008 9/1/2010 8/4/2010 1/16/2009 1/31/2011 12/10/2010 $3,000,000.00 $6,300,000.00 $2,400,000.00 $7,462,000.00 $24,990,000.00 $10,400,000.00 $26,440,000.00 10/28/2008 $25,000,000,000.00 12/10/2009 12/31/2008 4/25/2014 3/17/2014 3/14/2014 7/31/2009 4/1/2015 5/29/2009 1/11/2013 12/20/2012 12/19/2012 Original Investment Date Amount $0.00 $6,300,000.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Outstanding Investment Investment Status* $1,000.00 $650.13 $1,000.00 $512.50 $512.50 $1,000.00 $4.14 $991.00 $991.00 $1.00 $0.99 $0.99 Avg. Price ($839,688.00) ($5,850,000.00) ($6,332,625.00) ($10,400,000.00) ($2,330,000,000.00) ($60,660.00) ($2,340.00) ($149,400.00) ($600.00) $6,852,354,470.95 Gain5 Wt Amount $150,000.00 $53,015.60 $387,028.12 $258,018.75 $400,000.00 $54,621,848.84 $347,193.00 $991,000.00 $297,953.37 $198,635.58 150 120 750 500 194,794 210,084,034 350 991,000 300,000 200,000 Wt Shares Dividends and Interest $765,003.00 $535,813.22 $628,033.33 $223,571.11 $2,049,100.00 $932,291,666.67 $43,687,500.00 $1,766,525.81 $11,290,302.62 0 29 5 0 12 9 0 0 0 0 1 0 0 Continued on next page $0.00 $3,182,287.50 $163,500.00 $0.00 $4,086,000.00 $1,275,300.00 $0.00 $0.00 $0.00 $0.00 $29,125,000.00 $0.00 $0.00 Amount Dividends Paid Number of Missed of Missed to Date Dividends Dividend $424,645.84 3,000 2,400 7,462 12,000 12,990 26,440 7,692,307,692 6,740 260 19,817,000 9,960,000 40,000 Shares Warrant Proceeds Redeemed, in $3,574,645.84 full; warrants not outstanding ($25,000.00) ($128,073.75) ($69,370.00) ($98,500.00) (Fee)4 (Realized Loss) / (Write-off) $180,258.50 $3,000,000.00 $1,560,312.00 $7,462,000.00 $6,150,000.00 $6,657,375.00 $26,440,000.00 $25,000,000,000.00 $6,679,340.00 $257,660.00 $19,817,000.00 $9,810,600.00 $39,400.00 Amount Capital Repayment / Disposition / Auction3,5 Full investment outstanding; warrants outstanding $180,258.50 Sold, in full; $2,353,330.60 warrants not outstanding Redeemed, in $7,997,813.22 full; warrants not outstanding Sold, in full; $13,952,381.45 warrants not outstanding Currently Not $223,571.11 Collectible Redeemed, in $28,889,100.00 full; warrants not outstanding Redeemed, in $32,839,267,986.46 full; warrants not outstanding Exited $43,687,500.00 bankruptcy/ Receivership Sold, in full; $8,981,348.81 warrants not outstanding Redeemed, in $32,098,302.62 full; warrants not outstanding Total Cash Back2 CPP TRANSACTIONS DETAIL, AS OF 12/31/2016 (CONTINUED) TRANSACTION DETAIL I APPENDIX A I JANUARY 27, 2017 225 8,17 82 8,14 11 8,9,124 45 86 11 NC NC NC NJ SC SC CITIZENS SOUTH BANKING GASTONIA CORPORATION CITIZENS SOUTH BANKING GASTONIA CORPORATION CITIZENS SOUTH BANKING GASTONIA CORPORATION NEWARK NEWARK BEVERLY HILLS BEVERLY HILLS BEVERLY HILLS BEVERLY HILLS CLOVER CLOVER CLOVER CLOVER FERNANDINA BEACH FERNANDINA BEACH FERNANDINA BEACH FERNANDINA BEACH FERNANDINA BEACH FERNANDINA BEACH HILTON HEAD ISLAND HILTON HEAD ISLAND HILTON HEAD ISLAND CITY NATIONAL BANCSHARES CORPORATION CITY NATIONAL BANCSHARES CORPORATION CITY NATIONAL CORPORATION CITY NATIONAL CORPORATION CITY NATIONAL CORPORATION CITY NATIONAL CORPORATION CLOVER COMMUNITY BANKSHARES, INC. CLOVER COMMUNITY BANKSHARES, INC. CLOVER COMMUNITY BANKSHARES, INC. CLOVER COMMUNITY BANKSHARES, INC. COASTAL BANKING COMPANY, INC. COASTAL BANKING COMPANY, INC. COASTAL BANKING COMPANY, INC. COASTAL BANKING COMPANY, INC. COASTAL BANKING COMPANY, INC. COASTAL BANKING COMPANY, INC. COASTALSOUTH BANCHARES, INC. COASTALSOUTH BANCHARES, INC. COASTALSOUTH BANCHARES, INC. SC FL FL FL FL FL FL SC SC SC SC CA CA CA CA NJ MI KY KY MI BOWLING GREEN CITIZENS FIRST CORPORATION CITIZENS REPUBLIC BANCORP, INC. / FLINT FIRSTMERIT CORPORATION BOWLING GREEN CITIZENS FIRST CORPORATION KY KY CITIZENS REPUBLIC BANCORP, INC. / FLINT FIRSTMERIT CORPORATION BOWLING GREEN CITIZENS FIRST CORPORATION MI BOWLING GREEN CITIZENS FIRST CORPORATION KY State CITIZENS REPUBLIC BANCORP, INC. / FLINT FIRSTMERIT CORPORATION BOWLING GREEN City CITIZENS FIRST CORPORATION Footnote Institution Name 3/11/2013 3/8/2013 8/28/2009 6/12/2013 4/10/2013 4/9/2013 3/11/2013 3/8/2013 12/5/2008 1/11/2013 11/29/2012 11/28/2012 3/27/2009 4/7/2010 3/3/2010 12/30/2009 11/21/2008 8/7/2015 4/10/2009 11/9/2011 9/22/2011 12/12/2008 5/13/2015 4/12/2013 12/12/2008 4/15/2015 1/15/2014 2/13/2013 2/16/2011 12/19/2008 Date $16,015,000.00 $9,950,000.00 $3,000,000.00 $400,000,000.00 $9,439,000.00 $20,500,000.00 $300,000,000.00 $8,779,000.00 Original Investment Amount $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Outstanding Investment Sold, in full; $14,257,487.71 warrants not outstanding Sold, in full; $11,166,897.79 warrants not outstanding Sold, in full; $3,318,585.05 warrants not outstanding Redeemed, in $442,416,666.67 full; warrants not outstanding Sold, in full; $2,508,609.00 warrants not outstanding Redeemed, in $23,572,379.22 full; warrants not outstanding Redeemed, in $381,395,557.08 full; warrants not outstanding Redeemed, in $12,236,725.89 full; warrants not outstanding Investment Total Cash Back2 Status* CPP TRANSACTIONS DETAIL, AS OF 12/31/2016 (CONTINUED) $12,335,976.50 $397,550.00 $5,730,600.00 $3,772,645.00 $1,662,874.50 $955,825.50 $200,000,000.00 $200,000,000.00 $2,226,750.00 $20,500,000.00 $300,000,000.00 $3,265,788.00 $3,300,904.00 $2,212,308.00 Amount ($95,032.45) ($25,000.00) (Fee)4 15,515 500 6,000 3,950 1,905 1,095 200,000 200,000 9,439 20,500 300,000 93 94 63 Shares Capital Repayment / Disposition / Auction3,5 $795.10 $795.10 $955.10 $955.10 $872.90 $872.90 $1,000.00 $1,000.00 $235.91 $1,000.00 $1,000.00 $35,116.00 $35,116.00 $35,116.00 Avg. Price ($3,179,023.50) ($102,450.00) ($269,400.00) ($177,355.00) ($242,125.50) ($139,174.50) ($7,212,250.00) (Realized Loss) / (Write-off) Gain5 $25,990.47 $389,857.05 $225,647.45 $99,000.00 $114,021.50 $18,500,000.00 $225,157.00 $12,150,120.44 $1,705,802.78 Wt Amount 30 450 145,579 60,000 150 1,128,668 450,314 2,571,998 254,218 Wt Shares Warrant Proceeds $1,235,448.96 $1,434,037.79 $610,863.55 $23,916,666.67 $281,859.00 $2,847,222.22 $1,751,923.11 8 6 0 0 22 0 0 0 Continued on next page $1,687,900.00 $746,250.00 $0.00 $0.00 $2,973,285.00 $0.00 $0.00 $0.00 Amount Dividends Paid Number of Missed of Missed to Date Dividends Dividend Dividends and Interest 226 APPENDIX A I TRANSACTION DETAIL I JANUARY 27, 2017 14,15 11 11 8,14,44 11,16 8,11,14 8,14 44 45 CO PA PA YORK YORK YORK LAMAR LAMAR LAMAR LAMAR WEST CONSHOHOCKEN WEST CONSHOHOCKEN FITZGERALD FITZGERALD FITZGERALD FITZGERALD FITZGERALD TACOMA TACOMA TACOMA CODORUS VALLEY BANCORP, INC. CODORUS VALLEY BANCORP, INC. CODORUS VALLEY BANCORP, INC. COLOEAST BANKSHARES, INC. COLOEAST BANKSHARES, INC. COLOEAST BANKSHARES, INC. COLOEAST BANKSHARES, INC. COLONIAL AMERICAN BANK COLONIAL AMERICAN BANK COLONY BANKCORP, INC. COLONY BANKCORP, INC. COLONY BANKCORP, INC. COLONY BANKCORP, INC. COLONY BANKCORP, INC. COLUMBIA BANKING SYSTEM, INC. COLUMBIA BANKING SYSTEM, INC. COLUMBIA BANKING SYSTEM, INC. CO DALLAS DALLAS DALLAS NEWPORT BEACH NEWPORT BEACH NEWPORT BEACH LOUISVILLE LOUISVILLE LOUISVILLE LOUISVILLE LOUISVILLE COMERICA INC. COMERICA INC. COMERICA INC. COMMERCE NATIONAL BANK COMMERCE NATIONAL BANK COMMERCE NATIONAL BANK COMMONWEALTH BANCSHARES, INC. COMMONWEALTH BANCSHARES, INC. COMMONWEALTH BANCSHARES, INC. COMMONWEALTH BANCSHARES, INC. COMMONWEALTH BANCSHARES, INC. KY KY KY KY KY CA CA CA TX TX TX CO CO COLUMBINE CAPITAL CORP. BUENA VISTA COLUMBINE CAPITAL CORP. BUENA VISTA WA WA WA GA GA GA GA GA CO CO CO PA PA PA CO DENVER DENVER COBIZ FINANCIAL INC. CO SC State COBIZ FINANCIAL INC. DENVER HILTON HEAD ISLAND City COBIZ FINANCIAL INC. COASTALSOUTH BANCHARES, INC. Footnote Institution Name 8/10/2012 8/9/2012 8/8/2012 8/7/2012 5/22/2009 10/1/2013 10/7/2009 1/9/2009 5/12/2010 3/17/2010 11/14/2008 9/22/2011 2/27/2009 9/1/2010 8/11/2010 11/21/2008 6/12/2013 3/26/2013 2/8/2013 2/7/2013 1/9/2009 10/26/2011 3/27/2009 9/12/2013 7/22/2013 7/19/2013 2/13/2009 9/28/2011 8/18/2011 1/9/2009 11/23/2011 9/8/2011 12/19/2008 4/9/2013 $20,400,000.00 $5,000,000.00 $2,250,000,000.00 $2,260,000.00 $76,898,000.00 $28,000,000.00 $574,000.00 $10,000,000.00 $16,500,000.00 $64,450,000.00 Original Investment Date Amount $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Outstanding Investment Investment Status* Sold, in full; $21,575,016.54 warrants not outstanding Redeemed, in $5,602,969.61 full; warrants not outstanding Redeemed, in $2,582,039,543.40 full; warrants not outstanding Redeemed, in $2,689,478.64 full; warrants not outstanding Redeemed, in $86,821,419.22 full; warrants not outstanding Sold, in full; $26,480,089.20 warrants not outstanding Redeemed, in $668,142.53 full; warrants not outstanding Sold, in full; $10,670,784.03 warrants not outstanding Redeemed, in $19,178,479.00 full; warrants not outstanding Redeemed, in $73,357,086.72 full; warrants not outstanding Total Cash Back2 CPP TRANSACTIONS DETAIL, AS OF 12/31/2016 (CONTINUED) $600,000.00 $13,100,250.00 $1,469,250.00 $130,500.00 $5,000,000.00 $2,250,000,000.00 $2,260,000.00 $76,898,000.00 $265,135.29 $21,633,944.71 $574,000.00 $8,990,505.00 $46,995.00 $16,500,000.00 $64,450,000.00 Amount ($218,990.80) ($90,375.00) ($127,335.27) (Fee)4 800,000 17,467,000 1,959,000 174,000 5,000 2,250,000 2,260 76,898 339 27,661 574 9,948 52 16,500 64,450 Shares Capital Repayment / Disposition / Auction3,5 $0.75 $0.75 $0.75 $0.75 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $782.11 $782.11 $1,000.00 $903.75 $903.75 $1,000.00 $1,000.00 Avg. Price ($200,000.00) ($4,366,750.00) ($489,750.00) ($43,500.00) ($73,864.71) ($6,027,055.29) ($957,495.00) ($5,005.00) (Realized Loss) / (Write-off) Gain5 $105,732.00 $792,990.00 $566,858.50 $181,102,043.40 $113,000.00 $3,301,647.00 $810,000.00 $29,000.00 $494,381.25 $526,604.00 $143,677.00 Wt Amount 120,000 900,000 87,209 11,479,592 113 398,023 500,000 29 50 263,859 895,968 Wt Shares Warrant Proceeds Dividends and Interest $5,529,294.54 $36,111.11 $150,937,500.00 $316,478.64 $6,621,772.22 $3,990,000.00 $65,142.53 $1,229,277.78 $2,151,875.00 $8,763,409.72 0 3 0 0 0 4 2 8 0 0 Continued on next page $0.00 $150,000.00 $0.00 $0.00 $0.00 $1,400,000.00 $15,655.00 $1,090,000.00 $0.00 $0.00 Amount Dividends Paid Number of Missed of Missed to Date Dividends Dividend TRANSACTION DETAIL I APPENDIX A I JANUARY 27, 2017 227 8,14,76 81 8,14 11,101 44 9,11,36 8,17 8,11,14 8,11,14 8,11,14 8,14 KS MS MS AZ AZ CA COMMUNITY BANCSHARES GOFF OF KANSAS, INC. COMMUNITY BANCSHARES OF MISSISSIPPI, INC./ BRANDON COMMUNITY BANK OF MISSISSIPPI COMMUNITY BANCSHARES OF MISSISSIPPI, INC./ BRANDON COMMUNITY BANK OF MISSISSIPPI COMMUNITY BANCSHARES, KINGMAN INC. COMMUNITY BANCSHARES, KINGMAN INC. OAKLAND OAKLAND COMMUNITY BANK OF THE BAY COMMUNITY BANK OF THE BAY VA GLEN ALLEN GLEN ALLEN GLEN ALLEN GLEN ALLEN GLEN ALLEN WEST SACRAMENTO WEST SACRAMENTO WEST SACRAMENTO STAUNTON STAUNTON STAUNTON GLEN ELLYN COMMUNITY BANKERS TRUST CORPORATION COMMUNITY BANKERS TRUST CORPORATION COMMUNITY BANKERS TRUST CORPORATION COMMUNITY BANKERS TRUST CORPORATION COMMUNITY BANKERS TRUST CORPORATION COMMUNITY BUSINESS BANK COMMUNITY BUSINESS BANK COMMUNITY BUSINESS BANK COMMUNITY FINANCIAL CORPORATION / CITY HOLDING COMPANY COMMUNITY FINANCIAL CORPORATION / CITY HOLDING COMPANY COMMUNITY FINANCIAL CORPORATION / CITY HOLDING COMPANY COMMUNITY FINANCIAL SHARES, INC. IL VA VA VA CA CA CA VA VA VA VA IN IN COMMUNITY BANK SHARES NEW ALBANY OF INDIANA, INC. IN COMMUNITY BANK SHARES NEW ALBANY OF INDIANA, INC. COMMUNITY BANK SHARES NEW ALBANY OF INDIANA, INC. CA KS CA CA CA CA CA KY State COMMUNITY BANCSHARES GOFF OF KANSAS, INC. ROSEVILLE LOS ANGELES ROSEVILLE LOS ANGELES COMMONWEALTH BUSINESS BANK COMMUNITY 1ST BANK LOS ANGELES COMMONWEALTH BUSINESS BANK COMMUNITY 1ST BANK LOUISVILLE COMMONWEALTH BUSINESS BANK City COMMONWEALTH BANCSHARES, INC. Footnote Institution Name 5/15/2009 5/28/2015 1/9/2013 12/19/2008 1/11/2013 11/30/2012 2/27/2009 6/4/2014 4/23/2014 11/20/2013 7/24/2013 12/19/2008 10/19/2011 9/15/2011 5/29/2009 9/29/2010 1/16/2009 2/11/2015 7/24/2009 9/29/2010 9/11/2009 7/18/2012 3/6/2009 12/19/2012 1/16/2009 9/12/2013 7/17/2013 1/23/2009 9/11/2012 Date $6,970,000.00 $12,643,000.00 $3,976,000.00 $17,680,000.00 $19,468,000.00 $1,747,000.00 $3,872,000.00 $52,000,000.00 $500,000.00 $2,550,000.00 $7,701,000.00 Original Investment Amount $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Outstanding Investment Sold, in full; $4,240,743.82 warrants not outstanding Redeemed, in $16,080,204.94 full; warrants not outstanding Sold, in full; $4,674,050.16 warrants not outstanding Redeemed, in $23,135,879.12 full; warrants not outstanding Redeemed, in $22,802,281.62 full; warrants not outstanding Redeemed, in $1,823,188.61 full; warrants not outstanding Redeemed, in $5,197,157.57 full; warrants not outstanding Redeemed, in $57,575,699.54 full; warrants not outstanding Redeemed, in $616,741.75 full; warrants not outstanding Redeemed, in $2,899,659.67 full; warrants not outstanding Sold, in full; $8,451,110.79 warrants not outstanding Investment Total Cash Back2 Status* CPP TRANSACTIONS DETAIL, AS OF 12/31/2016 (CONTINUED) $12,643,000.00 $3,717,560.00 $10,680,000.00 $2,500,000.00 $4,500,000.00 $19,468,000.00 $1,747,000.00 $3,872,000.00 $52,000,000.00 $500,000.00 $2,550,000.00 $7,323,651.00 Amount ($25,000.00) ($73,236.51) ($153,000.00) (Fee)4 12,643 3,976 10,680 2,500 4,500 19,468 1,747 3,872 52,000 500 2,550 7,701 Shares Capital Repayment / Disposition / Auction3,5 $1,000.00 $935.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $951.00 Avg. Price ($258,440.00) ($377,349.00) (Realized Loss) / (Write-off) Gain5 $873,485.00 $167,035.00 $780,000.00 $1,100,869.50 $116,000.00 $2,600,000.00 $25,000.00 $128,000.00 $362,427.91 Wt Amount 61,796 199 780,000 386,270 116 2,600 25 128 385 Wt Shares Warrant Proceeds $947,193.82 $2,563,719.94 $814,455.16 $4,675,879.12 $2,233,412.12 $76,188.61 $1,209,157.57 $3,193,250.19 $91,741.75 $221,659.67 $838,268.39 0 0 0 0 0 0 0 0 0 10 10 Continued on next page $0.00 $0.00 $0.00 $0.00 $0.00 $72,549.00 $0.00 $0.00 $0.00 $323,994.00 $1,049,250.00 Amount Dividends Paid Number of Missed of Missed to Date Dividends Dividend Dividends and Interest 228 APPENDIX A I TRANSACTION DETAIL I JANUARY 27, 2017 8,14,44 15,17 44 8,14 8,67 8 8,14,44 8 HARRISON HARRISON HARRISON UNION CITY UNION CITY COMMUNITY FIRST BANCSHARES, INC. (AR) COMMUNITY FIRST BANCSHARES, INC. (AR) COMMUNITY FIRST BANCSHARES, INC. (AR) COMMUNITY FIRST BANCSHARES, INC. (TN) COMMUNITY FIRST BANCSHARES, INC. (TN) MIDDLETOWN MIDDLETOWN MIDDLETOWN HAM LAKE HAM LAKE HAM LAKE RUSTON RUSTON GOLETA COMMUNITY PARTNERS BANCORP COMMUNITY PARTNERS BANCORP COMMUNITY PRIDE BANK CORPORATION COMMUNITY PRIDE BANK CORPORATION COMMUNITY PRIDE BANK CORPORATION COMMUNITY TRUST FINANCIAL CORPORATION COMMUNITY TRUST FINANCIAL CORPORATION COMMUNITY WEST BANCSHARES BUCYRUS COMMUNITY INVESTORS BANCORP, INC. BUCYRUS BUCYRUS COMMUNITY INVESTORS BANCORP, INC. COMMUNITY PARTNERS BANCORP BRANDON COMMUNITY HOLDING COMPANY OF FLORIDA, INC. / COMMUNITY BANCSHARES OF MISSISSIPPI, INC. COMMUNITY INVESTORS BANCORP, INC. BRANDON COMMUNITY HOLDING COMPANY OF FLORIDA, INC. / COMMUNITY BANCSHARES OF MISSISSIPPI, INC. BUCYRUS BRANDON COMMUNITY HOLDING COMPANY OF FLORIDA, INC. / COMMUNITY BANCSHARES OF MISSISSIPPI, INC. BUCYRUS BRANDON COMMUNITY HOLDING COMPANY OF FLORIDA, INC. / COMMUNITY BANCSHARES OF MISSISSIPPI, INC. COMMUNITY INVESTORS BANCORP, INC. COLUMBIA COMMUNITY FIRST, INC. COMMUNITY INVESTORS BANCORP, INC. COLUMBIA COLUMBIA COMMUNITY FIRST, INC. COMMUNITY FIRST, INC. COLUMBIA HARRISON COMMUNITY FIRST BANCSHARES, INC. (AR) COMMUNITY FIRST, INC. GLEN ELLYN City COMMUNITY FINANCIAL SHARES, INC. Footnote Institution Name CA LA LA MN MN MN NJ NJ NJ OH OH OH OH OH MS MS MS MS TN TN TN TN TN TN AR AR AR AR IL State 12/19/2008 7/6/2011 1/9/2009 9/12/2013 8/12/2013 11/13/2009 10/26/2011 8/11/2011 1/30/2009 3/26/2013 1/11/2013 12/20/2012 12/19/2012 12/23/2008 3/26/2013 1/11/2013 11/30/2012 2/6/2009 7/18/2014 4/14/2014 4/11/2014 2/27/2009 8/18/2011 3/20/2009 3/19/2014 2/10/2014 2/7/2014 4/3/2009 12/21/2012 $15,600,000.00 $24,000,000.00 $4,400,000.00 $9,000,000.00 $2,600,000.00 $1,050,000.00 $17,806,000.00 $20,000,000.00 $12,725,000.00 Original Investment Date Amount $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Outstanding Investment Investment Status* Sold, in full; $14,341,140.33 warrants not outstanding Redeemed, in $28,459,100.00 full; warrants not outstanding Sold, in full; $5,462,045.14 warrants not outstanding Redeemed, in $10,598,750.00 full; warrants not outstanding Sold, in full; $3,115,616.28 warrants not outstanding Sold, in full; $1,220,300.65 warrants not outstanding Sold, in full; $7,665,362.89 warrants not outstanding Redeemed, in $23,628,111.33 full; warrants not outstanding Sold, in full; $16,441,884.63 warrants not outstanding Total Cash Back2 CPP TRANSACTIONS DETAIL, AS OF 12/31/2016 (CONTINUED) $24,000,000.00 $4,400,000.00 $9,000,000.00 $1,517,150.00 $952,850.00 $1,002,750.00 $4,028,202.50 $1,322,500.50 $20,000,000.00 $8,867,389.75 $3,705,037.50 $3,136,500.00 Amount ($48,849.24) ($300.00) ($24,700.00) ($14,972.50) ($10,027.50) ($53,507.03) ($125,724.27) (Fee)4 24,000 4,400,000 9,000 1,597 1,003 105 13,405 4,401 20,000 8,975 3,750 6,970 Shares Capital Repayment / Disposition / Auction3,5 $1,000.00 $1.11 $1,000.00 $950.00 $950.00 $9,550.00 $300.50 $300.50 $1,000.00 $988.01 $988.01 $450.00 Avg. Price ($79,850.00) ($50,150.00) ($47,250.00) ($9,376,797.50) ($3,078,499.50) ($107,610.25) ($44,962.50) ($3,833,500.00) (Realized Loss) / (Write-off) $484,924.00 Gain5 $1,200,000.00 $177,716.96 $460,000.00 $105,000.00 $25,000.00 $387,399.37 $72,314.55 $1,000,000.00 $544,614.34 $85,157.88 $157,050.00 Wt Amount 1,200 132,000 311,972 130 5 750 140 1,000 550 86 349 Wt Shares Warrant Proceeds Dividends and Interest $2,461,333.33 $3,259,100.00 $448,253.42 $1,138,750.00 $565,616.28 $1,908,453.00 $2,628,111.33 $3,365,409.43 3 0 9 0 0 0 12 0 5 Continued on next page $585,000.00 $0.00 $803,286.00 $0.00 $0.00 $0.00 $2,911,200.00 $0.00 $430,215.00 Amount Dividends Paid Number of Missed of Missed to Date Dividends Dividend TRANSACTION DETAIL I APPENDIX A I JANUARY 27, 2017 229 8,14 58 8 8 8,14 8,14 8,14 53,110 MILFORD COUNTRY BANK SHARES, INC. BUFFALO BUFFALO RALEIGH RALEIGH RALEIGH BLAINE CRAZY WOMAN CREEK BANCORP INCORPORATED CRAZY WOMAN CREEK BANCORP INCORPORATED CRESCENT FINANCIAL BANCSHARES, INC. (CRESCENT FINANCIAL CORPORATION) / VantageSouth Bancshares, Inc. CRESCENT FINANCIAL BANCSHARES, INC. (CRESCENT FINANCIAL CORPORATION) / VantageSouth Bancshares, Inc. CRESCENT FINANCIAL BANCSHARES, INC. (CRESCENT FINANCIAL CORPORATION) / VantageSouth Bancshares, Inc. CROSSTOWN HOLDING COMPANY BUFFALO MILFORD COUNTRY BANK SHARES, INC. CRAZY WOMAN CREEK BANCORP INCORPORATED CORNING CORNING SAVINGS AND LOAN ASSOCIATION CLARKSDALE CORNING CORNING SAVINGS AND LOAN ASSOCIATION COVENANT FINANCIAL CORPORATION CORNING CORNING SAVINGS AND LOAN ASSOCIATION CLARKSDALE AR CORNING CORNING SAVINGS AND LOAN ASSOCIATION COVENANT FINANCIAL CORPORATION SC CONGAREE BANCSHARES, CAYCE INC. MILFORD SC CONGAREE BANCSHARES, CAYCE INC. MILFORD SC CONGAREE BANCSHARES, CAYCE INC. COUNTRY BANK SHARES, INC. SC COUNTRY BANK SHARES, INC. NC CONGAREE BANCSHARES, CAYCE INC. MN NC NC NC WY WY WY MS MS NE NE NE NE AR AR AR NC CA CA COMMUNITYONE BANCORP ASHEBORO / FNB UNITED CORP. GOLETA COMMUNITY WEST BANCSHARES COMMUNITYONE BANCORP ASHEBORO / FNB UNITED CORP. GOLETA COMMUNITY WEST BANCSHARES CA CA NC GOLETA State COMMUNITYONE BANCORP ASHEBORO / FNB UNITED CORP. GOLETA COMMUNITY WEST BANCSHARES City COMMUNITY WEST BANCSHARES Footnote Institution Name 1/23/2009 6/11/2014 2/19/2014 1/9/2009 11/19/2014 1/8/2014 2/20/2009 4/30/2014 6/5/2009 1/11/2013 11/29/2012 11/28/2012 1/30/2009 3/26/2013 1/11/2013 11/30/2012 2/13/2009 1/11/2013 10/31/2012 10/29/2012 1/9/2009 5/27/2015 5/23/2014 2/13/2009 6/12/2013 1/11/2013 12/11/2012 12/10/2012 Date $10,650,000.00 $24,900,000.00 $3,100,000.00 $5,000,000.00 $7,525,000.00 $638,000.00 $3,285,000.00 $51,500,000.00 Original Investment Amount $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Outstanding Investment Sold, in full; $13,498,324.83 warrants not outstanding Redeemed, in $33,014,741.20 full; warrants not outstanding Redeemed, in $4,225,732.08 full; warrants not outstanding Redeemed, in $6,594,635.27 full; warrants not outstanding Sold, in full; $8,781,205.02 warrants not outstanding Sold, in full; $659,705.04 warrants not outstanding Sold, in full; $3,483,629.20 warrants not outstanding Sold, in full; $12,749,591.59 warrants not outstanding Investment Total Cash Back2 Status* CPP TRANSACTIONS DETAIL, AS OF 12/31/2016 (CONTINUED) $24,900,000.00 $2,100,000.00 $1,000,000.00 $5,000,000.00 $6,193,989.20 $713,208.30 $548,680.00 $2,687,046.56 $23,932.54 $10,149,929.90 $9,122,400.00 $2,172,000.00 Amount ($69,071.98) ($19,513.20) ($5,486.80) ($25,000.00) ($112,944.00) (Fee)4 24,900 2,100 1,000 5,000 6,748 777 638 3,256 29 1,085,554 12,600 3,000 Shares Capital Repayment / Disposition / Auction3,5 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $917.90 $917.90 $860.00 $825.26 $825.26 $9.35 $724.00 $724.00 Avg. Price ($554,010.80) ($63,791.70) ($89,320.00) ($568,953.44) ($5,067.46) ($41,350,070.10) ($3,477,600.00) ($828,000.00) (Realized Loss) / (Write-off) Gain5 $1,681,000.00 $155,000.00 $250,000.00 $372,240.00 $3,960.00 $106,364.00 $10,356.69 $698,351.00 Wt Amount 833,705 155 250 376 32 164 22,071 521,158 Wt Shares Warrant Proceeds $2,610,550.42 $11,011,235.28 $970,732.08 $1,344,635.27 $1,570,839.50 $132,065.04 $691,286.10 $2,589,305.00 0 0 0 0 0 0 0 0 0 0 Continued on next page $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Amount Dividends Paid Number of Missed of Missed to Date Dividends Dividend Dividends and Interest 230 APPENDIX A I TRANSACTION DETAIL I JANUARY 27, 2017 44 11 8,14 14,15 8,18 8,14 14,15, 44 8,14,44 11,16 8 WASHINGTON WASHINGTON WASHINGTON WASHINGTON WASHINGTON KANSAS CITY KANSAS CITY KANSAS CITY KANSAS CITY RIVERWOODS RIVERWOODS RIVERWOODS DOWNINGTOWN DOWNINGTOWN DIAMOND BANCORP, INC. DIAMOND BANCORP, INC. DIAMOND BANCORP, INC. DIAMOND BANCORP, INC. DICKINSON FINANCIAL CORPORATION II DICKINSON FINANCIAL CORPORATION II DICKINSON FINANCIAL CORPORATION II DICKINSON FINANCIAL CORPORATION II DISCOVER FINANCIAL SERVICES DISCOVER FINANCIAL SERVICES DISCOVER FINANCIAL SERVICES DNB FINANCIAL CORPORATION DNB FINANCIAL CORPORATION HORN LAKE DESOTO COUNTY BANK DIAMOND BANCORP, INC. HORN LAKE HORN LAKE DESOTO COUNTY BANK DESOTO COUNTY BANK HORN LAKE DELMAR DELMAR BANCORP HORN LAKE DELMAR DELMAR BANCORP DESOTO COUNTY BANK DELMAR DELMAR BANCORP DESOTO COUNTY BANK DELMAR DEERFIELD DEERFIELD FINANCIAL CORPORATION DELMAR BANCORP DEERFIELD DEERFIELD FINANCIAL CORPORATION BURLEY ONTARIO CVB FINANCIAL CORP. BURLEY ONTARIO CVB FINANCIAL CORP. D.L. EVANS BANCORP ONTARIO CVB FINANCIAL CORP. D.L. EVANS BANCORP ONTARIO CVB FINANCIAL CORP. WRENS WRENS CSRA BANK CORP. CSRA BANK CORP. BLAINE CROSSTOWN HOLDING COMPANY WRENS BLAINE CROSSTOWN HOLDING COMPANY CSRA BANK CORP. BLAINE City CROSSTOWN HOLDING COMPANY Footnote Institution Name PA PA IL IL IL MO MO MO MO MO MO MO MO MO MS MS MS MS MS MD MD MD MD WI WI ID ID CA CA CA CA GA GA GA MN MN MN State 8/4/2011 1/30/2009 7/7/2010 4/21/2010 3/13/2009 3/26/2013 2/8/2013 2/7/2013 1/16/2009 9/11/2012 8/10/2012 8/9/2012 8/8/2012 5/22/2009 10/29/2013 9/25/2013 9/24/2013 12/29/2009 2/13/2009 3/26/2013 2/8/2013 2/7/2013 12/4/2009 9/8/2011 5/15/2009 9/27/2011 2/27/2009 10/28/2009 9/2/2009 8/26/2009 12/5/2008 8/6/2015 6/29/2015 3/27/2009 9/12/2013 7/22/2013 7/19/2013 $11,750,000.00 $1,224,558,000.00 $146,053,000.00 $20,445,000.00 $1,508,000.00 $1,173,000.00 $9,000,000.00 $2,639,000.00 $19,891,000.00 $130,000,000.00 $2,400,000.00 Original Investment Date Amount $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Outstanding Investment Investment Status* Redeemed, in $13,683,277.61 full; warrants not outstanding Redeemed, in $1,464,248,844.00 full; warrants not outstanding Sold, in full; $87,459,858.69 warrants not outstanding Sold, in full; $21,101,618.19 warrants not outstanding Sold, in full; $2,781,331.97 warrants not outstanding Sold, in full; $6,598,331.15 warrants not outstanding Redeemed, in $3,283,338.96 full; warrants not outstanding Redeemed, in $23,686,592.33 full; warrants not outstanding Redeemed, in $136,046,583.33 full; warrants not outstanding Sold, in full; $3,210,755.60 warrants not outstanding Total Cash Back2 CPP TRANSACTIONS DETAIL, AS OF 12/31/2016 (CONTINUED) $11,750,000.00 $1,224,558,000.00 $72,684,793.30 $8,025,555.03 $350,520.00 $10,197,941.25 $4,381,500.00 $1,895,467.59 $301,428.58 $215,462.72 $5,293,527.28 $2,639,000.00 $19,891,000.00 $32,500,000.00 $97,500,000.00 $2,400,000.00 $10,117,381.00 $343,794.50 Amount ($807,103.48) ($149,299.61) ($33,333.34) ($55,089.90) ($25,000.00) ($104,611.76) (Fee)4 11,750 1,224,558 131,530 14,523 480,000 13,965,000 6,000,000 2,315 366 352 8,648 2,639,000 19,891 32,500 97,500 2,400 10,300 350 Shares Capital Repayment / Disposition / Auction3,5 $1,000.00 $1,000.00 $552.61 $552.61 $0.73 $0.73 $0.73 $818.78 $823.58 $612.11 $612.11 $1.00 $1,000.00 $1,000.00 $1,000.00 $1,213.75 $982.27 $982.27 Avg. Price ($58,845,206.70) ($6,497,444.97) ($129,480.00) ($3,767,058.75) ($1,618,500.00) ($419,532.41) ($64,571.42) ($136,537.28) ($3,354,472.72) ($182,619.00) ($6,205.50) (Realized Loss) / (Write-off) $513,000.00 Gain5 $172,000,000.00 $4,922,044.87 $3,372.19 $91,535.40 $688,041.09 $40,563.34 $311,943.55 $132,000.00 $995,000.00 $1,307,000.00 $141,815.60 $531,210.67 Wt Amount 20,500,413 7,298 5 120,000 902,000 59 450 132,000 995 834,761 120 533 Wt Shares Warrant Proceeds Dividends and Interest $1,475,277.61 $67,690,844.00 $2,631,196.78 $5,541,380.06 $577,205.80 $832,487.50 $512,338.96 $2,800,592.33 $4,739,583.33 $180,940.00 0 0 14 0 0 5 0 0 0 19 Continued on next page $0.00 $0.00 $27,859,720.00 $0.00 $0.00 $613,125.00 $0.00 $0.00 $0.00 $717,300.00 Amount Dividends Paid Number of Missed of Missed to Date Dividends Dividend TRANSACTION DETAIL I APPENDIX A I JANUARY 27, 2017 231 8,14,44 11 45 44 89 11,16 12,44 15 CA VA EAST WEST BANCORP, INC. PASADENA TAPPAHANNOCK TAPPAHANNOCK TAPPAHANNOCK TAPPAHANNOCK TAPPAHANNOCK ENGELHARD ENGELHARD ENGELHARD EASTERN VIRGINIA BANKSHARES, INC. EASTERN VIRGINIA BANKSHARES, INC. EASTERN VIRGINIA BANKSHARES, INC. EASTERN VIRGINIA BANKSHARES, INC. EASTERN VIRGINIA BANKSHARES, INC. ECB BANCORP, INC. / CRESCENT FINANCIAL BANCSHARES, INC. / VantageSouth Bancshares, Inc. ECB BANCORP, INC. / CRESCENT FINANCIAL BANCSHARES, INC. / VantageSouth Bancshares, Inc. ECB BANCORP, INC. / CRESCENT FINANCIAL BANCSHARES, INC. / VantageSouth Bancshares, Inc. ST. LOUIS ST. LOUIS ALLISON PARK ALLISON PARK ENTERPRISE FINANCIAL SERVICES CORP. ENTERPRISE FINANCIAL SERVICES CORP. ENTERPRISE FINANCIAL SERVICES GROUP, INC. ENTERPRISE FINANCIAL SERVICES GROUP, INC. PA PA MO MO TX MO ST. LOUIS ENTERPRISE FINANCIAL SERVICES CORP. TX ENCORE BANCSHARES INC. HOUSTON TX PA EMCLAIRE FINANCIAL CORP. EMLENTON ENCORE BANCSHARES INC. HOUSTON PA EMCLAIRE FINANCIAL CORP. EMLENTON ENCORE BANCSHARES INC. HOUSTON PA EMCLAIRE FINANCIAL CORP. EMLENTON NC NC NC VA VA VA VA CA MD CA BETHESDA EAGLE BANCORP, INC. MD MD EAST WEST BANCORP, INC. PASADENA BETHESDA MD MN MN MN MN PA State EAST WEST BANCORP, INC. PASADENA BETHESDA MINNEAPOLIS EAGLE BANCORP, INC. MINNEAPOLIS DUKE FINANCIAL GROUP, INC. EAGLE BANCORP, INC. MINNEAPOLIS DUKE FINANCIAL GROUP, INC. BETHESDA MINNEAPOLIS DUKE FINANCIAL GROUP, INC. EAGLE BANCORP, INC. DOWNINGTOWN DUKE FINANCIAL GROUP, INC. City DNB FINANCIAL CORPORATION Footnote Institution Name 8/25/2011 6/12/2009 1/9/2013 11/7/2012 12/19/2008 11/23/2011 9/27/2011 12/5/2008 12/7/2011 8/18/2011 12/23/2008 6/11/2014 2/19/2014 1/16/2009 5/13/2015 1/6/2014 10/21/2013 10/18/2013 1/9/2009 1/26/2011 12/29/2010 12/5/2008 11/23/2011 7/14/2011 12/23/2009 12/5/2008 4/2/2014 3/5/2014 11/27/2013 6/19/2009 9/21/2011 Date $4,000,000.00 $35,000,000.00 $34,000,000.00 $7,500,000.00 $17,949,000.00 $24,000,000.00 $306,546,000.00 $38,235,000.00 $12,000,000.00 Original Investment Amount $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Outstanding Investment Redeemed, in $4,680,205.56 full; warrants not outstanding Redeemed, in $42,801,933.33 full; warrants not outstanding Redeemed, in $39,415,959.89 full; warrants not outstanding Redeemed, in $8,545,904.67 full; warrants not outstanding Redeemed, in $23,397,494.08 full; warrants not outstanding Sold, in full; $28,568,653.60 warrants not outstanding Redeemed, in $352,722,420.00 full; warrants not outstanding Redeemed, in $44,847,153.76 full; warrants not outstanding Redeemed, in $17,424,285.82 full; warrants not outstanding Investment Total Cash Back2 Status* CPP TRANSACTIONS DETAIL, AS OF 12/31/2016 (CONTINUED) $4,000,000.00 $35,000,000.00 $34,000,000.00 $7,500,000.00 $17,949,000.00 $20,100,000.00 $3,900,000.00 $306,546,000.00 $23,235,000.00 $15,000,000.00 $5,000,000.00 $2,000,000.00 $5,000,000.00 Amount ($264,986.40) (Fee)4 4,000 35,000 34,000 7,500 17,949 20,100 3,900 306,546 23,235 15,000 5,000,000 2,000,000 5,000,000 Shares Capital Repayment / Disposition / Auction3,5 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,104.11 $1,104.11 $1,000.00 $1,000.00 $1,000.00 $1.00 $1.00 $1.00 Avg. Price (Realized Loss) / (Write-off) $2,092,611.00 $406,029.00 Gain5 $200,000.00 $1,006,100.00 $637,071.00 $51,113.00 $871,000.00 $115,000.00 $14,500,000.00 $2,794,422.00 $600,000.00 $458,000.00 Wt Amount 200 324,074 364,026 50,111 514,693 384,041 1,517,555 385,434 600,000 186,311 Wt Shares Warrant Proceeds $480,205.56 $6,795,833.33 $4,778,888.89 $994,791.67 $2,220,000.00 $31,676,420.00 $3,817,731.76 $4,824,285.82 0 0 0 0 0 0 0 11 0 0 0 Continued on next page $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $3,300,000.00 $0.00 $0.00 $0.00 Amount Dividends Paid Number of Missed of Missed to Date Dividends Dividend Dividends and Interest 232 APPENDIX A I TRANSACTION DETAIL I JANUARY 27, 2017 8,14 8,120 11 8,14 14,15 8,14 8,14,18 8,14 8,44,73 KS ARGONIA ARGONIA ARGONIA FARMERS & MERCHANTS FINANCIAL CORPORATION FARMERS & MERCHANTS FINANCIAL CORPORATION FARMERS & MERCHANTS FINANCIAL CORPORATION KS KS TX PA FARMERS & MERCHANTS BANCSHARES, INC. / HOUSTON ALLEGIANCE BANCSHARES, INC. HERMITAGE F.N.B. CORPORATION PA PA TX HERMITAGE F.N.B. CORPORATION TN TN TN TN TN MO MO MO MO NC NC NC NC NC TN TN TN TN TN TN CA CA CA CA CA CA CA FARMERS & MERCHANTS BANCSHARES, INC. / HOUSTON ALLEGIANCE BANCSHARES, INC. HERMITAGE F.N.B. CORPORATION CLARKSVILLE CLARKSVILLE F&M FINANCIAL CORPORATION (TN) F&M FINANCIAL CORPORATION (TN) CLARKSVILLE F&M FINANCIAL CORPORATION (TN) CLARKSVILLE HOLDEN F&C BANCORP. INC. CLARKSVILLE HOLDEN F&C BANCORP. INC. F&M FINANCIAL CORPORATION (TN) HOLDEN F&M FINANCIAL CORPORATION (TN) HOLDEN F&C BANCORP. INC. SALISBURY F & M FINANCIAL CORPORATION (NC) F&C BANCORP. INC. SALISBURY SALISBURY F & M FINANCIAL CORPORATION (NC) SALISBURY F & M FINANCIAL CORPORATION (NC) F & M FINANCIAL CORPORATION (NC) TREZEVANT SALISBURY F & M BANCSHARES, INC. TREZEVANT F & M BANCSHARES, INC. F & M FINANCIAL CORPORATION (NC) TREZEVANT F & M BANCSHARES, INC. SANTA ROSA EXCHANGE BANK TREZEVANT SANTA ROSA EXCHANGE BANK TREZEVANT SANTA ROSA EXCHANGE BANK F & M BANCSHARES, INC. SANTA ROSA EXCHANGE BANK F & M BANCSHARES, INC. SANTA ROSA EXCHANGE BANK TREZEVANT SANTA ROSA EXCHANGE BANK F & M BANCSHARES, INC. SANTA ROSA KS EXCHANGE BANK KS State EQUITY BANCSHARES, INC. WICHITA City EQUITY BANCSHARES, INC. WICHITA Footnote Institution Name 7/26/2013 6/24/2013 3/20/2009 7/15/2015 3/6/2009 11/23/2011 9/9/2009 1/9/2009 11/16/2012 9/21/2012 9/20/2012 9/19/2012 2/13/2009 1/11/2013 11/13/2012 11/8/2012 5/22/2009 11/16/2012 9/20/2012 9/19/2012 9/18/2012 2/6/2009 3/26/2013 2/8/2013 2/7/2013 2/6/2013 11/6/2009 1/30/2009 9/11/2012 8/13/2012 8/10/2012 8/9/2012 8/8/2012 8/3/2012 12/19/2008 8/11/2011 1/30/2009 $442,000.00 $11,000,000.00 $100,000,000.00 $17,243,000.00 $2,993,000.00 $17,000,000.00 $3,535,000.00 $4,609,000.00 $43,000,000.00 $8,750,000.00 Original Investment Date Amount $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Outstanding Investment Investment Status* Sold, in full; $500,199.14 warrants not outstanding Redeemed, in $15,971,339.07 full; warrants not outstanding Redeemed, in $104,023,433.33 full; warrants not outstanding Sold, in full; $17,573,762.97 warrants not outstanding Sold, in full; $3,842,376.65 warrants not outstanding Sold, in full; $20,119,744.45 warrants not outstanding Sold, in full; $9,405,391.28 warrants not outstanding Sold, in full; $47,294,527.29 warrants not outstanding Redeemed, in $10,394,872.56 full; warrants not outstanding Total Cash Back2 CPP TRANSACTIONS DETAIL, AS OF 12/31/2016 (CONTINUED) $425,425.00 $11,000,000.00 $100,000,000.00 $13,421,362.50 $157,500.00 $1,278,999.18 $1,590,599.43 $13,485,250.00 $2,664,750.00 $144,202.50 $2,734,192.50 $4,797,325.00 $10,503,000.00 $420,995.25 $8,725,367.25 $17,505,000.00 $481,387.50 $8,750,000.00 Amount ($25,000.00) ($135,788.63) ($25,000.00) ($161,500.00) ($76,757.21) ($376,357.50) (Fee)4 442 11,000 100,000 17,043 200 1,334,000 1,659,000 14,195 2,805 153 2,901 5,090 12,000 481 9,969 20,000 550 8,750 Shares Capital Repayment / Disposition / Auction3,5 $962.50 $1,000.00 $1,000.00 $787.50 $787.50 $0.96 $0.96 $950.00 $950.00 $942.50 $942.50 $942.50 $875.25 $875.25 $875.25 $875.25 $875.25 $1,000.00 Avg. Price ($16,575.00) ($3,621,637.50) ($42,500.00) ($55,000.82) ($68,400.57) ($709,750.00) ($140,250.00) ($8,797.50) ($166,807.50) ($292,675.00) ($1,497,000.00) ($60,004.75) ($1,243,632.75) ($2,495,000.00) ($68,612.50) (Realized Loss) / (Write-off) Gain5 ($2,835.00) $550,000.00 $690,100.00 $645,975.00 $96,465.60 $125,000.00 $638,460.90 $136,813.05 $222,007.50 $22,930.78 $120,386.57 $1,910,898.00 $438,000.00 Wt Amount 22 550 651,042 750 112 150,000 700 150 230 24 126 2,000 438 Wt Shares Warrant Proceeds Dividends and Interest $102,609.14 $4,421,339.07 $9,632,883.55 $3,388,248.50 $872,778.04 $3,355,970.50 $1,584,420.99 $7,980,919.44 $5,624,635.86 0 0 0 0 0 0 0 1 0 Continued on next page $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $585,875.00 $0.00 Amount Dividends Paid Number of Missed of Missed to Date Dividends Dividend TRANSACTION DETAIL I APPENDIX A I JANUARY 27, 2017 233 8,17 77 11,15,44 8,14 8,14,45 8,14 15,17 8,14,45 14,15 8,11 GREAT BEND FARMERS ENTERPRISES, INC. WABASH WABASH BATON ROUGE BATON ROUGE PITTSBURGH PITTSBURGH PITTSBURGH EVANSVILLE EVANSVILLE EVANSVILLE EVANSVILLE FFW CORPORATION FIDELITY BANCORP, INC. (LA) FIDELITY BANCORP, INC. (LA) FIDELITY