Saturday, November 15, 2008
Written by Rob Klingler

There is no complete answer, and that’s exactly how the Treasury and banking regulators want it.

Lists of Applicants

There are several lists of applicants: the Wall Street Journal has a list, FIG Partners has a list, and SNL Financial (account required) keeps a running tally of public announcements of applications, completions and decliners.  However, all of these lists are necessarily unofficial and incomplete, as they only include companies that have made voluntary public announcements.

There are no requirements that companies announce whether they have applied for TARP Capital.  The Treasury and federal banking regulators have made very clear that they will not publicly disclose the names of who applied for TARP Capital, or the names, if any, of companies that are ultimately turned down for TARP Capital.  (As noted by Assistant Treasury Secretary Kashkari on Monday, several opportunities will be made to allow applicants to withdraw their applications rather than facing a formal denial of applications.)  This confidentiality helps protect the overall stability of the banking system.

List of TARP Capital Recipients

Section 114(a) of Emergency Economic Stabilization Act of 2008 requires public disclosure of the completion of TARP purchases within two business days of the actual purchase.  (This is also confirmed in the Treasury’s FAQ, which provides “Treasury will provide electronic reports detailing any completed transactions, as required by the Emergency Economic Stabilization Act of 2008, within 48 hours.”)

The Treasury’s list of completed transactions is available here, and this is the only official list.  There is, however, a significant lag time between preliminary approval and completion of any given capital infusion.  The first TARP Capital infusions were not consummated until October 28th.  No further TARP Capital purchases were completed until November 14th (and the number and volume of the infusions that occurred on November 14th are not clear as of the time of this post).

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Wednesday, November 5, 2008
Written by Rob Klingler

We have added two new pages to the site for banks looking to see how other bankers are handling certain TARP Capital issues.  (We’ve always found bankers prefer to listen to other bankers rather than lawyers.)

For examples of press releases of banks that have decided to publicly announce that they will not be participating in the TARP Capital program, see our TARP Capital Decliners.

For examples of proxy statements where banks have decided to seek shareholder approval to put in blank check preferred stock, see our TARP Capital Proxies.