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United States Government Accountability Office

Report to Congressional Committees

October 2013

TROUBLED ASSET
RELIEF PROGRAM
Status of Treasury’s
Investments in
General Motors and
Ally Financial

GAO-14-6

October 2013

TROUBLED ASSET RELIEF PROGRAM
Status of Treasury’s Investments in General Motors
and Ally Financial
Highlights of GAO-14-6, a report to
congressional committees

Why GAO Did This Study

What GAO Found

As part of its Auto Industry Financing
Program (AIFP), funded through the
Troubled Asset Relief Program
(TARP), Treasury committed $67.3
billion to automaker GM and to Ally
Financial, a large bank holding
company whose primary business is
auto lending. TARP’s authorizing
legislation mandates that GAO report
every 60 days on TARP activities.

Since receiving federal assistance, General Motors Company (GM) has shown
increasingly positive financial results. For each of the past 3 years, GM has
reported profits, positive and growing operational cash flow, and a stable liquidity
position. This improved financial performance has been reflected in GM’s credit
rating, as each of the three largest credit rating agencies has increased GM’s
long-term credit rating. However, GM faces continued challenges to its
competitiveness. For instance, its market share of vehicles sold in North
America remains smaller today than in 2008. Furthermore, GM continues to
carry large pension liabilities.

This report examines (1) the current
financial condition of the two
companies and (2) the status of
Treasury’s investments in the
companies and its plans to sell those
investments.
To examine the financial condition of
GM and Ally Financial, GAO reviewed
industry, financial, and regulatory data
for the time period from the beginning
of 2008 through the second quarter of
2013. GAO also reviewed Treasury
reports and documentation detailing
Treasury’s investments in GM and Ally
Financial and its proposed strategies
for divesting itself of the investments,
as well as both companies’ financial
filings and reports. In addition, GAO
interviewed officials from Treasury, the
Board of Governors of the Federal
Reserve (Federal Reserve), GM, Ally
Financial, and financial analysts who
study GM and Ally Financial.
In its written comments on a draft of
this report, Treasury describes the auto
industry’s recovery and the progress
Treasury has made in unwinding its
investments in GM and Ally Financial.
Treasury, the Federal Reserve, GM,
and Ally Financial also provided
technical clarifications, which were
incorporated, as appropriate.

View GAO-14-6. For more information, contact
A. Nicole Clowers at (202) 512-8678 or
clowersa@gao.gov.

With Treasury’s investments in Ally Financial, the company’s condition has
stabilized. For example, Ally Financial’s capital and liquidity positions have
stabilized or improved over the last 4 years. Such improvements have been
noted by the three largest credit rating agencies, each of which has upgraded
Ally Financial’s credit rating. However, Ally Financial’s credit rating remains
below investment grade and its mortgage unit—Residential Capital LLC—
impacted the company’s financial performance. The mortgage unit filed for
bankruptcy in May 2012, and these proceedings are ongoing. Analysts with
whom GAO spoke indicated that the resolution of its mortgage unit’s bankruptcy
will be a positive development for Ally Financial’s future financial performance.
Status of Automotive Industry Financing Program, as of September 18, 2013 (in billions)

Note: Numbers may not sum because of rounding.

As of September 18, 2013, the Department of the Treasury (Treasury) has
recovered about $35.21 billion of its $51 billion investment in GM and reduced its
ownership stake from 60.8 percent to 7.32 percent. By early 2014, Treasury
plans to fully divest its GM common shares through installments and estimates
that it will lose at least 19 percent of its original investment. Treasury is working
to exit from Ally Financial with a recent agreement to sell all of its preferred stock
to the company for approximately $6 billion, but Treasury faces challenges. As a
regulated bank holding company, Ally Financial must be well capitalized to
receive its regulator’s approval to repurchase shares from Treasury. Earlier this
spring, Ally Financial’s tier 1 common ratio fell below the required 5 percent in the
Federal Reserve’s “stress test,” and the Federal Reserve objected to the
company’s capital plan. Ally Financial also faces growing competition in the
consumer lending and dealer financing sectors that could impact its financial
performance in the future. The extent of Treasury’s recoupment on its Ally
Financial investment will depend on the ongoing financial health of the company.
United States Government Accountability Office

Contents

Letter

1
Background
Financial Condition of GM and Ally Financial
Treasury Is Working to Exit from Its Remaining Investments in GM
and Ally Financial
Agency and Third Party Comments

3
9
22
31

Appendix I

Objectives, Scope, and Methodology

35

Appendix II

Comments from the Department of the Treasury

38

Appendix III

GAO Contact and Staff Acknowledgments

40

Tables
Table 1: GM’s Net Income, Operating Income and Cash Flow (in
billions), 2008-2012
Table 2: Ally Financial Capital Ratios, 2009-2012
Table 3: Selected Financial Performance Metrics for Ally Financial,
2009-2012

10
16
18

Figures
Figure 1: GM’s North American Market Share, 2008-2013
Figure 2: Trends in GM’s U.S. Pension Plans’ Liabilities and Assets
Figure 3: Ally Financial Net Income (Loss) by Operating Unit, 20092012
Figure 4: Ally Financial Liquidity Ratio, June 2009-June 2013
Figure 5: Ally Financial Operating Cash Flow, January 2009-June
2013
Figure 6: Breakeven Price for GM Shares Needed for Treasury to
Fully Recoup Its Investment
Figure 7: Dollar Amount of Consumer Auto Loans for Five Large
Bank Holding Companies, 2011-2013

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14
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19
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GAO-14-6 Troubled Asset Relief Program

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GAO-14-6 Troubled Asset Relief Program

441 G St. N.W.
Washington, DC 20548

October 29, 2013
Congressional Committees:
In 2008 and 2009, the Department of the Treasury (Treasury) provided
significant support to the automotive industry—including both auto
manufacturers and automotive finance companies—after deteriorating
economic conditions resulted in a dramatic decline in auto sales and
significant financial losses in the industry. In particular, through the
Automotive Industry Financing Program (AIFP) under the Troubled Asset
Relief Program (TARP), Treasury committed approximately $51 billion to
help General Motors Company (GM). 1 Through AIFP, Treasury also
provided about $16.3 billion to GMAC, a financial services company
whose businesses included providing consumer financing for vehicle
purchases and dealer financing for inventory. In 2010, GMAC LLC
became Ally Financial, Inc. (Ally Financial). 2 While Treasury has
recouped much of its investments in these companies—most notably,
through GM’s initial public offering (IPO) in November 2010—more than
$29.57 billion of Treasury’s assistance to GM and Ally Financial remained
outstanding as of September 18, 2013. 3
This report is based on our continuing analysis and monitoring of
Treasury’s activities in implementing the Emergency Economic
Stabilization Act of 2008 (EESA), which provided GAO with broad
oversight authorities for actions taken under TARP. 4 This report examines
(1) the financial condition of GM and Ally Financial and (2) the status of
Treasury’s investments in the companies and its plans to wind down
those investments.
1

Emergency Economic Stabilization Act of 2008, Pub. L. No. 110-343, § 101, 122 Stat.
3765, 3767 (codified at 12 U.S.C. § 5211). This report focuses on GM and Ally Financial
and does not examine the assistance provided to other auto manufacturers or auto
financing companies through AIFP, including Chrysler Holdings.

2

GMAC renamed itself Ally Financial, Inc., in 2009 and expanded its depository banking
operation under the name of Ally Bank. For this report, we use GMAC to refer to the
company for activities and events that predate the name change.

3

The amount outstanding does not include write-offs and realized losses that Treasury
has absorbed and dividends, interest, and other income that Treasury has realized on its
investments.

4

Pub. L. No. 110 -343, § 116, 122 Stat. 3765 3783 (codified at 12 U.S.C. § 5226).

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GAO-14-6 Troubled Asset Relief Program

To examine the financial condition of GM and Ally Financial, we reviewed
financial and industry data for 2008 and 2009, respectively, through June
2013 for both companies. To assess GM’s financial condition, we
reviewed its net income, operating income, operating cash flow, credit
ratings, sales of automobiles, share of the North American market, and
pension obligations and pension plan funding for its U.S. employees. For
Ally Financial, we reviewed capital ratios, net income, net interest spread,
return on assets, nonperforming asset ratio, liquidity ratio, bank deposits,
operating cash flow, and credit ratings. To describe the status of
Treasury’s investment in GM and Ally Financial, we reviewed Treasury’s
Section 105(a) Reports to Congress detailing the levels of the
investments made in GM and Ally Financial, including the number of
shares owned by Treasury and Treasury’s daily transactions reports. 5 We
also interviewed Treasury officials.
To analyze Treasury’s plan to wind down its investments, we reviewed
Treasury documentation relating to its exit from GM and Ally Financial. In
addition, we reviewed the Board of Governors of the Federal Reserve
System’s (Federal Reserve) publicly available reports relating to its 2013
stress tests on bank holding companies with assets of $50 billion or more
and the Comprehensive Capital Analysis and Review 2013. 6 We also
interviewed officials from Treasury, Federal Reserve, Federal Deposit
Insurance Corporation (FDIC), GM, and Ally Financial. We assessed the
completeness and accuracy of all data used in this report and determined
they were sufficiently reliable for the purposes of this report. For each
data source we reviewed the data for completeness and obvious errors,
such as outliers, and determined that these data were sufficiently reliable
for our purposes. We reviewed past GAO data reliability assessments to
5

Under EESA, every 30 days, Treasury must submit to Congress reports on actions taken
and funds obligated and spent during the reporting period as well as detailed financial
statements covering, among other items, agreements made, assets purchased,
transactions that occurred, and the valuation or pricing method used for each transaction.
§ 105(a), 122 Stat. at 3771-72.