BANCORP, INC. (PA) / WESBANCO, INC. FIDELITY BANCORP, INC. (PA) / WESBANCO, INC. FIDELITY BANCORP, INC. (PA) / WESBANCO, INC. FIDELITY FEDERAL BANCORP FIDELITY FEDERAL BANCORP FIDELITY FEDERAL BANCORP FIDELITY FEDERAL BANCORP WABASH FFW CORPORATION FFW CORPORATION WABASH LOUISVILLE FCB BANCORP, INC. FFW CORPORATION LOUISVILLE HOUSTON HOUSTON FC HOLDINGS, INC. FC HOLDINGS, INC. FCB BANCORP, INC. HOUSTON FC HOLDINGS, INC. BOULDER FARMERS STATE BANKSHARES, INC. BOULDER HOLTON FARMERS STATE BANKSHARES, INC. FBHC HOLDING COMPANY HOLTON FARMERS ENTERPRISES, INC. FBHC HOLDING COMPANY GREAT BEND GREAT BEND FARMERS ENTERPRISES, INC. GREAT BEND FRANKFORT FARMERS CAPITAL BANK CORPORATION GREAT BEND FRANKFORT FARMERS CAPITAL BANK CORPORATION FARMERS ENTERPRISES, INC. KY FRANKFORT FARMERS CAPITAL BANK CORPORATION FARMERS ENTERPRISES, INC. VA FARMERS BANK, WINDSOR, WINDSOR VIRGINIA IN IN IN IN PA PA PA LA LA IN IN IN IN KY KY TX TX TX CO CO KS KS KS KS KS KS KS KY KY VA FARMERS BANK, WINDSOR, WINDSOR VIRGINIA State VA City FARMERS BANK, WINDSOR, WINDSOR VIRGINIA Footnote Institution Name 9/12/2013 7/22/2013 7/19/2013 11/13/2009 5/6/2015 11/30/2012 12/12/2008 3/27/2013 5/29/2009 1/11/2013 11/30/2012 11/28/2012 12/19/2008 9/22/2011 12/19/2008 3/26/2013 2/20/2013 6/26/2009 3/9/2011 12/29/2009 7/21/2011 3/20/2009 1/11/2013 11/13/2012 11/9/2012 11/8/2012 6/19/2009 7/18/2012 6/19/2012 1/9/2009 12/31/2013 1/9/2013 1/23/2009 Date $6,657,000.00 $7,000,000.00 $3,942,000.00 $7,289,000.00 $9,294,000.00 $21,042,000.00 $3,035,000.00 $700,000.00 $12,000,000.00 $30,000,000.00 $8,752,000.00 Original Investment Amount $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Outstanding Investment Sold, in full; $7,220,908.83 warrants not outstanding Redeemed, in $10,634,864.33 full; warrants not outstanding Redeemed, in $5,404,924.35 full; warrants not outstanding Sold, in full; $8,441,836.26 warrants not outstanding Redeemed, in $11,156,234.25 full; warrants not outstanding Sold, in full; $19,836,630.66 warrants not outstanding Sold, in full; $804,592.16 warrants not outstanding Redeemed, in $830,173.67 full; warrants not outstanding Sold, in full; $15,452,669.34 warrants not outstanding Sold, in full; $27,105,349.50 warrants not outstanding Redeemed, in $11,396,202.11 full; warrants not outstanding Investment Total Cash Back2 Status* CPP TRANSACTIONS DETAIL, AS OF 12/31/2016 (CONTINUED) $6,218,000.00 $439,000.00 $7,000,000.00 $3,942,000.00 $5,701,813.50 $879,424.60 $9,294,000.00 $18,874,674.00 $650,000.00 $700,000.00 $11,458,510.00 $96,290.00 $22,196,700.00 $5,689,000.00 $3,063,000.00 Amount ($70,490.97) ($65,812.38) ($188,746.74) ($115,548.00) ($332,950.50) (Fee)4 6,218 439 7,000 3,942,000 6,315 974 9,294 21,042 3,035,000 700 11,900,000 100,000 30,000 5,689 3,063 Shares Capital Repayment / Disposition / Auction3,5 $1,058.90 $1,058.90 $1,000.00 $1.00 $902.90 $902.90 $1,000.00 $897.00 $0.21 $1,000.00 $0.96 $0.96 $739.89 $1,000.00 $1,000.00 Avg. Price ($613,186.50) ($94,575.40) ($2,167,326.00) ($2,385,000.00) ($441,490.00) ($3,710.00) ($7,803,300.00) (Realized Loss) / (Write-off) $366,240.20 $25,857.10 Gain5 $242,302.50 $2,246,531.00 $197,000.00 $358,558.20 $465,000.00 $994,613.40 $40,000.00 $552,936.00 $37,387.14 $75,000.00 $438,000.00 Wt Amount 200 101,321 197,000 364 465 1,052 4 562,000 38,000 223,992 438 Wt Shares Warrant Proceeds $1,265,924.35 $1,567,852.34 $1,397,234.25 $156,090.00 $154,592.16 $90,173.67 $3,423,094.20 $5,166,600.00 $2,206,202.11 14 0 0 0 0 14 2 0 0 0 0 Continued on next page $1,229,924.00 $0.00 $0.00 $0.00 $0.00 $4,013,730.00 $123,127.00 $0.00 $0.00 $0.00 $0.00 Amount Dividends Paid Number of Missed of Missed to Date Dividends Dividend Dividends and Interest 234 APPENDIX A I TRANSACTION DETAIL I JANUARY 27, 2017 8,14 8,14 15,17, 44 8,14,45 11 11 8,14 WINGER COON RAPIDS COON RAPIDS COON RAPIDS COON RAPIDS COON RAPIDS CORDOVA CORDOVA CORDOVA CORDOVA FINANCIAL SERVICES OF WINGER, INC. FIRST ADVANTAGE BANCSHARES, INC. FIRST ADVANTAGE BANCSHARES, INC. FIRST ADVANTAGE BANCSHARES, INC. FIRST ADVANTAGE BANCSHARES, INC. FIRST ADVANTAGE BANCSHARES, INC. FIRST ALLIANCE BANCSHARES, INC. FIRST ALLIANCE BANCSHARES, INC. FIRST ALLIANCE BANCSHARES, INC. FIRST ALLIANCE BANCSHARES, INC. BASIN FINANCIAL SECURITY CORPORATION WINGER BASIN FINANCIAL SECURITY CORPORATION FINANCIAL SERVICES OF WINGER, INC. WARSAW WARSAW FINANCIAL INSTITUTIONS, INC. WARSAW WARSAW FINANCIAL INSTITUTIONS, INC. FINANCIAL INSTITUTIONS, INC. CINCINNATI FIFTH THIRD BANCORP FINANCIAL INSTITUTIONS, INC. CINCINNATI ATLANTA FIDELITY SOUTHERN CORPORATION CINCINNATI ATLANTA FIDELITY SOUTHERN CORPORATION FIFTH THIRD BANCORP ATLANTA FIDELITY SOUTHERN CORPORATION FIFTH THIRD BANCORP WICHITA WICHITA FIDELITY FINANCIAL CORPORATION FIDELITY FINANCIAL CORPORATION FIDELITY FINANCIAL CORPORATION WICHITA WICHITA FIDELITY FINANCIAL CORPORATION WICHITA WICHITA FIDELITY FINANCIAL CORPORATION FIDELITY FINANCIAL CORPORATION FIDELITY FINANCIAL CORPORATION WICHITA WICHITA FIDELITY FINANCIAL CORPORATION WICHITA City FIDELITY FINANCIAL CORPORATION Footnote Institution Name TN TN TN TN MN MN MN MN MN MN MN WY WY NY NY NY NY OH OH OH GA GA GA KS KS KS KS KS KS KS KS KS State 3/26/2013 1/11/2013 12/20/2012 6/26/2009 3/26/2013 1/11/2013 12/11/2012 12/10/2012 5/22/2009 9/1/2011 7/31/2009 7/21/2011 2/13/2009 5/11/2011 3/30/2011 2/23/2011 12/23/2008 3/16/2011 2/2/2011 12/31/2008 5/28/2015 7/3/2012 12/19/2008 9/11/2012 8/10/2012 8/9/2012 8/8/2012 8/7/2012 8/3/2012 8/2/2012 8/1/2012 12/19/2008 $3,422,000.00 $1,177,000.00 $3,742,000.00 $5,000,000.00 $37,515,000.00 $3,408,000,000.00 $48,200,000.00 $36,282,000.00 Original Investment Date Amount $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Outstanding Investment Investment Status* Sold, in full; $3,003,674.75 warrants not outstanding Sold, in full; $1,289,436.37 warrants not outstanding Redeemed, in $4,487,322.46 full; warrants not outstanding Redeemed, in $5,914,597.33 full; warrants not outstanding Redeemed, in $43,787,611.61 full; warrants not outstanding Redeemed, in $4,043,972,602.67 full; warrants not outstanding Sold, in full; $82,715,982.47 warrants not outstanding Sold, in full; $40,966,780.82 warrants not outstanding Total Cash Back2 CPP TRANSACTIONS DETAIL, AS OF 12/31/2016 (CONTINUED) $2,395,742.20 $366,469.68 $690,723.49 $3,742,000.00 $5,000,000.00 $25,010,000.00 $12,505,000.00 $3,408,000,000.00 $43,408,920.00 $285,203.20 $26,056,877.36 $2,348,470.10 $3,200,514.66 $298,572.10 $26,737.80 $120,320.10 Amount ($1,042.58) ($23,957.42) ($14,428.07) ($10,571.93) ($651,133.80) ($323,366.95) (Fee)4 3,422 408 769 3,742,000 5,000 5,002 2,501 136,320 48,200 320 29,236 2,635 3,591 335 30 135 Shares Capital Repayment / Disposition / Auction3,5 $700.10 $898.21 $898.21 $1.00 $1,000.00 $5,000.00 $5,000.00 $25,000.00 $900.60 $891.26 $891.26 $891.26 $891.26 $891.26 $891.26 $891.26 Avg. Price ($1,026,257.80) ($41,530.32) ($78,276.51) ($4,791,080.00) ($34,796.80) ($3,179,122.64) ($286,529.90) ($390,485.34) ($36,427.90) ($3,262.20) ($14,679.90) (Realized Loss) / (Write-off) Gain5 $94,701.71 $26,318.80 $2,979.49 $112,000.00 $250,000.00 $2,079,962.50 $280,025,936.00 $31,429,313.38 $176,884.89 $1,210,615.36 $167,374.94 $170,227.93 Wt Amount 171 53 6 112,000 250 378,175 43,617,747 2,693,747 186 1,273 176 179 Wt Shares Warrant Proceeds Dividends and Interest $538,230.84 $227,944.91 $633,322.46 $664,597.33 $4,192,649.11 $355,946,666.67 $8,528,882.89 $7,228,349.33 2 0 0 0 0 0 0 0 Continued on next page $93,245.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Amount Dividends Paid Number of Missed of Missed to Date Dividends Dividend TRANSACTION DETAIL I APPENDIX A I JANUARY 27, 2017 235 ELK GROVE VILLAGE BROOKLYN BROOKLYN FIRST AMERICAN BANK CORPORATION FIRST AMERICAN INTERNATIONAL CORP. FIRST AMERICAN INTERNATIONAL CORP. 8,14,18 45 8 8,14,45 8,14,45 8,11,14 45 CA SAN DIEGO SAN DIEGO SAN DIEGO FIRST BUSINESS BANK, NATIONAL ASSOCIATION / BANK OF SOUTHERN CALIFORNIA, N.A. FIRST BUSINESS BANK, NATIONAL ASSOCIATION / BANK OF SOUTHERN CALIFORNIA, N.A. CA CA IL FIRST BUSINESS BANK, NATIONAL ASSOCIATION / BANK OF SOUTHERN CALIFORNIA, N.A. MO FIRST BUSEY CORPORATION URBANA CLAYTON FIRST BANKS, INC. MO IL CLAYTON FIRST BANKS, INC. MO MO FIRST BUSEY CORPORATION URBANA CLAYTON FIRST BANKS, INC. IL CLAYTON FIRST BANKS, INC. MO MO MO MO IL IL WV WV IL IL IL PR PR PR PR PR NC NC NC NY NY IL IL IL State FIRST BUSEY CORPORATION URBANA CLAYTON FIRST BANKS, INC. QUINCY FIRST BANKERS TRUSTSHARES, INC. CLAYTON QUINCY FIRST BANKERS TRUSTSHARES, INC. CLAYTON CHARLESTON FIRST BANK OF CHARLESTON, INC. FIRST BANKS, INC. CHARLESTON FIRST BANK OF CHARLESTON, INC. FIRST BANKS, INC. PARIS FIRST BANCTRUST CORPORATION CLAYTON PARIS FIRST BANCTRUST CORPORATION FIRST BANKS, INC. SAN JUAN PARIS FIRST BANCORP (PR) FIRST BANCTRUST CORPORATION SAN JUAN SAN JUAN SAN JUAN FIRST BANCORP (PR) FIRST BANCORP (PR) SAN JUAN FIRST BANCORP (PR) FIRST BANCORP (PR) TROY TROY FIRST BANCORP (NC) FIRST BANCORP (NC) TROY ELK GROVE VILLAGE FIRST AMERICAN BANK CORPORATION FIRST BANCORP (NC) ELK GROVE VILLAGE FIRST AMERICAN BANK CORPORATION 11,14, 15 9,11,36 City Footnote Institution Name 12/19/2012 12/11/2009 4/10/2009 11/23/2011 8/25/2011 3/6/2009 10/29/2013 9/25/2013 9/24/2013 9/12/2013 8/12/2013 8/9/2013 8/8/2013 12/31/2008 9/8/2011 1/16/2009 7/21/2011 2/6/2009 10/24/2012 1/18/2012 2/20/2009 3/6/2015 12/5/2014 9/13/2013 8/16/2013 1/16/2009 11/23/2011 9/1/2011 1/9/2009 8/13/2010 3/13/2009 12/11/2012 12/21/2011 7/24/2009 Date $0.00 $0.00 $0.00 Outstanding Investment $2,032,000.00 $2,211,000.00 $100,000,000.00 $295,400,000.00 $10,000,000.00 $3,345,000.00 $7,350,000.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $400,000,000.00 $124,966,503.71 $65,000,000.00 $17,000,000.00 $50,000,000.00 Original Investment Amount Sold, in full; $4,693,275.61 warrants not outstanding Redeemed, in $112,410,898.89 full; warrants not outstanding Sold, in full; $119,071,500.97 warrants not outstanding Redeemed, in $11,941,222.22 full; warrants not outstanding Redeemed, in $3,960,105.00 full; warrants not outstanding Redeemed, in $9,050,516.50 full; warrants not outstanding Sold, in part; $174,125,772.24 warrants outstanding Redeemed, in $74,518,906.44 full; warrants not outstanding Redeemed, in $18,204,166.78 full; warrants not outstanding Redeemed, in $65,558,530.56 full; warrants not outstanding Investment Total Cash Back2 Status* CPP TRANSACTIONS DETAIL, AS OF 12/31/2016 (CONTINUED) $1,373,084.00 $100,000,000.00 $3,226,801.50 $3,209,702.21 $87,028,900.00 $12,171,950.00 $105,000.00 $10,000,000.00 $3,345,000.00 $3,675,000.00 $3,675,000.00 $29,708,351.90 $22,063,492.11 $8,514,153.00 $81,000,000.00 $65,000,000.00 $17,000,000.00 $35,000,000.00 $15,000,000.00 Amount ($64,365.04) ($993,058.50) ($85,000.00) ($74,611.09) (Fee)4 1,500 100,000 5,850 5,819 248,654 34,777 300 10,000 3,345 3,675 3,675 5,000,000 4,388,888 1,261,356 12,000,000 65,000 17,000 35,000,000 15,000,000 Shares Capital Repayment / Disposition / Auction3,5 $915.39 $1,000.00 $551.59 $551.59 $350.00 $350.00 $350.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $5.94 $5.03 $6.75 $6.75 $1,000.00 $1,000.00 $1.00 $1.00 Avg. Price ($126,916.00) ($2,623,198.50) ($2,609,297.79) ($161,625,100.00) ($22,605,050.00) ($195,000.00) ($31,004,790.15) ($31,229,144.01) ($6,802,024.20) ($64,711,540.92) (Realized Loss) / (Write-off) Gain5 $90,461.65 $63,677.00 $5,919,151.59 $2,430,181.71 $500,000.00 $167,000.00 $368,000.00 $924,462.00 $2,500,000.00 Wt Amount 111 573,833 10,471 4,299 500 167 368 616,308 2,500,000 Wt Shares Warrant Proceeds $752,663.45 $12,347,221.89 $6,037,237.50 $1,441,222.22 $448,105.00 $1,332,516.50 $32,999,386.32 $8,594,444.44 $1,204,166.78 $13,058,530.56 0 0 0 17 0 0 0 0 0 0 0 Continued on next page $0.00 $0.00 $0.00 $64,543,063.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Amount Dividends Paid Number of Missed of Missed to Date Dividends Dividend Dividends and Interest 236 APPENDIX A I TRANSACTION DETAIL I JANUARY 27, 2017 8 8,72 12 8,14,44 8,11,14, 18,36 45 GLEN ALLEN GLEN ALLEN GLEN ALLEN FIRST CAPITAL BANCORP, INC. FIRST CAPITAL BANCORP, INC. FIRST CAPITAL BANCORP, INC. NH COLEBROOK COLEBROOK BLUEFIELD BLUEFIELD BLUEFIELD FIRST COLEBROOK BANCORP, INC. FIRST COLEBROOK BANCORP, INC. FIRST COMMUNITY BANCSHARES INC. FIRST COMMUNITY BANCSHARES INC. FIRST COMMUNITY BANCSHARES INC. KS FL FL SC FIRST COMMUNITY BANCSHARES, INC. / WICHITA EQUITY BANCSHARES, INC. FIRST COMMUNITY BANK PINELLAS PARK CORPORATION OF AMERICA FIRST COMMUNITY BANK PINELLAS PARK CORPORATION OF AMERICA LEXINGTON LEXINGTON LEXINGTON FIRST COMMUNITY CORPORATION FIRST COMMUNITY CORPORATION FIRST COMMUNITY CORPORATION IL IL IL IL IL FIRST COMMUNITY JOLIET FINANCIAL PARTNERS, INC. FIRST COMMUNITY JOLIET FINANCIAL PARTNERS, INC. FIRST COMMUNITY JOLIET FINANCIAL PARTNERS, INC. FIRST COMMUNITY JOLIET FINANCIAL PARTNERS, INC. FIRST COMMUNITY JOLIET FINANCIAL PARTNERS, INC. SC SC KS FIRST COMMUNITY BANCSHARES, INC. / WICHITA EQUITY BANCSHARES, INC. VA VA VA NH OH FIRST CITIZENS BANC CORP SANDUSKY OH FIRST CITIZENS BANC CORP SANDUSKY 9/19/2012 8/10/2012 8/9/2012 8/8/2012 12/11/2009 11/1/2012 8/29/2012 11/21/2008 5/31/2011 12/23/2008 7/16/2014 5/15/2009 11/22/2011 7/8/2009 11/21/2008 9/22/2011 3/20/2009 9/5/2012 7/3/2012 1/23/2009 9/24/2010 CA OH CERRITOS 12/22/2009 2/13/2009 2/6/2013 6/19/2012 4/3/2009 8/24/2011 7/14/2011 12/19/2008 1/11/2013 12/20/2012 CA CA VA VA VA CA CA CA CA CA State FIRST CITIZENS BANC CORP SANDUSKY FIRST CHOICE BANK WESTLAKE VILLAGE FIRST CALIFORNIA FINANCIAL GROUP, INC. CERRITOS WESTLAKE VILLAGE FIRST CALIFORNIA FINANCIAL GROUP, INC. CERRITOS WESTLAKE VILLAGE FIRST CALIFORNIA FINANCIAL GROUP, INC. FIRST CHOICE BANK SAN DIEGO FIRST BUSINESS BANK, NATIONAL ASSOCIATION / BANK OF SOUTHERN CALIFORNIA, N.A. FIRST CHOICE BANK SAN DIEGO City FIRST BUSINESS BANK, NATIONAL ASSOCIATION / BANK OF SOUTHERN CALIFORNIA, N.A. Footnote Institution Name $22,000,000.00 $11,350,000.00 $10,685,000.00 $14,800,000.00 $41,500,000.00 $4,500,000.00 $23,184,000.00 $2,836,000.00 $2,200,000.00 $10,958,000.00 $25,000,000.00 Original Investment Date Amount $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Outstanding Investment Investment Status* Sold, in full; $18,252,479.06 warrants not outstanding Sold, in full; $13,425,979.36 warrants not outstanding Sold, in full; $8,499,249.92 warrants not outstanding Redeemed, in $19,957,763.30 full; warrants not outstanding Redeemed, in $42,839,002.78 full; warrants not outstanding Redeemed, in $5,339,487.75 full; warrants not outstanding Sold, in full; $25,245,684.71 warrants not outstanding Redeemed, in $5,446,642.94 full; warrants not outstanding Sold, in full; $11,956,712.44 warrants not outstanding Redeemed, in $28,810,847.55 full; warrants not outstanding Total Cash Back2 CPP TRANSACTIONS DETAIL, AS OF 12/31/2016 (CONTINUED) $326,250.00 $11,155,120.50 $7,754,267.48 $14,800,000.00 $41,500,000.00 $4,500,000.00 $21,004,704.00 $5,036,000.00 $10,082,565.38 $25,000,000.00 $2,510,399.84 Amount ($167,326.81) ($315,070.56) ($151,238.48) ($33,333.33) (Fee)4 500 11,350 10,685 14,800 41,500 4,500 23,184 5,036 10,958 25,000 2,743 Shares Capital Repayment / Disposition / Auction3,5 $652.50 $982.83 $725.72 $1,000.00 $1,000.00 $1,000.00 $906.00 $1,000.00 $920.11 $1,000.00 $915.20 Avg. Price ($173,750.00) ($194,879.50) ($2,930,732.52) ($2,179,296.00) ($875,434.62) ($232,600.16) (Realized Loss) / (Write-off) Gain5 $209,563.20 $440,082.72 $70,727.58 $297,500.00 $740,000.00 $30,600.00 $225,000.00 $563,174.00 $110,000.00 $266,041.78 $599,042.00 Wt Amount 320 672 108 195,915 740 88,273 225 469,312 110 417,648 599,042 Wt Shares Warrant Proceeds Dividends and Interest $3,320,655.56 $2,140,685.67 $744,982.44 $1,308,402.78 $614,487.75 $3,992,877.27 $300,642.94 $1,759,343.76 $3,211,805.55 0 0 4 0 0 0 0 0 0 0 Continued on next page $0.00 $0.00 $534,250.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Amount Dividends Paid Number of Missed of Missed to Date Dividends Dividend TRANSACTION DETAIL I APPENDIX A I JANUARY 27, 2017 237 8,14 9,17 15,17,44 12,16 8,11,14 11,15,36 IL IL NE FIRST EAGLE BANCSHARES, HANOVER PARK INC. FIRST EAGLE BANCSHARES, HANOVER PARK INC. GERING GERING HARRISON HARRISON FIRST EXPRESS OF NEBRASKA, INC. FIRST EXPRESS OF NEBRASKA, INC. FIRST FEDERAL BANCSHARES OF ARKANSAS, INC. FIRST FEDERAL BANCSHARES OF ARKANSAS, INC. KS LAWRENCE LAWRENCE FIRST FINANCIAL BANCSHARES, INC. FIRST FINANCIAL BANCSHARES, INC. GOTHENBURG FIRST GOTHENBURG BANCSHARES, INC. TN LEBANON FIRST FREEDOM BANCSHARES, INC. GOTHENBURG KY FIRST FINANCIAL SERVICE CORPORATION / YOUR ELIZABETHTOWN COMMUNITY BANKSHARES, INC. FIRST GOTHENBURG BANCSHARES, INC. KY FIRST FINANCIAL SERVICE CORPORATION / YOUR ELIZABETHTOWN COMMUNITY BANKSHARES, INC. NE NE TN TN KY FIRST FINANCIAL SERVICE CORPORATION / YOUR ELIZABETHTOWN COMMUNITY BANKSHARES, INC. LEBANON KY FIRST FINANCIAL SERVICE CORPORATION / YOUR ELIZABETHTOWN COMMUNITY BANKSHARES, INC. LEBANON SC FIRST FINANCIAL HOLDINGS CHARLESTON INC. FIRST FREEDOM BANCSHARES, INC. SC FIRST FINANCIAL HOLDINGS CHARLESTON INC. FIRST FREEDOM BANCSHARES, INC. SC FIRST FINANCIAL HOLDINGS CHARLESTON INC. KS OH OH FIRST FINANCIAL BANCORP CINCINNATI FIRST FINANCIAL BANCORP CINCINNATI OH FIRST FINANCIAL BANCORP CINCINNATI AR AR NE OH OH FIRST DEFIANCE FINANCIAL DEFIANCE CORP. OH IL FIRST COMMUNITY JOLIET FINANCIAL PARTNERS, INC. FIRST DEFIANCE FINANCIAL DEFIANCE CORP. IL FIRST DEFIANCE FINANCIAL DEFIANCE CORP. IL State FIRST COMMUNITY JOLIET FINANCIAL PARTNERS, INC. City FIRST COMMUNITY JOLIET FINANCIAL PARTNERS, INC. Footnote Institution Name 10/29/2012 2/27/2009 1/11/2013 11/9/2012 12/22/2009 7/1/2015 5/31/2013 4/29/2013 1/9/2009 5/22/2013 4/3/2012 12/5/2008 9/22/2011 6/12/2009 6/8/2010 2/24/2010 12/23/2008 5/3/2011 3/6/2009 2/15/2012 2/6/2009 9/17/2010 9/11/2009 3/11/2015 6/19/2012 12/5/2008 11/16/2012 9/21/2012 9/20/2012 Date $7,570,000.00 $8,700,000.00 $20,000,000.00 $65,000,000.00 $3,756,000.00 $80,000,000.00 $16,500,000.00 $5,000,000.00 $7,500,000.00 $37,000,000.00 Original Investment Amount $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Outstanding Investment Sold, in full; $8,702,021.25 warrants not outstanding Sold, in full; $9,522,346.17 warrants not outstanding Sold, in full; $12,336,278.00 warrants not outstanding Sold, in full; $68,141,972.19 warrants not outstanding Redeemed, in $4,563,280.34 full; warrants not outstanding Redeemed, in $87,644,066.10 full; warrants not outstanding Sold, in full; $6,570,625.00 warrants not outstanding Redeemed, in $6,074,313.00 full; warrants not outstanding Redeemed, in $8,514,738.21 full; warrants not outstanding Sold, in full; $53,610,300.92 warrants not outstanding Investment Total Cash Back2 Status* CPP TRANSACTIONS DETAIL, AS OF 12/31/2016 (CONTINUED) $26,398.99 $8,025,750.00 $10,842,200.00 $56,778,150.00 $3,756,000.00 $80,000,000.00 $6,000,000.00 $5,000,000.00 $7,500,000.00 $35,618,420.00 $10,977,660.00 $3,051,090.00 Amount ($80,257.50) ($108,422.00) ($851,672.25) ($534,276.30) ($143,550.00) (Fee)4 29 8,700 20,000 65,000 3,756,000 80,000 16,500 5,000 7,500,000 37,000 16,824 4,676 Shares Capital Repayment / Disposition / Auction3,5 $910.31 $922.50 $542.11 $873.51 $1.00 $1,000.00 $363.64 $1,000.00 $1.00 $962.66 $652.50 $652.50 Avg. Price ($2,601.01) ($674,250.00) ($9,157,800.00) ($8,221,850.00) ($10,500,000.00) ($1,381,580.00) ($5,846,340.00) ($1,624,910.00) (Realized Loss) / (Write-off) Gain5 $256,118.75 $2,500.00 $1,400,000.00 $113,000.00 $2,966,288.32 $250,000.00 $375,000.00 $11,979,295.00 Wt Amount 261 215,983 241,696 113,000 465,117 250 375,000 550,595 Wt Shares Warrant Proceeds $1,517,766.09 $1,320,734.92 $1,600,000.00 $10,815,494.44 $694,280.34 $4,677,777.78 $570,625.00 $824,313.00 $639,738.21 $6,546,862.22 0 0 10 0 0 0 5 0 0 0 Continued on next page $0.00 $0.00 $2,500,000.00 $0.00 $0.00 $0.00 $1,031,250.00 $0.00 $0.00 $0.00 Amount Dividends Paid Number of Missed of Missed to Date Dividends Dividend Dividends and Interest 238 APPENDIX A I TRANSACTION DETAIL I JANUARY 27, 2017 IN IL IL MANITOWOC MANITOWOC RICHMOND RICHMOND NEENAH NEENAH MUNCIE MUNCIE MUNCIE FIRST MANITOWOC BANCORP, INC. FIRST MARKET BANK, FSB / UNION FIRST MARKET BANKSHARES CORPORATION FIRST MARKET BANK, FSB / UNION FIRST MARKET BANKSHARES CORPORATION FIRST MENASHA BANCSHARES, INC. FIRST MENASHA BANCSHARES, INC. FIRST MERCHANTS 33,44,45 CORPORATION FIRST MERCHANTS CORPORATION FIRST MERCHANTS CORPORATION FIRST MIDWEST BANCORP, ITASCA INC. FIRST MIDWEST BANCORP, ITASCA INC. 11 8,14,44 11,25 8,11,14 FIRST MANITOWOC BANCORP, INC. MS IN IN WI WI VA VA WI WI MS KOSCIUSKO KOSCIUSKO MS CT CT GA GA GA MI MI MI MI TN TN TN LA LA NE FIRST M&F CORPORATION KOSCIUSKO LITCHFIELD FIRST LITCHFIELD FINANCIAL CORPORATION FIRST M&F CORPORATION LITCHFIELD DORAVILLE FIRST INTERCONTINENTAL BANK FIRST LITCHFIELD FINANCIAL CORPORATION DETROIT FIRST INDEPENDENCE CORPORATION DORAVILLE DETROIT FIRST INDEPENDENCE CORPORATION DORAVILLE DETROIT FIRST INDEPENDENCE CORPORATION FIRST INTERCONTINENTAL BANK DETROIT FIRST INDEPENDENCE CORPORATION FIRST INTERCONTINENTAL BANK MEMPHIS MEMPHIS FIRST HORIZON NATIONAL CORPORATION MEMPHIS HAMMOND FIRST GUARANTY BANCSHARES, INC. FIRST HORIZON NATIONAL CORPORATION HAMMOND FIRST GUARANTY BANCSHARES, INC. FIRST HORIZON NATIONAL CORPORATION GOTHENBURG FIRST GOTHENBURG BANCSHARES, INC. NE State FIRST M&F CORPORATION 11,36 11 8 8,9 11 8,14,44 GOTHENBURG City FIRST GOTHENBURG BANCSHARES, INC. Footnote Institution Name 11/23/2011 12/5/2008 11/23/2011 9/22/2011 2/20/2009 9/15/2011 2/13/2009 12/7/2011 2/6/2009 5/27/2009 1/16/2009 8/30/2013 9/29/2010 2/27/2009 4/7/2010 12/12/2008 9/12/2013 8/12/2013 3/13/2009 3/26/2013 1/11/2013 12/20/2012 8/28/2009 3/9/2011 12/22/2010 11/14/2008 9/22/2011 8/28/2009 1/11/2013 10/31/2012 $193,000,000.00 $116,000,000.00 $4,797,000.00 $33,900,000.00 $12,000,000.00 $30,000,000.00 $10,000,000.00 $6,398,000.00 $3,223,000.00 $866,540,000.00 $20,699,000.00 Original Investment Date Amount $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Outstanding Investment Investment Status* Redeemed, in $222,528,333.33 full; warrants not outstanding Redeemed, in $131,383,055.11 full; warrants not outstanding Redeemed, in $5,713,865.00 full; warrants not outstanding Redeemed, in $40,834,859.35 full; warrants not outstanding Redeemed, in $12,837,983.33 full; warrants not outstanding Redeemed, in $36,472,843.94 full; warrants not outstanding Redeemed, in $12,147,768.63 full; warrants not outstanding Sold, in full; $4,118,886.85 warrants not outstanding Sold, in full; $2,820,256.96 warrants not outstanding Redeemed, in $1,037,467,405.56 full; warrants not outstanding Redeemed, in $24,059,476.66 full; warrants not outstanding Total Cash Back2 CPP TRANSACTIONS DETAIL, AS OF 12/31/2016 (CONTINUED) $193,000,000.00 $116,000,000.00 $4,797,000.00 $33,900,000.00 $12,000,000.00 $30,000,000.00 $10,000,000.00 $3,247,112.96 $2,336,675.00 $866,540,000.00 $20,699,000.00 $6,864,647.71 Amount ($25,000.00) ($26,633.25) ($23,366.75) ($68,910.46) (Fee)4 193,000 116,000 4,797 35,595 12,000 30,000 10,000 6,398 3,223 866,540 2,070 7,541 Shares Capital Repayment / Disposition / Auction3,5 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $507.52 $725.00 $1,000.00 $10,000.00 $910.31 Avg. Price ($3,150,887.04) ($886,325.00) ($676,352.29) (Realized Loss) / (Write-off) $1,695,000.00 Gain5 $367,500.00 $240,000.00 $600,000.00 $4,089,510.61 $1,488,046.41 $139,320.00 $79,700,000.00 $1,030,000.00 $362,118.92 Wt Amount 991,453 240 600 513,113 199,203 320 14,842,321 103 379 Wt Shares Warrant Proceeds Dividends and Interest $28,628,333.33 $15,015,555.11 $676,865.00 $237,983.33 $2,383,333.33 $659,722.22 $757,453.89 $533,581.96 $91,227,405.56 $2,330,476.66 0 0 0 0 0 0 0 0 8 0 0 0 Continued on next page $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $697,400.00 $0.00 $0.00 $0.00 Amount Dividends Paid Number of Missed of Missed to Date Dividends Dividend TRANSACTION DETAIL I APPENDIX A I JANUARY 27, 2017 239 79 87 8,14, 18,44, 45 8,14 8,14,18 73,97 11 44 12,16 8,14,44 8,14 VA STRASBURG STRASBURG FIRST NATIONAL CORPORATION LA NY FIRST NBC BANK HOLDING NEW ORLEANS COMPANY LOCKPORT LOCKPORT LOCKPORT DIXON DIXON DIXON FIRST NIAGARA FINANCIAL GROUP FIRST NIAGARA FINANCIAL GROUP FIRST NIAGARA FINANCIAL GROUP FIRST NORTHERN COMMUNITY BANCORP FIRST NORTHERN COMMUNITY BANCORP FIRST NORTHERN COMMUNITY BANCORP FLORENCE FLORENCE FIRST RELIANCE BANCSHARES, INC. FIRST RELIANCE BANCSHARES, INC. SEATTLE SEATTLE FIRST SOUND BANK FIRST SOUND BANK CHATTANOOGA FLORENCE FIRST RELIANCE BANCSHARES, INC. CHATTANOOGA MALVERN FIRST PRIORITY FINANCIAL CORP. FIRST SECURITY GROUP, INC. MALVERN FIRST PRIORITY FINANCIAL CORP. EXTON MALVERN FIRST PRIORITY FINANCIAL CORP. FIRST SECURITY GROUP, INC. MALVERN FIRST PRIORITY FINANCIAL CORP. FIRST RESOURCE BANK MALVERN FIRST PRIORITY FINANCIAL CORP. EXTON WARREN FIRST PLACE FINANCIAL CORP. FIRST RESOURCE BANK OH WARREN FIRST PLACE FINANCIAL CORP. EXTON CA FIRST PACTRUST BANCORP, CHULA VISTA INC. FIRST RESOURCE BANK CA FIRST PACTRUST BANCORP, CHULA VISTA INC. WA WA TN TN PA PA PA SC SC SC PA PA PA PA PA OH CA FIRST PACTRUST BANCORP, CHULA VISTA INC. CA CA CA NY NY LA FIRST NBC BANK HOLDING NEW ORLEANS COMPANY VA IL State FIRST NATIONAL CORPORATION City FIRST MIDWEST BANCORP, ITASCA INC. Footnote Institution Name 2/20/2013 12/23/2008 4/11/2013 1/9/2009 9/15/2011 12/11/2009 1/30/2009 4/9/2013 3/11/2013 3/6/2009 3/26/2013 2/8/2013 2/7/2013 12/18/2009 2/20/2009 10/29/2012 3/13/2009 1/5/2011 12/15/2010 11/21/2008 11/16/2011 9/15/2011 3/13/2009 6/24/2009 5/27/2009 11/21/2008 8/4/2011 3/20/2009 8/29/2012 3/13/2009 12/21/2011 Date $7,400,000.00 $33,000,000.00 $2,417,000.00 $2,600,000.00 $15,349,000.00 $4,596,000.00 $4,579,000.00 $72,927,000.00 $19,300,000.00 $17,390,000.00 $184,011,000.00 $17,836,000.00 $13,900,000.00 Original Investment Amount $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Outstanding Investment Sold, in full; $4,030,944.44 warrants not outstanding Sold, in full; $16,315,362.00 warrants not outstanding Redeemed, in $5,731,793.60 full; warrants not outstanding Sold, in full; $12,994,059.00 warrants not outstanding Sold, in full; $9,948,069.58 warrants not outstanding Exited $7,009,094.50 bankruptcy/ Receivership Redeemed, in $22,297,560.34 full; warrants not outstanding Redeemed, in $19,943,580.33 full; warrants not outstanding Redeemed, in $191,464,618.00 full; warrants not outstanding Redeemed, in $21,033,989.56 full; warrants not outstanding Sold, in full; $15,329,326.44 warrants not outstanding Investment Total Cash Back2 Status* CPP TRANSACTIONS DETAIL, AS OF 12/31/2016 (CONTINUED) $3,700,000.00 $14,912,862.00 $5,017,000.00 $10,431,333.89 $1,410,831.60 $6,682,192.50 $19,300,000.00 $17,390,000.00 $184,011,000.00 $17,836,000.00 $12,266,750.00 Amount ($104,313.34) ($80,930.24) ($184,001.25) (Fee)4 7,400 9,941,908 5,017 15,349 1,600 7,575 19,300 17,390 184,011 17,836 13,900 Shares Capital Repayment / Disposition / Auction3,5 $500.00 $1.50 $1,000.00 $679.61 $881.77 $882.14 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $882.50 Avg. Price ($3,700,000.00) ($18,087,138.00) ($4,917,666.11) ($189,168.40) ($892,807.50) ($72,927,000.00) ($1,633,250.00) (Realized Loss) / (Write-off) Gain5 $130,000.00 $624,632.45 $176,633.62 $48,083.60 $1,003,227.00 $375,000.00 $2,700,000.00 $892,000.00 $624,674.69 $900,000.00 Wt Amount 130 767 180 49 280,795 352,977 953,096 892 695 1,305,230 Wt Shares Warrant Proceeds $330,944.44 $1,402,500.00 $584,793.60 $2,042,406.00 $1,711,258.50 $7,009,094.50 $1,994,333.34 $2,178,580.33 $4,753,618.00 $2,305,989.56 $2,621,903.00 13 0 0 6 0 6 0 0 0 0 0 Continued on next page $1,202,500.00 $0.00 $0.00 $1,254,720.00 $0.00 $5,469,525.00 $0.00 $0.00 $0.00 $0.00 $0.00 Amount Dividends Paid Number of Missed of Missed to Date Dividends Dividend Dividends and Interest 240 APPENDIX A I TRANSACTION DETAIL I JANUARY 27, 2017 8,14,18 8,11, 14,36 8,11,14 14,15 8,14,44 8,14 8,11,14 CO MI FIRST WESTERN FINANCIAL, DENVER INC. FIRST WESTERN FINANCIAL, DENVER INC. ALMA ALMA FIRSTBANK CORPORATION FIRSTBANK CORPORATION MI CO CO FIRST WESTERN FINANCIAL, DENVER INC. CO CO CO FIRST WESTERN FINANCIAL, DENVER INC. CO FIRST WESTERN FINANCIAL, DENVER INC. FIRST WESTERN FINANCIAL, DENVER INC. AL AL MD VERNON OAKLAND FIRST UNITED CORPORATION MD MD FIRST WESTERN FINANCIAL, DENVER INC. OAKLAND FIRST UNITED CORPORATION MD VERNON OAKLAND FIRST UNITED CORPORATION FIRST VERNON BANCSHARES, INC. OAKLAND FIRST UNITED CORPORATION MD CA CA FIRST VERNON BANCSHARES, INC. OAKLAND OAKLAND FIRST ULB CORP. FIRST UNITED CORPORATION OAKLAND FIRST ULB CORP. LA LA FIRST TRUST CORPORATION NEW ORLEANS FIRST TRUST CORPORATION NEW ORLEANS TX LA FORT WORTH TX CO CO CO CO CO FL FL TN TN TN State FIRST TRUST CORPORATION NEW ORLEANS FIRST TEXAS BHC, INC. FIRST SOUTHWEST BANCORPORATION, INC. FORT WORTH ALAMOSA ALAMOSA FIRST SOUTHWEST BANCORPORATION, INC. FIRST TEXAS BHC, INC. ALAMOSA ALAMOSA FIRST SOUTHWEST BANCORPORATION, INC. ALAMOSA BOCA RATON FIRST SOUTHERN BANCORP, INC. FIRST SOUTHWEST BANCORPORATION, INC. BOCA RATON FIRST SOUTHERN BANCORP, INC. FIRST SOUTHWEST BANCORPORATION, INC. LEXINGTON LEXINGTON FIRST SOUTH BANCORP, INC. LEXINGTON FIRST SOUTH BANCORP, 11,14,15 INC. FIRST SOUTH BANCORP, INC. City Footnote Institution Name 7/3/2012 1/30/2009 7/26/2013 6/24/2013 9/11/2012 8/10/2012 8/9/2012 12/11/2009 2/6/2009 9/29/2010 6/12/2009 5/27/2015 1/9/2015 12/4/2014 12/3/2014 1/30/2009 4/22/2009 1/23/2009 3/26/2013 2/20/2013 6/5/2009 9/15/2011 3/6/2009 4/9/2013 3/28/2013 3/27/2013 3/26/2013 3/6/2009 6/16/2010 1/30/2009 11/28/2012 9/28/2011 7/17/2009 $33,000,000.00 $11,881,000.00 $8,559,000.00 $6,000,000.00 $30,000,000.00 $4,900,000.00 $17,969,000.00 $13,533,000.00 $5,500,000.00 $10,900,000.00 $50,000,000.00 Original Investment Date Amount $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Outstanding Investment Investment Status* Sold, in full; $38,185,560.05 warrants not outstanding Sold, in full; $21,142,314.80 warrants not outstanding Redeemed, in $6,662,770.42 full; warrants not outstanding Sold, in full; $40,183,721.33 warrants not outstanding Redeemed, in $5,211,020.69 full; warrants not outstanding Sold, in full; $15,304,180.50 warrants not outstanding Redeemed, in $16,072,389.00 full; warrants not outstanding Sold, in full; $5,359,772.59 warrants not outstanding Redeemed, in $12,263,468.31 full; warrants not outstanding Redeemed, in $65,432,450.94 full; warrants not outstanding Total Cash Back2 CPP TRANSACTIONS DETAIL, AS OF 12/31/2016 (CONTINUED) $31,053,330.00 $10,994,240.00 $62,000.00 $6,138,000.00 $6,000,000.00 $22,200,000.00 $7,800,000.00 $4,900,000.00 $13,750,058.49 $13,533,000.00 $1,800,040.00 $2,835,063.00 $315,007.00 $10,900,000.00 $36,875,000.00 $13,125,000.00 Amount ($465,799.95) ($109,942.41) ($62,000.00) ($300,603.00) ($137,500.58) ($49,501.10) (Fee)4 33,000 12,440 80 7,920 6,000 22,200 7,800 4,900 17,969,000 13,533 2,000 3,150 350 10,900 36,875,000 13,125,000 Shares Capital Repayment / Disposition / Auction3,5 $941.01 $883.78 $775.00 $775.00 $1,000.00 $1,002.01 $1,002.01 $1,000.00 $0.77 $1,000.00 $900.02 $900.02 $900.02 $1,000.00 $1.00 $1.00 Avg. Price ($1,946,670.00) ($1,445,760.00) ($18,000.00) ($1,782,000.00) ($4,218,941.51) ($199,960.00) ($314,937.00) ($34,993.00) (Realized Loss) / (Write-off) $44,622.00 $15,678.00 Gain5 $39,370.32 $311,681.70 $245,000.00 $117,162.42 $245,000.00 $644,726.19 $677,000.00 $45,788.48 $206,048.21 $545,000.00 $2,500,000.00 Wt Amount 48 380 245 326,323 245 898,000 677 50 225 545 2,500,000 Wt Shares Warrant Proceeds Dividends and Interest $5,651,360.00 $3,768,965.19 $417,770.42 $10,306,861.91 $66,020.69 $1,046,896.40 $1,862,389.00 $207,327.00 $818,468.31 $12,932,450.94 0 0 0 0 0 12 0 13 0 0 Continued on next page $0.00 $0.00 $0.00 $0.00 $0.00 $4,522,611.00 $0.00 $974,188.00 $0.00 $0.00 Amount Dividends Paid Number of Missed of Missed to Date Dividends Dividend TRANSACTION DETAIL I APPENDIX A I JANUARY 27, 2017 241 15 8,14 8,11,14 50,97 8,14,45 8,66,97 8,11,14 8,14,45 12,16 8,14,44 8,84 11 MI TROY TROY TROY TROY TROY FLAGSTAR BANCORP, INC. FLAGSTAR BANCORP, INC. FLAGSTAR BANCORP, INC. FLAGSTAR BANCORP, INC. FLAGSTAR BANCORP, INC. CA LAKE SUCCESS LAKE SUCCESS SOUTH SAN FRANCISCO SOUTH SAN FRANCISCO ROCKFORD ROCKFORD FORT LEE FORT LEE ARNOLD ARNOLD FLUSHING FINANCIAL CORPORATION FLUSHING FINANCIAL CORPORATION FNB BANCORP FNB BANCORP FORESIGHT FINANCIAL GROUP, INC. FORESIGHT FINANCIAL GROUP, INC. FORT LEE FEDERAL SAVINGS BANK, FSB FORT LEE FEDERAL SAVINGS BANK, FSB FORTUNE FINANCIAL CORPORATION FORTUNE FINANCIAL CORPORATION WASHINGTON WASHINGTON WASHINGTON FREEPORT FRANKLIN BANCORP, INC. FRANKLIN BANCORP, INC. FRANKLIN BANCORP, INC. FREEPORT BANCSHARES, INC. HAMMOND FPB FINANCIAL CORP. WASHINGTON HAMMOND FPB FINANCIAL CORP. FRANKLIN BANCORP, INC. HAMMOND FPB FINANCIAL CORP. PORT ST. LUCIE CA LAKE SUCCESS FLUSHING FINANCIAL CORPORATION PORT ST. LUCIE NY TAMPA FLORIDA BUSINESS BANCGROUP, INC. FPB BANCORP, INC. FL TAMPA FLORIDA BUSINESS BANCGROUP, INC. FPB BANCORP, INC. FL FLORIDA BANK GROUP, INC. TAMPA IL MO MO MO MO LA LA LA FL FL MO MO NJ NJ IL IL NY NY FL FL FLORIDA BANK GROUP, INC. TAMPA MI MI MI MI MI OH TROY FLAGSTAR BANCORP, INC. OH FIRSTMERIT CORPORATION AKRON OH MI State FIRSTMERIT CORPORATION AKRON ALMA City FIRSTMERIT CORPORATION AKRON FIRSTBANK CORPORATION Footnote Institution Name 5/8/2009 1/11/2013 11/13/2012 11/9/2012 5/22/2009 6/16/2010 12/16/2009 1/23/2009 7/15/2011 12/5/2008 9/15/2011 4/3/2009 4/20/2012 5/22/2009 12/11/2012 5/15/2009 9/15/2011 2/27/2009 12/30/2009 10/28/2009 12/19/2008 9/22/2011 2/20/2009 8/14/2013 7/24/2009 6/12/2013 4/9/2013 3/28/2013 3/27/2013 3/26/2013 1/30/2009 5/27/2009 4/22/2009 1/9/2009 7/18/2012 Date $3,000,000.00 $5,097,000.00 $3,240,000.00 $5,800,000.00 $3,100,000.00 $1,300,000.00 $15,000,000.00 $12,000,000.00 $70,000,000.00 $9,495,000.00 $20,471,000.00 $266,657,000.00 $125,000,000.00 Original Investment Amount $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Outstanding Investment Sold, in full; $4,363,022.95 warrants not outstanding Sold, in full; $4,336,183.67 warrants not outstanding Redeemed, in $3,623,721.50 full; warrants not outstanding Currently Not $273,888.89 Collectible Redeemed, in $3,668,927.67 full; warrants not outstanding Exited $87,184.85 bankruptcy/ Receivership Redeemed, in $18,670,291.67 full; warrants not outstanding Redeemed, in $14,267,700.00 full; warrants not outstanding Redeemed, in $73,904,166.66 full; warrants not outstanding Redeemed, in $11,309,750.50 full; warrants not outstanding Sold, in full; $9,180,793.08 warrants not outstanding Sold, in