SIGTARP: Report Quarterly to Congress | July 25, 2012

PECTO INS R G AL EN CI ER E A P L S

T R M O A U R B G L E RO D A F P SSET RELIE

Office of the Special Inspector General Q3 for the Troubled Asset Relief Program SIGTARPSIGTARP 2012 SIGTARPSIGTARP Advancing Economic Stability Through Transparency, Coordinated Oversight, and Robust Enforcement SIG-QR-12-03

202.622.1419 Hotline: 877.SIG.2009 Quarterly Report to Congress [email protected] July 25, 2012 www.SIGTARP.gov MISSION

SIGTARP’s Mission is to advance economic stability by promoting the efficiency and effectiveness of TARP management, through transparency, through coordinated oversight, and through robust enforcement against those, whether inside or outside of Government, who waste, steal, or abuse TARP funds.

STATUTORY AUTHORITY

SIGTARP was established by Section 121 of the Emergency Economic Stabilization Act of 2008 (“EESA”) and amended by the Special Inspector General for the Troubled Asset Relief Program Act of 2009 (“SIGTARP Act”). Under EESA and the SIGTARP Act, the Special Inspector General has the duty, among other things, to conduct, supervise, and coordinate audits and investigations of any actions taken under the Troubled Asset Relief Program (“TARP”) or as deemed appropriate by the Special Inspector General. In carrying out those duties, SIGTARP has the authority set forth in Section 6 of the Inspector General Act of 1978, including the power to issue subpoenas.

Office of the Special Inspector General for the Troubled Asset Relief Program General Telephone: 202.622.1419 Hotline: 877.SIG.2009 [email protected] www.SIGTARP.gov Contents

Executive Summary 3 Oversight Activities of SIGTARP 10 SIGTARP Recommendations on the Operation of TARP 11 Report Organization 11 Section 1 The Office of the Special Inspector General for the Troubled Asset Relief Program 13 SIGTARP Creation and Statutory Authority 15 SIGTARP Oversight Activities Since the April 2012 Quarterly Report 15 The SIGTARP Organization 33 Section 2 TARP Overview 35 TARP Funds Update 37 Financial Overview of TARP 42 Housing Support Programs 63 Financial Institution Support Programs 87 Asset Support Programs 128 Automotive Industry Support Programs 144 Section 3 AIG Remains in TARP as the Largest TARP Investment 151 Introduction 153 Rise and Fall of AIG Prior to TARP 154 Changes at AIG After the Government Bailout 156 AIG’s Current Businesses 160 AIG’s Changing Regulatory Environment 164 Section 4 TARP Operations and Administration 169 TARP Administrative and Program Expenditures 171 Current Contractors and Financial Agents 172 Section 5 SIGTARP Recommendations 181 Recommendations from SIGTARP’s Audit of the Hardest Hit Fund 183 Recommendations from SIGTARP’s Audit of the Net Present Value Test’s Impact on the Home Affordable Modification Program 186 Update on Recommendation Regarding Hardest Hit Fund Information Security 187

Endnotes 206 Appendices A. Glossary 228 B. Acronyms and Abbreviations 232 C. Reporting Requirements 235 D. Transaction Detail 239 E. Cross-Reference of Report to the Inspector General Act of 1978 320 F. Public Announcements of Audits 321 G. Key Oversight Reports and Testimony 322 H. Correspondence 324 I. Organizational Chart 333 Executive Summary 4 special inspector general I troubled asset relief program quarterly report to congress I July 25, 2012 5