6

Stress testing is one tool that helps bank supervisors measure whether a bank holding
company has enough capital to support its operations throughout periods of stress. The
Dodd-Frank Wall Street Reform and Consumer Protection Act requires the Federal
Reserve to perform an annual stress test of bank holding companies with $50 billion or
more in total consolidated assets. Pub. L. No. 111-203, § 165(i)(1)(A), 124 Stat. 1376,
1430 (2010)(codified at 12 U.S.C. § 5365(i)(1)(A)). The Comprehensive Capital Analysis
and Review is an annual assessment by the Federal Reserve of the internal capital
planning process and capital adequacy of large, complex U.S. bank holding companies.
12 C.F.R. §225.8.

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GAO-14-6 Troubled Asset Relief Program

ensure that we, in all material respects, used the data in a similar manner
and for similar purposes. For a more detailed discussion of the scope and
methodology, please see appendix I.
We conducted this performance audit from March 2013 to October 2013
in accordance with generally accepted government auditing standards.
Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our
findings and conclusions based on our audit objectives. We believe that
the evidence obtained provides a reasonable basis for our findings based
on our audit objectives.

Background

The decision to provide substantial amounts of funding to the auto
industry—more than 12 percent of all authorized TARP funds—and to
accept equity in the companies in return for some of the assistance
reflects Treasury’s view of the automotive industry’s importance to the
U.S. economy. According to Treasury officials, Treasury provided
assistance not simply because of the industry’s importance, but because
of the severity of the crisis and the desire to prevent significant disruption
to the economy that would have resulted from uncontrolled liquidations of
Chrysler and GM. To help stabilize the industry and avoid economic
disruptions, Treasury disbursed $79.7 billion through AIFP from
December 2008 through June 2009. The majority of the assistance was
used to support two automakers, Chrysler and GM, during restructuring,
along with their automotive finance companies, Chrysler Financial and
GMAC. 7 In July 2009, Treasury outlined guiding principles for the
investments made to the auto industry, including:
•
•

exiting its investments as soon as practicable in a timely and orderly
manner that minimizes financial market and economic impact;
protecting taxpayer investment and maximizing overall investment
returns within competing constraints;

7

Treasury disbursed a total of $12.4 billion to Chrysler-related entities including Old
Chrysler and New Chrysler. Of the $12.4 billion that was disbursed to Chrysler-related
entities under TARP, Treasury collected more than $11.1 billion through principal
repayments, sale of investments, and interest. While Treasury retains a right to receive
proceeds from a liquidation trust related to Old Chrysler, no significant future cash flows
are expected. Treasury completed its exit from New Chrysler in July 2011.

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GAO-14-6 Troubled Asset Relief Program

•

•

Assistance to GM

improving the strength and viability of GM and Chrysler so that they
can contribute to economic growth and jobs without government
involvement; and
managing its ownership stake in a hands-off, commercial manner,
including voting its shares only on core governance issues, such as
the selection of a company’s board of directors and major corporation
events or transactions. 8

GM is one of the world’s largest automotive companies and does
business in more than 120 countries worldwide. As of December 31,
2012, it employed 213,000 workers worldwide and marketed vehicles
through a network of independent retailers totaling 20,754 dealers. In
North America, GM manufactures and markets the following brands:
Buick, Cadillac, Chevrolet, and GMC.
Treasury provided a $13.4 billion loan in December 2008 to the Old GM
to fund working capital. 9 Treasury also lent $884 million to the Old GM for
the purchase of additional ownership interests in a rights offering by
GMAC. In April 2009, Treasury loaned an additional $6 billion to fund Old
GM as it worked to submit a viable restructuring plan (working capital
loan). These funds, along with loans from the Canadian government and
concessions from nearly every stakeholder, including the company’s
primary labor union—the International Union, United Automobile,
Aerospace and Agricultural Implement Workers of America (UAW)—were
intended to give the companies time to restructure to improve their
competitiveness and long-term viability.

8

Treasury established two other programs under AIFP—the Auto Supplier Support
Program and the Auto Warranty Commitment Program. The Auto Supplier Support
Program was designed to ensure that automakers received the parts and components
they needed to manufacture vehicles and that suppliers had access to liquidity on their
receivables. Under this program, GM and Chrysler received loans, all of which have been
repaid. The Auto Warranty Commitment Program was designed to mitigate consumer
uncertainty about purchasing vehicles from the restructuring automakers by providing
funding to guarantee the warranties on new vehicles from those automakers. Funds were
provided to GM and Chrysler under this program, but both companies were able to
continue to honor consumer warranties and the funds have been repaid in full.
9

General Motors Company is a new legal entity that was created through the bankruptcy
process to purchase substantially all of the operating assets of the former firm.
Throughout this report, we refer to the prereorganization company as “Old GM” and the
postreorganization company as “GM.”

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As a condition of receiving this assistance, Old GM was required to
submit a plan to Treasury that would, among other things, identify how it
intended to achieve and sustain long-term financial viability. GM’s initial
viability plan submitted in February 2009 was rejected. The plan
established targets for addressing some of the company’s key challenges
to achieving viability, including reducing debt, numbers of brands and
models, dealership networks, and production costs and capacity. In 2009,
Old GM filed a voluntary petition for reorganization under Chapter 11 of
the U.S. bankruptcy code. Subsequently, in June 2009, Treasury
provided Old GM with $30.1 billion under a debtor-in-possession
financing agreement to assist during the restructuring. 10 The newly
organized GM was able to purchase most of the operating assets of the
former company through a sale under Section 363 of the bankruptcy
code. 11 When the sale was completed on July 10, 2009, Treasury
converted most of its loans into 60.8 percent of the common equity in GM
and $2.1 billion in preferred stock. 12 In addition, $6.7 billion of the TARP
loans remained outstanding after the bankruptcy. In spring 2011, the
bankruptcy was completed, and Old GM’s remaining assets and liabilities
were transferred to liquidating trusts. As we concluded in our past work,
the federal assistance allowed GM to restructure its balance sheets and
obligations through the bankruptcy code and tackle key challenges to
achieving viability. 13

Assistance to Ally
Financial

Ally Financial, previously known as GMAC, formerly served as GM’s
captive auto finance company. 14 The primary purpose of auto financing is
to provide credit to consumers so that they can purchase automobiles. In

10

A debtor-in-possession financing agreement is financing arranged by a company while
under a Chapter 11 bankruptcy reorganization.
11

11 U.S.C. § 363 (2010).

12
Preferred stock is equity ownership that usually pays a fixed dividend and gives the
holder a claim on corporate earnings that is superior to the claims of common stock
owners. Preferred stock also has priority in the distribution of assets when a bankrupt
company is liquidated.
13
GAO, TARP: Treasury’s Exit from GM and Chrysler Highlights Competing Goals, and
Results of Support to Auto Communities Are Unclear, GAO-11-471 (Washington, D.C.:
May 10, 2011).
14

A captive auto lender’s primary business is to finance the purchase of a specific
manufacturer’s automobiles.

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GAO-14-6 Troubled Asset Relief Program

determining how to finance their purchases, consumers have many
financial institutions from which to choose, including banks, credit unions,
and auto finance companies, all of which may offer loans or other credit
accommodations for the purchase of new and used automobiles. In
addition to consumer financing, auto dealers have also traditionally used
manufacturers’ finance companies to finance their purchase of the
automobile inventory that they sell (known as floor-plan financing). 15
Prior to the financial crisis, GMAC’s subsidiaries expanded into other
areas of financial services, such as auto insurance and residential
mortgages, but GMAC remained a wholly owned subsidiary of the Old
GM. In 2006, Cerberus Capital Management purchased 51 percent of the
company. GM retained a 49 percent ownership stake. As the housing
market declined in the late 2000s, the previously profitable GMAC
mortgage business unit began producing significant losses. For example,
the company’s Residential Capital LLC (ResCap) subsidiary—which by
2006 had grown to be the country’s sixth-largest mortgage originator and
fifth-largest mortgage servicer—lost approximately $17 billion from 2007
through 2009. During the same time period, automobile sales in the U.S.
dropped from 16.4 million to 10.4 million, negatively affecting the
company’s core auto financing business.
According to Treasury, Treasury determined that without government
assistance GMAC would be forced to deny or suspend financing to
creditworthy dealerships, leaving them unable to purchase automobile
inventory for their lots. 16 Without orders for automobiles from dealerships,
GM would have been forced to slow or shut down its factories indefinitely
to match the drop in demand. Given its significant overhead, a slow-down
or stoppage of this magnitude would have caused GM to topple,
according to Treasury.

15

Floor-plan, or wholesale, lending is a form of retail goods inventory financing in which
each loan advance is made against a specific piece of collateral. As each piece of
collateral is sold by the dealer, the loan advance against that piece of collateral is repaid.
Items commonly subject to floor-plan debt are automobiles, large home appliances,
furniture, television and stereo equipment, boats, mobile homes, and other types of
merchandise usually sold under a sales finance contract.
16

Before the financial crisis, Chrysler had owned a finance company, Chrysler Financial.
Chrysler Financial ceased operating and its business taken on by GMAC.