full; $277,861,053.94 warrants not outstanding Redeemed, in $131,813,194.44 full; warrants not outstanding Investment Total Cash Back2 Status* CPP TRANSACTIONS DETAIL, AS OF 12/31/2016 (CONTINUED) $2,629,302.50 $594,550.00 $2,240,000.00 $1,000,000.00 $3,100,000.00 $15,000,000.00 $12,000,000.00 $70,000,000.00 $9,495,000.00 $8,000,000.00 $13,216,750.00 $228,401,847.00 $1,439,258.50 $125,000,000.00 Amount ($25,000.00) ($2,430,578.56) (Fee)4 4,157 940 2,240 1,000 3,100 15,000 12,000 70,000 9,495 20,471 14,500 250,578 1,579 125,000 Shares Capital Repayment / Disposition / Auction3,5 $632.50 $632.50 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $390.80 $911.50 $911.50 $911.50 $1,000.00 Avg. Price ($1,527,697.50) ($345,450.00) ($5,800,000.00) ($1,300,000.00) ($12,471,000.00) ($1,283,250.00) ($22,176,153.00) ($139,741.50) (Realized Loss) / (Write-off) Gain5 $45,188.88 $126,798.62 $162,000.00 $155,000.00 $750,000.00 $600,000.00 $900,000.00 $475,000.00 $12,905.00 $5,025,000.00 $1,946,670.00 Wt Amount 67 188 162 155 750 600 375,806 475 645,138 952,260 578,947 Wt Shares Warrant Proceeds $1,241,721.45 $965,343.67 $221,721.50 $273,888.89 $413,927.67 $87,184.85 $2,920,291.67 $1,667,700.00 $3,004,166.66 $1,339,750.50 $1,180,793.08 $37,220,872.00 $71,033,631.08 0 0 0 6 0 6 0 0 0 0 11 5 0 Continued on next page $0.00 $0.00 $0.00 $435,000.00 $0.00 $106,275.00 $0.00 $0.00 $0.00 $0.00 $3,068,203.00 $16,666,063.00 $0.00 Amount Dividends Paid Number of Missed of Missed to Date Dividends Dividend Dividends and Interest 242 APPENDIX A I TRANSACTION DETAIL I JANUARY 27, 2017 8,14,44 8,127 11 8,17, 91,97 8,14 8 8,11,14 8,14 11 11,14,15 8,14,44 11,14,15 TULSA GRAND CAPITAL CORPORATION NEW YORK SCOTTSDALE NEW YORK GOLDMAN SACHS GROUP, INC. GOLDMAN SACHS GROUP, INC. SCOTTSDALE NEW YORK GOLDMAN SACHS GROUP, INC. GOLDWATER BANK, N.A. GOLD CANYON GOLD CANYON BANK GOLDWATER BANK, N.A. GOLD CANYON GERMANTOWN GERMANTOWN GERMANTOWN CAPITAL CORPORATION GOLD CANYON BANK GERMANTOWN ATLANTA GEORGIA COMMERCE BANCSHARES, INC. GERMANTOWN CAPITAL CORPORATION ATLANTA GEORGIA COMMERCE BANCSHARES, INC. GERMANTOWN CAPITAL CORPORATION RINGGOLD GATEWAY BANCSHARES, INC. GERMANTOWN RINGGOLD GATEWAY BANCSHARES, INC. ATLANTA LANCASTER GERMANTOWN CAPITAL CORPORATION LANCASTER FULTON FINANCIAL CORPORATION GEORGIA PRIMARY BANK LANCASTER FULTON FINANCIAL CORPORATION ATLANTA AUSTIN FULTON FINANCIAL CORPORATION ATLANTA AUSTIN FRONTIER BANCSHARES, INC FRONTIER BANCSHARES, INC GEORGIA PRIMARY BANK AUSTIN GEORGIA PRIMARY BANK FRESNO FREMONT FREMONT BANCORPORATION FRONTIER BANCSHARES, INC FREMONT FREMONT BANCORPORATION FRESNO FIRST BANK FREEPORT FREEPORT BANCSHARES, INC. FRESNO FREEPORT FREEPORT BANCSHARES, INC. FRESNO FIRST BANK FREEPORT City FREEPORT BANCSHARES, INC. Footnote Institution Name OK AZ AZ NY NY NY AZ AZ TN TN TN TN GA GA GA GA GA GA GA PA PA PA TX TX TX CA CA CA CA IL IL IL State $1,607,000.00 $4,967,000.00 $4,500,000.00 $8,700,000.00 $6,000,000.00 $376,500,000.00 $3,000,000.00 $1,968,000.00 $35,000,000.00 4/24/2009 9/21/2015 1/30/2009 7/22/2009 6/17/2009 $4,000,000.00 $2,568,000.00 10/28/2008 $10,000,000,000.00 4/5/2013 6/26/2009 1/11/2013 10/31/2012 10/29/2012 3/6/2009 3/19/2014 2/10/2014 5/1/2009 2/16/2011 2/6/2009 4/13/2012 5/8/2009 9/8/2010 7/14/2010 12/23/2008 10/6/2010 11/24/2009 4/24/2009 11/1/2012 1/23/2009 7/25/2012 6/26/2009 7/18/2014 4/14/2014 4/11/2014 Original Investment Date Amount $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Outstanding Investment Investment Status* Redeemed, in $4,717,144.78 full; warrants not outstanding Sold, in full; $1,493,750.00 warrants not outstanding Redeemed, in $11,418,055,555.44 full; warrants not outstanding Exited $53,859.52 bankruptcy/ Receivership Sold, in full; $5,699,100.75 warrants not outstanding Sold, in full; $1,576,457.50 warrants not outstanding Redeemed, in $10,096,470.83 full; warrants not outstanding Redeemed, in $7,260,794.87 full; warrants not outstanding Redeemed, in $416,635,625.00 full; warrants not outstanding Redeemed, in $3,408,191.65 full; warrants not outstanding Redeemed, in $2,437,100.33 full; warrants not outstanding Redeemed, in $45,796,066.36 full; warrants not outstanding Total Cash Back2 CPP TRANSACTIONS DETAIL, AS OF 12/31/2016 (CONTINUED) $1,348,000.00 $10,000,000,000.00 $4,494,221.94 $26,393.77 $1,556,145.00 $8,700,000.00 $6,000,000.00 $376,500,000.00 $1,400,000.00 $1,600,000.00 $1,968,000.00 $35,000,000.00 $200,000.00 $2,800,000.00 Amount ($25,000.00) ($25,000.00) ($25,000.00) (Fee)4 2,568 10,000,000 4,938 29 4,500 8,700 6,000 376,500 1,400,000 1,600,000 1,968 35,000,000 200,000 2,800,000 Shares Capital Repayment / Disposition / Auction3,5 $524.92 $1,000.00 $910.13 $910.13 $345.81 $1,000.00 $1,000.00 $1,000.00 $1.00 $1.00 $1,000.00 $1.00 $1.01 $1.01 Avg. Price ($1,220,000.00) ($1,607,000.00) ($443,778.06) ($2,606.23) ($2,943,855.00) (Realized Loss) / (Write-off) Gain5 $1,302.00 $18,228.00 $1,100,000,000.00 $214,595.28 $45,312.50 $435,000.00 $300,000.00 $10,800,000.00 $150,000.00 $98,000.00 $1,750,000.00 $42,257.17 $84,514.33 Wt Amount 12,205,045 248 225 435 300 5,509,756 150,000 98 1,750,000 50,000 100,000 Wt Shares Warrant Proceeds Dividends and Interest $517,144.78 $145,750.00 $318,055,555.44 $53,859.52 $988,889.76 $961,470.83 $960,794.87 $29,335,625.00 $258,191.65 $371,100.33 $9,046,066.36 0 22 0 12 0 18 0 0 0 0 2 0 Continued on next page $0.00 $923,640.00 $0.00 $254,010.00 $0.00 $1,113,163.00 $0.00 $0.00 $0.00 $0.00 $33,357.00 $0.00 Amount Dividends Paid Number of Missed of Missed to Date Dividends Dividend TRANSACTION DETAIL I APPENDIX A I JANUARY 27, 2017 243 MO TN HATTIESBURG GRANBY GREENVILLE GREENVILLE GREENVILLE BAXTER BAXTER BAXTER BAXTER SPRINGFIELD SPRINGFIELD SPRINGFIELD GRAND MOUNTAIN BANCSHARES, INC. GRANDSOUTH BANCORPORATION GRANDSOUTH BANCORPORATION GRANDSOUTH BANCORPORATION GREAT RIVER HOLDING COMPANY GREAT RIVER HOLDING COMPANY GREAT RIVER HOLDING COMPANY GREAT RIVER HOLDING COMPANY GREAT SOUTHERN BANCORP GREAT SOUTHERN BANCORP GREAT SOUTHERN BANCORP GREEN BANKSHARES, INC. GREENEVILLE 8 8,14, 18,44 9,15,36 8,14,45 8,68,97 8 8,11,14 8,11,14 45 15 IA CLIVE CLIVE CLIVE CLIVE GREEN CIRCLE INVESTMENTS, INC. GREEN CIRCLE INVESTMENTS, INC. GREEN CIRCLE INVESTMENTS, INC. MO SC GREEN CITY BANCSHARES, GREEN CITY INC. GREER GREER GREER GREER GREER BANCSHARES INCORPORATED GREER BANCSHARES INCORPORATED GREER BANCSHARES INCORPORATED GREER BANCSHARES INCORPORATED NH MS GUARANTY BANCORP, INC. WOODSVILLE GUARANTY CAPITAL CORPORATION BELZONI NH MO GREGG BANCSHARES, INC. OZARK GUARANTY BANCORP, INC. WOODSVILLE MO GREGG BANCSHARES, INC. OZARK SC SC SC MO GREEN CITY BANCSHARES, GREEN CITY INC. IA IA IA TN GREEN BANKSHARES, INC. GREENEVILLE GREEN CIRCLE INVESTMENTS, INC. MO MO MN MN MN MN SC SC SC CO MS MS HATTIESBURG GRAND FINANCIAL CORPORATION 15 OK TULSA State GRAND FINANCIAL CORPORATION City GRAND CAPITAL CORPORATION Footnote Institution Name 9/25/2009 9/15/2011 2/20/2009 7/13/2012 2/13/2009 7/23/2014 6/11/2014 3/19/2014 1/30/2009 7/14/2010 2/27/2009 4/24/2013 1/23/2013 11/14/2012 2/27/2009 9/7/2011 12/23/2008 9/21/2011 8/18/2011 12/5/2008 7/18/2014 4/14/2014 4/11/2014 7/17/2009 9/8/2011 12/11/2009 1/9/2009 5/29/2009 7/8/2015 9/25/2009 9/8/2011 Date $14,000,000.00 $6,920,000.00 $825,000.00 $9,993,000.00 $651,000.00 $2,400,000.00 $72,278,000.00 $58,000,000.00 $8,400,000.00 $6,319,000.00 $9,000,000.00 $3,076,000.00 $2,443,320.00 Original Investment Amount $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $3,076,000.00 $0.00 Outstanding Investment Currently Not Collectible Redeemed, in $14,913,299.33 full; warrants not outstanding Redeemed, in $8,235,040.33 full; warrants not outstanding $45,190.00 Redeemed, in $13,693,111.07 full; warrants not outstanding Redeemed, in $733,037.33 full; warrants not outstanding Redeemed, in $3,036,021.12 full; warrants not outstanding Sold, in full; $74,642,857.78 warrants not outstanding Redeemed, in $72,274,419.56 full; warrants not outstanding Sold, in full; $11,306,571.15 warrants not outstanding $6,920,000.00 $4,863,000.00 $1,980,000.00 $3,150,000.00 $651,000.00 $800,000.00 $800,000.00 $800,000.00 $68,700,000.00 $58,000,000.00 $3,600,000.00 $4,800,000.00 ($100,212.00) 6,920 4,863 1,980 3,150 651 800 800 800 72,278 58,000 3,600,000 4,800,000 15,319 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $950.50 $1,000.00 $1.19 $1.19 $1,000.00 $1.00 $1,000.00 Avg. Price ($3,578,000.00) (Realized Loss) / (Write-off) $926,400.00 Gain5 ($825,000.00) $694,800.00 $346,000.00 $500,000.00 $33,000.00 $120,000.00 $6,436,364.00 $626,007.69 $450,000.00 $122,000.00 $200,000.00 Wt Amount 346 500 33 120 909,091 420,000 450 122,000 200 Wt Shares $1,856,917.08 $1,303,151.61 $0.00 $913,299.33 $969,040.33 $45,190.00 $3,200,111.07 $49,037.33 $516,021.12 $5,942,857.78 $7,838,055.56 $759,575.46 0 0 9 0 0 0 4 0 14 Continued on next page $0.00 $0.00 $101,115.00 $0.00 $0.00 $0.00 $3,613,900.00 $0.00 $2,466,660.00 0 30 0 Amount Dividends Paid Number of Missed of Missed to Date Dividends Dividend $0.00 2,443,320 4,000 Shares Dividends and Interest Redeemed, in $17,625,917.08 full; warrants not outstanding $15,319,000.00 (Fee)4 Warrant Proceeds $1,527,769.89 $2,443,320.00 $4,000,000.00 Amount Capital Repayment / Disposition / Auction3,5 Full investment outstanding; $0.00 warrants outstanding Redeemed, in $3,868,471.61 full; warrants not outstanding Investment Total Cash Back2 Status* CPP TRANSACTIONS DETAIL, AS OF 12/31/2016 (CONTINUED) 244 APPENDIX A I TRANSACTION DETAIL I JANUARY 27, 2017 SPRINGFIELD SPRINGFIELD SPRINGFIELD SPRINGFIELD GUARANTY FEDERAL BANCSHARES, INC. GUARANTY FEDERAL BANCSHARES, INC. GUARANTY FEDERAL BANCSHARES, INC. MO MO MO MO MO FL STUART HOSCHTON HOSCHTON NORFOLK NORFOLK BALTIMORE HAVILAND HAVILAND GULFSTREAM BANCSHARES, INC. HAMILTON STATE BANCSHARES, INC. HAMILTON STATE BANCSHARES, INC. HAMPTON ROADS BANKSHARES, INC. HAMPTON ROADS BANKSHARES, INC. HARBOR BANKSHARES CORPORATION HAVILAND BANCSHARES, INC. HAVILAND BANCSHARES, INC. 8,9 8,11,14 45 8,17 131 11 38 8,11,14 MO MO MO SC HAWTHORN BANCSHARES, LEE’S SUMMIT INC. HAWTHORN BANCSHARES, LEE’S SUMMIT INC. HAWTHORN BANCSHARES, LEE’S SUMMIT INC. LORIS LORIS HCSB FINANCIAL CORPORATION HCSB FINANCIAL CORPORATION IN IA HEARTLAND BANCSHARES, FRANKLIN INC. DUBUQUE DUBUQUE DUBUQUE HEARTLAND FINANCIAL USA, INC. HEARTLAND FINANCIAL USA, INC. HEARTLAND FINANCIAL USA, INC. IA IA IN HEARTLAND BANCSHARES, FRANKLIN INC. SC MO HAWTHORN BANCSHARES, LEE’S SUMMIT INC. KS KS MD VA VA GA GA FL FL STUART 8,14,45 GULFSTREAM BANCSHARES, INC. FL SPRINGFIELD GUARANTY FEDERAL BANCSHARES, INC. MO GULFSOUTH PRIVATE BANK DESTIN SPRINGFIELD GUARANTY FEDERAL BANCSHARES, INC. MS State GULFSOUTH PRIVATE BANK DESTIN 17,28, 70,97 11 BELZONI GUARANTY FEDERAL BANCSHARES, INC. City GUARANTY CAPITAL CORPORATION Footnote Institution Name 9/28/2011 9/15/2011 12/19/2008 7/17/2012 9/11/2009 4/11/2016 3/6/2009 6/12/2013 5/15/2013 5/9/2012 12/19/2008 12/29/2010 3/13/2009 7/17/2009 4/14/2014 12/31/2008 4/13/2011 2/20/2009 8/18/2011 6/26/2009 10/19/2012 9/25/2009 5/31/2013 5/15/2013 4/29/2013 4/26/2013 6/13/2012 1/30/2009 7/30/2010 Date $81,698,000.00 $7,000,000.00 $12,895,000.00 $30,255,000.00 $425,000.00 $6,800,000.00 $80,347,000.00 $7,000,000.00 $7,500,000.00 $7,500,000.00 $17,000,000.00 Original Investment Amount $0.00 $0.00 $0.00 $0.00 $0.00 $6,800,000.00 $0.00 $0.00 $0.00 $0.00 $0.00 Outstanding Investment Redeemed, in $94,686,087.22 full; warrants not outstanding Redeemed, in $8,321,471.08 full; warrants not outstanding Sold, in full; $1,219,652.00 warrants not outstanding Redeemed, in $36,849,504.67 full; warrants not outstanding $81,698,000.00 $7,000,000.00 $128,950.00 $18,255,000.00 $12,000,000.00 $425,000.00 81,698 7,000 12,895 18,255 12,000 425 $1,000.00 $1,000.00 $10.00 $1,000.00 $1,000.00 $1,000.00 $1.57 $25,000.00 $1,000.00 $967.50 $967.50 $1,000.00 $1.00 Avg. Price ($12,766,050.00) ($77,067,235.46) ($7,500,000.00) ($386,750.00) ($3,250.00) (Realized Loss) / (Write-off) Gain5 $21,000.00 $350,000.00 $375,000.00 $2,003,250.00 Wt Amount 21 35 375 459,459 Wt Shares $2,510,844.25 $819,165.89 $876,541.63 $757,380.08 $3,390,721.44 $1,800,000.00 $248,000.00 $540,000.00 609,687 248 287,134 $11,188,087.22 $1,073,471.08 $1,090,702.00 $6,054,504.67 0 0 21 0 0 26 0 0 0 5 0 Continued on next page $0.00 $0.00 $4,287,588.00 $0.00 $0.00 $2,822,000.00 $4,017,350.00 $0.00 $0.00 $494,063.00 $0.00 Amount Dividends Paid Number of Missed of Missed to Date Dividends Dividend $41,524.22 2,089,022 280 7,500 11,900 100 5,000 14,000,000 Shares Dividends and Interest Redeemed, in $487,524.22 full; warrants not outstanding ($116,100.00) (Fee)4 Warrant Proceeds $282,744.47 $3,279,764.54 $7,000,000.00 $7,500,000.00 $11,513,250.00 $96,750.00 $5,000,000.00 $14,000,000.00 Amount Capital Repayment / Disposition / Auction3,5 Full investment outstanding; $282,744.47 warrants not outstanding Sold, in full; $5,790,608.79 warrants outstanding Redeemed, in $8,169,165.89 full; warrants not outstanding Redeemed, in $8,751,541.63 full; warrants not outstanding Exited $757,380.08 bankruptcy/ Receivership Sold, in full; $21,887,871.44 warrants not outstanding Investment Total Cash Back2 Status* CPP TRANSACTIONS DETAIL, AS OF 12/31/2016 (CONTINUED) TRANSACTION DETAIL I APPENDIX A I JANUARY 27, 2017 245 8,14 8 11 8,11,14 8,111 8,18, 21,44 11 11 11,16 11 8,17,45 OLYMPIA OLYMPIA OLYMPIA HERITAGE FINANCIAL CORPORATION HERITAGE FINANCIAL CORPORATION HERITAGE FINANCIAL CORPORATION WA WA WA CA CA ROCHESTER HMN FINANCIAL, INC. HOMETOWN BANCSHARES, CORBIN INC. ONEONTA ROCHESTER HMN FINANCIAL, INC. ONEONTA ROCHESTER HMN FINANCIAL, INC. HOMETOWN BANCORP OF ALABAMA, INC. ROCHESTER HMN FINANCIAL, INC. CONWAY ROCHESTER HMN FINANCIAL, INC. HOMETOWN BANCORP OF ALABAMA, INC. ROCHESTER HMN FINANCIAL, INC. HOME BANCSHARES, INC. SUMMIT HILLTOP COMMUNITY BANCORP, INC. CONWAY NJ SUMMIT HILLTOP COMMUNITY BANCORP, INC. CONWAY FL HIGHLANDS INDEPENDENT SEBRING BANCSHARES, INC. HOME BANCSHARES, INC. FL HIGHLANDS INDEPENDENT SEBRING BANCSHARES, INC. HOME BANCSHARES, INC. NJ HIGHLANDS BANCORP, INC. VERNON KY AL AL AR AR AR MN MN MN MN MN MN NJ NJ SD NJ SIOUX FALLS HF FINANCIAL CORP. SD SD HIGHLANDS BANCORP, INC. VERNON SIOUX FALLS HF FINANCIAL CORP. HIGHLANDS BANCORP, INC. VERNON SIOUX FALLS HF FINANCIAL CORP. CA SAN JOSE HERITAGE COMMERCE CORP. CA SAN JOSE HERITAGE COMMERCE CORP. CA HERITAGE OAKS BANCORP PASO ROBLES SAN JOSE HERITAGE COMMERCE CORP. VA VA HERITAGE OAKS BANCORP PASO ROBLES NORFOLK HERITAGE BANKSHARES, INC. CA NORFOLK HERITAGE BANKSHARES, INC. VA State HERITAGE OAKS BANCORP PASO ROBLES NORFOLK City HERITAGE BANKSHARES, INC. Footnote Institution Name 2/13/2009 8/28/2013 2/20/2009 7/27/2011 7/6/2011 1/16/2009 5/28/2015 5/26/2015 3/26/2013 2/8/2013 2/7/2013 12/23/2008 4/21/2010 1/30/2009 10/24/2014 3/6/2009 9/22/2011 12/22/2009 5/8/2009 6/30/2009 6/3/2009 11/21/2008 8/7/2013 7/17/2013 3/20/2009 8/17/2011 12/22/2010 11/21/2008 6/10/2013 3/7/2012 11/21/2008 8/11/2011 3/16/2011 9/25/2009 Date $1,900,000.00 $3,250,000.00 $50,000,000.00 $26,000,000.00 $4,000,000.00 $6,700,000.00 $2,359,000.00 $3,091,000.00 $25,000,000.00 $21,000,000.00 $24,000,000.00 $40,000,000.00 $10,103,000.00 Original Investment Amount $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Outstanding Investment Sold, in full; $2,229,801.03 warrants not outstanding Redeemed, in $4,214,202.31 full; warrants not outstanding Redeemed, in $57,480,555.56 full; warrants not outstanding Sold, in full; $26,563,769.78 warrants not outstanding Redeemed, in $4,467,049.67 full; warrants not outstanding Sold, in full; $6,165,312.00 warrants not outstanding Redeemed, in $6,211,926.79 full; warrants not outstanding Redeemed, in $26,316,666.67 full; warrants not outstanding Redeemed, in $27,241,335.26 full; warrants not outstanding Redeemed, in $26,953,333.33 full; warrants not outstanding Redeemed, in $46,901,266.80 full; warrants not outstanding Redeemed, in $11,353,284.46 full; warrants not outstanding Investment Total Cash Back2 Status* CPP TRANSACTIONS DETAIL, AS OF 12/31/2016 (CONTINUED) $3,250,000.00 $50,000,000.00 $16,197,675.00 $2,561,325.00 $4,000,000.00 $5,547,600.00 $5,450,000.00 $25,000,000.00 $21,000,000.00 $24,000,000.00 $40,000,000.00 $7,497,000.00 $2,606,000.00 Amount ($187,590.00) (Fee)4 3,250 50,000 22,450 3,550 4,000 6,700 5,450 25,000 21,000 24,000 40,000 7,497 2,606 Shares Capital Repayment / Disposition / Auction3,5 $1,000.00 $1,000.00 $721.50 $721.50 $1,000.00 $828.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 Avg. Price ($6,252,325.00) ($988,675.00) ($1,152,400.00) (Realized Loss) / (Write-off) Gain5 $163,000.00 $1,300,000.00 $3,686,388.00 $1,843,194.00 $200,000.00 $155,000.00 $650,000.00 $1,575,000.00 $450,000.00 $140,000.00 $303,000.00 Wt Amount 163 158,472 555,555 277,778 200 155 302,419 611,650 138,037 462,963 303 Wt Shares Warrant Proceeds $393,196.03 $801,202.31 $6,180,555.56 $2,462,777.78 $267,049.67 $617,712.00 $606,926.79 $666,666.67 $4,666,335.26 $2,503,333.33 $6,761,266.80 $947,284.46 0 0 0 8 0 15 0 0 0 0 0 0 Continued on next page $0.00 $0.00 $0.00 $2,600,000.00 $0.00 $1,436,313.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Amount Dividends Paid Number of Missed of Missed to Date Dividends Dividend Dividends and Interest 246 APPENDIX A I TRANSACTION DETAIL I JANUARY 27, 2017 8,14 12,16 9,15,36 8,17 8,14 11 8,11, 14,18 8,14,44 11,45 11 8,17 ISELIN ISELIN ISELIN ISELIN IA BANCORP, INC / INDUS AMERICAN BANK IA BANCORP, INC / INDUS AMERICAN BANK IA BANCORP, INC / INDUS AMERICAN BANK IA BANCORP, INC / INDUS AMERICAN BANK IRVING TX LA LA IBERIABANK CORPORATION LAFAYETTE IBERIABANK CORPORATION LAFAYETTE IBT BANCORP, INC. LA IL IL NJ NJ NJ NJ PA PA PA PA IBERIABANK CORPORATION LAFAYETTE CHICAGO PHILADELPHIA HYPERION BANK IBC BANCORP, INC. PHILADELPHIA HYPERION BANK CHICAGO PHILADELPHIA IBC BANCORP, INC. PHILADELPHIA HYPERION BANK OH HUNTINGTON BANCSHARES COLUMBUS HYPERION BANK OH IL IL OH CHICAGO HPK FINANCIAL CORPORATION HUNTINGTON BANCSHARES COLUMBUS CHICAGO HPK FINANCIAL CORPORATION IL MD MD IN IN IN IN KY KY HUNTINGTON BANCSHARES COLUMBUS CHICAGO ELLICOTT CITY HPK FINANCIAL CORPORATION HOWARD BANCORP, INC. MICHIGAN CITY MICHIGAN CITY HORIZON BANCORP HORIZON BANCORP ELLICOTT CITY MICHIGAN CITY HOWARD BANCORP, INC. MICHIGAN CITY HORIZON BANCORP HOPKINSVILLE HORIZON BANCORP HOPKINSVILLE VA HOMETOWN BANKSHARES ROANOKE CORPORATION HOPFED BANCORP VA HOMETOWN BANKSHARES ROANOKE CORPORATION HOPFED BANCORP VA HOMETOWN BANKSHARES ROANOKE CORPORATION KY KY HOMETOWN BANCSHARES, CORBIN INC. HOPKINSVILLE KY HOMETOWN BANCSHARES, CORBIN INC. HOPFED BANCORP KY HOMETOWN BANCSHARES, CORBIN INC. State KY City HOMETOWN BANCSHARES, CORBIN INC. Footnote Institution Name 3/27/2009 5/20/2009 3/31/2009 12/5/2008 9/10/2010 5/15/2009 4/25/2014 3/17/2014 3/14/2014 9/18/2009 3/26/2013 1/11/2013 12/20/2012 2/6/2009 1/19/2011 12/22/2010 11/14/2008 12/11/2012 11/13/2009 5/1/2009 9/22/2011 2/27/2009 11/23/2011 8/25/2011 11/10/2010 12/19/2008 1/16/2013 12/19/2012 12/12/2008 1/11/2013 10/31/2012 9/18/2009 3/26/2013 1/11/2013 11/30/2012 11/28/2012 $2,295,000.00 $90,000,000.00 $4,205,000.00 $5,976,000.00 $1,552,000.00 $1,398,071,000.00 $5,000,000.00 $4,000,000.00 $5,983,000.00 $25,000,000.00 $18,400,000.00 $10,000,000.00 Original Investment Date Amount $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Outstanding Investment Investment Status* Redeemed, in $2,936,462.50 full; warrants not outstanding Redeemed, in $92,650,000.00 full; warrants not outstanding Redeemed, in $4,632,216.32 full; warrants not outstanding Sold, in full; $6,907,223.22 warrants not outstanding Sold, in full; $1,337,166.22 warrants not outstanding Redeemed, in $1,594,356,808.56 full; warrants not outstanding Redeemed, in $10,940,554.65 full; warrants not outstanding Redeemed, in $7,119,793.05 full; warrants not outstanding Redeemed, in $29,857,321.83 full; warrants not outstanding Redeemed, in $22,354,145.89 full; warrants not outstanding Sold, in full; $11,111,011.94 warrants not outstanding Total Cash Back2 CPP TRANSACTIONS DETAIL, AS OF 12/31/2016 (CONTINUED) $90,000,000.00 $4,205,000.00 $3,145,438.66 $2,717,674.70 $1,008,800.00 $1,398,071,000.00 $9,000,000.00 $5,983,000.00 $18,750,000.00 $6,250,000.00 $18,400,000.00 $9,185,000.00 $1,183,339.50 $608,170.50 Amount ($58,631.13) ($14,912.00) ($10,088.00) ($91,850.00) ($7,084.89) ($17,915.11) (Fee)4 90,000 4,205,000 3,206 2,770 1,552 1,398,071 9,000 5,983 18,750 6,250 18,400 10,000 1,255 645 Shares Capital Repayment / Disposition / Auction3,5 $1,000.00 $1.00 $981.11 $981.11 $650.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $918.50 $942.90 $942.90 Avg. Price ($60,561.34) ($52,325.30) ($543,200.00) ($815,000.00) ($71,660.50) ($36,829.50) (Realized Loss) / (Write-off) Gain5 $1,200,000.00 $186,513.52 $25,700.00 $49,100,000.00 $344,000.00 $299,000.00 $1,750,551.00 $256,257.00 $315,461.52 $70,095.00 Wt Amount 138,490 179 78 23,562,994 344 299 212,188 253,666 374 95 Wt Shares Warrant Proceeds Dividends and Interest $526,462.50 $1,450,000.00 $427,216.32 $916,227.47 $327,666.22 $147,185,808.56 $1,596,554.65 $837,793.05 $3,106,770.83 $3,697,888.89 $1,702,400.42 0 0 0 6 0 0 0 0 0 0 0 Continued on next page $0.00 $0.00 $0.00 $472,365.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Amount Dividends Paid Number of Missed of Missed to Date Dividends Dividend TRANSACTION DETAIL I APPENDIX A I JANUARY 27, 2017 247 11 115 22,52,97 11 8,22, 92,97 29 11 8 8,14, 18,44 8,108 8,14,44 8,10,11 RI SANDPOINT SANDPOINT LAREDO LAREDO LAREDO LAREDO LAREDO INTERNATIONAL BANCSHARES CORPORATION INTERNATIONAL BANCSHARES CORPORATION INTERNATIONAL BANCSHARES CORPORATION INTERNATIONAL BANCSHARES CORPORATION INTERNATIONAL BANCSHARES CORPORATION SANDPOINT INTERMOUNTAIN COMMUNITY BANCORP INTERMOUNTAIN COMMUNITY BANCORP EVANSVILLE INTEGRA BANK CORPORATION INTERMOUNTAIN COMMUNITY BANCORP COLUMBUS EVANSVILLE COLUMBUS INDIANA COMMUNITY BANCORP INTEGRA BANK CORPORATION DANA INDIANA COMMUNITY BANCORP DANA INDIANA BANK CORP. IONIA INDEPENDENT BANK CORPORATION INDIANA BANK CORP. MI IONIA INDEPENDENT BANK CORPORATION TX TX TX TX TX ID ID ID IN IN IN IN IN IN MI MA MA INDEPENDENT BANK CORP. ROCKLAND INDEPENDENT BANK CORP. ROCKLAND MA EAST GREENWICH RI IL IL IL ID ID CA CA DC DC TX State INDEPENDENT BANK CORP. ROCKLAND INDEPENDENCE BANK CHICAGO ILLINOIS STATE BANCORP, INC. EAST GREENWICH CHICAGO ILLINOIS STATE BANCORP, INC. INDEPENDENCE BANK CHICAGO BOISE IDAHO BANCORP ILLINOIS STATE BANCORP, INC. BOISE ONTARIO IDAHO BANCORP ONTARIO WASHINGTON ICB FINANCIAL WASHINGTON IBW FINANCIAL CORPORATION ICB FINANCIAL IRVING IBT BANCORP, INC. City IBW FINANCIAL CORPORATION Footnote Institution Name 6/11/2013 11/28/2012 11/1/2012 7/11/2012 12/23/2008 10/31/2014 11/20/2013 12/19/2008 7/29/2011 2/27/2009 9/12/2012 12/12/2008 4/9/2013 4/24/2009 8/30/2013 12/12/2008 5/27/2009 4/22/2009 1/9/2009 10/16/2013 1/9/2009 9/22/2011 12/29/2009 5/22/2009 4/24/2014 1/16/2009 11/1/2012 3/6/2009 9/3/2010 3/13/2009 6/12/2013 Date $216,000,000.00 $27,000,000.00 $83,586,000.00 $21,500,000.00 $1,312,000.00 $72,000,000.00 $78,158,000.00 $1,065,000.00 $4,000,000.00 $6,272,000.00 $6,900,000.00 $6,000,000.00 $6,000,000.00 Original Investment Amount $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Outstanding Investment Currently Not Collectible Redeemed, in $261,538,649.89 full; warrants not outstanding Redeemed, in $33,955,519.23 full; warrants not outstanding $1,950,340.00 Redeemed, in $27,331,250.00 full; warrants not outstanding Exited $165,139.00 bankruptcy/ Receivership Redeemed, in $83,430,000.00 full; warrants not outstanding Redeemed, in $81,476,093.61 full; warrants not outstanding Redeemed, in $1,394,723.17 full; warrants not outstanding Redeemed, in $11,836,113.40 full; warrants not outstanding Exited $555,673.08 bankruptcy/ Receivership Redeemed, in $7,494,458.33 full; warrants not outstanding Redeemed, in $6,453,067.00 full; warrants not outstanding Investment Total Cash Back2 Status* CPP TRANSACTIONS DETAIL, AS OF 12/31/2016 (CONTINUED) $131,000,000.00 $45,000,000.00 $40,000,000.00 $27,000,000.00 $21,500,000.00 $72,000,000.00 $78,158,000.00 $1,065,000.00 $10,272,000.00 $6,000,000.00 $6,000,000.00 $2,295,000.00 Amount (Fee)4 131,000 45,000 40,000 27,000 21,500 72,000 78,158 1,065 10,272 6,000 6,000 2,295 Shares Capital Repayment / Disposition / Auction3,5 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 Avg. Price ($83,586,000.00) ($1,312,000.00) ($6,900,000.00) (Realized Loss) / (Write-off) $2,426,000.00 Gain5 $4,018,511.00 $10,635.00 $1,800,000.00 $2,200,000.00 $53,000.00 $406,000.00 $300,000.00 $115,000.00 Wt Amount 1,326,238 65,323 188,707 481,664 53 406 300 115 Wt Shares Warrant Proceeds $41,520,138.89 $6,944,884.23 $1,950,340.00 $4,031,250.00 $165,139.00 $9,004,000.00 $1,118,093.61 $276,723.17 $1,158,113.40 $124,305.92 $1,194,458.33 $453,067.00 0 0 7 0 6 0 8 0 0 19 0 0 Continued on next page $0.00 $0.00 $7,313,775.00 $0.00 $107,310.00 $0.00 $6,164,420.00 $0.00 $0.00 $1,786,238.00 $0.00 $0.00 Amount Dividends Paid Number of Missed of Missed to Date Dividends Dividend Dividends and Interest 248 APPENDIX A I TRANSACTION DETAIL I JANUARY 27, 2017 8,14 12 11 8,11,14, 18,36 8,14 8 11 8,14,44 WARSAW MILWAUKEE LAYTON PARK FINANCIAL GROUP, INC. MILWAUKEE WARSAW LAKELAND FINANCIAL CORPORATION LAKELAND FINANCIAL CORPORATION LAYTON PARK FINANCIAL GROUP, INC. IN WARSAW LAKELAND FINANCIAL CORPORATION MILWAUKEE NJ LAKELAND BANCORP, INC. OAK RIDGE MILWAUKEE NJ LAKELAND BANCORP, INC. OAK RIDGE LAYTON PARK FINANCIAL GROUP, INC. NJ LAKELAND BANCORP, INC. OAK RIDGE LAYTON PARK FINANCIAL GROUP, INC. NJ LAKELAND BANCORP, INC. OAK RIDGE WI WI WI WI IN IN NJ MS LAKELAND BANCORP, INC. OAK RIDGE MS LAFAYETTE BANCORP, INC. OXFORD NC LAFAYETTE BANCORP, INC. OXFORD SMITHFIELD KS BANCORP, INC NC MS SMITHFIELD KS BANCORP, INC NC LAFAYETTE BANCORP, INC. OXFORD SMITHFIELD KS BANCORP, INC MO OH MO CLEVELAND KEYCORP OH OH KIRKSVILLE BANCORP, INC. KIRKSVILLE CLEVELAND ME ME NY NY NY MO MO NY NY NY NY State KIRKSVILLE BANCORP, INC. KIRKSVILLE CLEVELAND HOULTON KATAHDIN BANKSHARES CORP. KEYCORP HOULTON KATAHDIN BANKSHARES CORP. KEYCORP NEW YORK NEW YORK JPMORGAN CHASE & CO. JPMORGAN CHASE & CO. NEW YORK JPMORGAN CHASE & CO. SEDALIA 11 SEDALIA INTERVEST BANCSHARES CORPORATION INVESTORS FINANCIAL CORPORATION OF PETTIS COUNTY, INC. NEW YORK INTERVEST BANCSHARES CORPORATION INVESTORS FINANCIAL 15,71,97 CORPORATION OF PETTIS COUNTY, INC. NEW YORK NEW YORK INTERVEST BANCSHARES CORPORATION NEW YORK City INTERVEST BANCSHARES CORPORATION Footnote Institution Name $4,000,000.00 $25,000,000.00 3/26/2013 1/11/2013 11/29/2012 12/18/2009 11/22/2011 6/9/2010 2/27/2009 2/29/2012 2/8/2012 3/16/2011 8/4/2010 2/6/2009 9/29/2010 12/29/2009 2/20/2009 1/11/2013 11/30/2012 8/21/2009 3/19/2014 3/20/2009 4/20/2011 3/30/2011 11/14/2008 8/18/2011 1/30/2009 12/16/2009 6/17/2009 $3,000,000.00 $56,044,000.00 $59,000,000.00 $2,453,000.00 $1,998,000.00 $4,000,000.00 $470,000.00 $2,500,000,000.00 $10,449,000.00 10/28/2008 $25,000,000,000.00 10/19/2012 5/8/2009 9/3/2014 7/26/2013 6/24/2013 12/23/2008 Original Investment Date Amount $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Outstanding Investment Investment Status* Sold, in full; $2,932,162.50 warrants not outstanding Redeemed, in $60,517,713.33 full; warrants not outstanding Redeemed, in $68,260,833.33 full; warrants not outstanding Redeemed, in $4,818,134.50 full; warrants not outstanding Sold, in full; $4,137,336.64 warrants not outstanding Redeemed, in $622,228.44 full; warrants not outstanding Redeemed, in $2,867,222,222.22 full; warrants not outstanding Redeemed, in $12,423,046.75 full; warrants not outstanding Redeemed, in $26,731,202,358.00 full; warrants not outstanding Currently Not $174,324.60 Collectible Sold, in full; $32,927,621.56 warrants not outstanding Total Cash Back2 CPP TRANSACTIONS DETAIL, AS OF 12/31/2016 (CONTINUED) $2,370,930.00 $56,044,000.00 $19,000,000.00 $20,000,000.00 $20,000,000.00 $4,451,000.00 $3,308,000.00 $470,000.00 $2,500,000,000.00 $10,449,000.00 $25,000,000,000.00 $24,250,000.00 Amount ($1,290.71) ($23,709.29) ($25,000.00) ($242,500.00) (Fee)4 3,000 56,044 19,000 20,000 20,000 4,451 4,000 470 25,000 10,449 2,500,000 25,000 Shares Capital Repayment / Disposition / Auction3,5 $790.31 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $827.00 $1,000.00 $100,000.00 $1,000.00 $10,000.00 $970.00 Avg. Price ($629,070.00) ($692,000.00) ($4,000,000.00) ($750,000.00) (Realized Loss) / (Write-off) Gain5 $104,375.00 $877,557.00 $2,800,000.00 $100,000.00 $140,400.00 $24,000.00 $70,000,000.00 $522,000.00 $936,063,469.11 $2,892,066.00 Wt Amount 150 198,269 997,050 100 200 24 35,244,361 522 88,401,697 691,882 Wt Shares Warrant Proceeds Dividends and Interest $481,857.50 $3,596,156.33 $6,460,833.33 $267,134.50 $713,936.64 $128,228.44 $297,222,222.22 $1,452,046.75 $795,138,888.89 $174,324.60 $6,028,055.56 0 0 0 0 0 0 0 0 0 11 0 Continued on next page $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $922,900.00 $0.00 Amount Dividends Paid Number of Missed of Missed to Date Dividends Dividend TRANSACTION DETAIL I APPENDIX A I JANUARY 27, 2017 249 11 8,9,17 11 8 11 8,133 9,11,36 8,17 8,14,45 8,14,45 9,48,97 BUFFALO BUFFALO BUFFALO M&T BANK CORPORATION M&T BANK CORPORATION M&T BANK CORPORATION DURHAM DURHAM M&F BANCORP, INC. NORTH ANDOVER NORTH ANDOVER LSB CORPORATION LSB CORPORATION M&F BANCORP, INC. NORTH ANDOVER HOUSTON HOUSTON LONE STAR BANK LONE STAR BANK LSB CORPORATION HOUSTON LORAIN LNB BANCORP, INC. HOUSTON LORAIN LNB BANCORP, INC. LONE STAR BANK LORAIN LNB BANCORP, INC. LONE STAR BANK RADNOR NEW ORLEANS LIBERTY FINANCIAL SERVICES, INC. RADNOR NEW ORLEANS LIBERTY FINANCIAL SERVICES, INC. LINCOLN NATIONAL CORPORATION FORT WORTH LIBERTY BANCSHARES, INC. (TX) LINCOLN NATIONAL CORPORATION FORT WORTH LIBERTY BANCSHARES, INC. (TX) RADNOR SPRINGFIELD LIBERTY BANCSHARES, INC. (MO) LINCOLN NATIONAL CORPORATION SPRINGFIELD LIBERTY BANCSHARES, INC. (MO) HINESVILLE JONESBORO LIBERTY BANCSHARES, INC. (AR) HINESVILLE JONESBORO LIBERTY BANCSHARES, INC. (AR) LIBERTY SHARES, INC. MILWAUKEE LEGACY BANCORP, INC. LIBERTY SHARES, INC. MILWAUKEE ARLINGTON LEGACY BANCORP, INC. ARLINGTON LEADER BANCORP, INC. LEBANON LEBANON LCNB CORP. LCNB CORP. LEADER BANCORP, INC. LEBANON LCNB CORP. 11 8,11,14 City Footnote Institution Name NY NY NY NC NC MA MA MA TX TX TX TX OH OH OH PA PA PA GA GA LA LA TX TX MO MO AR AR WI WI MA MA OH OH OH State 8/21/2012 5/18/2011 12/23/2008 8/20/2010 6/26/2009 12/16/2009 11/18/2009 12/12/2008 1/9/2015 12/4/2014 12/3/2014 2/6/2009 7/18/2012 6/19/2012 12/12/2008 9/22/2010 6/30/2010 7/10/2009 6/30/2016 2/20/2009 9/24/2010 2/6/2009 1/14/2015 12/4/2009 8/18/2011 2/13/2009 7/21/2011 1/23/2009 3/11/2011 1/30/2009 11/24/2010 12/23/2008 11/22/2011 10/21/2009 1/9/2009 Date $600,000,000.00 $11,735,000.00 $15,000,000.00 $3,072,000.00 $25,223,000.00 $950,000,000.00 $17,280,000.00 $5,645,000.00 $6,500,000.00 $21,900,000.00 $57,500,000.00 $5,498,000.00 $5,830,000.00 $13,400,000.00 Original Investment Amount $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Outstanding Investment Currently Not Collectible Redeemed, in $718,392,161.34 full; warrants not outstanding Redeemed, in $12,409,762.50 full; warrants not outstanding Redeemed, in $16,260,000.00 full; warrants not outstanding Sold, in full; $1,950,881.54 warrants not outstanding Sold, in full; $26,893,046.60 warrants not outstanding Redeemed, in $1,209,851,873.70 full; warrants not outstanding Sold, in full; $4,999,560.00 warrants not outstanding Redeemed, in $6,106,008.58 full; warrants not outstanding Redeemed, in $8,447,271.11 full; warrants not outstanding Redeemed, in $25,995,452.08 full; warrants not outstanding Redeemed, in $68,191,965.77 full; warrants not outstanding $355,079.00 Redeemed, in $6,731,961.06 full; warrants not outstanding Redeemed, in $14,527,390.33 full; warrants not outstanding Investment Total Cash Back2 Status* CPP TRANSACTIONS DETAIL, AS OF 12/31/2016 (CONTINUED) $230,000,000.00 $370,000,000.00 $11,735,000.00 $15,000,000.00 $712,573.75 $1,195,906.25 $21,923,074.91 $950,000,000.00 $3,600,000.00 $5,645,000.00 $6,500,000.00 $21,900,000.00 $57,500,000.00 $5,830,000.00 $13,400,000.00 Amount ($25,000.00) ($328,846.12) (Fee)4 230,000 370,000 11,735 15,000 1,147 1,925 25,223 950,000 480,000 5,645 6,500 21,900 57,500 5,830 13,400 Shares Capital Repayment / Disposition / Auction3,5 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $621.25 $621.25 $869.17 $1,000.00 $7.50 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 Avg. Price ($434,426.25) ($729,093.75) ($3,299,925.09) ($13,680,000.00) ($5,498,000.00) (Realized Loss) / (Write-off) Gain5 $560,000.00 $67,401.54 $860,326.00 $213,671,319.20 $196,000.00 $1,095,000.00 $2,875,000.00 $292,000.00 $602,557.00 Wt Amount 209,497 154 561,343 13,049,451 196 1,095 2,875 292 217,063 Wt Shares Warrant Proceeds $155,027,270.00 $674,762.50 $700,000.00 $4,438,491.81 $46,180,554.50 $1,399,560.00 $461,008.58 $1,751,271.11 $3,000,452.08 $7,816,965.77 $355,079.00 $609,961.06 $524,833.33 0 0 0 23 0 0 23 0 0 0 0 3 0 0 Continued on next page $0.00 $0.00 $0.00 $1,059,242.00 $0.00 $0.00 $6,797,520.00 $0.00 $0.00 $0.00 $0.00 $206,175.00 $0.00 $0.00 Amount Dividends Paid Number of Missed of Missed to Date Dividends Dividend Dividends and Interest 250 APPENDIX A I TRANSACTION DETAIL I JANUARY 27, 2017 14,15 8 8 14,15 11 8,14 8,11,44 8 MANISTIQUE MANISTIQUE RICHMOND RICHMOND RICHMOND MACKINAC FINANCIAL CORPORATION MACKINAC FINANCIAL CORPORATION MADISON FINANCIAL CORPORATION MADISON FINANCIAL CORPORATION MADISON FINANCIAL CORPORATION IN CA IL IL IL IL FL MANHATTAN BANCSHARES, MANHATTAN INC. MANHATTAN BANCSHARES, MANHATTAN INC. MANHATTAN BANCSHARES, MANHATTAN INC. MANHATTAN BANCSHARES, MANHATTAN INC. VERO BEACH VERO BEACH VERO BEACH VERO BEACH VERO BEACH NEW MARKET NEW MARKET NEW MARKET MT. VERNON MT. VERNON MARINE BANK & TRUST COMPANY MARINE BANK & TRUST COMPANY MARINE BANK & TRUST COMPANY MARINE BANK & TRUST COMPANY MARINE BANK & TRUST COMPANY MARKET BANCORPORATION, INC. MARKET BANCORPORATION, INC. MARKET BANCORPORATION, INC. MARKET STREET BANCSHARES, INC. MARKET STREET BANCSHARES, INC. IL IL MN MN MN FL FL FL FL CA EL SEGUNDO CA IN EL SEGUNDO MAINSOURCE FINANCIAL GROUP, INC. MANHATTAN BANCORP GREENSBURG GREENSBURG MAINSOURCE FINANCIAL GROUP, INC. IN MANHATTAN BANCORP GREENSBURG MAINSOURCE FINANCIAL GROUP, INC. PA PA EL SEGUNDO EBENSBURG TN TN TN TN KY KY KY MI MI MI NY State MANHATTAN BANCORP EBENSBURG MAINLINE BANCORP, INC. MEMPHIS MAGNA BANK MAINLINE BANCORP, INC. MEMPHIS MEMPHIS MAGNA BANK MAGNA BANK MEMPHIS