Opting Out of the Temporary Liquidity Guarantee Program: Not for the Faint of Heart

Manatt, Phelps & Phillips, LLP
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Acting under the authority granted by the Emergency Economic Stabilization Act of 2008, the Federal Deposit Insurance Corporation (?FDIC?) announced several initiatives

to reduce ?systemic risk? in our nation?s financial system. As part of these initiatives, the FDIC implemented its Temporary Liquidity Guarantee Program, or "TLG Program." The TLG Program is designed to preserve confidence and encourage liquidity in the banking system in order to ease lending to creditworthy businesses and consumers. The TLG program consists of two basic components: (i) a temporary guarantee of newly-issued senior unsecured debt and (ii) a temporary unlimited guarantee of funds in noninterest-bearing transaction accounts at FDIC-insured institutions.

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