TARP Capital Exit Strategy (CaPP Public Institutions*)


Summary: Exiting the Treasury capital investment under the Capital Purchase Program (does not address Capital Assistance Program)

• Capital Purchase Program participants sold senior preferred stock and issued warrants to Treasury

• Repurchase by issuers of these securities is:

o governed by contracts with Treasury and

o subject to the Emergency Economic Stabilization Act of 2008 (Stabilization Act) and

o subject to the American Recovery and Reinvestment Act of 2009 (Recovery Act)

• Treasury has published limited information on the procedures for repurchasing/redeeming CaPP securities

• The American Recovery and Reinvestment Act (Recovery Act) amends provisions of the Emergency Economic Stabilization Act (Stabilization Act) applicable to the Capital Purchase Program – but Treasury has provided very limited information on the new law

* NOTE: warrants issued by private institutions were immediately exercised by Treasury

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