MANISTIQUE MACKINAC FINANCIAL CORPORATION MAGNA BANK BUFFALO City M&T BANK CORPORATION Footnote Institution Name 8/9/2012 5/15/2009 9/26/2014 7/2/2014 2/20/2009 9/26/2014 7/3/2014 7/2/2014 7/1/2014 3/6/2009 1/11/2013 12/11/2012 12/10/2012 6/19/2009 10/14/2009 9/16/2009 12/5/2008 6/11/2013 4/3/2012 1/16/2009 3/9/2012 12/29/2009 8/18/2011 6/8/2011 11/24/2009 12/23/2008 1/6/2014 11/19/2013 3/13/2009 12/19/2012 8/29/2012 4/24/2009 12/17/2012 $20,300,000.00 $2,060,000.00 $3,000,000.00 $2,639,000.00 $1,700,000.00 $57,000,000.00 $4,500,000.00 $13,795,000.00 $3,370,000.00 $11,000,000.00 Original Investment Date Amount $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Outstanding Investment Investment Status* Sold, in full; $24,429,245.84 warrants not outstanding Sold, in full; $2,714,911.32 warrants not outstanding Sold, in full; $2,296,213.00 warrants not outstanding Sold, in full; $3,438,793.11 warrants not outstanding Redeemed, in $1,829,711.12 full; warrants not outstanding Sold, in full; $62,949,121.28 warrants not outstanding Redeemed, in $5,263,187.50 full; warrants not outstanding Redeemed, in $16,146,467.87 full; warrants not outstanding Sold, in full; $3,773,495.65 warrants not outstanding Sold, in full; $13,521,828.15 warrants not outstanding Total Cash Back2 CPP TRANSACTIONS DETAIL, AS OF 12/31/2016 (CONTINUED) $17,919,962.10 $2,060,000.00 $21,440.00 $483,740.00 $1,504,820.00 $2,586,404.73 $1,700,000.00 $53,073,270.00 $4,500,000.00 $6,885,000.00 $3,455,000.00 $3,455,000.00 $3,370,000.00 $10,538,990.00 Amount ($25,000.00) ($25,000.00) ($25,000.00) ($796,099.05) ($25,000.00) ($158,084.85) (Fee)4 19,931,000 2,060 32 722 2,246 2,639,000 1,700 57,000 4,500 6,885 3,455 3,455 3,370 11,000 Shares Capital Repayment / Disposition / Auction3,5 $0.90 $1,210.03 $670.00 $670.00 $670.00 $0.98 $1,000.00 $931.11 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,022.61 $958.09 Avg. Price ($2,011,037.90) ($10,560.00) ($238,260.00) ($741,180.00) ($52,595.27) ($3,926,730.00) ($461,010.00) (Realized Loss) / (Write-off) $432,661.80 $76,195.70 Gain5 $727,225.54 $108,471.52 $503.33 $19,126.67 $55,870.00 $95,959.50 $11,385.02 $63,363.90 $1,512,177.00 $225,000.00 $690,000.00 $182,878.45 $1,300,000.00 $31,838,761.34 Wt Amount 895,000 103 1 38 111 118,000 14,000 29,480 571,906 225 690 169 398,734 1,218,522 Wt Shares Warrant Proceeds Dividends and Interest $5,535,302.50 $138,778.00 $235,713.00 $770,043.86 $66,347.22 $9,159,773.33 $538,187.50 $1,661,467.87 $169,421.50 $1,840,923.00 0 16 15 0 0 0 0 0 15 0 Continued on next page $0.00 $449,080.00 $613,125.00 $0.00 $0.00 $0.00 $0.00 $0.00 $688,913.00 $0.00 Amount Dividends Paid Number of Missed of Missed to Date Dividends Dividend TRANSACTION DETAIL I APPENDIX A I JANUARY 27, 2017 251 8,18 8,14,44 8,14,56 8,14,44 11 8,14, 18,44 8,14,45 11 8 43 8,14 TOWSON TOWSON MARYLAND FINANCIAL BANK MARYLAND FINANCIAL BANK BOSTON TOONE TOONE JOLIET JOLIET MERCANTILE CAPITAL CORPORATION MERCHANTS & PLANTERS BANCSHARES, INC. MERCHANTS & PLANTERS BANCSHARES, INC. MERCHANTS AND MANUFACTURERS BANK CORPORATION MERCHANTS AND MANUFACTURERS BANK CORPORATION DEVON BOSTON MERCANTILE CAPITAL CORPORATION MERIDIAN BANK GRAND RAPIDS MERCANTILE BANK CORPORATION MI GRAND RAPIDS GRAND RAPIDS GRAND RAPIDS MERCANTILE BANK CORPORATION MERCANTILE BANK CORPORATION SALT LAKE CITY MEDALLION BANK MERCANTILE BANK CORPORATION MI SALT LAKE CITY MEDALLION BANK PA IL IL TN TN MA MA MI MI UT UT SALT LAKE CITY UT MN MN IL IL IL MD MD MD WI WI IL IL IL IL IL IL IL State MEDALLION BANK SHOREWOOD TOWSON MARYLAND FINANCIAL BANK MCLEOD BANCSHARES, INC. MILWAUKEE MARSHALL & ILSLEY CORPORATION SHOREWOOD MILWAUKEE MARSHALL & ILSLEY CORPORATION CHICAGO CHICAGO MARQUETTE NATIONAL CORPORATION MCLEOD BANCSHARES, INC. CHICAGO MARQUETTE NATIONAL CORPORATION MB FINANCIAL INC. CHICAGO MARQUETTE NATIONAL CORPORATION CHICAGO CHICAGO MARQUETTE NATIONAL CORPORATION CHICAGO CHICAGO MARQUETTE NATIONAL CORPORATION MB FINANCIAL INC. MT. VERNON MB FINANCIAL INC. MT. VERNON MARKET STREET BANCSHARES, INC. City MARKET STREET BANCSHARES, INC. Footnote Institution Name 2/13/2009 9/8/2011 6/19/2009 9/7/2011 3/6/2009 8/4/2011 2/6/2009 7/3/2012 6/6/2012 4/4/2012 5/15/2009 7/21/2011 12/22/2009 2/27/2009 8/18/2011 11/20/2009 5/2/2012 3/14/2012 12/5/2008 9/26/2014 7/2/2014 3/27/2009 7/5/2011 11/14/2008 9/11/2012 8/10/2012 8/9/2012 8/7/2012 12/19/2008 9/11/2012 8/10/2012 Date $6,200,000.00 $3,510,000.00 $1,881,000.00 $3,500,000.00 $21,000,000.00 $9,698,000.00 $11,800,000.00 $6,000,000.00 $196,000,000.00 $1,700,000.00 $1,715,000,000.00 $35,500,000.00 Original Investment Amount $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Outstanding Investment Sold, in full; $13,582,165.84 warrants not outstanding Redeemed, in $4,110,668.47 full; warrants not outstanding Redeemed, in $2,231,560.00 full; warrants not outstanding Redeemed, in $4,150,815.03 full; warrants not outstanding Redeemed, in $31,631,120.56 full; warrants not outstanding Redeemed, in $24,460,674.81 full; warrants not outstanding Redeemed, in $6,870,433.33 full; warrants not outstanding Redeemed, in $229,613,072.00 full; warrants not outstanding Sold, in full; $817,240.50 warrants not outstanding Redeemed, in $1,944,772,916.66 full; warrants not outstanding Sold, in full; $33,835,943.42 warrants not outstanding Investment Total Cash Back2 Status* CPP TRANSACTIONS DETAIL, AS OF 12/31/2016 (CONTINUED) $3,510,000.00 $1,881,000.00 $3,500,000.00 $10,500,000.00 $10,500,000.00 $21,498,000.00 $6,000,000.00 $196,000,000.00 $527,000.00 $1,715,000,000.00 $17,133,307.00 $5,904,609.50 $2,530,958.50 $331,767.90 Amount ($25,000.00) ($255,688.75) ($182,517.30) (Fee)4 3,510 1,881 3,500 10,500 10,500 21,498 600 196,000 1,700 1,715,000 23,788 8,198 3,514 369,000 Shares Capital Repayment / Disposition / Auction3,5 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $10,000.00 $1,000.00 $310.00 $1,000.00 $720.25 $720.25 $720.25 $0.90 Avg. Price ($1,173,000.00) ($6,654,693.00) ($2,293,390.50) ($983,041.50) ($37,232.10) (Realized Loss) / (Write-off) Gain5 $176,000.00 $94,000.00 $175,000.00 $7,465,100.00 $645,000.00 $300,000.00 $1,518,072.00 $1,775.00 $3,250,000.00 $252,452.23 $1,054,743.77 $142,974.56 $97,505.10 Wt Amount 176 94 175 616,438 645 30 506,024 85 13,815,789 309 1,291 175 120,000 Wt Shares Warrant Proceeds $3,094,895.51 $424,668.47 $256,560.00 $475,815.03 $3,166,020.56 $2,317,674.81 $570,433.33 $32,095,000.00 $313,465.50 $226,522,916.66 $7,072,586.61 0 0 0 0 0 0 0 0 7 0 0 Continued on next page $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $162,138.00 $0.00 $0.00 Amount Dividends Paid Number of Missed of Missed to Date Dividends Dividend Dividends and Interest 252 APPENDIX A I TRANSACTION DETAIL I JANUARY 27, 2017 22,27,97 8 44 8,11,14 12 11 8,18 8,42 8,14 GA TX TX TX IL DORAVILLE DORAVILLE METROCORP BANCSHARES, HOUSTON INC. METROCORP BANCSHARES, HOUSTON INC. METROCORP BANCSHARES, HOUSTON INC. CHICAGO CHICAGO CHICAGO CHICAGO CHICAGO CHICAGO METRO CITY BANK METRO CITY BANK METROPOLITAN BANK GROUP, INC. METROPOLITAN BANK GROUP, INC. METROPOLITAN CAPITAL BANCORP, INC. METROPOLITAN CAPITAL BANCORP, INC. METROPOLITAN CAPITAL BANCORP, INC. METROPOLITAN CAPITAL BANCORP, INC. PA PA VA MID PENN BANCORP, INC./ MILLERSBURG MID PENN BANK MID PENN BANCORP, INC./ MILLERSBURG MID PENN BANK MIDDLEBURG MIDDLEBURG MIDDLEBURG EFFINGHAM EFFINGHAM MIDDLEBURG FINANCIAL CORPORATION MIDDLEBURG FINANCIAL CORPORATION MIDDLEBURG FINANCIAL CORPORATION MIDLAND STATES BANCORP, INC. MIDLAND STATES BANCORP, INC. GA ATLANTA ATLANTA ATLANTA MIDTOWN BANK & TRUST COMPANY MIDTOWN BANK & TRUST COMPANY MIDTOWN BANK & TRUST COMPANY IL IL MIDWEST BANC HOLDINGS, MELROSE PARK INC. MIDWEST BANC HOLDINGS, MELROSE PARK INC. GA GA LA LA MIDSOUTH BANCORP, INC. LAFAYETTE MIDSOUTH BANCORP, INC. LAFAYETTE LA MIDSOUTH BANCORP, INC. LAFAYETTE IL IL VA VA PA MID PENN BANCORP, INC./ MILLERSBURG MID PENN BANK IL IL IL IL IL GA GA DORAVILLE GA PA PA METRO CITY BANK DEVON MERIDIAN BANK DORAVILLE DEVON MERIDIAN BANK PA State METRO CITY BANK DEVON City MERIDIAN BANK Footnote Institution Name 5/14/2010 12/5/2008 1/6/2014 11/19/2013 2/27/2009 11/22/2011 8/25/2011 1/9/2009 12/23/2009 1/23/2009 11/18/2011 12/23/2009 1/30/2009 1/23/2013 12/28/2012 12/19/2008 8/6/2015 6/29/2015 11/20/2009 4/10/2009 6/28/2013 6/26/2009 6/11/2013 7/3/2012 1/16/2009 1/11/2013 11/1/2012 10/29/2012 1/30/2009 4/25/2014 3/17/2014 12/11/2009 $84,784,000.00 $5,222,000.00 $20,000,000.00 $10,189,000.00 $22,000,000.00 $10,000,000.00 $2,348,000.00 $2,040,000.00 $71,526,000.00 $45,000,000.00 $7,700,000.00 $6,335,000.00 Original Investment Date Amount $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Outstanding Investment Investment Status* Exited $824,288.89 bankruptcy/ Receivership Sold, in full; $3,520,137.55 warrants not outstanding Redeemed, in $22,834,334.78 full; warrants not outstanding Redeemed, in $11,206,989.34 full; warrants not outstanding Redeemed, in $23,287,945.11 full; warrants not outstanding Redeemed, in $12,070,979.20 full; warrants not outstanding Sold, in full; $5,663,197.28 warrants not outstanding Sold, in full; $27,172,726.72 warrants not outstanding Sold, in full; $53,406,628.25 warrants not outstanding Sold, in full; $8,806,297.80 warrants not outstanding Total Cash Back2 CPP TRANSACTIONS DETAIL, AS OF 12/31/2016 (CONTINUED) $3,133,200.00 $20,000,000.00 $10,189,000.00 $22,000,000.00 $10,000,000.00 $4,135,655.24 $23,718,541.95 $44,152,650.00 $6,904,667.10 $26,102.90 $10,328,152.35 Amount ($25,000.00) ($33,333.34) ($662,289.75) ($69,307.70) ($103,281.52) (Fee)4 5,222 20,000 10,189 22,000 10,000 4,388 71,526 45,000 7,671 29 12,535 Shares Capital Repayment / Disposition / Auction3,5 $600.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $942.49 $331.61 $981.17 $900.10 $900.10 $823.95 Avg. Price ($84,784,000.00) ($2,088,800.00) ($252,344.76) ($47,807,458.05) ($847,350.00) ($766,332.90) ($2,897.10) ($2,206,847.65) (Realized Loss) / (Write-off) Gain5 $136,833.05 $206,557.00 $509,000.00 $301,001.00 $58,479.20 $84,445.94 $2,087,368.00 $369,948.00 $262,399.50 Wt Amount 261 104,384 509 104,101 73,099 102 771,429 385 310 Wt Shares Warrant Proceeds Dividends and Interest $824,288.89 $275,104.50 $2,627,777.78 $508,989.34 $986,944.11 $2,012,500.00 $1,476,429.44 $3,786,440.95 $7,828,900.00 $1,574,887.50 0 15 0 0 0 0 0 0 0 0 Continued on next page $0.00 $1,067,213.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Amount Dividends Paid Number of Missed of Missed to Date Dividends Dividend TRANSACTION DETAIL I APPENDIX A I JANUARY 27, 2017 253 8,11,14 8,11,14 11 8,14,44 8,14,45 12,16 98 8,11,14 9,11,36 9,11 8 8,11,14 11 8,11,14 IA IA WI WI CO IOWA CITY IOWA CITY IOWA CITY SAN LUIS OBISPO SAN LUIS OBISPO MIDWESTONE FINANCIAL GROUP, INC. MID-WISCONSIN FINANCIAL MEDFORD SERVICES, INC. EDWARDS MIDWESTONE FINANCIAL GROUP, INC. MID-WISCONSIN FINANCIAL MEDFORD SERVICES, INC. EDWARDS MIDWESTONE FINANCIAL GROUP, INC. MILLENNIUM BANCORP, INC. MILLENNIUM BANCORP, INC. MISSION COMMUNITY BANCORP MISSION COMMUNITY BANCORP CA NH MISSION VALLEY BANCORP SUN VALLEY PETERBOROUGH PETERBOROUGH COLDWATER COLDWATER CHESAPEAKE CHESAPEAKE CHESAPEAKE MONADNOCK BANCORP, INC. MONADNOCK BANCORP, INC. MONARCH COMMUNITY BANCORP, INC. MONARCH COMMUNITY BANCORP, INC. MONARCH FINANCIAL HOLDINGS, INC. MONARCH FINANCIAL HOLDINGS, INC. MONARCH FINANCIAL HOLDINGS, INC. NEW YORK NEW YORK NEW YORK MERRIAM MERRIAM MOSCOW MOSCOW MORGAN STANLEY MORGAN STANLEY MORRILL BANCSHARES, INC. MORRILL BANCSHARES, INC. MOSCOW BANCSHARES, INC. MOSCOW BANCSHARES, INC. BETHESDA MONUMENT BANK MORGAN STANLEY BETHESDA TN TN KS KS NY NY NY MD MD TN MONEYTREE CORPORATION LENOIR CITY MONUMENT BANK TN MONEYTREE CORPORATION LENOIR CITY VA VA VA MI MI NH CA MISSION VALLEY BANCORP SUN VALLEY CA CA CO IA MO MIDWEST REGIONAL BANCORP, INC. / THE BANK FESTUS OF OTTERVILLE State MO City MIDWEST REGIONAL BANCORP, INC. / THE BANK FESTUS OF OTTERVILLE Footnote Institution Name $4,734,000.00 $9,516,000.00 $14,700,000.00 $6,785,000.00 $1,834,000.00 $5,500,000.00 $5,116,000.00 $7,260,000.00 $10,000,000.00 $16,000,000.00 $700,000.00 Original Investment Amount 4/25/2012 1/23/2009 7/20/2011 1/16/2009 8/12/2009 6/17/2009 $6,216,000.00 $13,000,000.00 10/28/2008 $10,000,000,000.00 8/11/2011 1/30/2009 9/15/2011 3/13/2009 2/10/2010 12/23/2009 12/19/2008 11/15/2013 2/6/2009 12/28/2012 12/19/2008 8/20/2010 12/23/2008 12/28/2011 1/9/2009 8/14/2012 4/3/2009 4/26/2013 2/20/2009 7/27/2011 7/6/2011 2/6/2009 11/10/2009 2/13/2009 Date $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Outstanding Investment Redeemed, in $7,803,377.38 full; warrants not outstanding Redeemed, in $15,429,122.22 full; warrants not outstanding Redeemed, in $11,268,055,555.11 full; warrants not outstanding Redeemed, in $5,623,958.50 full; warrants not outstanding Redeemed, in $11,291,481.00 full; warrants not outstanding Redeemed, in $15,703,166.66 full; warrants not outstanding Sold, in full; $4,808,121.00 warrants not outstanding Redeemed, in $2,339,348.60 full; warrants not outstanding Redeemed, in $5,956,041.66 full; warrants not outstanding Redeemed, in $5,875,583.89 full; warrants not outstanding Sold, in full; $4,296,561.73 warrants not outstanding Redeemed, in $12,844,226.31 full; warrants not outstanding Redeemed, in $18,933,333.33 full; warrants not outstanding Redeemed, in $763,294.14 full; warrants not outstanding Investment Total Cash Back2 Status* CPP TRANSACTIONS DETAIL, AS OF 12/31/2016 (CONTINUED) $1,100,000.00 $13,000,000.00 $10,000,000,000.00 $4,734,000.00 $9,516,000.00 $14,700,000.00 $4,545,202.00 $1,834,000.00 $5,500,000.00 $5,116,000.00 $2,904,000.00 $10,000,000.00 $16,000,000.00 $700,000.00 Amount (Fee)4 1,100 13,000 10,000,000 4,734 9,516 14,700 2,272,601 1,834 5,500 5,116 7,260 10,000 16,000 700 Shares Capital Repayment / Disposition / Auction3,5 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $2.00 $1,000.00 $1,000.00 $1,000.00 $400.00 $1,000.00 $1,000.00 $1,000.00 Avg. Price ($2,239,798.00) ($4,356,000.00) (Realized Loss) / (Write-off) Gain5 $650,000.00 $950,000,000.00 $237,000.00 $476,000.00 $260,000.00 $92,000.00 $500,000.00 $1,000,000.00 $35,000.00 Wt Amount 650 65,245,759 237 476 132,353 92 500 198,675 35 Wt Shares Warrant Proceeds $1,276,377.38 $1,779,122.22 $318,055,555.11 $652,958.50 $1,299,481.00 $743,166.66 $262,919.00 $413,348.60 $456,041.66 $759,583.89 $1,392,561.73 $2,344,226.31 $1,933,333.33 $28,294.14 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Continued on next page $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Amount Dividends Paid Number of Missed of Missed to Date Dividends Dividend Dividends and Interest 254 APPENDIX A I TRANSACTION DETAIL I JANUARY 27, 2017 IN IA PA NE NE IL LOS ANGELES BETTENDORF BETTENDORF BETTENDORF BETTENDORF BOYERTOWN BOYERTOWN BOYERTOWN NATIONAL BANCSHARES, INC. NATIONAL PENN BANCSHARES, INC. NATIONAL PENN BANCSHARES, INC. NATIONAL PENN BANCSHARES, INC. NATIONWIDE BANKSHARES, WEST POINT INC. CHICAGO NATIONAL BANCSHARES, INC. NATIONAL BANCSHARES, INC. NATIONWIDE BANKSHARES, 11,14,15 WEST POINT INC. CHICAGO NATIONAL BANCSHARES, INC. NC BANCORP, INC. / METROPOLITAN BANK GROUP, INC. NC BANCORP, INC. / METROPOLITAN BANK GROUP, INC. MADISON NEWPORT NEWPORT NEW HAMPSHIRE THRIFT BANCSHARES, INC. NEW HAMPSHIRE THRIFT BANCSHARES, INC. 44 NEMO BANCSHARES, INC. CA NH NH MO MO LOS ANGELES MADISON NCAL BANCORP CA IL PA PA IA IA CA CA LOS ANGELES 11,14,15 NEMO BANCSHARES, INC. 8,119 8,42 11,16 8,14 NCAL BANCORP IA LOS ANGELES NARA BANCORP, INC. / BBCN BANCORP, INC. CA FL NARA BANCORP, INC. / BBCN BANCORP, INC. 11,59 FL IN LOS ANGELES MUTUALFIRST FINANCIAL, INC. NAPLES MUNCIE MUNCIE MUTUALFIRST FINANCIAL, INC. IN NARA BANCORP, INC. / BBCN BANCORP, INC. MUNCIE MUTUALFIRST FINANCIAL, INC. TX TX NAPLES BANCORP, INC. KINGWOOD GA GA GA NAPLES KINGWOOD CLEVELAND MS FINANCIAL, INC. CLEVELAND MOUNTAIN VALLEY BANCSHARES, INC. MOUNTAIN VALLEY BANCSHARES, INC. MS FINANCIAL, INC. CLEVELAND MOUNTAIN VALLEY BANCSHARES, INC. TN State NAPLES BANCORP, INC. 8 45 8,11,14 8,14 MOSCOW City MOSCOW BANCSHARES, INC. Footnote Institution Name 8/25/2011 1/16/2009 4/24/2013 6/19/2009 12/10/2014 12/19/2008 6/28/2013 6/26/2009 12/29/2010 12/11/2009 4/13/2011 3/16/2011 12/12/2008 3/26/2013 2/20/2013 2/19/2013 2/27/2009 8/8/2012 6/27/2012 11/21/2008 7/12/2012 3/27/2009 9/28/2011 8/25/2011 12/23/2008 10/19/2011 3/27/2009 9/12/2013 7/22/2013 9/25/2009 12/5/2012 $10,000,000.00 $2,330,000.00 $10,000,000.00 $6,880,000.00 $2,000,000.00 $150,000,000.00 $24,664,000.00 $67,000,000.00 $4,000,000.00 $32,382,000.00 $7,723,000.00 $3,300,000.00 Original Investment Date Amount $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Outstanding Investment Investment Status* Redeemed, in $12,041,266.67 full; warrants not outstanding Redeemed, in $3,199,347.39 full; warrants not outstanding Sold, in full; $5,211,027.78 warrants not outstanding Sold, in full; $2,613,714.23 warrants not outstanding Redeemed, in $2,276,190.00 full; warrants not outstanding Redeemed, in $167,958,333.33 full; warrants not outstanding Sold, in full; $21,471,087.90 warrants not outstanding Redeemed, in $81,249,317.20 full; warrants not outstanding Sold, in full; $956,066.67 warrants not outstanding Redeemed, in $37,608,789.00 full; warrants not outstanding Redeemed, in $9,206,289.90 full; warrants not outstanding Sold, in full; $4,069,975.55 warrants not outstanding Total Cash Back2 CPP TRANSACTIONS DETAIL, AS OF 12/31/2016 (CONTINUED) $10,000,000.00 $2,330,000.00 $3,900,000.00 $2,281,458.05 $2,000,000.00 $150,000,000.00 $16,064,996.94 $2,438,182.50 $67,000,000.00 $600,000.00 $32,382,000.00 $7,723,000.00 $3,267,000.00 $5,116,000.00 Amount ($185,031.79) ($25,000.00) (Fee)4 10,000 2,330,000 10,000 6,880 2,000,000 150,000 21,414 3,250 67,000 4,000 32,382 7,723 3,300 5,116 Shares Capital Repayment / Disposition / Auction3,5 $1,000.00 $1.00 $390.00 $331.61 $1.00 $1,000.00 $750.21 $750.21 $1,000.00 $150.00 $1,000.00 $1,000.00 $990.00 $1,000.00 Avg. Price ($6,100,000.00) ($4,598,541.95) ($5,349,003.06) ($811,817.50) ($3,400,000.00) ($33,000.00) (Realized Loss) / (Write-off) Gain5 $117,000.00 $100,000.00 $1,000,000.00 $502,606.30 $342,841.95 $2,189,317.20 $900,194.00 $386,000.00 $140,034.65 $311,000.00 Wt Amount 117,000 100,000 735,294 733 500 521,266 625,135 386 165 311 Wt Shares Warrant Proceeds Dividends and Interest $1,304,166.67 $752,347.39 $1,311,027.78 $176,190.00 $16,958,333.33 $2,307,492.00 $23,237,328.30 $356,066.67 $4,326,595.00 $1,097,289.90 $687,940.90 0 0 14 9 0 0 9 0 6 0 0 0 Continued on next page $0.00 $0.00 $2,207,500.00 $9,511,543.00 $0.00 $0.00 $3,024,383.00 $0.00 $327,000.00 $0.00 $0.00 $0.00 Amount Dividends Paid Number of Missed of Missed to Date Dividends Dividend TRANSACTION DETAIL I APPENDIX A I JANUARY 27, 2017 255 8,11,14 8,14 8,14,44 11 109 8,11, 14,18 11 11 8,14,44 8,11,14 FORT DODGE FORT DODGE NORTH CENTRAL BANCSHARES, INC. NORTH CENTRAL BANCSHARES, INC. CLOSTER WAUKEGAN WAUKEGAN CHICAGO CHICAGO CHICAGO NORTHERN STATE BANK / FIRST COMMERCE BANK NORTHERN STATES FINANCIAL CORPORATION NORTHERN STATES FINANCIAL CORPORATION NORTHERN TRUST CORPORATION NORTHERN TRUST CORPORATION NORTHERN TRUST CORPORATION IL IL IL IL IL NJ NJ NJ ME ME ME IA IA IA WI WI NC NC SPOKANE SPOKANE SPOKANE SPOKANE NORTHWEST BANCORPORATION, INC. NORTHWEST BANCORPORATION, INC. NORTHWEST BANCORPORATION, INC. WA WA NORTHWEST COMMERCIAL LAKEWOOD BANK NORTHWEST COMMERCIAL LAKEWOOD BANK WA WA WA NH WA NORTHWAY FINANCIAL, INC. BERLIN NORTHWEST BANCORPORATION, INC. NH CLOSTER NORTHERN STATE BANK / FIRST COMMERCE BANK NC NC NORTHWAY FINANCIAL, INC. BERLIN CLOSTER NORTHERN STATE BANK / FIRST COMMERCE BANK LEWISTON FORT DODGE NORTH CENTRAL BANCSHARES, INC. NORTHEAST BANCORP GREEN BAY NICOLET BANKSHARES, INC. LEWISTON GREEN BAY NICOLET BANKSHARES, INC. LEWISTON GREENSBORO NEWBRIDGE BANCORP NORTHEAST BANCORP GREENSBORO NEWBRIDGE BANCORP NORTHEAST BANCORP GREENSBORO NC GREENSBORO NEWBRIDGE BANCORP GREENSBORO NY NEWBRIDGE BANCORP NY NEW YORK PRIVATE BANK & NEW YORK TRUST CORPORATION NEWBRIDGE BANCORP NH State NEWPORT City NEW YORK PRIVATE BANK & NEW YORK TRUST CORPORATION NEW HAMPSHIRE THRIFT BANCSHARES, INC. Footnote Institution Name 1/9/2013 2/13/2009 4/9/2013 3/11/2013 3/8/2013 2/13/2009 9/15/2011 1/30/2009 8/26/2009 6/17/2009 11/14/2008 4/30/2014 2/20/2009 3/28/2012 12/18/2009 5/15/2009 12/28/2012 11/28/2012 12/12/2008 1/11/2012 12/14/2011 1/9/2009 9/1/2011 12/23/2008 5/31/2013 5/15/2013 4/29/2013 4/26/2013 12/12/2008 7/24/2013 1/9/2009 2/15/2012 Date $1,992,000.00 $10,500,000.00 $10,000,000.00 $1,576,000,000.00 $17,211,000.00 $1,230,000.00 $1,341,000.00 $4,227,000.00 $10,200,000.00 $14,964,000.00 $52,372,000.00 $267,274,000.00 Original Investment Amount $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Outstanding Investment Redeemed, in $2,380,393.00 full; warrants not outstanding Sold, in full; $11,891,847.50 warrants not outstanding Redeemed, in $11,930,624.67 full; warrants not outstanding Redeemed, in $1,709,623,333.35 full; warrants not outstanding Sold, in full; $6,442,172.50 warrants not outstanding Redeemed, in $2,987,782.33 full; warrants not outstanding Redeemed, in $5,159,181.33 full; warrants not outstanding Redeemed, in $12,294,583.33 full; warrants not outstanding Redeemed, in $17,904,842.66 full; warrants not outstanding Sold, in full; $70,087,060.35 warrants not outstanding Redeemed, in $346,794,005.83 full; warrants not outstanding Investment Total Cash Back2 Status* CPP TRANSACTIONS DETAIL, AS OF 12/31/2016 (CONTINUED) $1,992,000.00 $8,500,000.00 $2,000,000.00 $10,000,000.00 $1,576,000,000.00 $6,023,850.00 $2,571,000.00 $4,227,000.00 $10,200,000.00 $14,964,000.00 $48,641,624.50 $2,709,121.50 $267,274,000.00 Amount ($108,371.55) ($513,507.46) (Fee)4 1,992 8,500 2,000 10,000 1,576,000 20,079,500 2,571 4,227 10,200 14,964 49,609 2,763 267,274 Shares Capital Repayment / Disposition / Auction3,5 $1,000.00 $1,032.11 $1,032.11 $1,000.00 $1,000.00 $0.30 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $980.50 $980.50 $1,000.00 Avg. Price ($11,187,150.00) ($967,375.50) ($53,878.50) (Realized Loss) / (Write-off) $272,935.00 $64,220.00 Gain5 $100,000.00 $587,634.55 $500,000.00 $87,000,000.00 $67,000.00 $95,000.00 $600,000.00 $748,000.00 $7,778,782.65 $13,364,000.00 $737,100.00 Wt Amount 100 525 500 3,824,624 67 67,958 99,157 748 2,567,255 13,364 184,275 Wt Shares Warrant Proceeds $288,393.00 $575,429.50 $1,430,624.67 $46,623,333.35 $418,322.50 $349,782.33 $837,181.33 $1,494,583.33 $2,192,842.66 $11,471,039.16 $66,156,005.83 5 12 0 0 0 18 0 0 0 0 0 Continued on next page $135,750.00 $1,716,750.00 $0.00 $0.00 $0.00 $3,872,475.00 $0.00 $0.00 $0.00 $0.00 $0.00 Amount Dividends Paid Number of Missed of Missed to Date Dividends Dividend Dividends and Interest 256 APPENDIX A I TRANSACTION DETAIL I JANUARY 27, 2017 BOWIE OLD LINE BANCSHARES, INC. ONEFINANCIAL CORPORATION OREGON BANCORP, INC. 15,17, 129, 135 8 SALEM LITTLE ROCK BOSTON ATLANTA ONE GEORGIA BANK ONE UNITED BANK ATLANTA ONE GEORGIA BANK LAKEWOOD LAKEWOOD AURORA OLD SECOND BANCORP, INC. OMEGA CAPITAL CORP. AURORA OLD SECOND BANCORP, INC. OMEGA CAPITAL CORP. AURORA OLD SECOND BANCORP, INC. LAKEWOOD AURORA OLD SECOND BANCORP, INC. LAKEWOOD AURORA OLD SECOND BANCORP, INC. OMEGA CAPITAL CORP. AURORA OLD SECOND BANCORP, INC. OMEGA CAPITAL CORP. EVANSVILLE EVANSVILLE OLD NATIONAL BANCORP OLD NATIONAL BANCORP EVANSVILLE BOWIE OLD LINE BANCSHARES, INC. OLD NATIONAL BANCORP BOWIE TOMS RIVER OCEANFIRST FINANCIAL CORP. OLD LINE BANCSHARES, INC. TOMS RIVER OCEANFIRST FINANCIAL CORP. OJAI TOMS RIVER OCEANFIRST FINANCIAL CORP. OJAI OAKDALE OAK VALLEY BANCORP OJAI COMMUNITY BANK OAKDALE OJAI COMMUNITY BANK OAKDALE OAK VALLEY BANCORP OAK RIDGE FINANCIAL SERVICES, INC. OAK VALLEY BANCORP OAK RIDGE OAK RIDGE FINANCIAL SERVICES, INC. 8,9 8,51,97 8,14 11 11 8 12,16 45 OAK RIDGE OAK RIDGE OAK RIDGE FINANCIAL SERVICES, INC. OAK RIDGE City OAK RIDGE FINANCIAL SERVICES, INC. Footnote Institution Name OR AR MA GA GA CO CO CO CO IL IL IL IL IL IL IN IN IN MD MD MD CA CA NJ NJ NJ CA CA CA NC NC NC NC State 4/24/2009 6/5/2009 12/19/2008 7/15/2011 5/8/2009 9/12/2013 7/22/2013 7/19/2013 4/17/2009 6/11/2013 4/9/2013 3/27/2013 3/26/2013 3/11/2013 1/16/2009 5/8/2009 3/31/2009 12/12/2008 9/2/2009 7/15/2009 12/5/2008 9/25/2013 1/30/2009 2/3/2010 12/30/2009 1/16/2009 9/28/2011 8/11/2011 12/5/2008 2/6/2013 1/11/2013 10/31/2012 1/30/2009 $3,216,000.00 $17,300,000.00 $12,063,000.00 $5,500,000.00 $2,816,000.00 $73,000,000.00 $100,000,000.00 $7,000,000.00 $2,080,000.00 $38,263,000.00 $13,500,000.00 $7,700,000.00 Original Investment Date Amount $0.00 $17,300,000.00 $12,063,000.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Outstanding Investment Investment Status* $1,142.90 $1,142.90 $377.02 $377.02 $352.50 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $921.50 Avg. Price ($5,500,000.00) ($1,103,920.56) ($747,576.00) ($45,343,130.00) ($604,450.00) $225,353.30 $177,053.10 Gain5 $159,886.25 $106,891.00 $1,200,000.00 $225,000.00 $104,000.00 $430,797.00 $560,000.00 $122,887.50 Wt Amount 141 815,339 813,008 141,892 104 190,427 350,346 163,830 Wt Shares Dividends and Interest $50,310.50 $5,769,027.78 $1,513,888.89 $213,888.89 $470,758.89 $1,828,121.61 $1,811,250.00 $1,444,854.00 Sold, in full; $4,116,801.92 warrants not outstanding $7,662,990.59 $787,354.72 0 19 31 8 15 10 0 0 2 0 0 0 Continued on next page $0.00 $9,248,612.72 $6,001,342.50 $605,328.00 $575,588.00 $9,125,000.00 $0.00 $0.00 $56,680.00 $0.00 $0.00 $0.00 Amount Dividends Paid Number of Missed of Missed to Date Dividends Dividend $3,782,990.59 1,577 1,239 1,772 1,200 70,028 100,000 7,000 2,080 38,263 13,500 7,700 Shares Warrant Proceeds Full investment outstanding; warrants outstanding ($25,000.00) ($258,053.73) ($70,955.50) (Fee)4 (Realized Loss) / (Write-off) $93,823.33 $1,577,000.00 $1,239,000.00 $668,079.44 $452,424.00 $24,684,870.00 $100,000,000.00 $7,000,000.00 $2,080,000.00 $38,263,000.00 $13,500,000.00 $7,095,550.00 Amount Capital Repayment / Disposition / Auction3,5 Full investment outstanding; $93,823.33 warrants not outstanding Exited $0.00 bankruptcy/ Receivership Sold, in full; $3,403,603.15 warrants not outstanding Sold, in full; $31,423,238.49 warrants not outstanding Redeemed, in $102,713,888.89 full; warrants not outstanding Redeemed, in $7,438,888.89 full; warrants not outstanding Redeemed, in $2,654,758.89 full; warrants not outstanding Redeemed, in $40,521,918.61 full; warrants not outstanding Redeemed, in $15,871,250.00 full; warrants not outstanding Sold, in full; $8,592,336.00 warrants not outstanding Total Cash Back2 CPP TRANSACTIONS DETAIL, AS OF 12/31/2016 (CONTINUED) TRANSACTION DETAIL I APPENDIX A I JANUARY 27, 2017 257 60 11 8,14 85 8 8,26 8,14,45 8 11,35 11,14,15 MADISON MADISON MADISON NEWARK NEWARK NEWARK SEWELL SEWELL SEWELL SEWELL SEWELL MONROEVILLE PARK BANCORPORATION, INC. PARK NATIONAL CORPORATION PARK NATIONAL CORPORATION PARK NATIONAL CORPORATION PARKE BANCORP, INC. PARKE BANCORP, INC. PARKE BANCORP, INC. PARKE BANCORP, INC. PARKE BANCORP, INC. PARKVALE FINANCIAL CORPORATION / F.N.B. CORPORATION MADISON PARK BANCORPORATION, INC. PARK BANCORPORATION, INC. MADISON PARK BANCORPORATION, INC. PARK BANCORPORATION, INC. SEATTLE PACIFIC INTERNATIONAL BANCORP / BBCN BANCORP, INC. SAN CLEMENTE PACIFIC COAST NATIONAL BANCORP SEATTLE SAN CLEMENTE PACIFIC COAST NATIONAL BANCORP LOS ANGELES SAN FRANCISCO PACIFIC COAST BANKERS’ BANCSHARES PACIFIC INTERNATIONAL BANCORP / BBCN BANCORP, INC. SAN FRANCISCO PACIFIC COAST BANKERS’ BANCSHARES PACIFIC COMMERCE BANK LOS ANGELES LOS ANGELES LOS ANGELES PACIFIC CITY FINANCIAL CORPORATION LOS ANGELES CA LOS ANGELES PACIFIC CITY FINANCIAL CORPORATION PACIFIC COMMERCE BANK CA PACIFIC CAPITAL BANCORP SANTA BARBARA PACIFIC CITY FINANCIAL CORPORATION PACIFIC COMMERCE BANK CA PACIFIC CAPITAL BANCORP SANTA BARBARA PA NJ NJ NJ NJ NJ OH OH OH WI WI WI WI WI WA WA CA CA CA CA CA CA CA CA CA CA PACIFIC CAPITAL BANCORP SANTA BARBARA TX OSB FINANCIAL SERVICES, ORANGE INC. OR TX SALEM OREGON BANCORP, INC. OR OR State OSB FINANCIAL SERVICES, ORANGE INC. SALEM SALEM OREGON BANCORP, INC. City OREGON BANCORP, INC. Footnote Institution Name 12/23/2008 6/12/2013 1/11/2013 11/29/2012 11/28/2012 1/30/2009 5/2/2012 4/25/2012 12/23/2008 9/11/2012 8/10/2012 8/9/2012 8/7/2012 3/6/2009 2/15/2013 12/12/2008 3/19/2014 2/10/2014 12/23/2008 2/11/2010 1/16/2009 7/28/2011 12/23/2008 1/6/2014 11/19/2013 12/19/2008 11/30/2012 2/23/2011 11/21/2008 10/5/2011 5/1/2009 1/6/2014 10/21/2013 10/18/2013 Date $31,762,000.00 $16,288,000.00 $100,000,000.00 $23,200,000.00 $6,500,000.00 $4,060,000.00 $4,120,000.00 $11,600,000.00 $16,200,000.00 $180,634,000.00 $6,100,000.00 Original Investment Amount $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Outstanding Investment Redeemed, in $42,596,063.59 full; warrants not outstanding Sold, in full; $16,365,554.76 warrants not outstanding Redeemed, in $119,536,844.44 full; warrants not outstanding Sold, in full; $22,020,064.10 warrants not outstanding Redeemed, in $7,937,744.97 full; warrants outstanding Sold, in full; $2,991,670.80 warrants not outstanding Exited $18,087.94 bankruptcy/ Receivership Redeemed, in $13,821,963.89 full; warrants not outstanding Sold, in full; $21,003,597.96 warrants not outstanding Sold, in full; $168,483,804.20 warrants not outstanding Redeemed, in $7,662,314.53 full; warrants not outstanding Investment Total Cash Back2 Status* CPP TRANSACTIONS DETAIL, AS OF 12/31/2016 (CONTINUED) $11,318,791.40 $394,072.28 $100,000,000.00 $11,216,640.00 $4,048,506.00 $1,676,654.00 $6,500,000.00 $2,519,960.80 $11,600,000.00 $16,200,000.00 $165,983,272.00 $14.75 $6,100,000.00 $3,116,000.00 $100,000.00 Amount ($117,128.64) ($169,418.00) ($25,000.00) ($196,857.54) ($25,000.00) (Fee)4 15,740 548 100,000 15,360 5,544 2,296 6,500 4,060 11,600 16,200 3,608,332 1 6,100,000 3,116 100 Shares Capital Repayment / Disposition / Auction3,5 $719.11 $719.11 $1,000.00 $730.25 $730.25 $730.25 $1,000.00 $620.68 $1,000.00 $1,215.17 $46.00 $29.50 $1.00 $1,000.00 $1,000.00 Avg. Price ($4,421,208.60) ($153,927.72) ($4,143,360.00) ($1,495,494.00) ($619,346.00) ($1,540,039.20) ($4,120,000.00) ($14,650,702.97) ($10.28) (Realized Loss) / (Write-off) $3,485,754.00 Gain5 $1,650,288.00 $2,842,400.00 $325,200.40 $482,779.69 $88,059.01 $109,487.50 $580,000.00 $1,156,636.50 $393,120.78 $305,000.00 $128,988.07 $9,459.13 Wt Amount 438,906 227,376 421 625 114 203 580 810 15,120 305,000 150 11 Wt Shares Warrant Proceeds $3,119,531.72 $16,694,444.44 $4,351,643.00 $387,222.50 $18,087.94 $1,641,963.89 $358,065.00 $2,107,396.67 $1,257,314.53 0 0 0 0 0 13 0 2 18 0 0 Continued on next page $0.00 $0.00 $0.00 $0.00 $0.00 $695,771.00 $0.00 $112,270.00 $3,973,050.00 $0.00 $0.00 Amount Dividends Paid Number of Missed of Missed to Date Dividends Dividend Dividends and Interest 258 APPENDIX A I TRANSACTION DETAIL I JANUARY 27, 2017 8,14,56 11 8,14,44 11 8,11,14 8 8,14 44 8,126 8,11,21 NE LYNDEN LYNDEN PEOPLES BANCORP (WA) PEOPLES BANCORP (WA) MARIETTA MARIETTA WAYNE PENN LIBERTY FINANCIAL CORP. PEOPLES BANCORP (OH) WAYNE PENN LIBERTY FINANCIAL CORP. PEOPLES BANCORP (OH) GLADSTONE PEAPACK-GLADSTONE FINANCIAL CORPORATION MARIETTA GLADSTONE PEAPACK-GLADSTONE FINANCIAL CORPORATION MARIETTA GLADSTONE PEAPACK-GLADSTONE FINANCIAL CORPORATION PEOPLES BANCORP (OH) GLADSTONE PEAPACK-GLADSTONE FINANCIAL CORPORATION PEOPLES BANCORP (OH) NJ GLADSTONE PEAPACK-GLADSTONE FINANCIAL CORPORATION WA WA OH OH OH OH PA PA NJ NJ NJ NJ LA LA PATTERSON BANCSHARES, PATTERSON INC. PATTERSON BANCSHARES, PATTERSON INC. LA LA PATTERSON BANCSHARES, PATTERSON INC. LA LA PATTERSON BANCSHARES, PATTERSON INC. PATTERSON BANCSHARES, PATTERSON INC. TX PATRIOT BANCSHARES, INC. HOUSTON PATTERSON BANCSHARES, PATTERSON INC. TX TX PATRIOT BANCSHARES, INC. HOUSTON PATRIOT BANCSHARES, INC. HOUSTON TX NE PATRIOT BANCSHARES, INC. HOUSTON CAIRO CAIRO PATHWAY BANCORP PATHWAY BANCORP NE NY CAIRO PATHFINDER BANCORP, INC. OSWEGO PATHWAY BANCORP NY PATHFINDER BANCORP, INC. OSWEGO MD NY DUNDALK PATAPSCO BANCORP, INC. MD NJ NJ PA PA State PATHFINDER BANCORP, INC. OSWEGO DUNDALK WESTWOOD PASCACK BANCORP, INC. PATAPSCO BANCORP, INC. WESTWOOD MONROEVILLE PASCACK BANCORP, INC. MONROEVILLE PARKVALE FINANCIAL CORPORATION / F.N.B. CORPORATION City PARKVALE FINANCIAL CORPORATION / F.N.B. CORPORATION Footnote Institution Name 8/3/2011 2/13/2009 2/15/2012 12/28/2011 2/2/2011 1/30/2009 9/1/2011 4/17/2009 4/4/2012 1/11/2012 3/2/2011 1/6/2010 1/9/2009 6/5/2013 5/8/2013 12/5/2012 8/22/2012 3/7/2012 4/17/2009 7/18/2014 4/14/2014 4/11/2014 12/19/2008 7/26/2013 6/24/2013 3/27/2009 2/1/2012 9/1/2011 9/11/2009 8/28/2015 12/19/2008 10/19/2011 2/6/2009 5/27/2015 1/3/2012 $18,000,000.00 $39,000,000.00 $9,960,000.00 $28,685,000.00 $3,690,000.00 $26,038,000.00 $3,727,000.00 $6,771,000.00 $6,000,000.00 $3,756,000.00 Original Investment Date Amount $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Outstanding Investment Investment Status* Redeemed, in $21,325,250.00 full; warrants not outstanding Redeemed, in $44,926,557.48 full; warrants not outstanding Redeemed, in $11,745,689.33 full; warrants not outstanding Redeemed, in $32,075,739.67 full; warrants not outstanding Redeemed, in $4,692,022.77 full; warrants not outstanding Sold, in full; $33,824,567.35 warrants not outstanding Sold, in full; $4,628,862.77 warrants not outstanding Redeemed, in $7,976,328.84 full; warrants not outstanding Redeemed, in $9,260,824.26 full; warrants not outstanding Redeemed, in $4,497,312.67 full; warrants not outstanding Total Cash Back2 CPP TRANSACTIONS DETAIL, AS OF 12/31/2016 (CONTINUED) $18,000,000.00 $18,000,000.00 $21,000,000.00 $9,960,000.00 $14,341,000.00 $7,172,000.00 $7,172,000.00 $2,440,000.00 $500,000.00 $250,000.00 $250,000.00 $250,000.00 $14,038,000.00 $12,000,000.00 $3,727,000.00 $6,771,000.00 $6,000,000.00 $3,756,000.00 $31,762,000.00 Amount ($297,361.77) ($25,000.00) (Fee)4 18,000 18,000 21,000 9,960 14,341 7,172 7,172 2,440 500 250 250 250 14,038 12,000 3,727 6,771 6,000 3,756 31,762 Shares Capital Repayment / Disposition / Auction3,5 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,142.03 $1,142.03 $1,167.01 $1,000.00 $1,000.00 $1,000.00 $1,000.00 Avg. Price (Realized Loss) / (Write-off) $1,993,817.14 $1,704,360.00 $622,446.27 Gain5 $900,000.00 $1,200,724.15 $498,000.00 $110,000.00 $185,000.00 $645,781.95 $1,035,834.25 $226,565.00 $537,633.00 $300,000.00 $188,000.00 $6,025,649.70 Wt Amount 900 313,505 498 150,296 185 500 802 186 154,354 300 188 819,640 Wt Shares Warrant Proceeds Dividends and Interest $2,425,250.00 $4,725,833.33 $1,287,689.33 $3,280,739.67 $817,022.77 $2,704,135.78 $77,851.50 $667,695.84 $2,960,824.26 $553,312.67 0 0 0 0 0 13 15 0 0 0 Continued on next page $0.00 $0.00 $0.00 $0.00 $0.00 $4,612,010.00 $761,588.00 $0.00 $0.00 $0.00 Amount Dividends Paid Number of Missed of Missed to Date Dividends Dividend TRANSACTION DETAIL I APPENDIX A I JANUARY 27, 2017 259 MADISONVILLE COLQUITT COLQUITT PIGEON FALLS PIGEON FALLS PEOPLESSOUTH BANCSHARES, INC. PEOPLESSOUTH BANCSHARES, INC. PFSB BANCORPORATION, INC. / PIGEON FALLS STATE BANK PFSB BANCORPORATION, INC. / PIGEON FALLS STATE BANK 20 15,17 8,14,44 QUINCY QUINCY QUINCY PLUMAS BANCORP PLUMAS BANCORP PLUMAS BANCORP SAN JUAN QUINCY PLUMAS BANCORP POPULAR, INC. SAINT PAUL PLATO HOLDINGS INC. SAN JUAN SAINT PAUL PLATO HOLDINGS INC. POPULAR, INC. SAINT PAUL PLATO HOLDINGS INC. DALLAS PLAINS CAPITAL CORPORATION SAINT PAUL DALLAS PLAINS CAPITAL CORPORATION PLATO HOLDINGS INC. NASHVILLE NASHVILLE NASHVILLE PINNACLE FINANCIAL PARTNERS, INC. PINNACLE FINANCIAL PARTNERS, INC. NASHVILLE PINNACLE FINANCIAL PARTNERS, INC. 11 PINNACLE FINANCIAL PARTNERS, INC. FL ORANGE CITY PINNACLE BANK HOLDING COMPANY, INC. 8,69 PR PR CA CA CA CA MN MN MN MN TX TX TN TN TN TN WA PIERCE COUNTY BANCORP TACOMA IL IL WI WI GA GA TN TN TN SC SC WA CHICAGO MADISONVILLE PEOPLES BANCSHARES OF TN, INC. PEOPLES BANCSHARES OF TN, INC. PGB HOLDINGS, INC. MADISONVILLE PEOPLES BANCSHARES OF TN, INC. CHICAGO EASLEY PEOPLES BANCORPORATION, INC. PGB HOLDINGS, INC. EASLEY PEOPLES BANCORPORATION, INC. NC NC NC State PIERCE COUNTY BANCORP TACOMA 8,46,97 9,11,36 8,17,45 8 8,14 8,14 NEWTON NEWTON PEOPLES BANCORP OF NORTH CAROLINA, INC. PEOPLES BANCORP OF NORTH CAROLINA, INC. NEWTON City PEOPLES BANCORP OF NORTH CAROLINA, INC. Footnote Institution Name 7/2/2014 12/5/2008 5/31/2013 5/22/2013 4/29/2013 1/30/2009 5/31/2013 4/29/2013 4/26/2013 7/17/2009 9/27/2011 12/19/2008 7/18/2012 6/20/2012 12/28/2011 12/12/2008 3/6/2009 11/5/2010 1/23/2009 8/13/2010 2/6/2009 8/25/2011 9/11/2009 9/18/2013 3/6/2009 1/11/2013 10/31/2012 3/20/2009 4/24/2012 4/24/2009 8/8/2012 7/3/2012 12/23/2008 Date $935,000,000.00 $11,949,000.00 $2,500,000.00 $87,631,000.00 $95,000,000.00 $4,389,000.00 $6,800,000.00 $3,000,000.00 $1,500,000.00 $12,325,000.00 $3,900,000.00 $12,660,000.00 $25,054,000.00 Original Investment Amount $0.00 $0.00 $0.00 $0.00 $0.00 $4,389,000.