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However, GMAC was not initially eligible for assistance under the TARP
Capital Purchase Program (CPP). 17 To become eligible for federal
financial assistance, GMAC sought to convert GMAC Bank’s charter from
an industrial loan company into a commercial bank in 2008 and applied to
the Federal Reserve for bank holding company status. 18 GMAC also
submitted an application to participate in the Capital Purchase Program,
conditional upon becoming a bank holding company. The Federal
Reserve approved GMAC’s bank holding company application in
December 2008. Although GMAC originally applied for participation in
CPP, in late December 2008, as a part of AIFP, Treasury agreed to
purchase $5 billion in senior preferred equity from GMAC and received an
additional $250 million in preferred shares through warrants that Treasury
exercised immediately.
Treasury subsequently provided GMAC with additional assistance
through TARP.
•
•

In May 2009, Treasury purchased $7.5 billion of mandatory
convertible preferred shares from GMAC. 19
In December 2009, Treasury purchased additional shares—$2.5
billion of trust preferred securities and approximately $1.3 billion of
mandatory convertible preferred shares. 20 Also, in December 2009,
Treasury converted $3 billion of existing mandatory convertible

17

As a commercial company, GMAC was not originally eligible for TARP assistance
through the Capital Purchase Program. However, in December 2008, Treasury
established AIFP to provide assistance to the U.S. automotive industry to help avoid
disruptions that would pose systemic risk to the nation’s economy; Treasury subsequently
provided assistance to GMAC through AIFP.
18

A bank holding company is a company that owns, or has controlling interest in 25
percent or more of the ownership in one or more banks. 12 U.S.C. § 1841(a) (2011). An
industrial loan company is an FDIC-supervised, state-chartered financial institution whose
distinct features include the fact that it can be owned by a commercial firm that is not
regulated by a federal banking agency.

19

Mandatory convertible preferred stock is a type of preferred share that must be
converted to common stock on or before a certain contractual date. Also, in May 2009,
Treasury exercised its option to exchange its $884 million loan with Old GM for a 35.4
percent common ownership share in GMAC
20

A trust preferred security is a security that has both equity and debt characteristics,
created by establishing a trust and issuing debt to it. Their use in meeting certain capital
requirements was restricted by the Dodd-Frank Wall Street Reform and Consumer
Protection Act, Pub. L. No. 111-203, § 171, 124 Stat. 1376, 1433-35 (2010).

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preferred shares into common stock, increasing its common equity
stake from 35 percent to 56.3 percent.
In December 2010, Treasury converted preferred stock in Ally
Financial that had a liquidation preference of $5.5 billion into common
stock. This stock conversion resulted in Treasury’s owning
approximately 74 percent of Ally Financial. In addition, as of
September 2013, Treasury continues to hold $5.9 billion of Ally
Financial’s mandatory convertible preferred shares. Ally Financial
pays a 9.0 percent fixed dividend annually to Treasury on these
preferred shares. 21 As will be discussed later in this report, Ally
Financial has entered into an agreement with Treasury to repurchase
the mandatory convertible preferred shares with possible completion
of the transaction sometime later this year.

•

As of June 2013, Ally Financial was the 20th largest U.S. bank holding
company, with total assets of $150.6 billion. Its primary line of business is
auto financing—both consumer financing and leasing and dealer floorplan financing. As a bank holding company, Ally Financial is regulated
and supervised by the Federal Reserve. 22 In addition, Ally Financial owns
Ally Bank, an Internet and-telephone-based, state-chartered nonmember
bank that is supervised by the FDIC and the Utah Department of
Financial Institutions. Ally Bank has over $92 billion in assets and $50.8
billion in total deposits, as of June 30, 2013.

21
Ally Financial is a privately held institution. These institutions did not issue warrants to
purchase shares of common stock for TARP investments. Instead, Treasury received from
privately held institutions warrants to purchase a specified number of shares of preferred
stock (warrant preferred stock) that paid annual dividends at 9 percent. Unlike the
warrants issued by publicly held institutions, such as Bank of America Corporation or
Citigroup, Inc., Treasury exercised these warrants immediately.
22

12 U.S.C. § 1844(b)-(c).

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Financial Condition of
GM and Ally Financial
General Motors’s Financial
Results Have Been
Increasingly Positive Since
Receiving Federal
Assistance, but Questions
Remain

Since receiving federal assistance, GM has shown increasingly positive
financial results. For each of the last 3 years, GM has reported profits, a
positive and growing operating cash flow, and a stable liquidity position.
This improved financial performance has been reflected in GM’s credit
ratings, with each of the three largest credit rating agencies increasing
GM’s long-term credit rating. Although Moody’s upgraded GM’s rating to
investment grade on September 23, 2013, Standard and Poor’s and Fitch
Ratings rate GM as below investment grade as of the same month.
Furthermore, GM’s market share of vehicles sold in North America was
smaller than in 2008, and it continued to carry large pension liabilities.
Based on our analysis of GM’s reported financial data, the company’s
financial performance has improved since 2008. We assessed GM’s
financial performance by examining its reported net income, operating
income, and operating cash flow. 23
•

Net income (loss): Net income (net profit or loss) is the difference
between total revenues and expenses and represents the company’s
income after all expenses and taxes have been deducted. For 2010,
2011, and 2012, GM reported net income of $6.5 billion, $9.3 billion,
and $6.1 billion, respectively (see table 1). In 2008, prior to the federal
government’s assistance and Old GM’s bankruptcy, GM reported a
net loss of $30.9 billion. As we found in our prior work, a key result of
the restructuring was that GM lowered its fixed costs by reducing the
number of employees, plants, and dealerships, among other things. 24
Reduced fixed costs allow GM to be profitable with fewer sales,
thereby lowering its “break-even” level.

•

Operating income (loss): Operating income (loss) describes a
company’s profit and loss from its core operations. It is the difference
between the revenues of a business and the related costs and
expenses, excluding income from sources other than its core

23

Data are from GM’s Form 10-Ks, in the year, they were reported. Subsequent
adjustments may have been made in later corporate filings.

24

GAO-11-471.

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business (e.g., income derived from investments). GM reported
operating income of $5.1 billion and $5.7 billion in 2010 and 2011,
respectively (see table 1). In 2012, GM took an approximate $27
billion goodwill impairment charge that significantly reduced its
operating income, contributing to a $30.4 billion operating loss. 25
•

Operating cash flow: Operating cash flow refers to the amount of cash
generated by a company’s core business operations. Operating cash
flow is important because it indicates whether a company is able to
generate sufficient positive cash flow to maintain and grow its
operations, or requires external financing. In its 2010, 2011, and 2012
annual reports, GM reported operating cash flow of $6.6 billion, $7.4
billion, and $9.6 billion, respectively. Further, in 2010 GM reported
total available liquidity from automotive operations of $32.5 billion,
including $5.9 billion from credit facilities. This amount had increased
slightly by 2012, when GM reported total available liquidity of $37.2
billion, including $11.1 billion from credit facilities. Finally, GM
reported current assets greater than current liabilities from 2010
through 2012, indicating that it could meet all current liabilities without
additional financing.

Table 1: GM’s Net Income, Operating Income and Cash Flow (in billions), 2008-2012

Net income (loss)

2008

2010

2011

2012

($30.9)

$6.5

$9.3

$6.1

Operating income (loss)

(21.2)

5.1

5.7

(30.4)

Operating cash flow

(12.1)

6.6

7.4

9.6

Source: GAO’s review of GM filings with the Securities and Exchange Commission (SEC). Net income for 2010, 2011, and 2012
excludes non-controlling interests. Data are from GM Form10-Ks, in the year they were reported. Subsequent adjustments may have
been made in later corporate filings.

25

Subsequent to its 2012 annual goodwill impairment testing, GM reversed $36.2 billion of
its deferred tax asset valuation allowances for its GM North America reporting unit. The
reversal of the deferred tax asset valuation allowances resulted in the carrying amount of
GM’s GM North America reporting unit exceeding its fair value. As a result, GM performed
an event-driven goodwill impairment test in the 3 months ended December 31, 2012.
Based on the results of this test, GM recorded a goodwill impairment charge of $26.4
billion in the 3 months ended December 31, 2012. The remaining goodwill impairment
charges were from GM’s European and international operations operating units. According
to the Federal Accounting Standards Board (FASB), an impairment exists when the
carrying amount of goodwill exceeds its implied fair value. If the carrying amount exceeds
the implied fair value, the difference is recognized as an impairment loss. However, the
recognized loss cannot be more than the carrying amount. (ASC 350-20-35-2 and 350-2035-11)

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Note: We did not include information for 2009 because GM began operations that year.
Consequently, annual data for 2009 are not comparable to data for previous or subsequent years.
Information for 2008 is for Old GM. On July 10, 2009, GM applied fresh-start reporting, following the
guidance in Accounting Standards Codification (ASC) 852, “Reorganizations” (ASC 852). The
consolidated financial statements for the periods ended on or before July 9, 2009, do not include the
effect of any changes in the fair value of assets or liabilities as a result of the application of fresh-start
reporting. GM’s financial information at and for any period after July 10, 2009, is not comparable to
Old GM’s financial information, which is provided only for reference.