Last quarter, SIGTARP reported that TARP’s legacies include white-collar crime that SIGTARP is uncovering and stopping. This quarter, SIGTARP agents, along with our law enforcement partners, arrested the CEO of TARP applicant the Bank of the Commonwealth (“BOC”) of Norfolk, Virginia, and four other bank executives for their alleged role in a massive fraud that contributed to the bank’s 2011 collapse and the financial crisis.i The Federal Reserve Board Office of Inspector General (“FRB OIG”) found that the bank’s regulator identified fundamental weaknesses with the bank as early as 2000. However, the regulator did not take advantage of multiple opportunities to “take stronger supervisory action by implementing more aggressive enforcement actions.” Bank failures have profound effects, including taxpayer losses for failed TARP banks;ii losses to the FDIC’s fund that insures customer deposits; and losses to communities that suffer from decreased access to lending for homes, small businesses, and education. Bank failures fueled by fraud erode public confidence in the financial system — confidence already down because of public perception of risky banking practices, soaring executive compensation, and recent scandals. BOC’s failure and the criminal charges provide lessons to be learned for the future. Banks should not wait for the Government to catch fraud. Banks must better regulate risky practices, strengthen internal controls, and eliminate opportunities to conceal losses. Banking regulators must be vigilant in their examinations and enforcement to discover risky practices and potential fraud that could threaten the safety and soundness of banks. This is particularly true at the more than 300 banks left in TARP in which taxpayers are investors. Only then will confidence in our nation’s banking system and a sense of accountability be restored.

Bank Failures Bank failures skyrocketed following the onset of the financial crisis, from zero to five failures a year between 1995 and 2007, to an average of 107 per year from 2008 through 2011. According to FDIC, 2010 was the high-water mark for bank failures post-crisis, with 157 bank failures. The pace of bank failures has slowed since the 2010 peak, but continues at an elevated rate, with 38 bank failures so far this year. While the crisis in real estate markets undoubtedly factored into the spike in bank failures, internal problems such as poor corporate governance, weak risk man- agement, and weak internal controls were contributing factors as well. The Federal Reserve Bank of Philadelphia stated in a 2009 article, “People often presume that the challenging economy and sluggish housing market were the key drivers behind these failures, particularly since many tended to be geographically clustered in distressed regions. While the external economic environment certainly was influen- tial, it was rarely a standalone factor in a bank’s demise. The root causes of problems are often traced to inherent risk exposures or management weaknesses that become

i in November 2008, Bank of the Commonwealth applied for $28 million in TARP funds, but was asked by its banking regulator to withdraw its application. ii as of June 30, 2012, 17 TARP banks have failed. 6 special inspector general I troubled asset relief program

more pronounced under stressful conditions and ultimately impair an institution’s ability to weather adverse conditions.” This is borne out in SIGTARP’s criminal investigations of failed TARP applicant and recipient banks.

SIGTARP’s Criminal Investigations SIGTARP has found in some of its criminal investigations that the financial crisis was a crossroads for many bank executives, particularly those at regional or community banks, whose business models focused predominantly on real estate loans. Thousands of bank executives faced bank losses during the financial crisis without turning to fraud. Those bank executives told the truth about losses and non-performing loans and adequately reserved for future losses or wrote off losses. Others turned to crime. For some bankers committing fraud, the sudden availability of TARP funds was seen as a way to play the float in concealing past due loans as bankers waited for a market upturn. These bankers viewed the financial crisis as an opportunity to extend their fraud by exploiting our nation’s vulnerability. The financial crisis also unveiled fraud that had been ongoing for years, as shrinking capital and increasing delinquent loans left bankers with nowhere to hide. For example, the criminal charges against five BOC executives and seven co- conspirators highlight a massive bank fraud at the highest levels of management, fueled by greed that included an unsuccessful attempt to use TARP funds.iii BOC was the eighth largest bank failure in 2011, with an FDIC-estimated loss of $268 million. The indictment alleges that for years the bankers fraudulently masked the bank’s condition out of fear that the bank’s declining health would negatively impact investor and customer confidence. According to the charges, many of the bank’s loans were funded and administered without regard to industry standards or the bank’s own internal controls. FRB OIG reported on the causes of the bank’s failure, including corporate governance weaknesses, insufficient risk management practices, and pervasive internal control weaknesses that when combined with deteriorating real estate markets led to rapid asset quality deterioration. The bank failed to acknowledge the extent of its problem loans and adequately reserve for losses. FRB OIG reported that the bank’s supervisor, FRB Richmond, identified the bank’s fundamental weaknesses in 2000, but did not take early and decisive action to resolve those weaknesses. The regulator identified broad authority in the hands of CEO Edward Woodard, an ineffective board that had not monitored risks, and a weak internal audit function. FRB OIG reported that the failure to implement appropriate risk management and internal controls created the opportunity for the bank to engage in unsafe and unsound practices designed to mask the bank’s true financial condition. In FRB OIG’s opinion, more forceful supervisory action through enforcement actions or downgrades could have mitigated losses.