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Outstanding Investment ($25,000.00) $1,000.00 $1,000.00 $1,000.00 $1,000.00 $755.00 $1,000.00 $933.36 Avg. Price ($6,800,000.00) ($955,500.00) ($1,669,598.56) (Realized Loss) / (Write-off) $180.00 Gain5 $755,000.00 $71,000.00 $616,000.00 $122,225.00 $633,000.00 $425,000.00 Wt Amount 267,455 71 616 195 633 357,234 Wt Shares $207,947.78 $227,916.67 $159,162.66 $3,044,994.66 $768,149.42 $2,069,909.75 $4,419,330.74 Redeemed, in $1,220,280,000.00 full; warrants not outstanding Sold, in full; $13,764,140.41 warrants not outstanding Sold, in full; $3,103,618.40 warrants not outstanding Redeemed, in $105,252,939.77 full; warrants not outstanding $935,000,000.00 $11,949,000.00 $2,380,000.00 $120,000.00 $87,631,000.00 $71,250,000.00 ($130,376.73) 935,000 11,949 2,380,000 120,000 87,631 71,250 $1,000.00 $1,091.11 $1.00 $1.00 $1,000.00 $1,000.00 $1,088,673.39 $3,570.00 $234,500.00 $90,582.47 $4,382,000.00 237,712 107,000 4,382 $269,280,000.00 $622,343.75 $534,285.93 $13,239,939.77 0 12 4 0 0 26 4 0 0 0 0 0 0 Continued on next page $0.00 $1,792,350.00 $207,266.00 $0.00 $0.00 $1,993,440.00 $370,600.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Amount Dividends Paid Number of Missed of Missed to Date Dividends Dividend $16,163,194.45 23,750 3,000 1,500 12,325 3,900 12,660 25,054 Shares Dividends and Interest Redeemed, in $111,918,194.45 full; warrants not outstanding $23,750,000.00 $3,000,000.00 ($25,000.00) ($350,766.02) (Fee)4 Warrant Proceeds $284,999.00 Currently Not Collectible $1,500,000.00 $12,325,000.00 $2,944,500.00 $12,660,000.00 $23,384,401.44 Amount Capital Repayment / Disposition / Auction3,5 Full investment outstanding; warrants outstanding $284,999.00 $207,947.78 Redeemed, in $3,227,916.67 full; warrants not outstanding Redeemed, in $1,730,162.66 full; warrants not outstanding Redeemed, in $15,985,994.66 full; warrants not outstanding Sold, in full; $3,809,874.42 warrants not outstanding Redeemed, in $15,362,909.75 full; warrants not outstanding Sold, in full; $27,877,966.16 warrants not outstanding Investment Total Cash Back2 Status* CPP TRANSACTIONS DETAIL, AS OF 12/31/2016 (CONTINUED) 260 APPENDIX A I TRANSACTION DETAIL I JANUARY 27, 2017 8,18 75,97 8,17 80 8 14,15 8,22,97 9,15,36 8 HUNTINGTON PREMIER FINANCIAL BANCORP, INC. WV WV WV MN IL MN PRINCETON PRINCETON NATIONAL BANCORP, INC. IL CA PRIVATE BANCORPORATION, MINNEAPOLIS INC. PRINCETON PRINCETON NATIONAL BANCORP, INC. PRIVATE BANCORPORATION, MINNEAPOLIS INC. SAN FRANCISCO PRESIDIO BANK CA CA MN SAN FRANCISCO PRESIDIO BANK CA OR OR CA CA PRIVATE BANCORPORATION, MINNEAPOLIS INC. SAN FRANCISCO PRESIDIO BANK MEDFORD SAN FRANCISCO PREMIERWEST BANCORP PRESIDIO BANK MEDFORD RIVERSIDE PREMIER SERVICE BANK PREMIERWEST BANCORP RIVERSIDE PREMIER SERVICE BANK IA HUNTINGTON PREMIER FINANCIAL BANCORP, INC. PREMIER FINANCIAL CORP. DUBUQUE HUNTINGTON PREMIER FINANCIAL BANCORP, INC. WV WV IA HUNTINGTON IA HUNTINGTON PREMIER FINANCIAL BANCORP, INC. WV PREMIER FINANCIAL CORP. DUBUQUE HUNTINGTON PREMIER FINANCIAL BANCORP, INC. FL FL IL IL KS KS KS KY KY KY KY PR State PREMIER FINANCIAL CORP. DUBUQUE TALLAHASSEE PREMIER FINANCIAL BANCORP, INC. OLATHE PREMIER BANK HOLDING COMPANY OLATHE PRAIRIE STAR BANCSHARES, INC. PRAIRIE STAR BANCSHARES, INC. TALLAHASSEE OLATHE PRAIRIE STAR BANCSHARES, INC. PREMIER BANK HOLDING COMPANY LOUISVILLE PORTER BANCORP, INC. (PBI) LOUISVILLE, KY WILMETTE LOUISVILLE PORTER BANCORP, INC. (PBI) LOUISVILLE, KY WILMETTE LOUISVILLE PORTER BANCORP, INC. (PBI) LOUISVILLE, KY PREMIER BANCORP, INC. LOUISVILLE PORTER BANCORP, INC. (PBI) LOUISVILLE, KY PREMIER BANCORP, INC. SAN JUAN City POPULAR, INC. Footnote Institution Name 6/25/2014 12/29/2009 2/27/2009 11/2/2012 1/23/2009 1/11/2013 12/11/2012 12/10/2012 11/20/2009 4/9/2013 2/13/2009 1/31/2014 2/20/2009 9/12/2013 7/22/2013 5/22/2009 5/6/2015 9/11/2012 8/10/2012 8/9/2012 8/8/2012 10/2/2009 8/14/2012 3/20/2009 8/13/2010 5/8/2009 8/6/2015 6/29/2015 4/3/2009 1/9/2015 12/4/2014 12/3/2014 11/21/2008 7/23/2014 $3,262,000.00 $4,960,000.00 $25,083,000.00 $10,800,000.00 $41,400,000.00 $4,000,000.00 $6,349,000.00 $22,252,000.00 $9,500,000.00 $6,784,000.00 $2,800,000.00 $35,000,000.00 Original Investment Date Amount $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Outstanding Investment Investment Status* Currently Not Collectible Redeemed, in $10,836,280.71 full; warrants not outstanding $2,271,405.00 Sold, in full; $11,077,694.89 warrants not outstanding Redeemed, in $42,446,500.00 full; warrants not outstanding Redeemed, in $4,300,522.22 full; warrants not outstanding Sold, in full; $8,778,669.11 warrants not outstanding Sold, in full; $28,727,240.29 warrants not outstanding Exited $467,412.50 bankruptcy/ Receivership Redeemed, in $7,444,215.12 full; warrants not outstanding Sold, in full; $3,596,579.20 warrants not outstanding Sold, in full; $8,233,333.33 warrants outstanding Total Cash Back2 CPP TRANSACTIONS DETAIL, AS OF 12/31/2016 (CONTINUED) $8,222,000.00 $8,887,232.90 $262,635.10 $41,400,000.00 $4,000,000.00 $6,349,000.00 $9,795,998.16 $8,575,102.51 $1,678,618.89 $6,784,000.00 $2,800,000.00 $806,200.00 $2,693,800.00 Amount ($91,498.68) ($78,563.80) ($200,497.20) ($25,000.00) ($50,000.00) (Fee)4 8,222 10,490 310 41,400 4,000 6,349,000 10,872 9,517 1,863 6,784,000 2,800 8,062 26,938 Shares Capital Repayment / Disposition / Auction3,5 $1,000.00 $847.21 $847.21 $1,000.00 $1,000.00 $1.24 $901.03 $901.03 $901.03 $1.00 $1,187.61 $100.00 $100.00 Avg. Price ($25,083,000.00) ($1,602,767.10) ($47,364.90) ($1,076,001.84) ($941,897.49) ($184,381.11) ($9,500,000.00) ($7,255,800.00) ($24,244,200.00) (Realized Loss) / (Write-off) $1,507,379.58 $525,308.00 Gain5 $248,000.00 $195,295.20 $83,086.12 $200,000.00 $478,590.75 $5,675,000.00 $164,018.20 $3,000,000.00 Wt Amount 248 228 97 200 317,000 636,378 140 2,093,284 Wt Shares Warrant Proceeds Dividends and Interest $2,366,280.71 $2,271,405.00 $1,740,944.25 $1,046,500.00 $100,522.22 $522,262.58 $3,203,017.93 $467,412.50 $660,215.12 $132,253.00 $4,783,333.33 0 7 0 14 18 12 0 9 0 21 13 Continued on next page $0.00 $2,194,763.00 $0.00 $7,245,000.00 $977,972.00 $1,597,857.00 $0.00 $1,164,938.00 $0.00 $913,150.00 $6,737,500.00 Amount Dividends Paid Number of Missed of Missed to Date Dividends Dividend TRANSACTION DETAIL I APPENDIX A I JANUARY 27, 2017 261 8,114 8,14,44 8,14,44 8,17 8 44 8,14,44 8,11,14 107 88 GA ROME ROME ROME EUREKA EUREKA RCB FINANCIAL CORPORATION RCB FINANCIAL CORPORATION RCB FINANCIAL CORPORATION REDWOOD CAPITAL BANCORP REDWOOD CAPITAL BANCORP DAVIE REGENT BANCORP, INC. FL FL MN DAVIE REDWOOD FINANCIAL, INC. REDWOOD FALLS REGENT BANCORP, INC. MN REDWOOD FINANCIAL, INC. REDWOOD FALLS CA CA GA GA NC IL RANDOLPH BANK & TRUST ASHEBORO COMPANY MOLINE QCR HOLDINGS, INC. IL IL NC MOLINE QCR HOLDINGS, INC. MO MO MO WA WA LA LA SC SC MD MD MD MD NC NC IL IL IL State RANDOLPH BANK & TRUST ASHEBORO COMPANY MOLINE QCR HOLDINGS, INC. CREVE COEUR PULASKI FINANCIAL CORP. MANY PSB FINANCIAL CORPORATION CREVE COEUR MANY PSB FINANCIAL CORPORATION PULASKI FINANCIAL CORP. ROCK HILL PROVIDENT COMMUNITY BANCSHARES, INC. CREVE COEUR ROCK HILL PROVIDENT COMMUNITY BANCSHARES, INC. PULASKI FINANCIAL CORP. BALTIMORE PROVIDENT BANCSHARES CORP. / M&T BANK CORPORATION BELLEVUE BALTIMORE PROVIDENT BANCSHARES CORP. / M&T BANK CORPORATION BELLEVUE BALTIMORE PROVIDENT BANCSHARES CORP. / M&T BANK CORPORATION PUGET SOUND BANK BALTIMORE PROVIDENT BANCSHARES CORP. / M&T BANK CORPORATION PUGET SOUND BANK ROCKY MOUNT ROCKY MOUNT CHICAGO PRIVATEBANCORP, INC. PROVIDENCE BANK CHICAGO PRIVATEBANCORP, INC. PROVIDENCE BANK CHICAGO PRIVATEBANCORP, INC. 12 8,17,44 City Footnote Institution Name 10/17/2014 3/6/2009 8/18/2011 1/9/2009 7/21/2011 1/16/2009 10/29/2013 9/25/2013 6/19/2009 9/30/2013 10/30/2009 11/16/2011 9/15/2011 2/13/2009 8/8/2012 7/3/2012 1/16/2009 8/11/2011 1/16/2009 9/29/2010 2/27/2009 4/30/2014 3/13/2009 3/25/2013 3/20/2013 8/21/2012 11/14/2008 9/15/2011 10/2/2009 11/14/2012 10/24/2012 1/30/2009 Date $9,982,000.00 $2,995,000.00 $3,800,000.00 $8,900,000.00 $6,229,000.00 $38,237,000.00 $32,538,000.00 $4,500,000.00 $9,270,000.00 $9,266,000.00 $151,500,000.00 $4,000,000.00 $243,815,000.00 Original Investment Amount $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Outstanding Investment Sold, in full; $8,755,019.00 warrants not outstanding Redeemed, in $3,570,810.92 full; warrants not outstanding Redeemed, in $4,510,626.39 full; warrants not outstanding Sold, in full; $9,139,863.61 warrants not outstanding Redeemed, in $7,190,593.33 full; warrants not outstanding Redeemed, in $44,286,567.33 full; warrants not outstanding Sold, in full; $35,195,847.13 warrants not outstanding Redeemed, in $5,355,156.75 full; warrants not outstanding Redeemed, in $10,536,802.00 full; warrants not outstanding Sold, in full; $5,639,391.00 warrants not outstanding Sold, in full; $199,100,113.41 warrants not outstanding Redeemed, in $4,596,311.80 full; warrants not outstanding Redeemed, in $290,552,132.92 full; warrants not outstanding Investment Total Cash Back2 Status* CPP TRANSACTIONS DETAIL, AS OF 12/31/2016 (CONTINUED) $7,970,737.50 $2,995,000.00 $3,800,000.00 $8,073,279.00 $6,229,000.00 $38,237,000.00 $28,893,744.00 $4,500,000.00 $9,270,000.00 $5,096,300.00 $151,500,000.00 $4,000,000.00 $243,815,000.00 Amount ($80,732.79) ($433,406.16) (Fee)4 1,449,225 2,995 3,800 8,900 6,229 38,237 32,538 4,500 9,270 9,266 151,500 4,000 243,815 Shares Capital Repayment / Disposition / Auction3,5 $5.50 $1,000.00 $1,000.00 $907.11 $1,000.00 $1,000.00 $888.00 $1,000.00 $1,000.00 $550.00 $1,000.00 $1,000.00 $1,000.00 Avg. Price ($2,011,262.50) ($826,721.00) ($3,644,256.00) ($4,169,700.00) (Realized Loss) / (Write-off) $19,047,005.12 $71.62 Gain5 $150,000.00 $190,000.00 $253,383.25 $311,000.00 $1,100,000.00 $1,100,000.00 $225,000.00 $464,000.00 $175,000.00 $1,225,000.00 Wt Amount 150 190 268 311 521,888 778,421 225 464 175 645,013 Wt Shares Warrant Proceeds $784,281.50 $425,810.92 $520,626.39 $893,934.15 $650,593.33 $4,949,567.33 $5,635,509.29 $630,156.75 $802,802.00 $543,091.00 $421,311.80 $45,512,132.92 0 0 0 9 8 0 0 0 0 15 0 0 0 Continued on next page $0.00 $0.00 $0.00 $1,055,520.00 $678,880.00 $0.00 $0.00 $0.00 $0.00 $1,737,375.00 $0.00 $0.00 $0.00 Amount Dividends Paid Number of Missed of Missed to Date Dividends Dividend Dividends and Interest 262 APPENDIX A I TRANSACTION DETAIL I JANUARY 27, 2017 8,95,97 15 11,14,15 8,116 8,14 8 11 8,14 8,17,62 8,14,44 WAUSAU WAUSAU LITTLE ROCK LITTLE ROCK LITTLE ROCK LITTLE ROCK NARBERTH NARBERTH NARBERTH NARBERTH RIVER VALLEY BANCORPORATION, INC. RIVERSIDE BANCSHARES, INC. RIVERSIDE BANCSHARES, INC. ROGERS BANCSHARES, INC. ROGERS BANCSHARES, INC. ROYAL BANCSHARES OF PENNSYLVANIA, INC. ROYAL BANCSHARES OF PENNSYLVANIA, INC. ROYAL BANCSHARES OF PENNSYLVANIA, INC. ROYAL BANCSHARES OF PENNSYLVANIA, INC. WAUSAU RIVER VALLEY BANCORPORATION, INC. RIVER VALLEY BANCORPORATION, INC. RISING SUN BROOKFIELD RISING SUN BANCORP BROOKFIELD RIDGESTONE FINANCIAL SERVICES, INC. RIDGESTONE FINANCIAL SERVICES, INC. RISING SUN BROOKFIELD RIDGESTONE FINANCIAL SERVICES, INC. RISING SUN BANCORP FRONTENAC BIRMINGHAM REGIONS FINANCIAL CORPORATION FRONTENAC HARTSVILLE REGIONAL BANKSHARES, INC. RELIANCE BANCSHARES, INC. HARTSVILLE REGIONAL BANKSHARES, INC. RELIANCE BANCSHARES, INC. HARTSVILLE REGIONAL BANKSHARES, INC. FRONTENAC HARTSVILLE REGIONAL BANKSHARES, INC. RELIANCE BANCSHARES, INC. HARTSVILLE REGIONAL BANKSHARES, INC. BIRMINGHAM VANCOUVER REGENTS BANCSHARES, INC. BIRMINGHAM VANCOUVER REGENTS BANCSHARES, INC. REGIONS FINANCIAL CORPORATION NOWATA REGIONS FINANCIAL CORPORATION NOWATA REGENT CAPITAL CORPORATION, INC. / REGENT BANK City REGENT CAPITAL CORPORATION, INC. / REGENT BANK Footnote Institution Name PA PA PA PA AR AR AR AR WI WI WI MD MD WI WI WI MO MO MO AL AL AL SC SC SC SC SC WA WA OK OK State 9/26/2014 7/2/2014 7/1/2014 2/20/2009 7/5/2013 1/30/2009 5/14/2014 5/15/2009 5/15/2013 6/6/2012 6/12/2009 10/17/2014 1/9/2009 3/26/2013 2/20/2013 2/27/2009 10/29/2013 9/25/2013 2/13/2009 5/2/2012 4/4/2012 11/14/2008 3/26/2013 1/11/2013 11/9/2012 11/8/2012 2/13/2009 1/26/2012 10/23/2009 7/21/2011 2/27/2009 $30,407,000.00 $25,000,000.00 $1,100,000.00 $15,000,000.00 $5,983,000.00 $10,900,000.00 $40,000,000.00 $3,500,000,000.00 $1,500,000.00 $12,700,000.00 $2,655,000.00 Original Investment Date Amount $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Outstanding Investment Investment Status* Currently Not Collectible Sold, in full; $36,696,518.83 warrants outstanding Currently Not $738,021.00 Collectible Redeemed, in $1,622,708.57 full; warrants not outstanding Redeemed, in $19,928,275.00 full; warrants not outstanding $195,637.00 Sold, in full; $9,630,106.93 warrants not outstanding Sold, in full; $45,820,950.80 warrants not outstanding Redeemed, in $4,138,055,555.55 full; warrants not outstanding Sold, in full; $1,718,159.50 warrants not outstanding Redeemed, in $14,594,338.99 full; warrants not outstanding Redeemed, in $3,135,328.00 full; warrants not outstanding Total Cash Back2 CPP TRANSACTIONS DETAIL, AS OF 12/31/2016 (CONTINUED) $21,407,000.00 $9,000,000.00 $1,100,000.00 $4,500,000.00 $10,500,000.00 $8,966,340.00 $40,000,000.00 $3,500,000,000.00 $1,140,525.00 $246,975.00 $12,700,000.00 $2,655,000.00 Amount ($367,045.94) ($89,663.40) ($401,960.00) ($11,125.00) ($13,875.00) (Fee)4 21,407 9,000 1,100,000 4,500,000 10,500,000 10,900 40,000 3,500,000 1,233 267 12,700 2,655 Shares Capital Repayment / Disposition / Auction3,5 $1,207.11 $1,207.11 $1.00 $1.00 $1.00 $822.60 $1,004.90 $1,000.00 $925.00 $925.00 $1,000.00 $1,000.00 Avg. Price ($25,000,000.00) ($5,983,000.00) ($1,933,660.00) ($92,475.00) ($20,025.00) (Realized Loss) / (Write-off) $4,433,603.77 $1,863,990.00 $196,000.00 Gain5 $55,000.00 $750,000.00 $476,206.83 $2,199,799.80 $45,000,000.00 $50,000.00 $381,000.00 $133,000.00 Wt Amount 55,000 750,000 545 2,000 48,253,677 75 381 133 Wt Shares Warrant Proceeds Dividends and Interest $358,971.00 $738,021.00 $467,708.57 $4,178,275.00 $195,637.00 $277,223.50 $3,827,111.00 $593,055,555.55 $305,659.50 $1,513,338.99 $347,328.00 20 15 0 0 20 14 11 0 0 0 0 Continued on next page $7,601,750.00 $5,109,375.00 $0.00 $0.00 $1,749,960.00 $2,079,175.00 $5,995,000.00 $0.00 $0.00 $0.00 $0.00 Amount Dividends Paid Number of Missed of Missed to Date Dividends Dividend TRANSACTION DETAIL I APPENDIX A I JANUARY 27, 2017 263 8,14,44 8,14 8,14,44 11 8,14,44 FL FL CA CA MO MO MO MO MO CA SEACOAST BANKING STUART CORPORATION OF FLORIDA SEACOAST BANKING STUART CORPORATION OF FLORIDA CHULA VISTA CHULA VISTA SEACOAST COMMERCE BANK SEACOAST COMMERCE BANK SECURITY BANCSHARES OF WAYNESVILLE PULASKI COUNTY, INC. SECURITY BANCSHARES OF WAYNESVILLE PULASKI COUNTY, INC. SECURITY BANCSHARES OF WAYNESVILLE PULASKI COUNTY, INC. SECURITY BANCSHARES OF WAYNESVILLE PULASKI COUNTY, INC. SECURITY BANCSHARES OF WAYNESVILLE PULASKI COUNTY, INC. SECURITY BUSINESS BANCORP SAN DIEGO FL SC SC SC CT CT CA CA CA CA CA MD MD SEACOAST BANKING STUART CORPORATION OF FLORIDA COLUMBIA ATASCADERO SANTA LUCIA BANCORP COLUMBIA ATASCADERO SANTA LUCIA BANCORP SCBT FINANCIAL CORPORATION SANTA PAULA SANTA CLARA VALLEY BANK, N.A SCBT FINANCIAL CORPORATION SANTA PAULA SANTA CLARA VALLEY BANK, N.A 8,14 COLUMBIA SANTA PAULA SANTA CLARA VALLEY BANK, N.A SCBT FINANCIAL CORPORATION OLNEY SANDY SPRING BANCORP, INC. SIMSBURY OLNEY SANDY SPRING BANCORP, INC. SBT BANCORP, INC. OLNEY SANDY SPRING BANCORP, INC. SIMSBURY MD OLNEY SANDY SPRING BANCORP, INC. SBT BANCORP, INC. CT SALISBURY BANCORP, INC. LAKEVILLE MD CT SALISBURY BANCORP, INC. LAKEVILLE 11,44 CT CA PA PA SALISBURY BANCORP, INC. LAKEVILLE INDIANA S&T BANCORP, INC. 44 INDIANA S&T BANCORP, INC. PA 8 INDIANA S&T BANCORP, INC. 11 State SAIGON NATIONAL BANK / CALIFORNIA WESTMINSTER INTERNATIONAL BANK, N.A. City Footnote Institution Name 1/9/2009 3/26/2013 1/11/2013 12/11/2012 12/10/2012 2/13/2009 9/1/2011 12/23/2008 5/30/2012 4/3/2012 12/19/2008 6/24/2009 5/20/2009 1/16/2009 8/11/2011 3/27/2009 10/21/2011 12/19/2008 4/9/2013 3/8/2013 2/13/2009 2/23/2011 12/15/2010 7/21/2010 12/5/2008 11/2/2011 8/25/2011 3/13/2009 12/23/2008 6/11/2013 12/7/2011 1/16/2009 Date $5,803,000.00 $2,152,000.00 $1,800,000.00 $50,000,000.00 $64,779,000.00 $4,000,000.00 $4,000,000.00 $2,900,000.00 $83,094,000.00 $8,816,000.00 $1,549,000.00 $108,676,000.00 Original Investment Amount $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $1,549,000.00 $0.00 Outstanding Investment $1,000.00 $1,000.00 Avg. Price ($434,971.00) (Realized Loss) / (Write-off) Gain5 Redeemed, in $6,888,017.86 full; warrants not outstanding Sold, in full; $1,983,756.24 warrants not outstanding Redeemed, in $2,153,780.00 full; warrants not outstanding Sold, in full; $49,045,470.38 warrants not outstanding Redeemed, in $67,294,638.84 full; warrants not outstanding Redeemed, in $4,717,144.78 full; warrants not outstanding Sold, in full; $3,131,111.11 warrants not outstanding Sold, in full; $2,697,208.51 warrants not outstanding Redeemed, in $95,137,868.33 full; warrants not outstanding $41,547,000.00 $1,315,959.00 $174,537.72 $1,800,000.00 $41,020,000.00 $64,779,000.00 $4,000,000.00 $2,800,000.00 $2,465,029.00 $41,547,000.00 ($10,095.03) ($14,904.97) ($615,300.00) 41,547 1,900 252 1,800 2,000 64,779 4,000 4,000 2,900 41,547 $1,000.00 $692.61 $692.61 $1,000.00 $20,510.00 $1,000.00 $1,000.00 $700.00 $850.01 $1,000.00 ($584,041.00) ($77,462.28) ($8,980,000.00) ($1,200,000.00) $69,186.80 $90,000.00 $55,000.00 $1,400,000.00 $200,000.00 $98,251.45 $4,450,000.00 $205,000.00 $527,361.00 Wt Amount 108 90 589,623 303,083 200 145 651,547 57,671 517,012 Wt Shares $1,079,960.44 $15,712,738.34 $0.00 $795,017.86 $449,072.72 $263,780.00 $8,585,770.38 $1,115,638.84 $517,144.78 $331,111.11 $158,928.06 $7,593,868.33 0 0 0 0 0 0 4 12 0 Continued on next page $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $200,000.00 $474,150.00 $0.00 0 32 0 Amount Dividends Paid Number of Missed of Missed to Date Dividends Dividend $0.00 8,816 108,676 Shares Dividends and Interest Redeemed, in $10,100,960.44 full; warrants not outstanding ($25,000.00) (Fee)4 Warrant Proceeds $836,523.22 $8,816,000.00 $108,676,000.00 Amount Capital Repayment / Disposition / Auction3,5 Full investment outstanding; $0.00 warrants outstanding Redeemed, in $124,916,099.34 full; warrants not outstanding Investment Total Cash Back2 Status* CPP TRANSACTIONS DETAIL, AS OF 12/31/2016 (CONTINUED) 264 APPENDIX A I TRANSACTION DETAIL I JANUARY 27, 2017 8,14 8,32, 97, 132 11 11 11,14,15 11 14,15 8,14,44 11,36 8,14, 36,111 8,14,44 ANNAPOLIS ANNAPOLIS SEVERN BANCORP, INC. SEVERN BANCORP, INC. MD MD MD NC SC SOUND BANKING COMPANY MOREHEAD CITY SOUTH FINANCIAL GROUP, INC./ CAROLINA FIRST BANK GREENVILLE NC SOUND BANKING COMPANY MOREHEAD CITY CA NC SOUND BANKING COMPANY MOREHEAD CITY SONOMA VALLEY BANCORP SONOMA NJ SOMERSET HILLS BANCORP BERNARDSVILLE CA NJ SONOMA VALLEY BANCORP SONOMA NJ NY SOMERSET HILLS BANCORP BERNARDSVILLE NEW YORK SIGNATURE BANK NY NY SOMERSET HILLS BANCORP BERNARDSVILLE NEW YORK NEW YORK SIGNATURE BANK SIGNATURE BANK TX ANNAPOLIS SEVERN BANCORP, INC. ND SIGNATURE BANCSHARES, DALLAS INC. JAMESTOWN ND TX JAMESTOWN SECURITY STATE BANK HOLDING COMPANY SECURITY STATE BANK HOLDING COMPANY ND SIGNATURE BANCSHARES, DALLAS INC. JAMESTOWN SECURITY STATE BANK HOLDING COMPANY MO MD CHARLESTON SECURITY STATE BANCSHARES, INC. MO MD CHARLESTON SECURITY STATE BANCSHARES, INC. SC SC SHORE BANCSHARES, INC. EASTON AIKEN SECURITY FEDERAL CORPORATION SC SHORE BANCSHARES, INC. EASTON AIKEN SECURITY FEDERAL CORPORATION MD AIKEN SECURITY FEDERAL CORPORATION MS MS CA CA CA State SHORE BANCSHARES, INC. EASTON BATESVILLE SECURITY CAPITAL CORPORATION RIVERSIDE SECURITY CALIFORNIA BANCORP BATESVILLE RIVERSIDE SECURITY CALIFORNIA BANCORP SECURITY CAPITAL CORPORATION SAN DIEGO City SECURITY BUSINESS BANCORP Footnote Institution Name 12/5/2008 1/11/2013 11/13/2012 1/9/2009 8/20/2010 2/20/2009 6/24/2009 5/20/2009 1/16/2009 3/16/2010 3/31/2009 12/12/2008 12/15/2010 6/26/2009 11/16/2011 4/15/2009 1/9/2009 10/29/2013 9/25/2013 11/21/2008 7/26/2013 6/24/2013 5/1/2009 9/22/2011 2/20/2009 7/31/2013 9/29/2010 12/19/2008 9/29/2010 6/26/2009 9/15/2011 1/9/2009 7/14/2011 $347,000,000.00 $3,070,000.00 $8,653,000.00 $7,414,000.00 $120,000,000.00 $1,700,000.00 $25,000,000.00 $23,393,000.00 $10,750,000.00 $12,500,000.00 $18,000,000.00 $17,388,000.00 $6,815,000.00 Original Investment Date Amount $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Outstanding Investment Investment Status* Currently Not Collectible Sold, in full; $146,965,329.86 warrants not outstanding Sold, in full; $3,575,224.44 warrants not outstanding $497,164.00 Redeemed, in $7,816,685.55 full; warrants not outstanding Redeemed, in $132,967,606.41 full; warrants not outstanding Redeemed, in $1,994,587.59 full; warrants not outstanding Redeemed, in $25,358,333.33 full; warrants not outstanding Sold, in full; $26,915,463.85 warrants outstanding Sold, in full; $14,543,635.13 warrants not outstanding Redeemed, in $14,888,679.86 full; warrants not outstanding Redeemed, in $19,650,000.00 full; warrants not outstanding Redeemed, in $19,063,111.00 full; warrants not outstanding Redeemed, in $8,152,698.33 full; warrants not outstanding Total Cash Back2 CPP TRANSACTIONS DETAIL, AS OF 12/31/2016 (CONTINUED) $2,832,412.70 $7,414,000.00 $120,000,000.00 $1,700,000.00 $25,000,000.00 $23,367,267.70 $10,750,000.00 $12,500,000.00 $18,000,000.00 $17,388,000.00 $6,815,000.00 $5,803,000.00 Amount ($25,000.00) ($233,672.68) ($125,346.08) (Fee)4 3,070 7,414 120,000 1,700,000 25,000 23,393 10,750,000 12,500 18,000 17,388 6,815 5,803 Shares Capital Repayment / Disposition / Auction3,5 $922.61 $1,000.00 $1,000.00 $1.00 $1,000.00 $998.90 $1.17 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 Avg. Price ($237,587.30) ($8,653,000.00) ($25,732.30) (Realized Loss) / (Write-off) $1,784,607.50 Gain5 $124,412.34 $275,000.00 $11,150,939.74 $85,000.00 $25,000.00 $720,368.55 $625,000.00 $50,000.00 $522,000.00 $341,000.00 $290,000.00 Wt Amount 154 163,065 595,829 85,000 172,970 538,000 625 137,966 522 341 290 Wt Shares Warrant Proceeds Dividends and Interest $16,386,111.11 $643,399.40 $347,164.00 $127,685.55 $1,816,666.67 $209,587.59 $333,333.33 $3,781,868.83 $1,414,005.16 $1,763,679.86 $1,600,000.00 $1,153,111.00 $996,698.33 0 0 3 0 0 0 0 6 10 0 0 0 0 Continued on next page $13,012,500.00 $0.00 $353,715.00 $0.00 $0.00 $0.00 $0.00 $1,754,475.00 $2,254,985.00 $0.00 $0.00 $0.00 $0.00 Amount Dividends Paid Number of Missed of Missed to Date Dividends Dividend TRANSACTION DETAIL I APPENDIX A I JANUARY 27, 2017 265 8 8 8,14,44 11 8 44 8,14,44 8,14,45 9,11,36 8,14 FAYETTEVILLE FAYETTEVILLE FAYETTEVILLE SOUTHCREST FINANCIAL GROUP, INC. SOUTHCREST FINANCIAL GROUP, INC. SOUTHCREST FINANCIAL GROUP, INC. GA GA GA GA WINSTON-SALEM WINSTON-SALEM GREENVILLE GREENVILLE GREENVILLE CLEVELAND CLEVELAND CARMI CARMI POPLAR BLUFF POPLAR BLUFF POPLAR BLUFF SOUTHERN COMMUNITY FINANCIAL CORP. SOUTHERN COMMUNITY FINANCIAL CORP. SOUTHERN FIRST BANCSHARES, INC. SOUTHERN FIRST BANCSHARES, INC. SOUTHERN FIRST BANCSHARES, INC. SOUTHERN HERITAGE BANCSHARES, INC. SOUTHERN HERITAGE BANCSHARES, INC. SOUTHERN ILLINOIS BANCORP, INC. SOUTHERN ILLINOIS BANCORP, INC. SOUTHERN MISSOURI BANCORP, INC. SOUTHERN MISSOURI BANCORP, INC. SOUTHERN MISSOURI BANCORP, INC. AL AL OK SOUTHFIRST BANCSHARES, SYLACAUGA INC. SOUTHFIRST BANCSHARES, SYLACAUGA INC. STILLWATER STILLWATER STILLWATER SOUTHWEST BANCORP, INC. SOUTHWEST BANCORP, INC. SOUTHWEST BANCORP, INC. BRISTOW BRISTOW BRISTOW ST. LOUIS SPIRIT BANKCORP, INC. SPIRIT BANKCORP, INC. ST. JOHNS BANCSHARES, INC. MO OK OK OK TX SOVEREIGN BANCSHARES, DALLAS INC. SPIRIT BANKCORP, INC. TX SOVEREIGN BANCSHARES, DALLAS INC. OK OK AL SOUTHFIRST BANCSHARES, SYLACAUGA INC. MO MO MO IL IL TN TN SC SC SC NC AR NC SOUTHERN BANCORP, INC. ARKADELPHIA AR FAYETTEVILLE SOUTHCREST FINANCIAL GROUP, INC. SC State SOUTHERN BANCORP, INC. ARKADELPHIA GREENVILLE City SOUTH FINANCIAL GROUP, INC./ CAROLINA FIRST BANK Footnote Institution Name 3/13/2009 1/6/2014 10/21/2013 3/27/2009 9/22/2011 3/13/2009 5/29/2013 8/8/2012 12/5/2008 8/6/2015 6/29/2015 6/12/2009 5/13/2015 7/21/2011 12/5/2008 8/25/2011 1/23/2009 9/8/2011 5/15/2009 7/25/2012 7/3/2012 2/27/2009 10/1/2012 12/5/2008 8/6/2010 1/16/2009 4/9/2013 3/11/2013 3/8/2013 7/17/2009 9/30/2010 Date $3,000,000.00 $30,000,000.00 $18,215,000.00 $70,000,000.00 $2,760,000.00 $9,550,000.00 $5,000,000.00 $4,862,000.00 $17,299,000.00 $42,750,000.00 $11,000,000.00 $12,900,000.00 Original Investment Amount $3,000,000.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Outstanding Investment $1,554,408.00 Full investment outstanding; warrants outstanding Sold, in full; $11,803,691.75 warrants not outstanding Redeemed, in $21,632,668.61 full; warrants not outstanding Redeemed, in $85,247,569.91 full; warrants not outstanding Sold, in full; $3,202,464.28 warrants not outstanding Redeemed, in $13,504,763.89 full; warrants not outstanding Redeemed, in $5,955,472.22 full; warrants not outstanding Redeemed, in $5,718,111.14 full; warrants not outstanding Sold, in full; $19,401,361.89 warrants not outstanding Redeemed, in $51,088,046.14 full; warrants not outstanding Redeemed, in $11,855,555.56 full; warrants not outstanding Sold, in full; $13,109,014.25 warrants not outstanding Investment Total Cash Back2 Status* CPP TRANSACTIONS DETAIL, AS OF 12/31/2016 (CONTINUED) $9,000,000.00 $18,215,000.00 $70,000,000.00 $2,722,050.00 $9,550,000.00 $5,000,000.00 $4,862,000.00 $15,638,296.00 $42,750,000.00 $11,000,000.00 $9,889,679.00 $1,814,620.00 $130,179,218.75 Amount ($90,000.00) ($25,000.00) ($234,574.44) ($117,042.99) (Fee)4 30,000 18,215 70,000 2,760 9,550 5,000 4,862 17,299 42,750 11,000 10,900 2,000 130,179 Shares Capital Repayment / Disposition / Auction3,5 $300.00 $1,000.00 $1,000.00 $986.25 $1,000.00 $1,000.00 $1,000.00 $904.00 $1,000.00 $1,000.00 $907.31 $907.31 $1,000.00 Avg. Price ($21,000,000.00) ($37,950.00) ($1,660,704.00) ($1,010,321.00) ($185,380.00) ($216,820,781.25) (Realized Loss) / (Write-off) Gain5 $631,941.75 $911,000.00 $2,287,197.00 $140,617.94 $2,700,000.00 $250,000.00 $243,000.00 $1,100,000.00 $588,264.19 $400,000.00 Wt Amount 1,500 911 703,753 138 231,891 250 243 399,970 645 10,106,796 Wt Shares Warrant Proceeds $1,554,408.00 $2,261,750.00 $2,506,668.61 $12,960,372.91 $364,796.34 $1,254,763.89 $705,472.22 $613,111.14 $2,897,640.33 $8,338,046.14 $855,555.56 $933,494.05 0 12 0 0 14 0 0 0 0 0 0 9 Continued on next page $0.00 $4,905,000.00 $0.00 $0.00 $609,270.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $1,581,863.00 Amount Dividends Paid Number of Missed of Missed to Date Dividends Dividend Dividends and Interest 266 APPENDIX A I TRANSACTION DETAIL I JANUARY 27, 2017 BARTLEY STATE BANK OF BARTLEY, THE CHARLOTTESVILLE CHARLOTTESVILLE CHARLOTTESVILLE STELLARONE CORPORATION STELLARONE CORPORATION STELLARONE CORPORATION 31 11 11 HOUSTON HOUSTON SPOKANE SPOKANE STERLING BANCSHARES, INC. STERLING FINANCIAL CORPORATION STERLING FINANCIAL CORPORATION HOUSTON STERLING BANCSHARES, INC. STERLING BANCSHARES, INC. NEW YORK NEW YORK STERLING BANCORP STERLING BANCORP NEW YORK CHARLOTTESVILLE STELLARONE CORPORATION STERLING BANCORP DENVER STEELE STREET BANK CORPORATION 11 DENVER STEELE STREET BANK 15,17,45 CORPORATION ST. CLOUD BOSTON ST. CLOUD BOSTON STATE STREET CORPORATION STATE STREET CORPORATION STEARNS FINANCIAL SERVICES, INC. GREENWOOD BOSTON STATE CAPITAL CORP. STATE STREET CORPORATION GREENWOOD STATE CAPITAL CORP. FARGO BARTLEY STATE BANK OF BARTLEY, THE FARGO JERICHO STATE BANKSHARES, INC. JERICHO STATE BANCORP, INC. / VALLEY NATIONAL BANCORP STATE BANKSHARES, INC. JERICHO STATE BANCORP, INC. / VALLEY NATIONAL BANCORP FARGO HICKORY HILLS STATE BANCORP, INC. / VALLEY NATIONAL BANCORP STATE BANKSHARES, INC. HICKORY HILLS STANDARD BANCSHARES, INC. STEARNS FINANCIAL 11,14,15 SERVICES, INC. 12,16 8,11,36 8,11 15,17,44 11,61 8,14,74 City STANDARD BANCSHARES, INC. Footnote Institution Name WA WA TX TX TX NY NY NY VA VA VA VA CO CO MN MN MA MA MA MS MS ND ND ND NE NE NY NY NY IL IL State 8/20/2012 12/5/2008 6/15/2010 5/5/2009 12/12/2008 5/18/2011 4/27/2011 12/23/2008 12/18/2013 12/28/2011 4/13/2011 12/19/2008 9/1/2011 9/25/2009 1/18/2012 6/26/2009 7/8/2009 6/17/2009 10/28/2008 9/29/2010 2/13/2009 6/29/2011 8/12/2009 1/16/2009 9/22/2011 9/4/2009 5/27/2015 12/14/2011 12/5/2008 2/22/2013 4/24/2009 $303,000,000.00 $125,198,000.00 $42,000,000.00 $30,000,000.00 $11,019,000.00 $24,900,000.00 $2,000,000,000.00 $15,000,000.00 $50,000,000.00 $1,697,000.00 $36,842,000.00 $60,000,000.00 Original Investment Date Amount $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Outstanding Investment Investment Status* Sold, in full; $121,757,209.63 warrants not outstanding Redeemed, in $130,542,485.91 full; warrants not outstanding Redeemed, in $47,869,108.33 full; warrants not outstanding Redeemed, in $37,191,875.00 full; warrants not outstanding Redeemed, in $13,078,672.60 full; warrants not outstanding Redeemed, in $31,495,442.29 full; warrants not outstanding Redeemed, in $2,123,611,111.12 full; warrants not outstanding Redeemed, in $17,080,708.67 full; warrants not outstanding Redeemed, in $58,008,472.23 full; warrants not outstanding Redeemed, in $2,030,299.18 full; warrants not outstanding Redeemed, in $42,514,919.19 full; warrants not outstanding Redeemed, in $75,757,163.03 full; warrants not outstanding Total Cash Back2 CPP TRANSACTIONS DETAIL, AS OF 12/31/2016 (CONTINUED) $114,772,740.00 $125,198,000.00 $42,000,000.00 $22,500,000.00 $7,500,000.00 $11,019,000.00 $24,900,000.00 $2,000,000,000.00 $15,000,000.00 $37,500,000.00 $12,500,000.00 $1,697,000.00 $36,842,000.00 $60,000,000.00 Amount ($1,434,659.25) (Fee)4 5,738,637 125,198 42,000 22,500 7,500 11,019,000 24,900,000 20,000 15,000 37,500 12,500 1,697,000 36,842 12,903,226 Shares Capital Repayment / Disposition / Auction3,5 $20.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1.00 $1.00 $100,000.00 $1,000.00 $1,000.00 $1,000.00 $1.00 $1,000.00 $4.65 Avg. Price ($188,227,260.00) (Realized Loss) / (Write-off) $3,000,000.00 Gain5 $2,857,914.52 $945,775.00 $2,920,000.00 $331,000.00 $1,245,000.00 $60,000,000.00 $750,000.00 $2,500,000.00 $51,000.00 $100,566.69 Wt Amount 2,615,557 516,817 302,623 331,000 1,245,000 2,788,104 750 250 51,000 488,847 Wt Shares Warrant Proceeds Dividends and Interest $7,594,128.88 $2,486,571.39 $4,923,333.33 $4,271,875.00 $1,728,672.60 $5,350,442.29 $63,611,111.12 $1,330,708.67 $5,508,472.23 $282,299.18 $12,757,163.03 0 0 0 0 0 0 0 0 0 0 0 0 Continued on next page $18,937,500.