These improvements in GM’s financial performance have been reflected
in its credit ratings. A credit rating is an assessment of the credit
worthiness of an obligor as an entity or with respect to specific securities
or money market instruments. 26 Credit ratings are important because
investors and financial institutions may consider them when making
investment and lending decisions. The three largest credit rating agencies
have each increased GM’s long-term credit rating two steps in the past 3
years. 27 Fitch Ratings and Standard and Poor’s raised their long-term
rating on GM from BB- to BB+. Moody’s raised its long-term corporate
family rating on GM from Ba2 to Baa3, an investment grade rating (i.e.,
the issuer or bond has a relatively low risk of default). Comparatively,
Standard and Poor’s also rates Ford Motor Company as one step below
investment grade, with a positive outlook. Fitch and Moody’s upgraded
Ford to an investment grade rating in April and May 2012, respectively.
Toyota, another competitor of GM, maintains an investment grade rating
with all three of these credit rating agencies.
Although GM’s financial performance has improved significantly since the
company initially received federal assistance, questions remain about
competitiveness and costs. One of the factors in GM’s improved financial
condition has been increased sales of automobiles generally, including
GM’s, over the last 3 years. Overall, North American vehicle sales
increased more than 23 percent from 2010 to 2012, rising from 14.4
million to 17.8 million. Over this same period, sales of GM automobiles in
North America increased 15 percent, from 2.6 million to 3 million.
However, GM’s North American market share generally has declined over

26
Securities Exchange Act of 1934, Pub. L. No. 73-291, § 3(a)(60), 48 Stat. 881 (codified
at 15 U.S.C. § 78c(a)(60)).
27
Each of the three credit rating agencies uses its own methodology to evaluate
qualitative and quantitative information about a company to develop its rating. These
ratings are considered opinions of the credit rating agencies.

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the past 5 years (see fig. 1). 28 In 2008, GM reported capturing 21.5
percent of the North American market, compared with 16.9 percent in
2012. GM reported that its North American market share was 17.2
percent through the second quarter of 2013.
Figure 1: GM’s North American Market Share, 2008-2013

Another factor contributing to GM’s financial performance has been its
ability to control labor costs. GM’s ability to remain competitive will also
depend on its ability to continue to control costs, in particular its labor
costs. Labor costs refer to the costs that GM incurs to pay workers to
build its vehicles at factories in the United States and elsewhere. Through
its restructuring, GM lowered labor costs, in part by reducing its workforce
and making more efficient use of its remaining workers. For instance, it
has closed plants and run additional shifts at existing plants, increasing
production capacity at those plants. In September 2011, GM and the

28

GM’s worldwide market share from 2008 to 2012 remained largely flat. In 2008 GM
reported worldwide market share of 12.4 percent, compared with 11.5 percent in 2012.

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UAW reached an agreement on a new 4-year contract that would
increase the company’s labor costs by 1 percent annually, according to
GM executives. In November 2011, the Center for Automotive Research
(CAR) reported that GM’s 2011 labor costs of $56/hour—while still among
the highest in the industry—were in line with those of its competitors.
CAR reported that Ford and Toyota had labor costs of $58 and $55 per
hour, respectively. As we concluded in prior work, maintaining competitive
labor costs in future negotiations is important to GM’s bottom line. 29 GM
officials told us another important factor in maintaining competitiveness is
GM’s ability to design, build, and sell vehicles that customers want to
purchase.
Finally, GM’s large pension obligations could have a potential impact on
GM’s costs. Based on our analysis of GM’s filings with the Securities and
Exchange Commission (SEC), GM reported U.S. pension plan assets of
$68 billion and obligations of $82 billion in 2012, creating an underfunded
position of approximately $14 billion. 30 This underfunded position is
somewhat less than in fiscal year 2009, when it reported an underfunded
position of $17.1 billion. Prior to its receipt of government assistance and
restructuring, GM had taken steps to reduce the risk it faced from its
underfunded plan, including modifying or closing plans to new hires or
halting further benefit accruals. 31 More recently, it offered selected
salaried retirees an option to receive a lump-sum settlement and those
selected salaried retirees that did not elect a lump-sum had their benefit
settled with GM via the purchase of an annuity contract with an insurance
company. GM paid lump-sum payments totaling $3.6 billion and a total
annuity premium of $27 billion in exchange for the insurance company
assuming future obligations to the beneficiaries. Some analysts with
whom we spoke saw this move as largely net neutral because of the
amount of cash GM used to complete this transaction. Others viewed it
somewhat positively for GM because, despite the cash used, the transfer

29

GAO-11-471.

30

Plan liabilities and assets reflect measurements in accordance with Financial Accounting
Standards. Both plan liabilities and assets could grow or diminish overtime, depending on
such factors as investment returns, interest rates, changes in plan demographics, and
whether benefits are revised in future years.
31

We have previously reported on GM’s pension plan and steps it has taken to reduce the
size of its pension obligations. See GAO, Troubled Asset Relief Program: Automaker
Pension Funding and Multiple Federal Roles Pose Challenges for the Future,
GAO-10-492,(Washington, D.C.: April 6, 2010).

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reduces the risk of future volatility in the company’s cash pension
obligations. GM does not expect any mandatory contributions to the
pension plans in the next several years. 32 Figure 2 shows the trends in
GM’s U.S. pension plans’ liabilities and assets.
Figure 2: Trends in GM’s U.S. Pension Plans’ Liabilities and Assets

Note: U.S. pension data were taken from the benefit obligations and the fair value of plan assets on
December 31 of the corresponding year.

Financial Condition of Ally
Financial Has Stabilized,
but Challenges Remain

With Treasury’s investments in Ally Financial, the company’s condition
has stabilized. To assess Ally Financial’s condition, we examined multiple
capital, profitability, and liquidity measures. These measures suggest that
Ally Financial’s financial performance is improving. The three largest
credit rating agencies have noted these improvements by upgrading Ally
Financial’s rating. However, the ratings remain below investment grade,

32
Minimum funding requirements are set forth in the Employee Retirement Income
Security Act of 1974. Pub. L. No. 93-406, 88 Stat. 829 (codified as amended at 29 U.S.C.
§§ 1001-1461). For more information, see GAO-10-492.

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and Ally’s mortgage unit—Residential Capital LLC—impacted the
company’s financial performance.
Ally Financial’s capital position has remained the same or improved since
2009. Capital can be measured in several ways, but we focused on tier 1
capital because it is currently the strongest form of capital. 33 We
examined Ally Financial’s tier 1 capital ratio and tier 1 leverage ratio and
compared them to minimums required under the Federal Reserve’s
capital adequacy guidelines for bank holding companies. We also
examined Ally Financial’s tier 1 common ratio. The Federal Reserve has
long held the view that bank holding companies generally should operate
with capital positions well above the minimum regulatory capital ratios,
with amount of capital held commensurate with a bank holding company’s
risk profile. 34
•

Tier 1 capital and common capital ratios: A tier 1 capital ratio
measures tier 1 capital as a percentage of risk-weighted assets. As
shown in table 2, Ally Financial’s tier 1 capital ratio increased from
2009 to 2010 but declined slightly in 2011 and 2012. Federal Reserve

33

Tier 1 capital is currently considered the most stable and readily available capital that a
banking institution can have to support its operations by absorbing unexpected financial
losses. It consists of core capital elements, such as common stockholders’ equity and
noncumulative perpetual preferred stock. As defined in the Federal Reserve’s Risk-Based
Capital Adequacy Guidelines, tier 1 capital is composed of common and non-common
equity elements, some of which are subject to limits on their inclusion in tier 1 capital. See
12 CFR § 225, Appendix A, § II.A.1. These elements include common stockholders’
equity, qualifying perpetual preferred stock, certain minority interests, and trust preferred
securities. Certain intangible assets, including goodwill and deferred tax assets, are
deducted from tier 1 capital or are included subject to limits. See 12 CFR § 225, Appendix
A, § II.B. Tier 1 common capital is tier 1 capital less the non-common elements of tier 1
capital, including perpetual preferred stock and related surplus, minority interest in
subsidiaries, trust preferred securities, and mandatory convertible preferred securities. 12
CFR §225.8(c)(8). Common equity is considered the most loss-absorbing form of capital.
In July 2013, the federal banking regulators issued revised requirements for minimum
capital, regulatory capital, and additional capital “buffers” to enhance the resiliency of
banking organizations during periods of financial stress. These new standards will be
implemented over multiple years. Regulatory Capital Rules: Regulatory Capital,
Implementation of Basel III, Capital Adequacy, Transition Provisions, Prompt Corrective
Action, Standardized Approach for Risk-Weighted Assets, Market Discipline and
Disclosure Requirements, Advanced Approaches Risk-Based Capital Rule, and Market
Risk Capital Rule, 78 Fed. Reg. 62019 (Oct. 11, 2013); 78 Fed. Reg. 55340 (Sept. 10,
2013).
34

Capital Plans, 76 Fed. Reg. 74631, 74632 (Dec. 1, 2011); see also Capital Adequacy
Guidelines for Bank Holding Companies, 12 CFR § 225, Appendix A, § I.

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Capital Adequacy Guidelines require bank holding companies to have
a tier 1 risk-based capital ratio of at least 4 percent. 35 Ally Financial’s
tier 1 one capital ratio met or exceeded the minimum ratio required
each year from 2009 through 2012. A tier 1 common capital ratio
measures common capital—that is, the common equity component of
tier 1 capital as a share of risk-weighted assets. Ally Financial’s tier 1
common ratio has increased from 4.85 percent at year-end 2009 to
6.98 percent at the end of the first quarter of 2013. 36 Higher tier 1
capital and common capital ratios may indicate that a bank holding
company is in a better position to absorb financial losses.
•

Tier 1 leverage ratio: A tier 1 leverage ratio shows the relationship
between a banking organization’s core capital and total assets. The
tier 1 leverage ratio is calculated by dividing the tier 1 capital by the
firm’s average total consolidated assets. Generally, a larger tier 1
leverage ratio indicates that a company is less risky because it has
more equity to absorb losses in the value of its assets. Ally Financial’s
leverage ratio remained largely unchanged from 2009 through 2012
(see table 2).

