TARP 30-Day Report Card

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It is just short of a month since the Treasury and the federal banking regulators first announced the implementation of programs authorized by the Emergency Economic Stabilization Act, including the Capital Purchase Program (CPP). Since then, the Treasury has funded CPP commitments to the first nine institutions and news of commitments to an array of regional and smaller banks has been made public. The selection process remains somewhat murky with press reports shedding some light on the process. However, other than anecdotal evidence or unofficial commentary, the Treasury has offered a minimum of guidance as to what factors are guiding the decision-making process.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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