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Amount Dividends Paid Number of Missed of Missed to Date Dividends Dividend TRANSACTION DETAIL I APPENDIX A I JANUARY 27, 2017 267 WEST CHESTER WEST CHESTER WEST CHESTER WEST CHESTER ELMHURST ELMHURST STONEBRIDGE FINANCIAL CORP. STONEBRIDGE FINANCIAL CORP. STONEBRIDGE FINANCIAL CORP. STONEBRIDGE FINANCIAL CORP. SUBURBAN ILLINOIS BANCORP, INC. SUBURBAN ILLINOIS BANCORP, INC. 12,16 8,11,14 11 8,11,14 SANTA CLARA STERLING SVB FINANCIAL GROUP SV FINANCIAL, INC. LITITZ SUSQUEHANNA BANCSHARES, INC. STERLING LITITZ SUSQUEHANNA BANCSHARES, INC. SV FINANCIAL, INC. LITITZ SUSQUEHANNA BANCSHARES, INC. CA IL IL PA PA PA PA NC MOUNT AIRY LITITZ SURREY BANCORP NC AL AL GA GA GA GA NJ NJ NJ CA CA CA IL IL PA PA PA PA SD SD SD NJ NJ NJ WA State MOUNT AIRY SUSQUEHANNA BANCSHARES, INC. SURREY BANCORP BIRMINGHAM ATLANTA SUNTRUST BANKS, INC. SUPERIOR BANCORP INC. ATLANTA SUNTRUST BANKS, INC. BIRMINGHAM ATLANTA SUNTRUST BANKS, INC. VINELAND SUN BANCORP, INC. ATLANTA VINELAND SUN BANCORP, INC. SUNTRUST BANKS, INC. VINELAND SUN BANCORP, INC. SANTA ROSA RAPID CITY SUMMIT STATE BANK RAPID CITY STOCKMENS FINANCIAL CORPORATION SANTA ROSA RAPID CITY STOCKMENS FINANCIAL CORPORATION SANTA ROSA MIDLAND PARK STOCKMENS FINANCIAL CORPORATION SUMMIT STATE BANK MIDLAND PARK STEWARDSHIP FINANCIAL CORPORATION SUMMIT STATE BANK MIDLAND PARK STEWARDSHIP FINANCIAL CORPORATION 24,49,97 SUPERIOR BANCORP INC. 11 11 44 15,123 8,14 8,11,14 44 SPOKANE STEWARDSHIP FINANCIAL CORPORATION City STERLING FINANCIAL CORPORATION Footnote Institution Name 12/12/2008 8/31/2011 4/10/2009 1/19/2011 12/22/2010 4/21/2010 12/12/2008 12/29/2010 1/9/2009 4/15/2011 12/5/2008 9/28/2011 3/30/2011 12/31/2008 11/14/2008 5/27/2009 4/8/2009 1/9/2009 9/14/2011 8/4/2011 12/19/2008 7/16/2015 6/19/2009 4/9/2013 3/27/2013 3/26/2013 1/23/2009 3/16/2011 1/12/2011 2/6/2009 10/26/2011 9/1/2011 1/30/2009 9/19/2012 Date $235,000,000.00 $4,000,000.00 $300,000,000.00 $2,000,000.00 $69,000,000.00 $1,350,000,000.00 $3,500,000,000.00 $89,310,000.00 $8,500,000.00 $15,000,000.00 $10,973,000.00 $15,568,000.00 $10,000,000.00 Original Investment Amount $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Outstanding Investment Currently Not Collectible Redeemed, in $253,929,027.78 full; warrants not outstanding Redeemed, in $4,721,382.89 full; warrants not outstanding Redeemed, in $328,991,401.58 full; warrants not outstanding Redeemed, in $2,314,972.22 full; warrants not outstanding $4,983,333.33 Redeemed, in $5,448,052,772.51 full; warrants not outstanding Redeemed, in $92,513,970.83 full; warrants not outstanding Redeemed, in $9,930,625.00 full; warrants not outstanding Redeemed, in $24,929,429.70 full; warrants not outstanding Sold, in full; $2,652,816.96 warrants not outstanding Redeemed, in $18,101,553.84 full; warrants not outstanding Redeemed, in $11,400,453.22 full; warrants not outstanding Investment Total Cash Back2 Status* CPP TRANSACTIONS DETAIL, AS OF 12/31/2016 (CONTINUED) $4,000,000.00 $100,000,000.00 $200,000,000.00 $2,000,000.00 $4,850,000,000.00 $89,310,000.00 $8,500,000.00 $15,000,000.00 $107,935.66 $1,796,209.03 $11,568,000.00 $4,000,000.00 $10,000,000.00 Amount ($25,000.00) (Fee)4 4,000 100,000 200,000 2,000 48,500 89,310 8,500 15,000,000 622 10,351 11,568 4,000 10,000 Shares Capital Repayment / Disposition / Auction3,5 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $100,000.00 $1,000.00 $1,000.00 $1.00 $173.53 $173.53 $1,000.00 $1,000.00 $1,000.00 Avg. Price ($69,000,000.00) ($514,064.34) ($8,554,790.97) (Realized Loss) / (Write-off) Gain5 $200,000.00 $5,269,179.36 $100,000.00 $30,066,661.40 $2,100,000.00 $315,000.00 $750,000.00 $8,358.99 $130,704.17 $778,000.00 $107,398.00 $825,000.00 Wt Amount 200 3,028,264 100 17,900,182 1,620,545 239,212 750,000 33 516 778 133,475 97,541 Wt Shares Warrant Proceeds $12,109,027.78 $521,382.89 $23,722,222.22 $214,972.22 $4,983,333.33 $567,986,111.11 $1,103,970.83 $1,115,625.00 $9,179,429.70 $634,609.11 $1,755,553.84 $1,293,055.22 0 0 0 0 3 0 0 0 0 12 0 0 Continued on next page $0.00 $0.00 $0.00 $0.00 $2,587,500.00 $0.00 $0.00 $0.00 $0.00 $1,794,180.00 $0.00 $0.00 Amount Dividends Paid Number of Missed of Missed to Date Dividends Dividend Dividends and Interest 268 APPENDIX A I TRANSACTION DETAIL I JANUARY 27, 2017 12,16 8,14,44 8,11,14 11 8,14 63,97 8,11,14 TN TN FRANKLIN FRANKLIN TENNESSEE COMMERCE BANCORP, INC. TENNESSEE COMMERCE BANCORP, INC. TENNESSEE VALLEY OAK RIDGE FINANCIAL HOLDINGS, INC. DALLAS JACKSONVILLE JACKSONVILLE TEXAS CAPITAL BANCSHARES, INC. TEXAS NATIONAL BANCORPORATION INC. TEXAS NATIONAL BANCORPORATION INC. THE BANCORP, INC. WILMINGTON TERRELL DALLAS TEXAS CAPITAL BANCSHARES, INC. TERRELL DALLAS TEXAS CAPITAL BANCSHARES, INC. THE ANB CORPORATION TX TENNESSEE VALLEY OAK RIDGE FINANCIAL HOLDINGS, INC. THE ANB CORPORATION TN TENNESSEE VALLEY OAK RIDGE FINANCIAL HOLDINGS, INC. DE TX TX TX TX TX TX TN TN TENNESSEE VALLEY OAK RIDGE FINANCIAL HOLDINGS, INC. TN OH DAYTON OH DAYTON MN TCNB FINANCIAL CORP WAYZATA MN MN TX TX SC SC IL IL IL ID ID TCNB FINANCIAL CORP WAYZATA 11 TCF FINANCIAL CORPORATION GREENWOOD TCB CORPORATION/ COUNTY BANK TCF FINANCIAL CORPORATION GREENWOOD TCB CORPORATION/ COUNTY BANK WAYZATA ROSEMONT TAYLOR CAPITAL GROUP TCF FINANCIAL CORPORATION ROSEMONT TAYLOR CAPITAL GROUP THE WOODLANDS ROSEMONT TAYLOR CAPITAL GROUP THE WOODLANDS BOISE SYRINGA BANCORP TCB HOLDING COMPANY BOISE SYRINGA BANCORP GA WI SYNOVUS FINANCIAL CORP. COLUMBUS HORICON SWORD FINANCIAL CORPORATION WI CA GA HORICON SWORD FINANCIAL CORPORATION CA State SYNOVUS FINANCIAL CORP. COLUMBUS SANTA CLARA SVB FINANCIAL GROUP 8,97,100 TCB HOLDING COMPANY 15,17,45 8,103 11 14,15,44 SANTA CLARA City SVB FINANCIAL GROUP Footnote Institution Name 12/12/2008 8/25/2011 8/7/2009 5/19/2010 1/9/2009 3/17/2010 5/13/2009 1/16/2009 5/31/2013 4/29/2013 4/26/2013 12/23/2008 1/27/2012 12/19/2008 8/3/2011 12/23/2008 12/21/2009 4/22/2009 11/14/2008 12/13/2013 1/16/2009 9/8/2011 8/28/2009 7/18/2012 6/19/2012 11/21/2008 1/31/2014 1/16/2009 7/26/2013 12/19/2008 9/15/2011 5/8/2009 6/16/2010 12/23/2009 $45,220,000.00 $20,000,000.00 $3,981,000.00 $75,000,000.00 $3,000,000.00 $30,000,000.00 $2,000,000.00 $361,172,000.00 $11,730,000.00 $9,720,000.00 $104,823,000.00 $8,000,000.00 $967,870,000.00 $13,644,000.00 Original Investment Date Amount $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Outstanding Investment Investment Status* Currently Not Collectible Currently Not Collectible Redeemed, in $52,787,673.44 full; warrants not outstanding Redeemed, in $23,234,499.98 full; warrants not outstanding Redeemed, in $4,475,307.67 full; warrants not outstanding Redeemed, in $82,777,816.21 full; warrants not outstanding Sold, in full; $3,331,713.17 warrants not outstanding $3,233,333.33 Redeemed, in $2,384,611.11 full; warrants not outstanding Redeemed, in $378,547,699.45 full; warrants not outstanding Currently Not $690,832.08 Collectible Redeemed, in $11,611,381.34 full; warrants not outstanding Sold, in full; $120,845,170.80 warrants not outstanding $253,122.22 Redeemed, in $1,190,614,526.39 full; warrants outstanding Redeemed, in $17,019,233.91 full; warrants not outstanding Total Cash Back2 CPP TRANSACTIONS DETAIL, AS OF 12/31/2016 (CONTINUED) $20,000,000.00 $3,981,000.00 $75,000,000.00 $2,702,000.00 $298,000.00 $2,000,000.00 $361,172,000.00 $9,720,000.00 $93,659,350.50 $967,870,000.00 $13,644,000.00 $235,000,000.00 Amount ($25,000.00) ($1,404,890.26) (Fee)4 20,000 3,981 75,000 2,702 298 2,000 361,172 9,720,000 104,823 967,870 13,644,000 235,000 Shares Capital Repayment / Disposition / Auction3,5 $1,000.00 $1,000.00 $1,000.00 $1,022.11 $1,022.11 $1,000.00 $1,000.00 $1.00 $893.50 $1,000.00 $1.00 $1,000.00 Avg. Price ($30,000,000.00) ($11,730,000.00) ($11,163,649.50) ($8,000,000.00) (Realized Loss) / (Write-off) $59,741.22 $6,588.78 Gain5 $1,000,000.00 $199,000.00 $6,559,066.21 $124,922.63 $19,218.87 $100,000.00 $9,449,980.56 $292,000.00 $9,839,273.00 $682,000.00 $6,820,000.00 Wt Amount 1,000 199 758,086 130 20 100 3,199,988 292,000 1,462,647 682,000 354,058 Wt Shares Warrant Proceeds Dividends and Interest $2,813,688.89 $2,234,499.98 $295,307.67 $1,218,750.00 $146,241.67 $3,233,333.33 $284,611.11 $7,925,718.89 $690,832.08 $1,599,381.34 $18,751,437.56 $253,122.22 $222,744,526.39 $2,693,233.91 0 0 0 0 13 3 0 0 15 0 0 17 0 0 Continued on next page $0.00 $0.00 $0.00 $0.00 $531,375.00 $1,125,000.00 $0.00 $0.00 $2,397,488.00 $0.00 $0.00 $1,853,000.00 $0.00 $0.00 Amount Dividends Paid Number of Missed of Missed to Date Dividends Dividend TRANSACTION DETAIL I APPENDIX A I JANUARY 27, 2017 269 8,14,44 11 8,11,14 8,11,14 11,36 11 44 8,14 11 8 MS HARPER MO THE HARTFORD FINANCIAL HARTFORD SERVICES GROUP, INC. COLUMBIA CT CT THE HARTFORD FINANCIAL HARTFORD SERVICES GROUP, INC. THE LANDRUM COMPANY CT THE HARTFORD FINANCIAL HARTFORD SERVICES GROUP, INC. KS KS MS HARPER THE FIRST BANCSHARES, INC. MS THE FREEPORT STATE BANK HATTIESBURG HATTIESBURG THE FIRST BANCSHARES, INC. ME TX HATTIESBURG THE FIRST BANCSHARES, INC. THE FREEPORT STATE BANK DAMARISCOTTA THE FIRST BANCORP, INC. ME THE FIRST STATE BANK OF MOBEETIE MOBEETIE DAMARISCOTTA THE FIRST BANCORP, INC. ME ME TX DAMARISCOTTA ME NY NY NY CT CT WI WI WI WI KY KY KY KY NC NC DE DE State THE FIRST STATE BANK OF MOBEETIE MOBEETIE DAMARISCOTTA THE FIRST BANCORP, INC. ELMIRA ELMIRA THE ELMIRA SAVINGS BANK, FSB THE ELMIRA SAVINGS BANK, FSB THE FIRST BANCORP, INC. ELMIRA THE ELMIRA SAVINGS BANK, FSB DAMARISCOTTA HARTFORD THE CONNECTICUT BANK AND TRUST COMPANY THE FIRST BANCORP, INC. HARTFORD BARABOO THE BARABOO BANCORPORATION, INC. THE CONNECTICUT BANK AND TRUST COMPANY BARABOO THE BARABOO BANCORPORATION, INC. BARABOO CRESTVIEW HILLS THE BANK OF KENTUCKY FINANCIAL CORPORATION BARABOO CRESTVIEW HILLS THE BANK OF KENTUCKY FINANCIAL CORPORATION THE BARABOO BANCORPORATION, INC. CRESTVIEW HILLS THE BANK OF KENTUCKY FINANCIAL CORPORATION THE BARABOO BANCORPORATION, INC. MOYOCK CRESTVIEW HILLS THE BANK OF CURRITUCK THE BANK OF KENTUCKY FINANCIAL CORPORATION MOYOCK THE BANK OF CURRITUCK WILMINGTON WILMINGTON THE BANCORP, INC. City THE BANCORP, INC. Footnote Institution Name 5/22/2009 9/27/2010 3/31/2010 6/26/2009 12/19/2012 2/6/2009 4/14/2010 2/27/2009 5/13/2015 9/29/2010 2/6/2009 5/28/2015 5/8/2013 3/27/2013 8/24/2011 1/9/2009 5/6/2015 8/25/2011 12/19/2008 4/19/2012 12/19/2008 1/11/2013 12/11/2012 12/10/2012 1/16/2009 5/29/2013 11/23/2011 12/22/2010 2/13/2009 12/3/2010 2/6/2009 9/8/2010 3/10/2010 Date $15,000,000.00 $3,400,000,000.00 $301,000.00 $731,000.00 $5,000,000.00 $25,000,000.00 $9,090,000.00 $5,448,000.00 $20,749,000.00 $34,000,000.00 $4,021,000.00 Original Investment Amount $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Outstanding Investment Redeemed, in $17,580,291.55 full; warrants not outstanding Redeemed, in $4,236,125,671.00 full; warrants not outstanding Redeemed, in $379,458.89 full; warrants not outstanding Redeemed, in $813,086.56 full; warrants not outstanding Redeemed, in $5,714,215.56 full; warrants not outstanding Redeemed, in $29,722,063.78 full; warrants not outstanding Redeemed, in $11,795,867.07 full; warrants not outstanding Redeemed, in $6,902,866.33 full; warrants not outstanding Sold, in full; $18,023,831.85 warrants not outstanding Redeemed, in $40,091,342.55 full; warrants not outstanding Sold, in full; $1,912,684.00 warrants not outstanding Investment Total Cash Back2 Status* CPP TRANSACTIONS DETAIL, AS OF 12/31/2016 (CONTINUED) $3,400,000,000.00 $301,000.00 $731,000.00 $5,000,000.00 $10,000,000.00 $2,500,000.00 $12,500,000.00 $9,090,000.00 $5,448,000.00 $11,577,672.70 $1,956,900.00 $17,000,000.00 $17,000,000.00 $1,742,850.00 $45,220,000.00 Amount ($135,345.73) (Fee)4 3,400,000 301 731 5,000 10,000 2,500 12,500 9,090 5,448 17,749 3,000 17,000 17,000 4,021 45,220 Shares Capital Repayment / Disposition / Auction3,5 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $652.30 $652.30 $1,000.00 $1,000.00 $433.44 $1,000.00 Avg. Price ($6,171,327.30) ($1,043,100.00) ($2,278,150.00) (Realized Loss) / (Write-off) Gain5 $706,264,559.89 $15,000.00 $37,000.00 $302,410.00 $389,077.67 $1,486,292.07 $792,783.00 $455,316.35 $403,161.92 $2,150,648.55 $4,753,984.55 Wt Amount 52,093,973 15 37 54,705 226,819 151,030 175,742 550 487 276,078 980,203 Wt Shares Warrant Proceeds $1,830,291.55 $129,861,111.11 $63,458.89 $45,086.56 $411,805.56 $4,332,986.11 $1,219,575.00 $662,083.33 $3,766,126.61 $3,940,694.00 $169,834.00 0 0 0 0 0 0 0 4 2 0 4 Continued on next page $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $246,673.00 $565,390.00 $0.00 $219,140.00 Amount Dividends Paid Number of Missed of Missed to Date Dividends Dividend Dividends and Interest 270 APPENDIX A I TRANSACTION DETAIL I JANUARY 27, 2017 8,47,97 134 8,21 8,18, 21,44 8,14 8,14,44 11 8,14 FL HOQUIAM HOQUIAM HOQUIAM HOQUIAM HOQUIAM HOQUIAM TIMBERLAND BANCORP, INC. TIMBERLAND BANCORP, INC. TIMBERLAND BANCORP, INC. TIMBERLAND BANCORP, INC. TIMBERLAND BANCORP, INC. TIMBERLAND BANCORP, INC. WA WA WA WA WA GA WA TIFTON BANKING COMPANY TIFTON GA TIFTON BANKING COMPANY TIFTON SC NAPLES TIB FINANCIAL CORP FL TIDELANDS BANCSHARES, MT. PLEASANT INC. NAPLES TIB FINANCIAL CORP FL FL SC ORLANDO FL FL PA PA PA GA GA GA GA CA CA PA PA PA NC NC NC MO State TIDELANDS BANCSHARES, MT. PLEASANT INC. ORLANDO LOUISVILLE THE QUEENSBOROUGH COMPANY THREE SHORES BANCORPORATION, INC. LOUISVILLE THE QUEENSBOROUGH COMPANY ORLANDO LOUISVILLE THE QUEENSBOROUGH COMPANY THREE SHORES BANCORPORATION, INC. LOUISVILLE THE QUEENSBOROUGH COMPANY THREE SHORES BANCORPORATION, INC. LOS ANGELES THE PRIVATE BANK OF CALIFORNIA ORLANDO LOS ANGELES THE PRIVATE BANK OF CALIFORNIA THREE SHORES BANCORPORATION, INC. PITTSBURGH LIMERICK PITTSBURGH THE PNC FINANCIAL SERVICES GROUP, INC. LIMERICK PITTSBURGH THE PNC FINANCIAL SERVICES GROUP, INC. THE VICTORY BANCORP, INC. KINSTON THE PNC FINANCIAL SERVICES GROUP, INC. LIMERICK KINSTON THE LITTLE BANK, INCORPORATED THE LITTLE BANK, INCORPORATED THE VICTORY BANCORP, INC. KINSTON THE LITTLE BANK, INCORPORATED THE VICTORY BANCORP, INC. COLUMBIA City THE LANDRUM COMPANY Footnote Institution Name 6/11/2013 1/11/2013 11/13/2012 11/9/2012 11/8/2012 12/23/2008 11/12/2010 4/17/2009 7/1/2016 12/19/2008 9/30/2010 12/5/2008 1/11/2013 11/9/2012 11/8/2012 1/23/2009 9/22/2011 12/11/2009 2/27/2009 4/9/2013 3/11/2013 3/8/2013 1/9/2009 9/1/2011 2/20/2009 5/5/2010 2/10/2010 12/31/2008 1/11/2013 10/31/2012 12/23/2008 8/18/2011 $16,641,000.00 $3,800,000.00 $14,448,000.00 $37,000,000.00 $5,677,000.00 $1,505,000.00 $541,000.00 $12,000,000.00 $5,450,000.00 $7,579,200,000.00 $7,500,000.00 Original Investment Date Amount $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Outstanding Investment Investment Status* Sold, in full; $18,857,818.52 warrants not outstanding Exited $223,208.00 bankruptcy/ Receivership Sold, in full; $10,180,200.33 warrants not outstanding Sold, in full; $13,444,359.59 warrants not outstanding Sold, in full; $6,449,130.64 warrants not outstanding Redeemed, in $2,322,183.20 full; warrants not outstanding Sold, in full; $13,065,246.00 warrants not outstanding Redeemed, in $6,474,752.14 full; warrants not outstanding Redeemed, in $8,320,638,950.83 full; warrants not outstanding Sold, in full; $9,232,652.17 warrants not outstanding Total Cash Back2 CPP TRANSACTIONS DETAIL, AS OF 12/31/2016 (CONTINUED) $9,481,462.50 $1,580,962.50 $3,290,437.50 $8,984,227.00 $12,119,637.37 $3,877,691.40 $1,165,528.32 $2,046,000.00 $11,478,575.00 $244,225.00 $5,450,000.00 $7,579,200,000.00 $7,359,000.00 $15,000,000.00 Amount ($143,528.63) ($50,432.20) ($117,228.00) ($73,590.00) (Fee)4 10,993 1,833 3,815 14,448 12,120 4,365 1,312 2,046 11,750 250 5,450 75,792 7,500 15,000 Shares Capital Repayment / Disposition / Auction3,5 $862.50 $862.50 $862.50 $621.83 $1,000.00 $888.36 $888.36 $1,000.00 $976.90 $976.90 $1,000.00 $100,000.00 $981.20 $1,000.00 Avg. Price ($1,511,537.50) ($252,037.50) ($524,562.50) ($3,800,000.00) ($5,463,773.00) ($24,880,362.63) ($487,308.60) ($146,471.68) ($271,425.00) ($5,775.00) ($141,000.00) (Realized Loss) / (Write-off) Gain5 $1,301,856.00 $40,000.00 $282,284.64 $61,000.00 $571,967.55 $4,806.45 $273,000.00 $320,372,284.16 $371,250.00 $750,000.00 Wt Amount 370,899 1,106,389 284 61 595 5 273 16,885,192 375 750 Wt Shares Warrant Proceeds Dividends and Interest $3,346,628.65 $223,208.00 $1,195,973.33 $1,284,722.22 $1,174,058.48 $215,183.20 $882,900.00 $751,752.14 $421,066,666.67 $1,575,992.17 0 1 23 4 0 0 11 0 0 0 Continued on next page $0.00 $51,775.00 $5,454,120.00 $1,850,000.00 $0.00 $0.00 $1,798,500.00 $0.00 $0.00 $0.00 Amount Dividends Paid Number of Missed of Missed to Date Dividends Dividend TRANSACTION DETAIL I APPENDIX A I JANUARY 27, 2017 271 8,14,44 11 8,14,18 8,11 8,9,11 8,14 8,14,44 8,14,44 8 45 8 8,11,14 LOS ALAMOS MEMPHIS MEMPHIS PITTSBURGH PITTSBURGH TRINITY CAPITAL CORPORATION TRI-STATE BANK OF MEMPHIS TRI-STATE BANK OF MEMPHIS TRISTATE CAPITAL HOLDINGS, INC. TRISTATE CAPITAL HOLDINGS, INC. IA BURLINGTON TWO RIVERS FINANCIAL GROUP, INC. IA MS BURLINGTON TWO RIVERS FINANCIAL GROUP, INC. MS TRUSTMARK CORPORATION JACKSON TRUSTMARK CORPORATION JACKSON MS TN TN TN TN PA PA TN TN NM NM NM NM NM MD MD MO MO TRUSTMARK CORPORATION JACKSON KINGSPORT LOS ALAMOS TRINITY CAPITAL CORPORATION TRISUMMIT BANK LOS ALAMOS TRINITY CAPITAL CORPORATION KINGSPORT LOS ALAMOS TRINITY CAPITAL CORPORATION KINGSPORT LOS ALAMOS TRINITY CAPITAL CORPORATION TRISUMMIT BANK WALDORF TRI-COUNTY FINANCIAL CORPORATION TRISUMMIT BANK WALDORF TRI-COUNTY FINANCIAL CORPORATION KINGSPORT FRONTENAC TRIAD BANCORP, INC. TRISUMMIT BANK FRONTENAC TX TX TREATY OAK BANCORP, INC. AUSTIN TREATY OAK BANCORP, INC. AUSTIN TRIAD BANCORP, INC. TX VA TX PORTSMOUTH TOWNEBANK VA TREATY OAK BANCORP, INC. AUSTIN PORTSMOUTH TOWNEBANK VA KY KY IA IA State TREATY OAK BANCORP, INC. AUSTIN PORTSMOUTH HOPKINSVILLE TOWNEBANK HOPKINSVILLE TODD BANCSHARES, INC. TITONKA TITONKA BANCSHARES, INC. TODD BANCSHARES, INC. TITONKA City TITONKA BANCSHARES, INC. Footnote Institution Name 9/1/2011 5/29/2009 12/30/2009 12/9/2009 11/21/2008 1/11/2013 11/29/2012 12/22/2009 4/3/2009 9/26/2012 2/27/2009 8/13/2010 4/3/2009 9/11/2012 8/10/2012 8/9/2012 8/7/2012 3/27/2009 9/22/2011 12/19/2008 9/22/2011 3/27/2009 8/6/2015 12/21/2012 2/15/2011 1/16/2009 5/15/2013 9/22/2011 12/12/2008 9/25/2013 2/6/2009 4/4/2012 4/3/2009 Date $12,000,000.00 $215,000,000.00 $4,237,000.00 $2,765,000.00 $23,000,000.00 $2,795,000.00 $35,539,000.00 $15,540,000.00 $3,700,000.00 $3,268,000.00 $76,458,000.00 $4,000,000.00 $2,117,000.00 Original Investment Amount $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Outstanding Investment Redeemed, in $14,075,133.27 full; warrants not outstanding Redeemed, in $236,287,500.00 full; warrants not outstanding Sold, in full; $6,496,417.16 warrants not outstanding Redeemed, in $28,642,402.33 full; warrants not outstanding Redeemed, in $2,985,215.11 full; warrants not outstanding Sold, in full; $34,644,476.74 warrants not outstanding Redeemed, in $18,653,115.75 full; warrants not outstanding Redeemed, in $4,386,324.64 full; warrants not outstanding Sold, in full; $2,412,702.03 warrants outstanding Redeemed, in $88,577,166.67 full; warrants not outstanding Redeemed, in $5,210,672.22 full; warrants not outstanding Redeemed, in $2,569,490.36 full; warrants not outstanding Investment Total Cash Back2 Status* CPP TRANSACTIONS DETAIL, AS OF 12/31/2016 (CONTINUED) $12,000,000.00 $215,000,000.00 $5,251,500.00 $23,000,000.00 $2,795,000.00 $16,984,909.75 $7,038,845.50 $2,639,379.50 $15,540,000.00 $3,700,000.00 $150,000.00 $500,000.00 $76,458,000.00 $4,000,000.00 $2,117,000.00 Amount ($52,515.00) ($266,631.35) (Fee)4 12,000 215,000 7,002 23,000 2,795 22,639 9,382 3,518 15,540 3,700 150,000 3,118 76,458 4,000 2,117 Shares Capital Repayment / Disposition / Auction3,5 $1,000.00 $1,000.00 $750.00 $1,000.00 $1,000.00 $750.25 $750.25 $750.25 $1,000.00 $1,000.00 $1.00 $160.36 $1,000.00 $1,000.00 $1,000.00 Avg. Price ($1,750,500.00) ($5,654,090.25) ($2,343,154.50) ($878,620.50) ($2,618,000.00) (Realized Loss) / (Write-off) Gain5 $600,000.00 $10,000,000.00 $124,665.75 $1,150,000.00 $191,948.33 $1,300,776.05 $163,062.90 $777,000.00 $185,000.00 $1,570,287.00 $1,500,000.00 $200,000.00 $106,000.00 Wt Amount 60 1,647,931 138 1,150 206 1,396 175 777 185 554,330 200 106 Wt Shares Warrant Proceeds $1,475,133.27 $11,287,500.00 $1,172,766.41 $4,492,402.33 $190,215.11 $6,592,186.06 $2,336,115.75 $501,324.64 $192,415.03 $10,619,166.67 $1,010,672.22 $346,490.36 0 0 0 0 0 0 0 0 3 0 0 0 Continued on next page $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $133,553.00 $0.00 $0.00 $0.00 Amount Dividends Paid Number of Missed of Missed to Date Dividends Dividend Dividends and Interest 272 APPENDIX A I TRANSACTION DETAIL I JANUARY 27, 2017 ALBUQUERQUE UNION FINANCIAL CORPORATION 11,14,15 11,36 8 SAN MATEO TECUMSEH TECUMSEH TECUMSEH UNITED AMERICAN BANK UNITED BANCORP, INC. UNITED BANCORP, INC. UNITED BANCORP, INC. MI MI MI CA CA GA UNITED BANCORPORATION ATMORE OF ALABAMA, INC. BARNESVILLE BARNESVILLE BLAIRSVILLE BLAIRSVILLE UNITED BANK CORPORATION UNITED BANK CORPORATION UNITED COMMUNITY BANKS, INC. UNITED COMMUNITY BANKS, INC. GA GA GA AL AL UNITED BANCORPORATION ATMORE OF ALABAMA, INC. AL SAN MATEO UNITED AMERICAN BANK CA VA VA VA NM NM NM NC NC NC UNITED BANCORPORATION ATMORE OF ALABAMA, INC. SAN MATEO UNITED AMERICAN BANK BOWLING GREEN ALBUQUERQUE UNION FINANCIAL CORPORATION BOWLING GREEN ALBUQUERQUE UNION FINANCIAL CORPORATION UNION FIRST MARKET BANKSHARES CORPORATION OXFORD UNION FIRST MARKET BANKSHARES CORPORATION OXFORD UNION BANK & TRUST COMPANY BOWLING GREEN OXFORD UNION BANK & TRUST COMPANY OR UMPQUA HOLDINGS CORP. PORTLAND UNION BANK & TRUST COMPANY OR UMPQUA HOLDINGS CORP. PORTLAND CA CA OR SAN FRANCISCO KS KS FL FL MN MN MN State UMPQUA HOLDINGS CORP. PORTLAND SAN FRANCISCO UCBH HOLDINGS INC. MARYSVILLE UBT BANCSHARES, INC. UCBH HOLDINGS INC. MARYSVILLE UBT BANCSHARES, INC. UNION FIRST MARKET 12,16,25 BANKSHARES CORPORATION 8,11,17 8,14,18, 44,45 12,16 22,97 8,14,44 MIAMI U.S. CENTURY BANK MINNEAPOLIS U.S. BANCORP MIAMI MINNEAPOLIS U.S. BANCORP U.S. CENTURY BANK MINNEAPOLIS U.S. BANCORP 11 8,122 City Footnote Institution Name 3/26/2013 12/5/2008 7/3/2012 5/22/2009 5/13/2015 9/3/2010 12/23/2008 7/18/2012 6/19/2012 1/16/2009 9/26/2014 7/2/2014 2/20/2009 12/23/2009 11/18/2009 12/19/2008 10/2/2013 7/25/2012 12/29/2009 9/22/2011 12/18/2009 5/1/2009 3/31/2010 2/17/2010 11/14/2008 11/6/2009 11/14/2008 8/11/2011 1/30/2009 3/17/2015 8/7/2009 7/15/2009 6/17/2009 11/14/2008 $180,000,000.00 $14,400,000.00 $10,300,000.00 $20,600,000.00 $8,700,000.00 $59,000,000.00 $2,179,000.00 $2,997,000.00 $3,194,000.00 $214,181,000.00 $298,737,000.00 $8,950,000.00 $50,236,000.00 $6,599,000,000.00 Original Investment Date Amount $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Outstanding Investment Investment Status* Currently Not Collectible Sold, in full; $210,367,527.00 warrants not outstanding Redeemed, in $18,882,079.62 full; warrants not outstanding Redeemed, in $11,182,763.89 full; warrants not outstanding Sold, in full; $20,315,924.72 warrants not outstanding Sold, in full; $3,432,657.85 warrants not outstanding Redeemed, in $62,145,972.22 full; warrants not outstanding Redeemed, in $2,639,873.33 full; warrants not outstanding Redeemed, in $7,031,291.65 full; warrants not outstanding Redeemed, in $232,156,554.58 full; warrants not outstanding $7,509,920.07 Redeemed, in $10,634,911.78 full; warrants not outstanding Sold, in full; $13,070,409.40 warrants not outstanding Redeemed, in $6,933,220,416.67 full; warrants not outstanding Total Cash Back2 CPP TRANSACTIONS DETAIL, AS OF 12/31/2016 (CONTINUED) $1,516,900.00 $14,400,000.00 $10,300,000.00 $17,005,300.00 $3,319,050.00 $59,000,000.00 $1,579,000.00 $600,000.00 $6,191,000.00 $214,181,000.00 $8,950,000.00 $11,738,143.76 $6,599,000,000.00 Amount ($255,079.50) ($25,000.00) (Fee)4 1,576 14,400,000 10,300 20,600 8,700 59,000 1,579 600 6,191 214,181 8,950 50,236 6,599,000 Shares Capital Repayment / Disposition / Auction3,5 $962.50 $1.00 $1,000.00 $825.50 $381.50 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $233.66 $1,000.00 Avg. Price ($59,100.00) ($3,594,700.00) ($5,380,950.00) ($298,737,000.00) ($38,497,856.24) (Realized Loss) / (Write-off) Gain5 $720,000.00 $10,125.00 $38,000.00 $138,607.85 $450,000.00 $65,000.00 $160,000.00 $4,500,000.00 $450,000.00 $586,953.92 $139,000,000.00 Wt Amount 720,000 111,258 311,492 435 211,318 65 160 1,110,898 45 2,512 32,679,102 Wt Shares Warrant Proceeds Dividends and Interest $38,843,350.00 $3,762,079.62 $872,638.89 $3,527,704.22 $7,935,831.57 $395,873.33 $680,291.65 $13,475,554.58 $7,509,920.07 $1,234,911.78 $745,311.72 $195,220,416.67 0 0 0 0 21 0 0 0 0 1 0 21 0 Continued on next page $0.00 $0.00 $0.00 $0.00 $2,482,702.00 $0.00 $0.00 $0.00 $0.00 $3,734,213.00 $0.00 $15,378,590.00 $0.00 Amount Dividends Paid Number of Missed of Missed to Date Dividends Dividend TRANSACTION DETAIL I APPENDIX A I JANUARY 27, 2017 273 11 8 8,11,14 8,11 8 9,11,15 8 11 8,11,44 CA VA VALLEY COMMUNITY BANK PLEASANTON ROANOKE ROANOKE ROANOKE ROANOKE ROANOKE ROANOKE ROANOKE VALLEY FINANCIAL CORPORATION VALLEY FINANCIAL CORPORATION VALLEY FINANCIAL CORPORATION VALLEY FINANCIAL CORPORATION VALLEY FINANCIAL CORPORATION VALLEY FINANCIAL CORPORATION VALLEY FINANCIAL CORPORATION VA VA VA VA VA VA CA CA CA VISALIA VALLEY COMMERCE BANCORP CA VALLEY COMMUNITY BANK PLEASANTON VISALIA VALLEY COMMERCE BANCORP NC NC NC CA CA MN MN IN IN IN IN NJ NJ NJ NJ VALLEY COMMUNITY BANK PLEASANTON ALBEMARLE ALBEMARLE UWHARRIE CAPITAL CORP UWHARRIE CAPITAL CORP ALBEMARLE GARDEN GROVE UWHARRIE CAPITAL CORP US METRO BANK ST. PAUL UNIVERSITY FINANCIAL CORP. GARDEN GROVE ST. PAUL UNIVERSITY FINANCIAL CORP. US METRO BANK BLOOMFIELD BLOOMFIELD UNIVERSAL BANCORP UNIVERSAL BANCORP BLOOMFIELD CLINTON UNITY BANCORP, INC. BLOOMFIELD CLINTON UNITY BANCORP, INC. UNIVERSAL BANCORP CLINTON UNITY BANCORP, INC. UNIVERSAL BANCORP CLINTON VA UNITY BANCORP, INC. VA GA GA UNITED FINANCIAL VIENNA BANKING COMPANIES, INC. BLAIRSVILLE UNITED COMMUNITY BANKS, INC. UNITED FINANCIAL VIENNA BANKING COMPANIES, INC. BLAIRSVILLE UNITED COMMUNITY BANKS, INC. GA GA VA BLAIRSVILLE State UNITED FINANCIAL VIENNA BANKING COMPANIES, INC. BLAIRSVILLE UNITED COMMUNITY BANKS, INC. City UNITED COMMUNITY BANKS, INC. Footnote Institution Name 11/13/2013 10/16/2013 8/14/2013 5/15/2013 2/20/2013 11/14/2012 12/12/2008 1/6/2014 10/21/2013 1/9/2009 3/21/2012 1/30/2009 10/16/2013 4/3/2013 12/23/2008 3/23/2016 2/6/2009 7/30/2010 6/19/2009 9/12/2013 8/12/2013 8/8/2013 5/22/2009 8/28/2013 7/3/2013 5/15/2013 12/5/2008 9/15/2011 12/15/2010 1/16/2009 6/10/2013 4/9/2013 3/28/2013 3/27/2013 Date $16,019,000.00 $5,500,000.00 $7,700,000.00 $10,000,000.00 $2,861,000.00 $11,926,000.00 $9,900,000.00 $20,649,000.00 $5,658,000.00 Original Investment Amount $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Outstanding Investment Redeemed, in $21,311,670.48 full; warrants not outstanding Sold, in full; $2,947,090.75 warrants not outstanding Redeemed, in $9,403,400.50 full; warrants not outstanding Redeemed, in $12,916,040.83 full; warrants not outstanding Redeemed, in $3,465,216.00 full; warrants not outstanding Redeemed, in $12,948,886.40 full; warrants not outstanding Sold, in full; $12,066,668.65 warrants not outstanding Redeemed, in $28,013,814.50 full; warrants not outstanding Redeemed, in $6,649,963.92 full; warrants not outstanding Investment Total Cash Back2 Status* CPP TRANSACTIONS DETAIL, AS OF 12/31/2016 (CONTINUED) $9,619,000.00 $1,600,000.00 $1,600,000.00 $1,600,000.00 $1,600,000.00 $2,296,800.00 $7,700,000.00 $2,258,000.00 $7,742,000.00 $2,861,000.00 $11,926,000.00 $9,168,561.50 $237,527.50 $10,325,000.00 $10,324,000.00 $2,658,000.00 $3,000,000.00 $159,145,525.00 $12,587,575.00 Amount ($25,000.00) ($94,060.89) ($1,732,500.00) (Fee)4 9,619 1,600 1,600 1,600 1,600 5,500 7,700 2,258 7,742 2,861 11,926,000 9,650 250 10,325 10,324 2,658 3,000 165,346 13,078 Shares Capital Repayment / Disposition / Auction3,5 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $417.60 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1.00 $950.11 $950.11 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $962.50 $962.50 Avg. Price ($3,203,200.00) ($481,438.50) ($12,472.50) ($6,200,475.00) ($490,425.00) (Realized Loss) / (Write-off) Gain5 $1,547,891.58 $45,815.25 $385,000.00 $500,000.00 $143,000.00 $476,573.62 $2,707,314.00 $283,000.00 $6,677.00 Wt Amount 344,742 275 385 500 143 495 764,778 283 219,908 Wt Shares Warrant Proceeds $3,744,778.90 $629,475.50 $1,318,400.50 $2,416,040.83 $461,216.00 $1,022,886.40 $2,278,066.92 $4,657,500.50 $708,963.92 0 10 0 0 17 0 0 0 0 Continued on next page $0.00 $749,375.00 $0.00 $0.00 $891,540.00 $0.00 $0.00 $0.00 $0.00 Amount Dividends Paid Number of Missed of Missed to Date Dividends Dividend Dividends and Interest 274 APPENDIX A I TRANSACTION DETAIL I JANUARY 27, 2017 11 8,11,17 8,14,45 8,11,14 8,17 11 8,41,44 11 8,14,44 BOSTON CLINTON WACHUSETT FINANCIAL SERVICES, INC. WAINWRIGHT BANK & TRUST COMPANY CLINTON WACHUSETT FINANCIAL SERVICES, INC. BOSTON SPOKANE W.T.B. FINANCIAL CORPORATION WAINWRIGHT BANK & TRUST COMPANY SPOKANE W.T.B. FINANCIAL CORPORATION CLINTON WYOMISSING VIST FINANCIAL CORP. CLINTON WYOMISSING VIST FINANCIAL CORP. WACHUSETT FINANCIAL SERVICES, INC. RICHARDSON VISION BANK - TEXAS WACHUSETT FINANCIAL SERVICES, INC. RICHARDSON NEWPORT NEWS VIRGINIA COMPANY BANK VISION BANK - TEXAS NEWPORT NEWS VIRGINIA COMPANY BANK RICHARDSON NEWPORT NEWS VIRGINIA COMPANY BANK VISION BANK - TEXAS NEWPORT NEWS VIRGINIA COMPANY BANK ARLINGTON VIRGINIA COMMERCE BANCORP, INC. MA MA MA MA MA MA WA WA PA PA TX TX TX VA VA VA VA VA VA ARLINGTON VIRGINIA COMMERCE BANCORP, INC. TX VA DALLAS VERITEX HOLDINGS, INC. (FIDELITY RESOURCES COMPANY) TX ARLINGTON DALLAS VERITEX HOLDINGS, INC. (FIDELITY RESOURCES COMPANY) NJ NJ VIRGINIA COMMERCE BANCORP, INC. WAYNE VALLEY NATIONAL BANCORP VA WAYNE VALLEY NATIONAL BANCORP NJ NJ VA WAYNE VILLAGE BANK AND TRUST MIDLOTHIAN FINANCIAL CORP. WAYNE VALLEY NATIONAL BANCORP NJ VILLAGE BANK AND TRUST MIDLOTHIAN FINANCIAL CORP. WAYNE VALLEY NATIONAL BANCORP MI VA SAGINAW VALLEY NATIONAL BANCORP MI State VILLAGE BANK AND TRUST MIDLOTHIAN FINANCIAL CORP. SAGINAW VALLEY FINANCIAL GROUP, LTD. City VALLEY FINANCIAL GROUP, LTD. Footnote Institution Name 11/24/2009 12/19/2008 4/23/2014 1/30/2013 4/4/2012 12/11/2009 9/15/2011 1/30/2009 8/1/2012 12/19/2008 7/10/2013 12/28/2012 4/24/2009 9/12/2013 8/12/2013 8/8/2013 6/12/2009 1/31/2014 12/11/2012 12/12/2008 1/6/2014 11/19/2013 5/1/2009 8/25/2011 6/26/2009 5/24/2010 12/23/2009 9/23/2009 6/3/2009 11/14/2008 9/22/2011 12/18/2009 $22,000,000.00 $12,000,000.00 $110,000,000.00 $25,000,000.00 $1,500,000.00 $4,700,000.00 $71,000,000.00 $14,738,000.00 $3,000,000.00 $300,000,000.00 $1,300,000.00 Original Investment Date Amount $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Outstanding Investment Investment Status* Redeemed, in $23,592,311.11 full; warrants not outstanding Redeemed, in $14,731,826.23 full; warrants not outstanding Redeemed, in $131,236,874.33 full; warrants not outstanding Redeemed, in $30,710,646.33 full; warrants not outstanding Redeemed, in $1,898,258.59 full; warrants not outstanding Sold, in full; $3,694,442.50 warrants not outstanding Redeemed, in $118,453,138.89 full; warrants not outstanding Sold, in full; $6,933,870.05 warrants outstanding Redeemed, in $3,503,795.81 full; warrants not outstanding Redeemed, in $318,400,781.94 full; warrants not outstanding Redeemed, in $1,489,774.73 full; warrants not outstanding Total Cash Back2 CPP TRANSACTIONS DETAIL, AS OF 12/31/2016 (CONTINUED) $22,000,000.00 $5,000,000.00 $4,000,000.00 $3,000,000.00 $110,000,000.00 $25,000,000.00 $712,500.00 $787,500.00 $2,543,620.14 $325,353.86 $71,000,000.00 $5,672,361.44 $3,000,000.00 $100,000,000.00 $125,000,000.00 $75,000,000.00 $1,300,000.00 Amount ($25,000.00) ($56,723.61) (Fee)4 22,000 5,000 4,000 3,000 110,000 25,000 713 788 4,167 533 71,000 14,738 3,000 100,000 125,000 75,000 1,300 Shares Capital Repayment / Disposition / Auction3,5 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $610.42 $610.42 $1,000.00 $384.88 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00 Avg. Price ($1,623,379.86) ($207,646.14) ($9,065,638.56) (Realized Loss) / (Write-off) Gain5 $478,000.00 $5,500,000.00 $1,189,813.00 $75,000.00 $63,481.25 $33,263,000.00 $150,000.00 $5,421,615.27 $65,000.00 Wt Amount 478 5,500 367,984 75 143 2,696,203 150 2,532,542 65 Wt Shares Warrant Proceeds Dividends and Interest $1,023,611.11 $2,253,826.23 $15,736,874.33 $4,520,833.33 $323,258.59 $786,987.25 $14,190,138.89 $1,318,232.22 $353,795.81 $18,551,519.17 $124,774.73 0 0 0 0 0 3 0 11 0 0 0 Continued on next page $0.00 $0.00 $0.00 $0.00 $0.00 $185,903.00 $0.00 $2,026,475.00 $0.00 $0.00 $0.00 Amount Dividends Paid Number of Missed of Missed to Date Dividends Dividend TRANSACTION DETAIL I APPENDIX A I JANUARY 27, 2017 275 11 11 11 11 11 8,17 8,18, 21,44 11 11,16 SEATTLE MINNEAPOLIS WELLS FARGO & CO. WHEELING WHEELING WEST DES MOINES WEST DES MOINES WEST DES MOINES SAN RAFAEL SAN RAFAEL SAN RAFAEL SAN RAFAEL WESBANCO, INC. WESBANCO, INC. WEST BANCORPORATION, INC. WEST BANCORPORATION, INC. WEST BANCORPORATION, INC. WESTAMERICA BANCORPORATION WESTAMERICA BANCORPORATION WESTAMERICA BANCORPORATION WESTAMERICA BANCORPORATION WHEELING MINNEAPOLIS WELLS FARGO & CO. WESBANCO, INC. MINNEAPOLIS WATERBURY WATERBURY WEBSTER FINANCIAL CORPORATION WEBSTER FINANCIAL CORPORATION WELLS FARGO & CO. WATERBURY WATERBURY WEBSTER FINANCIAL CORPORATION CA CA CA CA IA IA IA WV WV WV MN MN MN CT CT CT CT CT WATERBURY WEBSTER FINANCIAL CORPORATION WEBSTER FINANCIAL CORPORATION WI WI WAUKESHA BANKSHARES, WAUKESHA INC. WAUKESHA BANKSHARES, WAUKESHA INC. WAUKESHA BANKSHARES, WAUKESHA INC. WI WI WAUKESHA BANKSHARES, WAUKESHA INC. WI VA VA VA WA WA WA WA WA WA MA State WAUKESHA BANKSHARES, WAUKESHA INC. RESTON SEATTLE WASHINGTON FEDERAL, INC. RESTON SEATTLE WASHINGTON FEDERAL, INC. WASHINGTONFIRST BANKSHARES, INC. OAK HARBOR WASHINGTON FEDERAL, INC. WASHINGTONFIRST BANKSHARES, INC. OAK HARBOR WASHINGTON BANKING COMPANY RESTON OAK HARBOR WASHINGTON BANKING COMPANY WASHINGTONFIRST BANKSHARES, INC. BOSTON WASHINGTON BANKING COMPANY City WAINWRIGHT BANK & TRUST COMPANY Footnote Institution Name $400,000,000.00 $5,625,000.00 $6,842,000.00 $6,633,000.00 $200,000,000.00 $26,380,000.00 Original Investment Amount 11/21/2011 11/18/2009 9/2/2009 2/13/2009 8/31/2011 6/29/2011 12/31/2008 12/23/2009 9/9/2009 12/5/2008 5/26/2010 12/23/2009 $83,726,000.00 $36,000,000.00 $75,000,000.00 10/28/2008 $25,000,000,000.00 6/8/2011 12/29/2010 10/13/2010 3/3/2010 11/21/2008 3/26/2013 2/8/2013 2/7/2013 2/6/2013 6/26/2009 8/4/2011 10/30/2009 1/30/2009 3/15/2010 5/27/2009 11/14/2008 3/2/2011 1/12/2011 1/16/2009 12/16/2009 Date $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Outstanding Investment Redeemed, in $87,360,236.61 full; warrants not outstanding Redeemed, in $41,195,000.00 full; warrants not outstanding Redeemed, in $78,804,166.67 full; warrants not outstanding Redeemed, in $27,281,347,113.95 full; warrants not outstanding Redeemed, in $457,333,286.51 full; warrants not outstanding Sold, in full; $6,398,893.44 warrants not outstanding Redeemed, in $15,317,317.86 full; warrants not outstanding Redeemed, in $220,749,985.18 full; warrants not outstanding Redeemed, in $30,628,344.45 full; warrants not outstanding Investment Total Cash Back2 Status* CPP TRANSACTIONS DETAIL, AS OF 12/31/2016 (CONTINUED) $41,863,000.00 $41,863,000.00 $36,000,000.00 $75,000,000.00 $25,000,000,000.00 $200,000,000.00 $100,000,000.00 $100,000,000.00 $290,119.70 $92,690.00 $4,831,002.80 $13,475,000.00 $200,000,000.00 $26,380,000.00 Amount ($52,138.13) (Fee)4 41,863 41,863 36,000 75,000 25,000 200,000 100,000 100,000 313 100 5,212 13,475 200,000 26,380 Shares Capital Repayment / Disposition / Auction3,5 $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,000,000.00 $1,000.00 $1,000.00 $1,000.00 $926.90 $926.90 $926.90 $1,000.00 $1,000.00 $1,000.00 Avg. Price ($22,880.30) ($7,310.00) ($380,997.20) (Realized Loss) / (Write-off) Gain5 $878,256.00 $700,000.00 $950,000.00 $840,374,891.73 $20,388,842.06 $147,194.69 $18,644.66 $332,000.00 $15,388,874.07 $1,625,000.00 $568,700.00 Wt Amount 246,698 474,100 439,282 110,261,688 3,282,276 150 19 332 1,707,456 246,082 390,071 Wt Shares Warrant Proceeds $2,755,980.61 $4,495,000.00 $4,242,500.00 $1,440,972,222.22 $36,944,444.45 $1,071,379.72 $1,510,317.86 $5,361,111.11 $2,623,344.45 0 0 0 0 0 0 0 0 0 Continued on next page $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Amount Dividends Paid Number of Missed of Missed to Date Dividends Dividend Dividends and Interest 276 APPENDIX A I TRANSACTION DETAIL I JANUARY 27, 2017 8,14 11 11 8 8,11,78 8,14,18 8,117 44 PALM DESERT MONMOUTH MONMOUTH MONMOUTH MONMOUTH MONMOUTH MEDINA MEDINA WESTERN COMMUNITY BANCSHARES, INC. WESTERN ILLINOIS BANCSHARES, INC. WESTERN ILLINOIS BANCSHARES, INC. WESTERN ILLINOIS BANCSHARES, INC. WESTERN ILLINOIS BANCSHARES, INC. WESTERN ILLINOIS BANCSHARES, INC. WESTERN RESERVE BANCORP, INC. WESTERN RESERVE BANCORP, INC. OH OH IL IL IL IL IL CA CA WILMINGTON WSFS FINANCIAL CORPORATION HUNTSVILLE WORTHINGTON FINANCIAL HOLDINGS, INC. WILMINGTON LAKE FOREST WINTRUST FINANCIAL CORPORATION WSFS FINANCIAL CORPORATION LAKE FOREST WINTRUST FINANCIAL CORPORATION HUNTSVILLE LAKE FOREST WINTRUST FINANCIAL CORPORATION HUNTSVILLE LOS ANGELES WILSHIRE BANCORP, INC. WORTHINGTON FINANCIAL HOLDINGS, INC. LOS ANGELES WILSHIRE BANCORP, INC. WORTHINGTON FINANCIAL HOLDINGS, INC. CA LOS ANGELES WILSHIRE BANCORP, INC. DE DE AL AL AL IL IL IL CA CA DE NEW ORLEANS WHITNEY HOLDING CORPORATION WILMINGTON TRUST CORPORATION / M&T BANK WILMINGTON CORPORATION LA NEW ORLEANS WHITNEY HOLDING CORPORATION DE LA WHITE RIVER BANCSHARES FAYETTEVILLE COMPANY WILMINGTON TRUST CORPORATION / M&T BANK WILMINGTON CORPORATION AR AR WHITE RIVER BANCSHARES FAYETTEVILLE COMPANY AR PALM DESERT WESTERN COMMUNITY BANCSHARES, INC. NV NV WHITE RIVER BANCSHARES FAYETTEVILLE COMPANY LAS VEGAS AR LAS VEGAS WESTERN ALLIANCE BANCORPORATION NV State WHITE RIVER BANCSHARES FAYETTEVILLE COMPANY LAS VEGAS WESTERN ALLIANCE BANCORPORATION City WESTERN ALLIANCE BANCORPORATION Footnote Institution Name 4/3/2012 1/23/2009 7/26/2013 6/24/2013 5/15/2009 2/14/2011 12/22/2010 12/19/2008 6/20/2012 4/3/2012 12/12/2008 5/13/2011 12/12/2008 6/3/2011 12/19/2008 9/26/2014 7/2/2014 7/1/2014 2/20/2009 11/30/2012 5/15/2009 1/11/2013 11/9/2012 11/8/2012 12/29/2009 12/23/2008 11/7/2014 12/23/2008 11/23/2011 9/27/2011 11/21/2008 $52,625,000.00 $2,720,000.00 $250,000,000.00 $62,158,000.00 $330,000,000.00 $300,000,000.00 $16,800,000.00 $4,700,000.00 $4,567,000.00 $6,855,000.00 $7,290,000.00 $140,000,000.00 Original Investment Date Amount $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Outstanding Investment Investment Status* Sold, in full; $57,640,856.64 warrants not outstanding Sold, in full; $2,780,391.21 warrants not outstanding Redeemed, in $300,704,730.81 full; warrants not outstanding Sold, in full; $68,809,170.52 warrants not outstanding Redeemed, in $369,920,833.33 full; warrants outstanding Redeemed, in $343,733,333.33 full; warrants not outstanding Sold, in full; $20,275,427.10 warrants not outstanding Redeemed, in $5,842,197.92 full; warrants not outstanding Sold, in full; $13,053,910.87 warrants not outstanding Currently Not $554,083.00 Collectible Redeemed, in $160,365,000.00 full; warrants not outstanding Total Cash Back2 CPP TRANSACTIONS DETAIL, AS OF 12/31/2016 (CONTINUED) $48,157,663.75 $2,343,851.20 $250,000,000.00 $58,646,694.58 $330,000,000.00 $300,000,000.00 $15,500,000.00 $1,300,000.00 $4,700,000.00 $9,673,015.37 $1,050,524.72 $140,000,000.00 Amount ($722,364.96) ($24,999.99) ($879,700.42) ($178,619.28) ($107,235.41) (Fee)4 52,625 2,720 250,000 62,158 330,000 300,000 15,500 1,300 4,700 10,305 1,117 140,000 Shares Capital Repayment / Disposition / Auction3,5 $915.11 $861.71 $1,000.00 $943.51 $1,000.00 $1,000.00 $1,063.21 $1,063.21 $1,000.00 $938.67 $940.49 $1,000.00 Avg. Price ($4,467,336.25) ($376,148.80) ($3,511,305.42) ($631,984.63) ($66,475.28) ($7,290,000.00) (Realized Loss) / (Write-off) $979,755.00 $82,173.00 Gain5 $90,940.00 $25,600,564.15 $760,000.00 $6,900,000.00 $1,002,535.38 $235,000.00 $335,417.06 $415,000.00 Wt Amount 136 1,643,295 949,460 2,631,579 840 235 343 787,107 Wt Shares Warrant Proceeds Dividends and Interest $8,405,557.85 $370,600.00 $25,104,166.66 $10,282,176.36 $36,833,333.33 $1,589,583.00 $907,197.92 $2,102,189.13 $554,083.00 $19,950,000.00 0 6 0 0 0 0 14 0 0 17 0 Continued on next page $0.00 $222,360.00 $0.00 $0.00 $0.00 $0.00 $3,204,600.00 $0.00 $0.00 $1,834,538.00 $0.00 Amount Dividends Paid Number of Missed of Missed to Date Dividends Dividend TRANSACTION DETAIL I APPENDIX A I JANUARY 27, 2017 277 SALT LAKE CITY SALT LAKE CITY SALT LAKE CITY ZIONS BANCORPORATION ZIONS BANCORPORATION ZIONS BANCORPORATION SALT LAKE CITY YORK ZIONS BANCORPORATION YORK TRADITIONS BANK NC YADKIN VALLEY FINANCIAL CORPORATION / YADKIN ELKIN FINANCIAL CORPORATION UT UT UT UT PA PA NC YADKIN VALLEY FINANCIAL CORPORATION / YADKIN ELKIN FINANCIAL CORPORATION YORK NC YORK TRADITIONS BANK NC YADKIN VALLEY FINANCIAL CORPORATION / YADKIN ELKIN FINANCIAL CORPORATION $1,400,000,000.00 $4,871,000.00 $13,312,000.00 $36,000,000.00 Original Investment Amount $204,894,726,320.00 12/5/2012 9/26/2012 3/28/2012 11/14/2008 7/14/2011 4/24/2009 6/11/2013 6/10/2013 9/18/2012 7/24/2009 1/16/2009 9/12/2012 Date $199,050,724.29 $0.00 $0.00 $0.00 Outstanding Investment $226,677,723,102.83 Redeemed, in $1,661,027,529.62 full; warrants not outstanding Redeemed, in $5,705,022.14 full; warrants not outstanding Sold, in full; $52,383,419.85 warrants not outstanding Investment Total Cash Back2 Status* $199,591,660,290.79 $700,000,000.00 $700,000,000.00 $4,871,000.00 $44,149,056.00 Amount ($38,027,858.19) ($662,235.84) (Fee)4 700,000 700,000 4,871 49,312 Shares Capital Repayment / Disposition / Auction3,5 $1,000.00 $1,000.00 $1,000.00 $895.30 Avg. Price ($5,104,015,304.92) ($5,162,944.00) (Realized Loss) / (Write-off) $6,907,490,828.42 Gain5 $8,065,534,497.60 $7,666,418.51 $244,000.00 $20,000.00 $55,677.00 $1,800,000.00 Wt Amount 5,789,909 244 128,663 91,178 175,105 Wt Shares Warrant Proceeds $253,361,111.11 $590,022.14 $8,820,922.69 $0.00 $0.00 $0.00 Continued on next page 0 0 0 Amount Dividends Paid Number of Missed of Missed to Date Dividends Dividend Dividends and Interest Notes: Numbers may not total due to rounding. Data as of 12/31/2016. Numeric notes were taken verbatim from Treasury’s 12/30/2016, Transactions Report. All amounts and totals reflect cumulative receipts from inception through 12/31/2016. Sources: Treasury, Transactions Report, 12/30/2016; Dividends and Interest Report, 1/10/2017. 1 All pricing is at par. 2 Total Cash Back includes net capital repayments, interest and dividends, warrant proceeds, and other income (less expenses). 3 Capital Repayments includes gross capital repayments, gross auction proceeds, exchanges into CDCI, and SBLF fundings. 4 Includes: (i) placement fees in private auctions of a CPP issuer’s securities where Treasury pays placement fees to the placement agents in an amount equal to a minimum of $50,000 (per issuer) or 1.00% of gross aggregate proceeds for each security and (ii) unreimbursed underwriting fees in public offerings. Placement fees in private auctions are paid approximately one month after settlement. 5 Net proceeds from sales and auctions can be calculated by adding the “Amount” and “(Fee)” columns under the “Capital Repayment / Disposition / Auction” plus any amount in the “Gain” column. Note that “(Fee)” is a negative number. 6 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. 7 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. 8 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. 9 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. 10 Treasury cancelled the warrants received from this institution due to its designation as a CDFI. 11 Repayment pursuant to Title VII, Section 7001(g) of the American Recovery and Reinvestment Act of 2009. 12 Redemption pursuant to a qualified equity offering. 13 This amount does not include accrued and unpaid dividends, which must be paid at the time of capital repayment. 14 The proceeds associated with the disposition of this investment do not include accrued and unpaid dividends. 15 Subchapter S corporation; Treasury received a warrant to purchase additional subordinated debentures (unless the institution is a CDFI), which it exercised immediately. 16 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. 17 This institution participated in the expansion of CPP for small banks. 18 This institution received an additional investment through the expansion of CPP for small banks. 19 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. 20 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. 21 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. 22 As of the date of this report, this institution is in bankruptcy proceedings. 23 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. 24 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. 25 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. 26 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. 27 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. 28 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. 29 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. On 7/26/13, Treasury entered into a securities purchase agreement with Independent pursuant to which Treasury agreed to sell to Independent the MCP and the warrant issued by Independent, subject to the conditions specified in such agreement. On 8/30/13, Treasury completed the sale of the MCP and warrant to Independent pursuant to the terms of such agreement. 11 8,14,45 NC DE State YADKIN VALLEY FINANCIAL CORPORATION / YADKIN ELKIN FINANCIAL CORPORATION WILMINGTON City YADKIN VALLEY FINANCIAL CORPORATION / YADKIN ELKIN FINANCIAL CORPORATION WSFS FINANCIAL CORPORATION Footnote Institution Name CPP TRANSACTIONS DETAIL, AS OF 12/31/2016 (CONTINUED) 278 APPENDIX A I TRANSACTION DETAIL I JANUARY 27, 2017 3 Continued on next page 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 April 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 June 30, 2010 (or on completion of the sale). Completion of the sale under this authority occurred on May 26, 2010. On May 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 June 30, 2010 (or on completion of the sale). Completion of the sale under this authority occurred on June 30, 2010. On July 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 September 30, 2010 (or on completion of the sale). Completion of the sale under this authority occurred on September 30, 2010. On October 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 December 31, 2010 (or upon completion of the sale), which plan was terminated on December 6, 2010. All such sales were generally made at the market price. On December 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. 31 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. 32 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. 33 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. 3 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 10/07/2011, 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. 35 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. Following a reverse stock split effective 12/28/10, Treasury held 3,608,332 shares of Pacific Capital common stock. Effective 11/30/12, Pacific Capital merged with and into UnionBanCal Corporation and each outstanding share of common stock of the Company was converted into the right to receive $46.00 per share in cash, and Treasury received $165,983,272 in respect of its common stock and $393,121 in respect of its warrant. 36 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. 37 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. 38 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. 39 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. 40 On 2/18/11, 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. 41 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. 42 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. 43 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 Treasury-held 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 05/16/2011. 44 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. 45 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. 46 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. 47 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. 48 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. 49 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. 50 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. 51 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. 52 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. 53 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 08/12/2011. 54 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. 55 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. 56 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. 57 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. 58 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. 59 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. 60 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 01/01/2012. 61 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. 62 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. 63 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. 64 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. 65 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. 66 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. 67 As a result of the acquisition of Community Holding Company of Florida, Inc. (the acquired company) by Community Bancshares of Mississippi, Inc. (the acquiror), the preferred stock and exercised warrants issued by the acquired company on 2/6/2009 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 7/19/2012. 68 On 7/13/2012, Glasgow Savings Bank, Glasgow, MO, the banking subsidiary of Gregg Bancshares, Inc. , was closed by the Missouri Division of Finance, which appointed the Federal Deposit Insurance Corporation (FDIC) as receiver. 69 On 7/27/2012, Treasury entered into an agreement with Pinnacle Bank Holding Company, Inc. (“Pinnacle”) pursuant to which Treasury agreed to sell its CPP preferred stock back to Pinnacle at a discount subject to the satisfaction of the conditions specified in the agreement. 70 On 10/19/2012, GulfSouth Private Bank, Destin, Florida, was closed by the Florida Office of Financial Regulation, which appointed the Federal Deposit Insurance Corporation (FDIC) as receiver. 71 On 10/19/2012, Excel Bank, Sedalia, Missouri, the banking subsidiary of Investors Financial Corporation of Pettis County, Inc., was closed by the Missouri Division of Finance, which appointed the Federal Deposit Insurance Corporation (FDIC) as receiver. 72 On 10/25/2012, pursuant to the terms of the merger of First Community Bancshares, Inc. (“First Community”) and Equity Bancshares, Inc. (“Equity”), Treasury received a like amount of preferred stock and exercised warrants from Equity in exchange for Treasury’s original investment in First Community, plus accrued and unpaid dividends, pursuant to a placement agency agreement executed on 10/23/2012. 73 On 10/29/2012, First Place Financial Corp. filed for Chapter 11 protection in the U.S. Bankruptcy Court for the District of Delaware. 74 On 2/22/2013, Treasury completed the exchange of its Standard Bancshares, Inc. preferred stock for common stock, pursuant to an exchange agreement, dated as of 11/5/2012, with Standard Bancshares, Inc., and immediately sold the resulting Standard Bancshares, Inc. common stock, pursuant to securities purchase agreements, each dated as of 11/5/2012, with W Capital Partners II, L.P., Trident SBI Holdings, LLC, PEPI Capital, LP, LCB Investment, LLC, Cohesive Capital Partners, L.P., and Athena Select Private Investment Fund LLC. 75 On 11/2/2012, Citizens First National Bank, Princeton, IL, the banking subsidiary of Princeton National Bancorp, was closed by the Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation (FDIC) was named Receiver. 76 On 11/13/2012, Treasury entered into an agreement with Community Financial Shares, Inc. (“CFS”) pursuant to which Treasury agreed to sell its CPP preferred stock back to CFS at a discount subject to the satisfaction of the conditions specified in the agreement. 77 In connection with the merger of Fidelity Bancorp, Inc. (“Fidelity”) and WesBanco, Inc. (“WesBanco”) effective 01/01/2012, Treasury (i) sold to WesBanco all of the preferred stock that had been issued by Fidelity to Treasury for a purchase price of $7,000,000 plus accrued dividends and (ii) exchanged the Fidelity warrant held by Treasury for a like WesBanco warrant, pursuant to the terms of an agreement among Treasury and WesBanco entered into on 11/28/2012. 78 On 11/30/12, Western Reserve Bancorp, Inc. was acquired by an affiliate of Westfield Bancorp, Inc. Pursuant to the terms of the merger, each outstanding share of Series A and Series B preferred stock issued to Treasury was redeemed for the respective principal amount together with accrued and unpaid dividends thereon. 79 On 2/20/2013, Treasury sold its CPP preferred stock and warrant issued by First Sound Bank (“First Sound”) back to First Sound for an aggregate purchase price of $3,700,000, pursuant to the terms of the agreement between Treasury and First Sound entered into on 11/30/2012. 80 On 4/9/2013, Treasury sold its CPP preferred stock and warrant issued by PremierWest Bancorp (“PremierWest”) pursuant to an agreement with PremierWest and Starbuck Bancshares, Inc. (“Starbuck”) entered into on 12/11/2012. 81 In connection with the merger of Community Financial Corporation (“Community Financial”) and City Holding Company (“City Holding”) effective 1/09/13, Treasury (i) sold to City Holding all of the preferred stock that had been issued by Community Financial to Treasury for a purchase price of $12,643,000 plus accrued dividends and (ii) exchanged the Community Financial warrant held by Treasury for a like City Holding warrant, pursuant to the terms of an agreement among Treasury and City Holding entered into on 1/09/13. 82 On 1/29/2013, Treasury executed a placement agency agreement pursuant to which Treasury agreed to sell 9,950 shares of Coastal Banking Company, Inc. Preferred stock at $815.00 per share (less a placement agent fee) for net proceeds of $8,028,157.50. On 2/6/2013, the placement agent notified Coastal Banking Company, Inc. that, pursuant to the placement agency agreement, it was terminating the transaction and, therefore, Treasury did not receive any proceeds or pay any fees in connection with the transaction. CPP TRANSACTIONS DETAIL, AS OF 12/31/2016 (CONTINUED) TRANSACTION DETAIL I APPENDIX A I JANUARY 27, 2017 279 137 136 135 134 133 132 131 130 129 128 127 126 125 124 123 122 121 120 119 118 117 116 115 114 113 112 111 110 109 108 107 106 105 104 103 102 101 100 99 98 97 96 95 94 93 92 91 90 89 88 87 86 85 84 83 On 2/15/2013, Treasury sold its CPP preferred stock and warrant issued by BancTrust Financial Group, Inc. (“BancTrust”) pursuant to an agreement with BancTrust and Trustmark Corporation (“Trustmark”) entered into on 02/11/2013. On 8/14/2013, Treasury sold its CPP preferred stock issued by Florida Bank Group, Inc. (“FBG”) back to FBG for an aggregate purchase price of $8,000,000, pursuant to the terms of the agreement between Treasury and FBG entered into on 2/12/13. On 2/15/2013, pursuant to the terms of the merger of Pacific International Bancorp, Inc. (“Pacific International”) with BBCN Bancorp, Inc. (“BBCN”), Treasury received $7,474,619.97 (representing the par amount together with accrued and unpaid dividends thereon) in respect of the preferred stock that had been issued to Treasury by Pacific International. Treasury exchanged its Pacific International warrant for an equivalent warrant issued by BBCN. On 4/12/2013, Treasury completed (i) the sale of its CPP preferred in Citizens Republic Bancorp, Inc. (Citizens Republic) to FirstMerit Corporation (FirstMerit) and (ii) the exchange of its warrant in Citizens Republic for a warrant issued by FirstMerit, pursuant to a securities purchase agreement, dated as of 2/19/13, among Treasury, FirstMerit and Citizens Republic. On 4/11/2013, Treasury completed the exchange of its First Security Group, Inc. (FSGI) preferred stock for common stock, pursuant to an exchange agreement, dated as of 2/25/2013, between Treasury and FSGI, and sold the resulting FSGI common stock, pursuant to securities purchase agreements, each dated as of 4/9/2013, between Treasury and the purchasers party thereto. On 3/19/2013, Treasury exercised its warrant on a cashless basis and received (i) 186,589 shares of common stock and (ii) $71.62 in cash in lieu of fractional shares. Treasury sold such shares of common stock on 3/19/2013. As a result of the acquisition of ECB Bancorp, Inc. by Crescent Financial Bancshares, Inc., the preferred stock and warrant issued by ECB Bancorp, Inc. were exchanged for a like amount of securities of Crescent Financial Bancshares, Inc., pursuant to the terms of an agreement among Treasury, ECB Bancorp, Inc., and Crescent Financial Bancshares, Inc. entered into on 4/1/2013. As a result of the merger of Annapolis Bancorp, Inc. into F.N.B. Corporation, the warrant issued by Annapolis Bancorp, Inc. was exchanged for a like warrant issued by F.N.B. Corporation, pursuant to the terms of an agreement among Treasury, Annapolis Bancorp, Inc., and F.N.B. Corporation entered into on 4/6/2013. On 04/05/2013, Gold Canyon Bank, Gold Canyon, Arizona was closed by the Arizona Department of Financial Institutions, and the Federal Deposit Insurance Corporation (FDIC) was named Receiver. On 04/09/2013, Indiana Bank Corp. filed for Chapter 11 protection in the U.S. Bankruptcy Court for the Southern District of Indiana. On 7/17/13, Treasury entered into a securities purchase agreement with Central Virginia Bankshares, Inc. (CVB) and C&F Financial Corporation (C&F) pursuant to which Treasury agreed to sell to C&F the CPP preferred stock and warrant issued by CVB, subject to the conditions specified in such agreement. The sale was completed on 10/01/2013. On 8/12/2013, Anchor BanCorp Wisconsin Inc. ( “Anchor”) filed a voluntary petition for Chapter 11 protection in the U.S. Bankruptcy Court for the Western District of Wisconsin to implement a “pre-packaged” Plan of Reorganization in order to facilitate the restructuring of Anchor. On 9/27/ 2013, the Plan of Reorganization became effective in accordance with its terms, pursuant to which (i) Treasury’s preferred stock was exchanged for 60,000,000 shares of common stock (the “Common Stock”) and (ii) Treasury’s warrant was cancelled. On 9/27/2013, Treasury sold the Common Stock to purchasers pursuant to securities purchase agreements entered into on 9/19/2013. On 7/5/2013, Rogers Bancshares, Inc. filed for Chapter 11 protection in the U.S. Bankruptcy Court for the Eastern District of Arkansas. On 8/22/2013, Treasury exchanged its preferred stock in Broadway Financial Corporation for 10,146 shares of common stock equivalent representing (i) 50% of the liquidation preference of the preferred stock, plus (ii) 100% of previously accrued and unpaid dividends on the preferred stock ($2,646,000). The common stock equivalent will be converted to common stock upon the receipt of certain shareholder approvals. This institution has entered into bankruptcy or receivership. For a full list of institutions that have entered bankruptcy or receivership and Treasury’s remaining investments, reference appendices B and C in the section titled “Capital Purchase Program Institutions” in the most recent report to congress found on Treasury’s website: http://www.treasury.gov/initiatives/financial-stability/reports/Pages/Monthly-Report-to-Congress.aspx. On 10/30/2013, Treasury entered into an agreement with Monarch Community Bancorp, Inc. (Monarch) to exchange Treasury’s CPP warrant and $6,785,000 of preferred stock for common stock. The exchange was subject to the fulfillment by Monarch of certain conditions, including the satisfactory completion of a capital plan. On 11/15/2013, the exchange of the CPP warrant and preferred stock for common stock was completed and Treasury sold such common stock to purchasers pursuant to securities purchase agreements dated as of 11/15/2013. On 12/5/2013, Treasury’s 10,146 shares of common stock equivalent in Broadway Financial converted to 10,146,000 shares of common stock. On 12/13/2013, Texas Community Bank, National Association, The Woodlands, Texas, the banking subsidiary of TCB Holding Company, was closed by the Office of the Comptroller of the Currency, which appointed the Federal Deposit Insurance Corporation (FDIC) as receiver. As a result of a reincorporation merger of Community Bankers Trust Corporation, a Delaware corporation (CBTC Delaware) into Community Bankers Trust Corporation, a Virginia corporation (CBTC Virginia), the outstanding preferred stock and warrant issued by CBTC Delaware were exchanged for a like amount of securities issued by CBTC Virginia, pursuant to the terms of an agreement among Treasury, CBTC Delaware and CBTC Virginia entered into on 1/1/14. On 10/15/13, Treasury entered into a securities purchase agreement with First-Citizens Bank & Trust Company (FCBTC) and 1st Financial Services Corporation (FFSC) pursuant to which Treasury agreed to sell to FCBTC the CPP preferred stock and warrant issued by FFSC, subject to the conditions specified in such agreement. The sale was completed on 12/31/2013. On 1/31/2014, Syringa Bank, Boise, Idaho, the banking subsidiary of Syringa Bancorp, was closed by the Idaho Department of Finance, which appointed the Federal Deposit Insurance Corporation (FDIC) as receiver. On 4/1/2014, pursuant to the terms of the merger of Alaska Pacific Bancshares, Inc. with Northrim Bancorp, Inc., Treasury received $2,370,908.26 for the warrants that had been issued to Treasury by Alaska Pacific Bancshares, Inc. On 4/18/2014, Treasury entered into an agreement with Bank of the Carolinas Corporation (“BCAR”) pursuant to which Treasury agreed to sell its CPP preferred stock and warrant back to BCAR at a discount subject to the satisfaction of the conditions specified in the agreement. The sale was completed on 7/16/2014. On 4/24/2014, Treasury sold all of its preferred stock issued by Bankers’ Bank of the West Bancorp, Inc. (BBW) to private investors for total proceeds of $13.5million, pursuant to securities purchase agreements dated as of April 21, 2014. BBW paid all accrued and unpaid dividends on the preferred stock as of April 24, 2014. On 4/25/2014, Treasury entered into a securities purchase agreement with Provident Community Bankshares, Inc. (PCBS) and Park Sterling Corporation (Park Sterling) pursuant to which Treasury agreed to sell to Park Sterling the CPP preferred stock and warrant issued by PCBS, subject to the conditions specified in such agreement. The sale was completed on 4/30/2014. On 4/24/2014, Idaho Bancorp filed for Chapter 11 protection in the U.S. Bankruptcy Court for the District of Idaho. On 11/25/2014, the bankruptcy court for the District of Idaho confirmed Idaho Bancorp’s amended plan of reorganization. On 8/5/2015 and 9/29/2015, UST received net distributions of $427,844.29 and $3,522.87, respectively, from Idaho Bancorp (after payment to the Department of Justice of a 3% litigation fee). On 4/30/2014, Treasury completed the exchange of its Northern States Financial Corporation preferred stock for common stock, pursuant to an exchange agreement, dated as of 4/29/2014, with Northern States Financial Corporation, and immediately sold the resulting Northern States Financial Corporation common stock, pursuant to securities purchase agreements, each dated as of 4/29/14, with Blue Pine Financial Opportunities Fund II, LP, EJF Sidecar Fund, Series LLC, Endeavour Regional Bank Opportunities Fund L.P., Endeavour Regional Bank Opportunities Fund II L.P., Hot Creek Investors, L.P.,JCSD Partners, LP, and PRB Investors, LP. On 5/23/2014 Treasury completed the sale of its CommunityOne Bancorp common stock in an underwritten public offering. On 5/30/2014, Treasury entered into a securities purchase agreement with Highlands Independent Bancshares, Inc. (“Highlands”) and HCBF Holding Company, Inc. (“HCBF”) pursuant to which Treasury agreed to sell to HCBF the CPP preferred stock issued by Highlands, subject to the conditions specified in such agreement. The sale was completed on 10/24/2014. On 6/30/2014, BCB Holding Company, Inc. (the “Institution”) repurchased their preferred and warrant preferred shares from Treasury and funds were wired from the Institution to the Bank of New York Mellon (BNYM) for the benefit of Treasury. The repurchase was finalized after the close of business on 6/30/14 and the funds were subsequently transferred from BNYM to Treasury on 7/1/2014. On 8/28/2014, Treasury entered into an agreement with Central Bancorp, Inc. and Hanmi Financial Corporation, in connection with a merger, pursuant to which Treasury agreed to sell its Central Bancorp, Inc. CPP preferred stock (including warrant preferred stock) to Hanmi Financial Corporation for (i) $23,625,000, plus (ii) all accrued and unpaid dividends, subject to the satisfaction of the conditions specified in the agreement. The sale was completed on 8/29/2014. On 10/17/2014, Treasury completed the exchange of its Regent Bancorp, Inc. preferred stock and warrant-preferred stock for common stock, pursuant to an exchange agreement, dated as of 10/16/2014, with Regent Bancorp, Inc., and immediately sold the resulting Regent Bancorp, Inc. common stock to purchasers pursuant to securities purchase agreements dated as of 10/16/2014. On 10/30/2014, Treasury entered into an agreement with Columbia Banking System, Inc. (Columbia) pursuant to which Treasury agreed to sell its warrant in Intermountain Community Bancorp to Columbia subject to the satisfaction of the conditions specified in the agreement. The sale was completed on 10/31/2014. The subsidiary bank of Rising Sun Bancorp, NBRS Financial, was closed by the Maryland Office of the Commissioner of Financial Regulation, and the FDIC was named Receiver on Friday, 10/17/2014. The subsidiary bank of Western Community Bancshares, Inc., Frontier Bank, was closed by the Office of the Comptroller of the Currency, and the FDIC was named Receiver on Friday, 11/7/2014. On 9/8/2014, Treasury gave Credit Suisse Securities (USA) LLC discretionary authority, as its sales agent, to sell subject to certain parameters shares of common stock from time to time during the period ending on 12/7/2014. Completion of the sale under this authority occurred on December 5, 2014. On 12/10/2014, Treasury sold all of its preferred stock issued by NCAL Bancorp to purchasers for total proceeds of $3.9 million, pursuant to a securities purchase agreement dated as of November 25, 2014. As a result of the merger of Farmers & Merchants Bancshares, Inc. into Allegiance Bancshares, Inc., the outstanding preferred stock and warrant preferred stock issued by Farmers & Merchants Bancshares, Inc. was exchanged for a like amount of securities issued by Allegiance Bancshares, Inc., pursuant to the terms of an agreement among Treasury, Farmers & Merchants Bancshares, Inc. and Allegiance Bancshares, Inc., entered into on 1/1/2015. On 12/11/2014, Treasury gave Credit Suisse Securities (USA) LLC discretionary authority, as its sales agent, to sell subject to certain parameters shares of common stock from time to time during the period ending on 3/8/2015. Completion of the sale under this authority occurred on 3/6/2015. On 03/17/2015, Treasury sold all of its preferred stock issued by U.S. Century Bank to purchasers for total proceeds of $12.3 million, pursuant to a securities purchase agreement dated as of March 17, 2015. On 7/15/2015, Treasury entered into an agreement with Suburban Illinois Bancorp, Inc. (Suburban), pursuant to which Treasury agreed to sell its CPP senior subordinated securities to Suburban for (i) $15,750,000, plus (ii) all accrued and unpaid dividends through 4/1/2015 subject to the conditions specified in such agreement. This transaction was in conjunction with a merger between Suburban and Wintrust Financial Corporation. The sale was completed on 7/16/2015. On 8/4/2015, Treasury entered into an agreement with City National Bancshares Corporation (the “Company”) pursuant to which Treasury agreed to sell its CPP preferred stock back to the Company at a discount subject to the satisfaction of the conditions specified in the agreement. The sale was completed on 8/7/2015. 