Table 2: Ally Financial Capital Ratios, 2009-2012

Tier 1 capital ratio
Tier 1 common capital ratio
Tier 1 leverage ratio

a

2009

2010

2011

2012

14.15%

15.00%

13.71%

13.13%

4.85

8.57

7.57

6.98

12.70

13.05

11.50

11.16

Source: GAO’s analysis of Ally Financial filings with SEC. Data are from Ally Financial Form10-Ks, in the year they were reported.
Subsequent adjustments may have been made in later corporate filings.
a

Federal Reserve Capital Adequacy Guidelines do not require a minimum tier 1 common capital ratio.
However, companies subject to the Federal Reserve’s capital plan rule must develop a capital plan
that demonstrates the company’s ability to meet a tier 1 common ratio above 5 percent under
stressed conditions. See 12 CFR 225.8(d)(2) (i)(B).

35
12 C.F.R. 225, Appendix G, § 3(a)(1)(ii). Federal Reserve Capital Adequacy Guidelines
require bank holding companies to have a minimum tier 1 risk-based capital ratio of 6
percent to be considered well capitalized. 12 C.F.R. § 225.2(r)(ii).
36

As previously mentioned, GMAC (now Ally Financial) became a bank holding company
in December 2008. We examined financial data from 2009 to 2013 because Ally Financial
became subject to new regulatory and reporting requirements when it became a bank
holding company.

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Ally Financial’s profitability has also improved since 2009. We examined
several measures of profitability, including net income (loss), net interest
spread, return on assets, and nonperforming assets ratio.
•

Net income (loss): Ally Financial suffered a net loss in 2009 of $10
billion, but has reported net income for 2 of the last 3 years. As shown
in figure 3, the 2009 loss was driven by substantial losses in its
mortgage business operating unit. Ally Financial reported net income
of $1.1 billion in 2010, a loss of $160 million in 2011, and net income
of $1.2 billion in 2012.

Figure 3: Ally Financial Net Income (Loss) by Operating Unit, 2009-2012

Notes: Data are from Ally Financial 10-Ks, in the year they are reported. Subsequent adjustments
may have been made in later corporate filings. Total reported net income does not always equal the
sum of the three operating units because of the exclusion of “other” income.

•

Net interest spread: The net interest spread is the difference between
the rate on total interest-earning assets and the rate on total interestbearing liabilities, excluding discontinued operations for the period. In
general, the larger the spread, the more a company is earning. Ally

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saw its net interest spread increase from a reported .58 percent at the
end of 2009 to 1.14 percent at the end of 2012 (see table 3).
•

Return on assets (ROA): ROA is calculated by dividing a company’s
net income by its total assets. It is an indication of how profitable a
company is relative to its total assets and gives an idea of
management’s efficiency in using its assets to generate earnings. A
higher ROA suggests that a company is using its assets efficiently.
Ally reported improved ROA from the end of 2009 to 2012, with a
reported negative 5.79 percent ROA for 2009 and a positive .65
percent in 2012 (see table 3).

•

Nonperforming asset ratio: This ratio measures asset quality by
dividing the value of nonperforming assets by the value of total
assets. The lower the ratio, the fewer poorly performing assets a
company holds. As shown in table 3, Ally’s nonperforming asset ratio
fell from 4.36 percent for the fourth quarter of 2009 to 1.06 percent for
the fourth quarter of 2012.

Table 3: Selected Financial Performance Metrics for Ally Financial, 2009-2012
Financial performance metric
Net interest spread
Return on assets
Nonperforming asset ratio

a

2009

2010

2011

2012

.58

1.23

1.07

1.14

(5.79)

.61

(.09)

.65

4.36

3.46

2.69

1.06

Source: GAO analysis of Ally Financial filings with SEC. Data are from Ally Financial Form 10-Ks, in the year they were reported.
Subsequent adjustments may have been made in later corporate filings.
a

Nonperforming asset ratio data from SNL Financial for December of corresponding year.

In addition, Ally Financial’s liquidity position has generally stabilized since
2009. To examine Ally Financial’s liquidity position, we examined the
company’s total liquidity ratio, bank deposits, and operating cash flow.
•

Total liquidity ratio: Liquidity ratios measure a bank’s total liquid
assets against its total liabilities. Generally, a high ratio indicates a
relatively large margin of safety in covering short-term debts. Overall,
Ally Financial’s liquidity ratio remained stable from 2009 through the
third quarter of 2012 (see fig. 4). Reductions in the fourth quarter of
2012 ratio are associated with the repayment of $7.4 billion in

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Temporary Liquidity Guarantee Program debt. 37 For the quarter
ending June 30, 2013, Ally Financial reported a total liquidity ratio of
18.7 percent.
Figure 4: Ally Financial Liquidity Ratio, June 2009-June 2013

•

Bank deposits: Bank deposits are the funds that consumers and
businesses place with a bank, and growth in deposits is an important
factor in the bank’s liquidity position. From December 2008 to
December 2012, Ally Bank saw its deposits grow from $19.2 billion to
$46.9 billion. Deposits accounted for 37 percent of Ally’s total funding
as of the fourth quarter of 2012, offering the company a low-cost
source of funding that is less sensitive to interest rate changes and
market volatility than other sources of funding.

37
FDIC created the Temporary Liquidity Guarantee Program in October 2008 to
encourage liquidity in the banking system by guaranteeing newly issued senior unsecured
debt of banks, thrifts, and certain holding companies and providing full coverage of noninterest-bearing deposit transaction accounts. In 2009, Ally Financial issued $7.4 billion in
debt under this program with maturity dates in October and December 2012. Ally Financial
repaid $2.9 billion on October 30, 2012, and the remaining $4.5 billion on December 19,
2012.

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•

Operating cash flow: From the first quarter of 2009 through the
second quarter of 2013, Ally Financial generated positive cash flow
from operating activities in all but 6 quarters (see fig. 5). However, as
the figure shows, cash flows have also varied greatly over this period.
In each of the last 3 years, the company repaid unsecured debt
maturities averaging more than $10 billion, a move that could improve
its cash flow by reducing the amount required to service its debt.
Analysts expect Ally’s annual unsecured maturities to be substantially
lower going forward, and the company reported annual maturities of
$5.6 billion or less for the years 2014 through 2018.

Figure 5: Ally Financial Operating Cash Flow, January 2009-June 2013

Ally Financial’s improving financial condition is reflected in its credit rating.
Ally’s long-term credit rating with two of the three largest credit rating
agencies has seen multiple upgrades since 2009. Currently, Ally’s longterm ratings with Moody’s, Standard and Poor’s, and Fitch Ratings are
B1, B+, and BB-, respectively. However, these ratings all remain below
investment grade.
According to analysts with whom we spoke, Ally’s mortgage unit, ResCap
impacted the company’s financial condition. Recent events are providing
a clearer picture of Ally Financial’s potential exposure to ResCap’s

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obligations. ResCap filed for bankruptcy in May 2012. 38 In June 2013, a
bankruptcy judge approved a settlement agreement that releases Ally
Financial from any and all legal claims by ResCap and many of its
creditors in exchange for $2.1 billion in cash from Ally Financial and its
insurers. 39 In June 2013, the bankruptcy judge also granted ResCap
permission to repay $1.1 billion in debt owed to Ally. 40 The agreement still
must be incorporated into ResCap’s formal plan for exiting bankruptcy
and be approved by the bankruptcy court. 41 Hearings on this agreement
and related motions are scheduled to take place later this year. According
to analysts with whom we spoke, knowing the amount of Ally Financial’s
final potential exposure to ResCap and that Ally Financial will no longer
support ResCap financially are positive developments for the company’s
future financial condition. Treasury officials told us that in their view, the
recent ResCap settlement agreement between the ResCap creditors
(other than the FDIC and the FHFA) and Ally Financial resolves the
uncertainty of the ResCap bankruptcy and Ally Financial’s potential
financial liabilities related to ResCap.

38

See Voluntary Petition, In re Residential Capital, LLC, No. 1:12-12020 (Bankr. S.D.N.Y.
May 14, 2012).
39

See Order Granting Debtors’ Motion for an Order Under Bankruptcy Code Sections
105(A) and 363(B) Authorizing the Debtors to Enter Into a Plan Support Agreement with
Ally Financial Inc., the Creditors’ Committee, and Certain Consenting Claimants, In re
Residential Capital, LLC, No. 1:12-12020 (Bankr. S.D.N.Y. June 26, 2013); Debtors’
Motion for an Order Under Bankruptcy Code Sections 105(A) and 363(B) Authorizing the
Debtors to Enter Into a Plan Support Agreement with Ally Financial Inc., the Creditors’
Committee, and Certain Consenting Claimants at 7, In re Residential Capital, LLC, No.
1:12-12020 (Bankr. S.D.N.Y. May 23, 2013). The agreement does not include claims
made by the Federal Housing Finance Agency and Federal Deposit Insurance
Corporation.

40

See Order Granting Debtors’ Motion for Entry of an Order Under 11 U.S.C. §§ 105 and
363 Authorizing the Debtors To Satisfy Certain Secured Claims at 2, In re Residential
Capital, LLC, No. 1:12-12020 (Bankr. S.D.N.Y. June 13, 2013).

41
See Joint Chapter 11 Plan Proposed by Residential Capital, LLC, et al., and the Official
Committee of Unsecured Creditors, In re Residential Capital, LLC, No. 1:12-12020 (Bankr.
S.D.N.Y. July 3, 2013).