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. On 8/27/2015, Treasury entered into an agreement with Patapsco Bancorp, Inc. and Howard Bancorp, Inc., in connection with a merger pursuant to which Treasury agreed to sell its Patapsco Bancorp, Inc. CPP preferred stock (including warrant preferred stock) to Howard Bancorp, Inc. for (i) $6,300,000, plus (ii) all accrued and unpaid dividends, subject to the satisfaction of the conditions specified in the agreement. The sale was completed on 8/28/2015. On 9/18/2015, Treasury entered into an agreement with Goldwater Bank, N.A. and Kent Wiechert, pursuant to which Treasury agreed to sell all of its CPP preferred stock issued by Goldwater Bank, N.A.to Wiechert for total proceeds of $1,348,000 subject to the satisfaction of conditions specified in the agreement. The sale was completed on 9/21/2015. On 10/2/2015, Treasury completed the exchange of its Capital Commerce Bancorp, Inc. preferred stock and warrant-preferred stock for common stock pursuant to an exchange agreement of the same date with Capital Commerce Bancorp, Inc. The consideration for that exchange included accrued and unpaid dividends through June 30, 2015. As part of the exchange transaction, Treasury immediately sold the resulting Capital Commerce Bancorp, Inc. common stock to purchasers pursuant to securities purchase agreements, each dated as of 10/2/2015, with the purchaser parties thereto. On 11/13/2015, Treasury received $3.88 million from the Department of Justice as a payment related to the United States’ $4.00 million False Claims Act action against the estate and trusts of the late Layton P. Stuart, former owner, president, and Chief Executive Officer of One Financial Corporation. On 12/23/2015, Treasury completed the exchange of its CalWest Bancorp preferred stock and warrant-preferred stock for common stock pursuant to an exchange agreement of the same date with CalWest Bancorp. As part of that transaction, Treasury immediately sold the resulting CalWest Bancorp common stock to purchasers pursuant to securities purchase agreements, each dated as of 12/23/2015, with the purchaser parties thereto. On 2/29/2016, Treasury entered into an agreement with HCSB (the “Company”) pursuant to which Treasury agreed to sell its CPP preferred stock back to the Company at a discount subject to the satisfaction of the conditions specified in the agreement. The sale was completed on 4/11/2016. Sonoma Valley Bancorp was liquidated and dissolved pursuant to the provision of the California Corporations Code. As part of that liquidation and dissolution, UST received a distribution of $150,000 from Sonoma Valley Bancorp on 6/15/2016. On 6/30/2016, Treasury completed the exchange of its Liberty Shares, Inc. preferred stock and warrant-preferred stock for common stock pursuant to an exchange agreement of the same date with Liberty Shares, Inc. As part of that transaction, Treasury immediately sold the resulting Liberty Shares, Inc. common stock to purchasers pursuant to securities purchase agreements, each dated as of 6/30/2016, with the purchaser parties thereto. On 7/1/2016, Treasury completed the sale to United Community Banks, Inc. (UCBI) of all of its CPP preferred stock and associated warrants issued by Tidelands Bancshares, Inc. (Tidelands) to UCBI for total proceeds of $8,984,227 subject to the satisfaction of conditions specified in the agreement. This transaction was in conjunction with a merger between Tidelands and UCBI. On 6/28/2016, the United States completed a settlement of several lawsuits related to Treasury’s investment in One Financial Corporation (OFC). As a result of that settlement, it received 344,227 shares of OFC common stock on 6/23/2016. On 12/21/2016, Treasury entered into an agreement with Broadway Financial Corporation, First Republic Bank, and Broadway Federal Bank, f.s.b Employee Ownership Trust, pursuant to which Treasury agreed to sell part of its CPP common stock to the three entities for total proceeds of $7,477,547.40 subject to the satisfaction of conditions specified in the agreement. The transaction was completed on December 22, 2016. On 12/28/2016, Treasury entered into an agreement with Allied First Bancorp (the “Company”) pursuant to which Treasury agreed to sell its CPP preferred stock back to the Company at a discount subject to the satisfaction of the conditions specified in the agreement. The sale was completed on 12/28/2016. CPP TRANSACTIONS DETAIL, AS OF 12/31/2016 (CONTINUED) 280 APPENDIX A I TRANSACTION DETAIL I JANUARY 27, 2017 Buffalo Buffalo Cooperative Federal Credit Union 21 3,4 3,12 Hagatna Rantoul Rantoul Berkeley Community Plus Federal Credit Union Community Plus Federal Credit Union Cooperative Center Federal Credit Union Brandon Community Bancshares of Mississippi, Inc. Oakland MS Brandon Community Bancshares of Mississippi, Inc. Community First Guam Federal Credit Union GA Citizens Bancshares Corporation Atlanta Community Bank of the Bay GA CA IL IL GU CA MS GA Citizens Bancshares Corporation Atlanta DC DC NY LA LA CA CA NY NY NY WI WI TX TX NY NY NJ NJ MS MS MS MS GA GA GA Citizens Bancshares Corporation Atlanta Washington CFBanc Corporation 3,5,33 Washington CFBanc Corporation 20 New York Springhill Carter Federal Credit Union Carver Bancorp, Inc Springhill Carter Federal Credit Union Biggs Brooklyn Brooklyn Cooperative Federal Credit Union Biggs Brooklyn Brooklyn Cooperative Federal Credit Union Butte Federal Credit Union Milwaukee Butte Federal Credit Union Milwaukee Brewery Credit Union Del Rio Brewery Credit Union Del Rio Border Federal Credit Union Bronx Border Federal Credit Union Bronx Bethex Federal Credit Union Palisades Park Bethex Federal Credit Union Palisades Park BankAsiana Ridgeland BancPlus Corporation BankAsiana Ridgeland BancPlus Corporation Okolona Bancorp of Okolona, Inc. Bainbridge Bainbridge Bancshares, Inc. Okolona Bainbridge Bancorp of Okolona, Inc. Bainbridge Bainbridge Bancshares, Inc. WY Bainbridge Bancshares, Inc. WY IL American Bancorp of Illinois, Inc. Oak Brook Atlantic City Federal Credit Union Lander NY Atlantic City Federal Credit Union Lander NY Alternatives Federal Credit Union Ithaca State Alternatives Federal Credit Union Ithaca City 3,6 8 8,10 27 8 8 8 8,11 3,4,14 8 8 8 26 Footnote Institution Name 9/24/2010 12/20/2016 9/29/2010 9/24/2010 9/29/2010 10/11/2016 9/29/2010 12/30/2016 9/17/2010 8/13/2010 12/20/2016 9/17/2010 8/27/2010 2/6/2013 9/29/2010 12/31/2014 9/24/2010 9/24/2010 12/27/2016 9/30/2010 10/3/2012 9/24/2010 10/15/2014 9/29/2010 11/18/2015 9/29/2010 10/1/2013 9/29/2010 10/18/2016 9/29/2010 3/13/2013 9/29/2010 1/7/2015 9/10/2014 9/24/2010 9/26/2012 9/24/2010 9/17/2010 12/27/2016 9/24/2010 Date $1,747,000 $54,600,000 $7,462,000 $18,980,000 $50,400,000 Exchange From CPP $2,799,000 $450,000 $2,650,000 $2,313,000 $4,379,000 $5,781,000 $6,300,000 $1,000,000 $145,000 $300,000 $1,096,000 $3,260,000 $502,000 $5,250,000 $30,514,000 $3,297,000 $3,372,000 $2,500,000 $5,457,000 $2,234,000 Original Investment Amount CDCI PROGRAM TRANSACTION DETAIL, AS OF 12/31/2016 TABLE A.2 $2,799,000 $0 $2,650,000 $4,060,000 $0 $7,462,000 $0 $18,980,000 $3,800,000 $0 $145,000 $0 $0 $0 $0 $0 $0 $0 $0 $0 $5,457,000 $0 Full investment outstanding Full investment outstanding Full investment outstanding $343,811 Full investment outstanding $471,025 Sold, in full Full investment $325,508 outstanding Full investment $477,276 outstanding $57,366,400 Sold, in full $5,711,166 Sold, in part $6,273,349 Sold, in full $446,512 $3,083,350 Redeemed, in part $1,085,389 Redeemed, in Full $17,811 $317,450 Sold, in full $1,140,388 Redeemed, in Full $3,523,698 Redeemed, in Full $553,567 Redeemed, in Full $5,565,583 Redeemed, in Full $85,045,109 Sold, in full $3,547,975 Redeemed, in Full $3,645,637 Redeemed, in Full $2,600,278 Redeemed, in Full $1,042,257 $2,334,902 Sold, in full Outstanding Investment Investment Total Cash Back2 Status* $415,000 $50,778,000 $4,227,049 $5,549,760 $2,500,000 $1,000,000 $280,000 $1,096,000 $3,260,000 $502,000 $5,250,000 $75,250,020 $3,297,000 $1,000,000 $2,372,000 $2,500,000 $2,055,280 Amount (Fee) 450,000 54,600 4,379 5,781 2,500,000 1,000,000 300,000 1,096,000 3,260,000 502,000 5,250 80,914 3,297,000 1,000 2,372 2,500,000 2,234,000 Shares Capital Repayment / Disposition / Auction $0.92 $930.00 $965.30 $960.00 $1.00 $1.00 $0.93 $1.00 $1.00 $1.00 $1,000.00 $930.00 $1.00 $1,000.00 $1,000.00 $1.00 $0.92 Avg. Price ($35,000.00) ($3,822,000.00) ($151,951.00) ($231,240.00) ($20,000.00) ($5,663,980.00) ($178,720.00) (Realized Loss) / (Write-off) Gain $343,811 $55,150 $325,508 $477,276 $6,588,400 $1,473,169 $712,348 $446,507 $583,350 $85,389 $17,811 $36,750 $44,388 $263,698 $51,567 $315,583 $9,795,089 $250,975 $273,637 $100,278 $1,042,257 $274,410 Dividends Paid to Date 1 Continued on next page $20,300 Number Amount of Missed of Missed Dividends Dividend Dividends and Interest Report TRANSACTION DETAIL I APPENDIX A I JANUARY 27, 2017 281 Fairfax Fairfax County Federal Credit Union Missoula Missoula Rochester Rochester Gateway Community Federal Credit Union Gateway Community Federal Credit Union Genesee Co-op Federal Credit Union Genesee Co-op Federal Credit Union Hilo Independent Employers Group Federal Credit Union 8 Kilmichael Hilo Independent Employers Group Federal Credit Union Kilmichael Bancorp, Inc. Washington IBW Financial Corporation 8 Washington IBW Financial Corporation Jackson Hope Federal Credit Union 3,35 Pittsburgh Hill District Federal Credit Union Chicago Belzoni Guaranty Capital Corporation IBC Bancorp, Inc. Belzoni Guaranty Capital Corporation Kinston Roanoke Freedom First Federal Credit Union Greater Kinston Credit Union Roanoke Freedom First Federal Credit Union Kinston Vernon First Vernon Bancshares, Inc. Greater Kinston Credit Union Vernon First Vernon Bancshares, Inc. Kosciusko First M&F Corporation Charlotte First Legacy Community Credit Union Kosciusko Charlotte First Legacy Community Credit Union First M&F Corporation Hanover Park First Eagle Bancshares, Inc. 3,4 3,8 8 28 8 8 3,17 3,8 8 Hanover Park First Eagle Bancshares, Inc. Cerritos First Choice Bank 3,8 Cerritos First Choice Bank 3,8 New York Fidelis Federal Credit Union First American International Corp. Brooklyn New York Fidelis Federal Credit Union 3 8 VA CA MS HI HI DC DC IL MS PA MS MS NC NC NY NY MT MT VA VA AL AL MS MS NC NC IL IL CA CA NY NY NY CA Los Angeles Episcopal Community Federal Credit Union CT Faith Based Federal Credit Union Oceanside Bridgeport East End Baptist Tabernacle Federal Credit Union DC DC CA Washington D.C. Federal Credit Union State Faith Based Federal Credit Union Oceanside Washington D.C. Federal Credit Union 34 8 City Footnote Institution Name 9/3/2010 11/18/2015 9/29/2010 12/30/2016 9/3/2010 9/10/2010 9/17/2010 9/29/2010 12/21/2016 7/30/2010 4/10/2012 9/29/2010 12/27/2016 9/17/2010 10/17/2012 9/24/2010 6/12/2013 9/29/2010 11/29/2016 9/29/2010 8/30/2013 9/29/2010 4/2/2014 9/29/2010 3/25/2016 9/17/2010 5/1/2013 9/24/2010 8/13/2010 10/14/2015 9/29/2010 8/19/2015 9/29/2010 9/24/2010 9/29/2010 9/29/2010 12/30/2016 9/29/2010 Date $6,000,000 $4,205,000 $14,000,000 $6,245,000 $30,000,000 $7,875,000 $5,146,000 $17,000,000 Exchange From CPP $3,154,000 $698,000 $3,881,000 $4,520,000 $100,000 $350,000 $300,000 $1,657,000 $9,278,000 $1,000,000 $14,000 $30,000 $8,044,000 $100,000 $7,000 $1,522,000 $0 $0 $0 $8,086,000 $4,520,000 $100,000 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $17,000,000 $0 $0 $8,044,000 $100,000 $7,000 $500,000 Full investment outstanding Full investment outstanding $3,756,668 Redeemed, in Full $769,701 Redeemed, in Full $698,000 698,000 6,000 $1.00 $935.00 ($390,000.00) $602,668 $71,701 $744,000 $1,549,255 $2,730,583 $10,714 $36,967 $68,397 $501,527 $783,123 $1,751,667 $70,167 $1,348,113 $267,878 $2,142,976 $1,412 $2,933 $988,071 $12,256 $858 $186,530 Dividends Paid to Date Full investment outstanding $5,610,000 ($21,000.00) ($499,600.00) ($51,100.00) Gain $556,964 $1.00 $1.00 $0.93 $1.00 $1.00 $920.00 $1,000.00 $1.00 $1.00 $1,000.00 $1.00 $1.00 $0.95 (Realized Loss) / (Write-off) Full investment outstanding 14,000,000 350,000 300,000 1,657,000 9,278,000 6,245 30,000 1,000,000 7,875,000 5,146 14,000 30,000 1,022,000 Avg. Price $12,256 $14,000,000 $350,000 $279,000 $1,657,000 $9,278,000 $5,745,400 $30,000,000 $1,000,000 $7,875,000 $5,146,000 $14,000 $30,000 $970,900 Shares Continued on next page Number Amount of Missed of Missed Dividends Dividend Dividend and Interest Report Full investment outstanding $6,369,000 Sold, in full $1,549,255 $556,964 $12,256 $16,773,983 Redeemed, in Full $360,714 Redeemed, in Full $316,667 Sold, in full $1,725,397 Redeemed, in Full $9,779,527 Redeemed, in Full $6,528,523 Sold, in full $31,751,667 Redeemed, in Full $1,070,167 Redeemed, in Full $9,223,113 Redeemed, in Full $5,413,878 Redeemed, in Full $2,142,976 $15,412 Redeemed, in Full $32,933 Redeemed, in Full Full investment $988,071 outstanding Full investment $12,256 outstanding $858 $1,159,985 Sold, in part Amount (Fee) Capital Repayment / Disposition / Auction Investment Outstanding Investment Total Cash Back2 Status* (CONTINUED) Original Investment Amount CDCI PROGRAM TRANSACTION DETAIL, AS OF 12/31/2016 282 APPENDIX A I TRANSACTION DETAIL I JANUARY 27, 2017 3,4,15 3,8 8,16 3,8 8 3,7 30 3,24 3,5 3,23 36 3,4,22 8 3,8 San Francisco Burlington Northeast Community Federal Credit Union Opportunities Credit Union Aiken Security Federal Corporation Batesville Security Capital Corporation Aiken Batesville Security Federal Corporation Batesville Santa Cruz Santa Cruz Community Credit Union Security Capital Corporation Somerset Renaissance Community Development Credit Union Security Capital Corporation Tucson Pyramid Federal Credit Union Batesville Tucson Pyramid Federal Credit Union Security Capital Corporation Tucson Pyramid Federal Credit Union Many PSB Financial Corporation HI SC SC MS MS MS MS CA NJ AZ AZ AZ LA LA Prince Kuhio Federal Credit Union Honolulu / Hawaii Federal Credit Union Many HI Prince Kuhio Federal Credit Union Honolulu / Hawaii Federal Credit Union PSB Financial Corporation IL Wilmette IL Wilmette Premier Bancorp, Inc. AL Premier Bancorp, Inc. AL Phenix Pride Federal Credit Union Phenix City IL IL VT CA IL NY CA CA NC Phenix Pride Federal Credit Union Phenix City Chicago Chicago North Side Community Federal Credit Union PGB Holdings, Inc. New York Neighborhood Trust Federal Credit Union Chicago Sun Valley Mission Valley Bancorp PGB Holdings, Inc. Sun Valley Mission Valley Bancorp Durham M&F Bancorp, Inc. NC NY Durham M&F Bancorp, Inc. NY Lower East Side People’s Federal New York Credit Union LA Lower East Side People’s Federal New York Credit Union New Orleans TX Liberty County Teachers Federal Liberty Credit Union Liberty Financial Services, Inc. TX Liberty County Teachers Federal Liberty Credit Union LA TX Liberty County Teachers Federal Liberty Credit Union New Orleans TX Liberty County Teachers Federal Liberty Credit Union Liberty Financial Services, Inc. MS Oxford Lafayette Bancorp, Inc. MS MS State Oxford Kilmichael City Lafayette Bancorp, Inc. Kilmichael Bancorp, Inc. Footnote Institution Name 10/31/2016 9/29/2010 5/27/2016 3/23/2016 9/9/2015 9/29/2010 9/24/2010 9/29/2010 11/22/2016 3/9/2016 9/24/2010 12/28/2012 9/29/2010 9/9/2015 9/24/2010 1/29/2013 8/13/2010 12/27/2016 9/24/2010 12/20/2016 8/13/2010 9/29/2010 9/24/2010 9/29/2010 9/24/2010 9/24/2010 8/20/2010 12/20/2016 8/20/2010 12/30/2016 9/24/2010 12/20/2016 9/24/2010 12/16/2015 12/31/2014 4/2/2014 9/24/2010 1/27/2016 9/29/2010 11/2/2016 Date $18,000,000 $17,910,000 $9,734,000 $6,784,000 $3,000,000 $5,500,000 $11,735,000 $5,645,000 $4,551,000 Exchange From CPP $4,000,000 $2,828,000 $31,000 $2,500,000 $273,000 $153,000 $1,091,000 $350,000 $325,000 $283,000 $4,836,000 $898,000 $5,689,000 $435,000 $0 $0 $2,828,000 $31,000 $0 $0 $0 $0 $0 $0 $1,091,000 $350,000 $325,000 $283,000 $10,336,000 $0 $0 $0 $174,000 $0 Full investment outstanding Full investment outstanding ($60,000.00) ($2,347,000.00) ($70,881.78) ($742,377.00) Gain $39,831 $34,763 $1,279,994 $1,463,615 $146,475 $1,392,193 $44,027 $484,934 Dividends Paid to Date Full investment outstanding $24,019,111 Sold, in full $19,794,560 Redeemed, in Full Full investment $347,373 outstanding $3,799 $2,716,972 Sold, in full $10,171,489 Redeemed, in Full $300,073 Redeemed, in Full $79,900 Sold, in full $161,151 Sold, in full $3,327,125 Sold, in full $21,340,000 $5,660,000 $3,000,000 $9,250,000 $930,000 $1,500,000 $9,734,000 $273,000 $79,900 $142,000 22,000 5,660 3,000 9,250 1,000,000 1,500,000 9,734 273,000 6,784,000 153,000 $970.00 $1,000.00 $1,000.00 $1,000.00 $0.93 $1.00 $1,000.00 $1.00 $0.01 $0.93 ($660,000.00) ($70,000.00) ($6,704,100.00) ($11,000.00) $2,679,111 $1,884,560 $347,373 $3,799 $286,972 $437,489 $27,073 - $18,794 $381,292 $133,708 $980.00 $800.00 $0.92 $934.50 $1.00 $1.00 $1.00 $1,000.00 $1.00 (Realized Loss) / (Write-off) $42,992 3,000 11,735 898,000 11,334 87,000 87,000 87,000 4,551 3,154,000 Avg. Price Full investment $133,708 outstanding $2,940,000 $9,388,000 $827,118.22 $10,591,623 $87,000 $87,000 $87,000 $4,551,000 $3,154,000 Shares 6 Continued on next page $316,624 Number Amount of Missed of Missed Dividends Dividend Dividend and Interest Report Full investment $42,992 outstanding Full investment $39,831 outstanding $34,763 $1,279,994 $10,874,433 Sold, in full $939,668 Sold, in full $12,005,854 Sold, in full $305,027 Redeemed, in part $5,035,934 Redeemed, in Full Amount (Fee) Capital Repayment / Disposition / Auction Outstanding Investment Investment Total Cash Back2 Status* (CONTINUED) Original Investment Amount CDCI PROGRAM TRANSACTION DETAIL, AS OF 12/31/2016 TRANSACTION DETAIL I APPENDIX A I JANUARY 27, 2017 283 8 8,32 8 3,4,8 8 3,8 9 3 29 8 3,4,19 3,13 8 25 Atmore Atmore United Bancorporation of Alabama, Inc. AL AL NY Christiansburg Virginia Community Capital, Inc. IN Vigo County Federal Credit Union Terre Haute VA VA IN Vigo County Federal Credit Union Terre Haute Christiansburg IN Virginia Community Capital, Inc. IN LA LA Vigo County Federal Credit Union Terre Haute New Orleans MN MN Vigo County Federal Credit Union Terre Haute New Orleans UNO Federal Credit Union St. Paul University Financial Corp, Inc. UNO Federal Credit Union St. Paul University Financial Corp, Inc. NY New York United Bancorporation of Alabama, Inc. NY UNITEHERE Federal Credit Union (Workers United Federal Credit New York Union) New York Union Settlement Federal Credit Union IN NY Fort Wayne Union Settlement Federal Credit Union LA TN AK WA WA MS MS MS MS MS MS TX TX NY NY AR AR LA LA State UNITEHERE Federal Credit Union (Workers United Federal Credit New York Union) New Orleans Ketchikan Tongass Federal Credit Union Union Baptist Church Federal Credit Union Olympia Thurston Union of Low-Income People (TULIP) Cooperative Credit Union / Harborstone Credit Union Memphis Olympia Thurston Union of Low-Income People (TULIP) Cooperative Credit Union / Harborstone Credit Union Tulane-Loyola Federal Credit Union Bay Springs Tri-State Bank of Memphis Bay Springs The Magnolia State Corporation Hattiesburg The Magnolia State Corporation Hattiesburg The First Bancshares, Inc. Greenwood State Capital Corporation The First Bancshares, Inc. Greenwood State Capital Corporation San Antonio Lakewood Southern Chautauqua Federal Credit Union Southside Credit Union Lakewood Southern Chautauqua Federal Credit Union San Antonio Arkadelphia Southside Credit Union Arkadelphia Southern Bancorp, Inc. Shreveport Shreveport Federal Credit Union Southern Bancorp, Inc. Shreveport Shreveport Federal Credit Union 31 3,4,18 City Footnote Institution Name 6/29/2016 9/24/2010 12/27/2016 12/23/2015 2/25/2015 9/29/2010 9/4/2013 9/24/2010 11/28/2012 7/30/2010 3/20/2013 9/29/2010 11/16/2016 9/3/2010 12/30/2016 9/29/2010 9/24/2010 9/24/2010 8/13/2010 9/24/2010 12/27/2016 9/24/2010 12/17/2014 9/29/2010 12/6/2016 9/29/2010 10/11/2016 9/29/2010 10/30/2013 9/29/2010 12/20/2016 9/29/2010 11/29/2016 8/6/2010 12/27/2016 9/29/2010 Date $363,290,000 $11,926,000 $10,300,000 $2,795,000 $5,000,000 $15,750,000 $11,000,000 Exchange From CPP $206,783,000 $1,915,000 $1,229,000 $743,000 $10,189,000 $57,000 $295,000 $10,000 $424,000 $1,600,000 $75,000 $7,922,000 $12,123,000 $1,100,000 $1,709,000 $22,800,000 $2,646,000 $108,281,450 $0 $102,450 $0 $0 $0 $0 $0 $10,000 $424,000 $2,795,000 $1,600,000 $0 $4,222,000 $0 $0 $0 $0 $0 $0 $498,304,387 $2,135,757 Redeemed, in Full $1,225,617 Sold, in part $786,754 Redeemed, in Full $23,710,843 Redeemed, in Full $59,822 Redeemed, in Full $11,577,772 Redeemed, in Full $308,623 Sold, in full Full investment $1,228 outstanding Full investment $52,081 outstanding $435,108,078 $0.00 $1,915,000 $358,018 $245,800 $491,600 $743,000 $22,115,000 $57,000 $10,300,000 $271,714.78 1,915,000 389,150 245,800 491,600 743,000 22,115,000 57,000 10,300 295,000 $1.00 $0.92 $1.00 $1.00 $1.00 $1.00 $1.00 $1,000.00 $0.92 ($26,683,472.00) $0.00 ($31,132.00) ($23,285.22) ($3,795.00) ($1,198,000.00) ($1,000,000.00) ($119,630.00) ($2,366,000.00) ($211,680.00) Gain $9,213 $1,285,667 $2,098,519 $1,900,500 $67,894 $209,447 $4,268,189 $324,282 Dividends Paid to Date $220,757 $129,291 $43,754 $1,595,843 $2,822 $1,277,772 $0 $1,228 $52,081 $209,936 $0.95 $1.00 $930.04 $936.51 $1.00 $0.93 $930.00 $0.92 (Realized Loss) / (Write-off) $196,533 75,000 3,700,000 17,123 15,750 1,100,000 1,709,000 33,800 2,646,000 Avg. Price Full investment $209,936 outstanding $71,205 $3,700,000 $15,925,000 $14,750,000 $1,100,000 $1,589,370 $31,434,000 $2,434,320 Shares 10 Continued on next page $139,750 Number Amount of Missed of Missed Dividends Dividend Dividend and Interest Report Full investment outstanding $196,533 $80,593 Sold, in full $4,985,667 Redeemed, in part $18,043,496 Sold, in full $16,650,500 Sold, in full $1,167,894 Redeemed, in Full $1,802,140 Sold, in full $35,702,189 Sold, in full $2,764,776 Sold, in full Amount (Fee) Capital Repayment / Disposition / Auction Outstanding Investment Investment Total Cash Back2 Status* (CONTINUED) Original Investment Amount CDCI PROGRAM TRANSACTION DETAIL, AS OF 12/31/2016 284 APPENDIX A I TRANSACTION DETAIL I JANUARY 27, 2017 (CONTINUED) Notes: Numbers may not total due to rounding. Data as of 12/31/2016. Numeric notes were taken verbatim from Treasury’s 12/30/2016, Transactions Report. All amounts and totals reflect cumulative receipts from inception through 12/31/2016. Sources: Treasury, Transactions Report, 12/30/2016; Dividends and Interest Report, 1/10/2017. 1 All pricing is at par. 2 Total Cash Back includes net capital repayments, interest and dividends, warrant proceeds, and other income (less expenses). 3 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. 4 Treasury made an additional investment in this institution at the time it entered the CDCI program. 5 Treasury made an additional investment in this institution after the time it entered the CDCI program. 6 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 06/29/2011. Accrued and previously unpaid dividends were paid on the date of the exchange. 7 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. On 1/29/2013, UST received $79,900 representing the total amount of distributions paid to creditors as a result of the liquidation of Premier Bancorp, Inc. 8 Repayment pursuant to one or more of the following, as appropriate: Section 5 of the CDCI Certificate of Designation, Section 6.10 or 6.11 of the CDCI Securities Purchase Agreement, and/or Section 5.11 of the CDCI Exchange Agreement. 9 On 10/31/2014, in connection with the merger of Union Settlement Federal Credit Union (Union) with Lower East Side People’s Federal Credit Union (Lower East Side), Treasury exchanged its $295,000 in aggregate principal amount of Union senior subordinated securities for a like amount of additional Lower East Side senior subordinated securities. Accrued dividends on the Union senior subordinated securities were paid on the date of the exchange. 10 On 12/23/2014, in connection with the merger of Butte Federal Credit Union (Butte) with Self-Help Credit Union (SHFCU), Treasury exchanged its 1,000,000 in senior subordinated securities for a like amount of SHFCU senior subordinated securities. Accrued and unpaid interest were paid on the date of the exchange. 11 On 10/1/2013, Treasury completed the sale to Wilshire Bancorp, Inc. (“Wilshire”) of all of the preferred stock that had been issued by BankAsiana (“BankAsiana”) to Treasury for a purchase price of $5,250,000 plus accrued dividends, pursuant to the terms of the agreement between Treasury, Wilshire and BankAsiana entered into on 9/25/2013 in connection with the merger of Wilshire and BankAsiana. 12 On 10/11/2016, Treasury entered into an agreement with Community Bancshares of Mississippi, Inc. (the “Company”) pursuant to which Treasury agreed to sell its CDCI preferred stock to the Company for fair value of $50,778,000 plus accrued and unpaid dividends to the date of closing, subject to the satisfaction of the conditions specified in the agreement. The sale was completed on 10/11/2016. 13 On 10/11/2016, Treasury entered into an agreement with State Capital Corp. (the “Company”) pursuant to which Treasury agreed to sell its CDCI preferred stock to the Company for fair value of $14,750,000 plus accrued and unpaid dividends to the date of closing, subject to the satisfaction of the conditions specified in the agreement. The sale was completed on 10/11/2016. 14 On 10/18/2016, Treasury entered into an agreement with BancPlus Corporation (the “Company”), pursuant to which Treasury agreed to sell its CDCI preferred stock to the Company for fair value of $75,250,020 plus accrued and unpaid dividends to the date of closing, subject to the satisfaction of the conditions specified in the agreement. The sale was completed on 10/18/2016. 15 On 10/31/2016, Treasury entered into an agreement with Security Federal Corporation (the “Company”), pursuant to which Treasury agreed to sell its CDCI preferred stock to the Company for fair value of $21,340,000 plus accrued and unpaid dividends to the date of closing, subject to the satisfaction of the conditions specified in the agreement. The sale was completed on 10/31/2016. 16 On 11/22/2016, Treasury entered into an agreement with Pyramid Federal Credit Union (the “Company”), pursuant to which Treasury agreed to sell its CDCI senior subordinated securities to the Company for fair value of $930,000 plus accrued and unpaid interest to the date of closing, subject to the satisfaction of the conditions specified in the agreement. The sale was completed on 11/22/2016. 17 On 11/29/2016, Treasury entered into an agreement with First Vernon Bancshares, Inc. (the “Company”), pursuant to which Treasury agreed to sell its CDCI preferred stock to the Company for fair value of $5,745,400 plus accrued and unpaid dividends to the date of closing, subject to the satisfaction of the conditions specified in the agreement. The sale was completed on 11/29/2016. 18 On 11/29/2016, Treasury entered into an agreement with Southern Bancorp, Inc. (the “Company”), pursuant to which Treasury agreed to sell its CDCI preferred stock to the Company for fair value of $31,434,000 plus accrued and unpaid dividends to the date of closing, subject to the satisfaction of the conditions specified in the agreement. The sale was completed on 11/29/2016. 19 On 12/06/2016, Treasury entered into an agreement with The First Bancshares, Inc. (“the “Company”), pursuant to which Treasury agreed to sell its CDCI preferred stock to the Company for fair value of $15,925,000.00 plus accrued and unpaid dividends to the date of closing, subject to the satisfaction of the conditions specified in the agreement. The sale was completed on 12/06/2016. 20 On 12/20/2016, Treasury entered into an agreement with CFBanc Corporation (the “Company”), pursuant to which Treasury agreed to sell its CDCI preferred stock to the Company for fair value of $5,549,760 plus accrued and unpaid dividends to the date of closing, subject to the satisfaction of the conditions specified in the agreement. The sale was completed on 12/20/2016. 21 On 12/20/2016, Treasury entered into an agreement with Community Plus Federal Credit Union (the “Company”), pursuant to which Treasury agreed to sell its CDCI senior subordinated securities to the Company for fair value of $415,000 plus accrued and unpaid interest to the date of closing, subject to the satisfaction of the conditions specified in the agreement. The sale was completed on 12/20/2016. 22 On 12/20/2016, Treasury entered into an agreement with Liberty Financial Services, Inc. (the “Company”), pursuant to which Treasury agreed to sell its CDCI preferred stock to the Company for fair value of $10,591,623 plus accrued and unpaid dividends to the date of closing, subject to the satisfaction of the conditions specified in the agreement. The sale was completed on 12/20/2016. 23 On 12/20/2016, Treasury entered into an agreement with M&F Bancorp, Inc. (the “Company”), pursuant to which Treasury agreed to sell its CDCI preferred stock to the Company for fair value of $9,388,000 plus accrued and unpaid dividends to the date of closing, subject to the satisfaction of the conditions specified in the agreement. The sale was completed on 12/20/2016. 24 On 12/20/2016, Treasury entered into an agreement with PGB Holdings, Inc. (the “Company”), pursuant to which Treasury agreed to sell its CDCI preferred stock to the Company for fair value of $2,940,000 plus accrued and unpaid dividends to the date of closing, subject to the satisfaction of the conditions specified in the agreement. The sale was completed on 12/20/2016. 25 On 12/20/2016, Treasury entered into an agreement with Southern Chautauqua Federal Credit Union (the “Company”), pursuant to which Treasury agreed to sell its CDCI senior subordinated securities to the Company for fair value of $1,589,370 plus accrued and unpaid interest to the date of closing, subject to the satisfaction of the conditions specified in the agreement. The sale was completed on 12/20/2016. 26 On 12/27/2016, Treasury entered into an agreement with Alternatives Federal Credit Union (the “Company”), pursuant to which Treasury agreed to sell its CDCI senior subordinated securities to the Company for fair value of $2,055,280 plus accrued and unpaid interest to the date of closing, subject to the satisfaction of the conditions specified in the agreement. The sale was completed on 12/27/2016. 27 On 12/27/2016, Treasury entered into an agreement with Brooklyn Cooperative Federal Credit Union (the “Company”), pursuant to which Treasury agreed to sell its CDCI senior subordinated securities to the Company for fair value of $280,000 plus accrued and unpaid interest to the date of closing, subject to the satisfaction of the conditions specified in the agreement. The sale was completed on 12/27/2016. 28 On 12/27/2016, Treasury entered into an agreement with Genesee Co-Op Federal Credit Union (the “Company”), pursuant to which Treasury agreed to sell its CDCI senior subordinated securities to the Company for fair value of $279,000 plus accrued and unpaid interest to the date of closing, subject to the satisfaction of the conditions specified in the agreement. The sale was completed on 12/27/2016. 29 On 12/27/2016, Treasury entered into an agreement with Harborstone Credit Union (the “Company”), which had purchased Thurston Union of Low-Income People (TULIP) Cooperative Credit Union, pursuant to which Treasury agreed to sell its TULIP CDCI senior subordinated securities to the Company for fair value of $71,205 plus accrued and unpaid interest to the date of closing, subject to the satisfaction of the conditions specified in the agreement. The sale was completed on 12/27/2016. 30 On 12/27/2016, Treasury entered into an agreement with Phenix Pride Federal Credit Union (the “Company”), pursuant to which Treasury agreed to sell its CDCI senior subordinated securities to the Company for fair value of $142,000 plus accrued and unpaid interest to the date of closing, subject to the satisfaction of the conditions specified in the agreement. The sale was completed on 12/27/2016. 31 On 12/27/2016, Treasury entered into an agreement with Shreveport Federal Credit Union (the “Company”), pursuant to which Treasury agreed to sell its CDCI senior subordinated securities to the Company for fair value of $2,434,320 plus accrued and unpaid interest to the date of closing, subject to the satisfaction of the conditions specified in the agreement. The sale was completed on 12/27/2016. 32 On 12/27/2016, Treasury entered into an agreement with Vigo County Federal Credit Union (the “Company”), pursuant to which Treasury agreed to sell 389,150 of its CDCI senior subordinated securities to the Company for fair value of $358,018 plus accrued and unpaid interest to the date of closing, subject to the satisfaction of the conditions specified in the agreement. The sale was completed on 12/27/2016. 33 On 12/30/2016, Treasury entered into an agreement with Citizens Bancshares Corporation (the “Company”) pursuant to which Treasury agreed to sell its CDCI preferred stock to State Capital Corp. for fair value of $4,227,049 plus accrued and unpaid dividends to the date of closing, subject to the satisfaction of the conditions specified in the agreement. The sale was completed on 12/30/2016. 34 On 12/30/2016, Treasury entered into an agreement with D.C. Federal Credit Union (the “Company”), pursuant to which Treasury agreed to sell 1,022,000 of its CDCI senior subordinated securities to the Company for fair value of $970,900 plus accrued and unpaid interest to the date of closing, subject to the satisfaction of the conditions specified in the agreement. The sale was completed on 12/30/2016. 35 On 12/30/2016, Treasury entered into an agreement with IBW Financial Corporation (the “Company”) pursuant to which Treasury agreed to sell its CDCI preferred stock to State Capital Corp. for fair value of $5,610,000 plus accrued and unpaid dividends to the date of closing, subject to the satisfaction of the conditions specified in the agreement. The sale was completed on 12/30/2016. 36 On 12/30/2016, Treasury entered into an agreement with Lower East Side People’s Federal Credit Union (the “Company”), pursuant to which Treasury agreed to sell its CDCI senior subordinated securities to the Company for fair value of $1,098,833 plus accrued and unpaid interest to the date of closing, subject to the satisfaction of the conditions specified in the agreement. The sale was completed on 12/30/2016. CDCI PROGRAM TRANSACTION DETAIL, AS OF 12/31/2016 TRANSACTION DETAIL I APPENDIX A I JANUARY 27, 2017 285 286 APPENDIX B I CORRESPONDENCE I JANUARY 27, 2017 CORRESPONDENCE This appendix provides a copy of the following correspondence: CORRESPONDENCE Date From To Regarding 11/3/2016 SIGTARP Treasury Recommendations to Prevent, Fraud, Waste, and Abuse for TARP Investments in CDCI 12/16/2016 Treasury SIGTARP Response to SIGTARP’s CDCI Recommendations CORRESPONDENCE I APPENDIX B I JANUARY 27, 2017 287 288 APPENDIX B I CORRESPONDENCE I JANUARY 27, 2017 CORRESPONDENCE I APPENDIX B I JANUARY 27, 2017 289 290 APPENDIX B I CORRESPONDENCE I JANUARY 27, 2017 Criminal Charges from Investigations LOCATIONSSIGTARP WHERE CRIMINAL CHARGES WERE FILED AS A RESULT OF FIGURE 1.9 SIGTARP INVESTIGATIONS Tacoma Fargo Concord Boise Sacramento Oakland San Francisco Fresno Las Vegas Los Angeles Santa Ana Salt Lake City Boston Hartford Buffalo Brooklyn New Haven Madison White Plains Bridgeport New York Central Islip Rockford Newark Chicago Philadelphia Omaha Columbus Wilmington Upper Marlboro Lincoln Baltimore Peoria Washington, DC Denver Alexandria Louisville Kansas City (KS) Kansas City (MO) Norfolk Lexington East St. Louis Wichita Jefferson City St. Louis Nashville Bakersfield Riverside San Diego Little Rock Rome Birmingham San Antonio Houston Knoxville Gainesville Atlanta Macon Valdosta Pensacola New Orleans Ocala Orlando Tampa Fort Myers West Palm Beach Criminal Law Enforcement Agency Prevent Fraud, Identify Waste, Abuse, and Cost Savings SIGTARP OFFICE OF THE SPECIAL INSPECTOR GENERAL FOR THE TROUBLED ASSET RELIEF PROGRAM
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