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Treasury Is Working
to Exit from Its
Remaining
Investments in GM
and Ally Financial
Treasury Plans to Exit
from GM by Early 2014 but
Projects a Loss on its
Investment

Treasury invested over $51 billion in GM through AIFP. In exchange for
this assistance, Treasury received 60.8 percent of the common equity in
GM, $2.1 billion in preferred stock, and $7.1 billion in notes from GM.
Through September 18, 2013, Treasury had recovered about $35.21
billion of its investments in GM and reduced its ownership stake to 7.32
percent through three major actions. 42 As of September 18, 2013,
Treasury has recouped $37.75 billion from its GM and Ally Financial
investment. 43
First, Treasury participated in GM’s IPO in November 2010, selling about
412.3 million shares at an average price per share of approximately
$32.75. This sale generated $13.5 billion for Treasury and reduced its
ownership share to 32 percent. As we found in our 2011 report, by
participating in GM’s IPO, Treasury tried to fulfill two goals—to maximize
taxpayers’ return and to exit the company as soon as practicable. 44
Second, GM and Treasury entered into an agreement that allowed GM to
repurchase 200 million shares in December 2012. According to GM, as a
general matter, GM was interested in reducing Treasury’s interest in GM
and facilitating Treasury’s eventual complete exit from GM ownership.
GM purchased the shares at $27.50 per share, about 7.8 percent over the
market price of about $25.50. This generated about $5.5 billion in
revenue for Treasury and further reduced its ownership interest to just
over 22 percent. GM officials said that they determined the premium price
based on an arms-length negotiation between GM and Treasury.
According to GM officials, the decision to agree to a premium price
42

In May 2010, GM repaid to Treasury the $6.7 billion TARP loan.

43
The amount of recoupment does not include dividends, interest, and other income
Treasury has realized on its investments.
44

GAO-11-471.

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reflected the benefits GM and other stakeholders received from the
transaction, including increased knowledge as to when and how Treasury
was going to exit its holdings thereby eliminating the perceived
“overhang” on GM’s common stock price; mitigation of the stigma
associated with the “Government Motors” moniker that negatively
impacted customer perceptions; and the fact that the transaction was
accretive to earnings. Furthermore, as part of the transaction, Treasury
agreed to remove certain governance and reporting requirements.
Treasury announced in December 2012 that it planned to divest fully of its
GM common equity stake within 12-15 months, subject to market
conditions.
Third, to achieve its goal of fully divesting by 2014, Treasury has
developed and is implementing an exit strategy to sell its shares in
tranches. Similar to the process Treasury used to divest its ownership in
Citigroup, Treasury began placing its GM shares on the market in
tranches, or “dribbles,” for a specific time period, beginning in January
2013. 45 Treasury reports these sales after the end of each period for
selling a particular tranche. According to Treasury officials, in the case of
GM, the dribble approach is a better divestment method than discrete
large offerings given the remaining size of its equity holdings and time
frame in which it is planning to exit. Furthermore, the dribble approach
helps (1) secure the highest possible prevailing market price for
taxpayers, (2) limit the impact of additional supply in the market, and (3)
ensures that Treasury has flexibility to average the proceeds over time
and make adjustments if necessary. As of September 2013, Treasury has
sold over 811 million shares for more than $25 billion, leaving it with
101,336,666 shares which represent a 7.32 percent ownership stake in
GM. On September 26, 2013, Treasury announced it was launching a
third pre-defined written trading plan for its GM common stock.
Although Treasury has implemented a plan to divest itself of its ownership
stake in GM, it does not anticipate fully recouping its investments. In
September 2013, Treasury projected approximately at least a 19 percent
loss on its GM investment. The extent of the loss, however, will depend
on GM’s stock price. As shown in figure 6, the price of GM’s stock is not
at the level needed for Treasury to fully recoup its investment.

45

Treasury contracted with financial institutions to develop and implement the dribble
approach for selling the GM shares.

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Nevertheless, according to Treasury officials, Treasury has continued to
sell its shares in line with its guiding principle of exiting its TARP
investments as soon as practicable while maximizing return to taxpayers.
Doing so, however, has increased the break-even price—that is, the price
the stock must reach for Treasury to fully recoup its investment—for its
remaining shares. Based on our analysis, we estimate that GM’s stock
price would have to reach $156 per share for Treasury to fully recoup its
investment as of September 16, 2013. At the beginning of September
2013, GM’s stock was trading at around $36 per share.
Figure 6: Breakeven Price for GM Shares Needed for Treasury to Fully Recoup Its Investment

Treasury Is Working to
Exit from Ally Financial
and Faces Challenges
Unwinding Its Investments

Although Treasury’s ownership stake in Ally Financial has remained
unchanged for the last 3 years at about 74 percent, the company has
recently announced planned actions that will facilitate Treasury’s exit,
pending regulatory approval. As of September 2, 2013, Treasury has
recovered about $2.5 billion of the $16.3 billion invested in Ally Financial
from a sale of trust preferred shares. 46 Treasury’s remaining investment in
46

Treasury has also received about $3.4 billion in dividend payments from Ally Financial.

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Ally Financial consists of common stock and $5.9 billion in mandatory
convertible preferred shares. In August 2013, Ally Financial announced
plans, discussed below, to repurchase the mandatory convertible
preferred shares.
Treasury has stated that it would like to divest itself of its ownership stake
in Ally Financial in a manner that balances the speed of recovery with
maximizing returns for taxpayers. Furthermore, Treasury has stated that it
will unwind its remaining common stock investment through a sale of
stock (either public or private sale) or through future sales of assets. As of
September 2013, Treasury has announced the plan for unwinding its
preferred stock investments in Ally Financial, though not for its common
stock investment. According to Treasury officials, Treasury will announce
its precise plans for the common stock investment once it is ready to take
action.
To accelerate repayment of Treasury’s investment and strengthen its
longer term financial profile, Ally Financial announced in May 2012 that it
was undertaking two strategic initiatives. These initiatives were (1) the
discontinuation of providing financial support to its subsidiary ResCap
pursuant to the ResCap bankruptcy and (2) the sale of its international
auto finance business. ResCap’s mortgage business created significant
uncertainty for Ally Financial and thus an impediment to Ally Financial’s
ability to repay Treasury’s investment. Also, Ally Financial sought to sell
its international operations as a means to accelerate repayment plans to
Treasury. At the same time as Ally Financial’s announcement last year,
Treasury stated that the company’s two strategic initiatives would put
taxpayers in a stronger position to continue recovering their investment in
Ally Financial. As previously noted, Ally Financial achieved a settlement
agreement with the ResCap creditors, which was approved by the
bankruptcy court in June 2013. In addition, during the second quarter of
2013, Ally Financial completed the sale of its international auto finance
business in Europe and the majority of its finance operations in Latin
America. Ally Financial plans to complete the sale of its remaining
international assets—its operations in Brazil and its joint venture in
China—in late 2013 and 2014, respectively.
However, in exiting its Ally Financial investment, Treasury faces
challenges and considerations, including Ally Financial’s failure to meet
Federal Reserve capital requirements and competition from other
institutions, which may ultimately affect the price of Ally Financial stock
once the company is publicly traded.

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GAO-14-6 Troubled Asset Relief Program

Capital Requirements

In contrast to GM, Ally Financial is a regulated bank holding company that
must receive the Federal Reserve’s approval before it can repurchase its
preferred shares from Treasury. However, Ally Financial’s initial plan to
repurchase the mandatory convertible preferred shares stalled after the
Federal Reserve objected to its proposed capital plan in the spring 2013
Comprehensive Capital Analysis and Review (CCAR). The Dodd-Frank
Wall Street Reform and Consumer Protection Act requires the Federal
Reserve to conduct an annual supervisory stress test of bank holding
companies with $50 billion or more in total consolidated assets to
evaluate whether the companies have sufficient capital to absorb losses
resulting from adverse economic conditions. 47 As part of the stress test
for each company, the Federal Reserve projects revenue, expenses,
losses, and resulting post-stress test capital levels, regulatory capital
ratios, and the tier 1 common ratio under three scenarios (baseline,
adverse, and severely adverse). 48 In March 2013, the Federal Reserve
reported the results of its most recent supervisory stress test and of the
CCAR exercise. The Federal Reserve found that Ally Financial’s tier 1
common capital ratio fell below the required 5 percent under the severely
adverse scenario. Ally Financial was the only one of the 18 bank holding
companies tested that fell below this required level. 49
Further, as previously indicated, the Federal Reserve objected to Ally
Financial’s capital plans during the 2013 CCAR. 50 CCAR is an annual
exercise the Federal Reserve conducts to help ensure that financial
institutions have robust, forward-looking capital planning processes that
take into account their unique risks and sufficient capital to continue

47

Pub. L. No. 111-203, §165(i)(1)(A), 124 Stat. 1376, 1430 (2010) (codified at 12 U.S.C. §
5365(i)(1)(A)).
48

12 C.F.R. § 252.134(a)(2).

49
In 2013 18 bank holding companies were subject to the Dodd-Frank Act stress tests and
CCAR. These were Ally Financial Inc., American Express Company, Bank of America
Corporation, The Bank of New York Mellon Corporation, BB&T Corporation, Capital One
Financial Corporation, Citigroup Inc., Fifth Third Bancorp, The Goldman Sachs Group,
Inc., JPMorgan Chase and Co., KeyCorp, MorganStanley, The PNC Financial Services
Group, Inc., Regions Financial Corporation, State Street Corporation, Sun Trust Banks,
Inc., U.S. Bancorp, and Wells Fargo and Co.
50

In November 2011, the Federal Reserve issued a new regulation requiring large bank
holding companies to submit an annual capital plan. Capital Plans, 76 Fed. Reg. 74631
(Dec. 1, 2011) (codified at 12 C.F.R. § 225.8). The same 18 bank holding companies
subject to the Dodd-Frank stress tests were subject to CCAR.

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GAO-14-6 Troubled Asset Relief Program

operating during periods of economic and financial stress. 51 As part of the
CCAR process, the Federal Reserve evaluates institutions’ capital
adequacy; internal processes for assessing capital adequacy; plans to
make capital distributions, such as dividend payments or stock
repurchases; and other actions that affect capital. 52 The Federal Reserve
may object to a capital plan because of significant deficiencies in the
capital planning process or because one or more relevant capital ratios
would fall below required levels under the assumption of stress and
planned capital distributions. 53 If the Federal Reserve objects to the
proposed capital plan, the bank holding company is only permitted to
make capital distributions if the Federal Reserve indicates in writing that it
does not object and must resubmit the capital plan to the Federal
Reserve following remediation of these deficiencies. 54 Of the 18 bank
holding companies reviewed in 2013, the Federal Reserve objected to
Ally Financial’s and one other company’s capital plans. 55
According to the Federal Reserve, Ally Financial’s capital ratios did not
meet the required minimums under the proposed capital plan.
Specifically, the Federal Reserve reported that under stress conditions
Ally Financial’s plan resulted in a tier 1 ratio of common capital of 1.52
percent, which is below the required level of 5 percent under the capital
plan rule. According to the Federal Reserve report, these results
assumed that Ally Financial remained subject to contingent liabilities
associated with ResCap. The Federal Reserve required Ally Financial to

51

12 C.F.R. § 225.8(d).

52

12 C.F.R. § 225.8(e).

53

12 C.F.R. § 225.8(e)(2)(ii). A capital distribution is defined as a redemption or
repurchase of any debt or equity capital instrument, a payment of common or preferred
stock dividends, a payment that may be temporarily or permanently suspended by the
issuer on any instrument that is eligible for inclusion in the numerator of any minimum
regulatory capital ratio, and any similar transaction that the Federal Reserve determines to
be in substance a distribution of capital. 12 C.F.R. § 225.8(c)(2) .
54

12 C.F.R. § 225.8(d) (4), (e)(2)(iv).

55
The other bank holding company resubmitted a new capital plan under the Federal
Reserve’s regulation. After reviewing the plan, the Federal Reserve decided not to object
to the resubmitted capital plan.

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GAO-14-6 Troubled Asset Relief Program

resubmit a capital plan. 56 Ally Financial resubmitted its new capital plan to
the Federal Reserve in September 2013, and in accordance with federal
regulation, the Federal Reserve will have 75 days to review the plan. 57
On August 19, 2013, Ally Financial announced that it had entered into
agreements with certain accredited investors to issue and to sell to them
an aggregate of 166,667 shares of its common stock (private placement
securities) for an aggregate purchase price of $1 billion. Ally Financial did
not identify the investors. According to Ally Financial, the agreement
would strengthen the company’s common equity base and support its
capital plan resubmission to the Federal Reserve. The agreement
requires that the private placement close no later than November 30,
2013. Also on August 19, Ally Financial and Treasury entered into an
agreement under which Ally Financial is to repurchase all of the
mandatory convertible preferred shares. The agreement is conditioned on
Ally Financial receiving a non-objection by the Federal Reserve on its
resubmitted CCAR capital plan and the closing of the private placement
securities transaction.

Competition from Other
Lenders

Ally Financial faces growing competition in both consumer lending and
dealer financing from Chrysler Capital, GM Financial, and other large
bank holding companies. This competition may affect the future
profitability of Ally Financial, which could influence the share price of Ally
Financial once the company becomes publicly traded and thus the timing
of Treasury’s exit. Similar to its GM investment, the eventual amount of
Treasury’s recoupment on its Ally Financial investment will be determined
by the share price of Ally Financial stock.
Chrysler Capital: In February 2013, Chrysler announced that it had
entered into an agreement with Santander Consumer USA Inc., a

•

56
In its quantitative assessment, the Federal Reserve evaluated each bank holding
company’s ability to make all planned capital actions in its CCAR capital plan and maintain
poststress capital ratios of greater than 5 percent of tier 1 common capital and all required
regulatory minimum levels. The evaluations are based on the results of stress tests run by
the bank holding companies and poststress capital ratios estimated by the Federal
Reserve’s CCAR. In the qualitative assessment, the Federal Reserve evaluates the
analysis underlying the capital plan to determine whether it appropriately addresses
potential risks based on the reasonableness of the assumptions and analysis underlying
the capital plan, the robustness of the bank holding company’s capital adequacy process,
and corporate governance and controls in the capital planning process. 12 C.F.R. § 225.8.
57

12 C.F.R. § 225.8(e)(2)(i)(B).

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subsidiary of Banco Santander, S.A., that specializes in subprime
auto lending, to provide a full spectrum of auto financing services to
Chrysler Group customers and dealers under the name of Chrysler
Capital. Under the 10-year, private-label agreement, Santander
Consumer USA was to establish a separate lending operation
dedicated to providing financial services under the Chrysler Capital
name, including financing for retail loans and leases, new and used
vehicle inventory, dealership construction, real estate, working capital,
and revolving lines of credit. The agreement grants Santander
Consumer USA the right to a minimum percentage of Chrysler’s
subvention volume and the right to use the Chrysler Capital name for
its auto loan and lease offerings. 58 Santander Consumer USA will also
provide loans to Chrysler dealers to finance inventory, working capital,
and capital improvements. On May 1, 2013, Chrysler Capital started
its lending operations.
•

GM Financial: In 2009, GM acquired AmeriCredit Corporation
(AmeriCredit), a subprime automobile finance company, to serve its
subprime customers. AmeriCredit was renamed GM Financial and
made a wholly owned subsidiary of GM. Its target lending market is
lending to consumers who have difficulty securing auto financing from
banks and credit unions. According to GM officials, the purpose of GM
Financial is to drive incremental GM automobile sales by providing
solid and stable funding for GM dealers and consumers. GM Financial
would serve as a captive lender for GM, much as GMAC did. This
year, GM Financial increased its overall assets by purchasing Ally
Financial’s international assets in Europe and Latin America, including
the dealer financing arrangements in these countries.

•

Other bank holding companies: We compared the amount of Ally
Financial consumer auto lending with four large bank holding
companies (Bank of America Corporation, Capital One Financial
Corporation, JPMorgan Chase & Company, and Wells Fargo &
Company) that reported consumer automobile loans. These data do
not include all types of automobile financing, such as automobile
leasing and dealer financing, only retail consumer automobile loans

58
Subvention occurs when a manufacturer offers financial incentives through a finance
company conditioned upon the consumer financing the purchase of a vehicle or leasing a
car through a finance company.

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GAO-14-6 Troubled Asset Relief Program

for the time period. 59 As shown in figure 7, the dollar amount of
consumer auto loans Wells Fargo & Company and Capital One
Financial Corporation made increased from March 2011 through June
2013. However, Ally Financial remained the leader among the four
institutions for the same time period.
Figure 7: Dollar Amount of Consumer Auto Loans for Five Large Bank Holding
Companies, 2011-2013

Treasury officials noted that such competition could also be a benefit
because Ally Financial’s assets could be viewed as valuable to the other

59
Consumer automobile loans are defined as the Federal Reserve defines them for bank
holding company reporting purposes. See Instructions for Preparation of Consolidated
Financial Statements for Bank Holding Companies, Reporting Form FR Y-9C, Schedule
HC—Consolidated Balance Sheet. Automobile loans are all consumer loans extended for
the purpose of purchasing new and used passenger cars and other vehicles such as
minivans, vans, sport-utility vehicles, pickup trucks, and similar light trucks for personal
use. Id. at HC-C-13. These loans include both direct and indirect consumer automobile
loans as well as retail installment sales papers purchased by the bank from automobile
dealers. Id.

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competitors. Treasury officials noted that the value of Ally Financial can
be demonstrated by the recent private placement agreement. Specifically,
if Treasury sells its Ally Financial common stock at the share price agreed
to in the private placement agreement—$6,000 per share—Treasury
would receive a significant profit on its Ally Financial investment.

Agency and Third
Party Comments

We provided a draft of this report to FDIC, the Federal Reserve and
Treasury for their review and comment. In addition, we provided excerpts
of the draft report to Ally Financial, GM, and Chrysler Capital to help
ensure the accuracy of our report.
Treasury provided written comments which are reprinted in appendix II.
Treasury agreed with the report’s overall findings. In its written
comments, Treasury describes the auto industry’s recovery and the
progress Treasury has made in unwinding its investments in Ally
Financial and GM. Treasury also noted that it expects to complete the
exit from GM by the first quarter of 2014 and wind down the remaining
Ally Financial investment either by selling stock in a public or private
offering, or through future asset sales.
The Federal Reserve, Treasury, Ally Financial, GM, and Chrysler Capital
provided technical comments that we incorporated as appropriate. In its
technical comments, GM highlighted what third parties have suggested
could have happened had Treasury not provided assistance to the auto
industry, including the potential adverse effects on unemployment levels
and tax receipts of all levels of government. FDIC did not provide any
comments.
We are sending copies of this report to the appropriate congressional
committees. This report will also be available at no charge on our website
at http://www.gao.gov.
If you or your staffs have any questions about this report, please contact
me at (202) 512-8678 or clowersa@gao.gov. Contact points for our
Offices of Congressional Relations and Public Affairs may be found on

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GAO-14-6 Troubled Asset Relief Program

the last page of this report. Key contributors to this report are listed in
appendix III.

A. Nicole Clowers
Director
Financial Markets
and Community Investment

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GAO-14-6 Troubled Asset Relief Program

List of Committees
The Honorable Barbara Mikulski
Chairwoman
The Honorable Richard C. Shelby
Vice Chairman
Committee on Appropriations
United States Senate
The Honorable Tim Johnson
Chairman
The Honorable Mike Crapo
Ranking Member
Committee on Banking, Housing, and Urban Affairs
United States Senate
The Honorable Patty Murray
Chairman
The Honorable Jeff Sessions
Ranking Member
Committee on the Budget
United States Senate
The Honorable Max Baucus
Chairman
The Honorable Orrin G. Hatch
Ranking Member
Committee on Finance
United States Senate
The Honorable Hal Rogers
Chairman
The Honorable Nita Lowey
Ranking Member
Committee on Appropriations
House of Representatives
The Honorable Paul Ryan
Chairman
The Honorable Chris Van Hollen
Ranking Member
Committee on the Budget
House of Representatives

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GAO-14-6 Troubled Asset Relief Program

The Honorable Jeb Hensarling
Chairman
The Honorable Maxine Waters
Ranking Member
Committee on Financial Services
House of Representatives
The Honorable Dave Camp
Chairman
The Honorable Sander Levin
Ranking Member
Committee on Ways and Means
House of Representatives

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GAO-14-6 Troubled Asset Relief Program

Appendix I: Objectives, Scope, and
Methodology
Appendix I: Objectives, Scope, and
Methodology

This report is based on our continuing analysis and monitoring of the U.S.
Department of the Treasury’s (Treasury) activities in implementing the
Emergency Economic Stabilization Act of 2008 (EESA), which provided
GAO with broad oversight authorities for actions taken under the Troubled
Asset Relief Program (TARP). 1 Under TARP, Treasury established the
Automotive Industry Financing Program, through which Treasury
committed $51 billion to help General Motors Company (GM) and $16.3
billion to GMAC LLC, a financial services company that provides
automotive financing and that later became Ally Financial, Inc. (Ally
Financial).
This report examines (1) the financial condition of GM and Ally Financial
and (2) the status of Treasury’s investments in the companies as well as
its plans to wind down those investments.
To assess the financial conditions of GM, we analyzed net income,
operating income, operating cash flow, operating income, sales of
automobiles, GM’s share of the North American market, credit ratings,
and pension obligations and pension plan funding for GM’s U.S.
employees from 2008 through the second quarter (June 30) of 2013. For
Ally Financial, we reviewed the institution’s capital ratios, net income,
operating income, net interest spread, return on assets, nonperforming
assets ratio, liquidity ratio, bank deposits, operating cash flow, and credit
ratings, generally from 2008 through the second quarter (June 30) of
2013. To obtain information on the financial ratios and indicators used in
their analyses of GM’s or Ally Financial’s financial condition, we
interviewed staff from Treasury, the Board of Governors of the Federal
Reserve System (Federal Reserve), Federal Deposit Insurance
Corporation (FDIC), GM, Ally Financial, and analysts from the three
largest credit rating agencies as well as investment firms. To select
analysts from investment firms to interview, we identified analysts who
covered GM. We identified them using GM’s investor relations webpage
(http://www.gm.com/company/investors/analyst-coverage.html) and
selected four to contact based on an electronic search for automotive
equity analysts cited in reputable trade and business publications. We
reached out to four analysts and interviewed two. We also interviewed
analysts responsible for covering GM from one of the credit rating
agencies and analysts responsible for covering Ally from all three of the

1

Pub. L. No. 110-343, § 116, 122 Stat. 3765, 3783 (codified at 12 U.S.C. § 5226).

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Appendix I: Objectives, Scope, and
Methodology

credit rating agencies. The views of these analysts cannot be generalized
to all analysts from investment firms and credit rating agencies.
We reviewed past GAO reports, information from GM’s and Ally
Financial’s annual 10-K filings with the Securities and Exchange
Commission, reports and documentation from Treasury and the
companies, and data from SNL Financial from 2008 through the second
quarter (June 30) of 2013. For both GM and Ally Financial, we collected
information, generally from 2008 through the second quarter (June 30) of
2013, the most recent information that was publicly available. We have
relied on SNL Financial data for past reports, and we reviewed past GAO
data reliability assessments to ensure that we, in all material respects,
used the data in a similar manner and for similar purposes. For each data
source we reviewed the data for completeness and obvious errors, such
as outliers, and determined that these data were sufficiently reliable for
our purposes. We also reviewed the credit ratings from three rating
agencies for each of these companies. Although we have reported on
actions needed to improve the oversight of rating agencies, we included
these ratings because they are widely used by GM, Ally Financial,
Treasury, and market participants.
To examine the status of Treasury’s investments and its plans to wind
down those investments, we reviewed Treasury’s TARP reports, which
included monthly 105(a) and daily TARP updates on AIFP program data
for the time period from 2008 through September 2013. 2 We have used
Treasury’s data on AIFP in previous GAO reports. We determined that
the AIFP program data from Treasury were sufficiently reliable to assess
the status of the program. For example, we tested the Office of Financial
Stability’s internal controls over financial reporting as they related to our
annual audit of the office’s financial statements and found the information
to be sufficiently reliable based on the results of our audit of the TARP

2

Under EESA, every 30 days, Treasury must submit to Congress reports on actions taken
and funds obligated and spent during the reporting period as well as detailed financial
statements covering, among other items, agreements made, assets purchased,
transactions that occurred, and the valuation or pricing method used for each transaction.
§105(a), 122 Stat. at 3771-72.

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Appendix I: Objectives, Scope, and
Methodology

financial statements for fiscal years 2009, 2010, 2011, and 2012. 3 AIFP
was included in these financial audits. Using the AIFP program data, we
analyzed Treasury’s equity ownership and recovery of funds in GM and
Ally Financial for the time period from January 2009 to September 2013.
We reviewed the data for completeness and obvious errors, such as
outliers, and determined that these data were sufficiently reliable for our
purposes. For the divestment of GM equity, we interviewed Treasury and
GM officials on the December 2012 repurchase of GM shares and the
“dribble” strategy developed by Treasury. For analyzing Treasury’s exit
from Ally Financial, we reviewed Treasury and Federal Reserve
documentation, such as Treasury’s monthly reports to Congress,
Treasury’s contractual agreements for the mandatory convertible
preferred shares, and the proposed capital plan that Ally submitted to the
Federal Reserve. We also reviewed two publicly available reports from
the Federal Reserve on the Dodd-Frank Wall Street Reform and
Consumer Protection Act and capital plan analysis, Dodd-Frank Act
Stress Test 2013: Supervisory Stress Test Methodology and Results and
Comprehensive Capital Analysis and Review 2013: Assessment
Framework and Results. 4 In addition, we interviewed officials from
Treasury’s Office of Financial Stability, Federal Reserve, Federal Reserve
Bank of Chicago, FDIC, GM, and Ally Financial.
We conducted this performance audit from March 2013 to October 2013
in accordance with generally accepted government auditing standards.
Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our
findings and conclusions based on our audit objectives. We believe that
the evidence obtained provides a reasonable basis for our findings based
on our audit objectives.

3

See GAO, Financial Audit: Office of Financial Stability (Troubled Asset Relief Program)
Fiscal Years 2012 and 2011 Financial Statements, GAO-13-126R (Washington, D.C.:
Nov. 9. 2012); Financial Audit: Office of Financial (Troubled Asset Relief Program) Fiscal
Years 2011 and 2010 Financial Statements, GAO-12-169 (Washington, D.C.: Nov. 10,
2011); Financial Audit: Office of Financial Stability (Troubled Asset Relief Program) Fiscal
Years 2010 and 2009 Financial Statements, GAO-11-174 (Washington, D.C.: Nov. 15,
2010); and Financial Audit: Office of Financial Stability (Troubled Asset Relief Program)
Fiscal Year 2009 Financial Statements, GAO-10-301 (Washington, D.C.: Dec. 9, 2009).

4

Board of Governors of the Federal Reserve System, Dodd-Frank Act Stress Test 2013:
Supervisory Stress Test Methodology and Results, March 2013, and Board of Governors
of the Federal Reserve System, Comprehensive Capital Analysis and Review 2013:
Assessment Framework and Results, March 2013.

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GAO-14-6 Troubled Asset Relief Program

Appendix II: Comments from the Department
of the Treasury
Appendix II: Comments from the Department
of the Treasury

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GAO-14-6 Troubled Asset Relief Program

Appendix II: Comments from the Department
of the Treasury

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GAO-14-6 Troubled Asset Relief Program

Appendix III: GAO Contact and Staff
Acknowledgments
Appendix III: GAO Contact and Staff
Acknowledgments

GAO Contact

A. Nicole Clowers, (202) 512-8678, clowersa@gao.gov

Staff
Acknowledgments

In addition to the individual named above, Raymond Sendejas (Assistant
Director), Bethany Benitez, Emily Chalmers, Nancy Eibeck, Matthew
Keeler, Risto Laboski, Sara Ann Moessbauer, Marc Molino, and Roberto
Pinero made key contributions to this report.

(250716)

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GAO-14-6 Troubled Asset Relief Program

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