iii Federal indictments are only charges and not evidence of guilt. A defendant is presumed to be innocent until and unless proven guilty. quarterly report to congress I July 25, 2012 7

These findings, along with allegations in the criminal charges resulting from SIGTARP’s investigation, provide an opportunity for banks and their regulators to take advantage of lessons learned. This is particularly true for banks in which taxpayers still hold a TARP investment. Banks should not wait for the Government to catch these schemes. Banks should engage in strong corporate governance and internal controls to expose risky practices that could threaten the bank’s health. Banking regulators have an opportunity to strengthen their examination processes, including educating their examiners on identifying indicators of fraud schemes in the BOC case and other SIGTARP cases that could impact the safety and soundness of a bank. These schemes, as described below, are not isolated to the few examples cited in this summary.

Common Fraud Schemes to Mask a Bank’s Financial Conditioniv

Extend and Pretend Schemes SIGTARP has uncovered “extend and pretend” schemes, by which bank insiders create the illusion that a past-due loan is current. Methods include extending the due date of a payment, changing loan terms, and creating new loans that bankers know will be used not for the stated purpose, but instead to generate proceeds to bring delinquent loans current. The bankers do not expect any payments to be made on the new loans and eventually write off losses on the new loans. In these schemes, bankers falsify the books and records to avoid reporting past-due loans and to increase the amount of new loans. BOC allegedly engaged in an “extend and pretend” scheme. CEO Edward Woodard, his son bank officer Troy Brandon Woodard, and executive vice presi- dents Simon Hounslow and Stephen Fields were charged with overdrawing deposit accounts to make loan payments, extending new loans or additional principal on existing loans to cover payment shortfalls, changing the terms of loan agreements to make loans appear current, and using funds from related entities to make loan payments. According to the criminal charges, the bank funded new loans without current borrower financial statements, without adequate collateral, and without current appraisals for collateral. BOC loan officer Jeremy Churchill pled guilty to submitting false information for new loans to developer Dwight Etheridge (also charged), who allegedly used the proceeds to pay down his existing delinquent loan. Another SIGTARP investigation demonstrating an “extend and pretend” scheme involved failed, TARP-approved, First Community Bank in Hammond, Louisiana. There, former CEO Reginald Harper and developer Troy Fouquet pled guilty to fraud in which they knowingly hid Fouquet’s delinquent loans through a number of methods to extend and pretend. This fraud impacted the bank’s $3.3 million TARP application, which the bank withdrew after Treasury approval.

iv The discussion of charges that follows is based on Federal indictments. Federal indictments are only charges and not evidence of guilt. A defendant is presumed to be innocent until and unless proven guilty. SIGTARP has noted where the defendant pled guilty. 8 special inspector general I troubled asset relief program

Fraudulent Construction Draws Banks may fund fraudulent draws on construction loans for work not completed and use the proceeds to make it appear that delinquent loans are current. BOC CEO Woodard is charged with funding eight fraudulent construction draws to developer Dwight Etheridge, who was also charged, and who allegedly used the proceeds to pay down his past-due BOC loans. BOC loan officer Churchill and Etheridge’s vice president Recardo Lewis pled guilty to this scheme. BOC vice president Stephen Fields is charged with funding fraudulent construction draws to customers Menden and George Hranowskyj (who both pled guilty), without Fields verifying that work was completed.v

Bank-Financed Sales of Bank-Owned Property or Troubled Loans BOC CEO Woodard and three other bank executives are charged with funneling bank-owned property (such as property the bank took over in foreclosure) to certain borrowers who were delinquent on loans, to the detriment of the bank. It is alleged that in exchange for preferential treatment on delinquent loans and no-questions- asked new loans, Menden (who pled guilty) used “straw purchasers” who were Menden’s employees to buy bank-owned property. It is alleged that these “sales” allowed the bank to take the properties off the bank’s books. The bank allegedly concealed that it funded these purchases. As a result of another SIGTARP investigation, Jerry Williams, CEO and chair- man of TARP applicant Orion Bank of Naples, Florida, Thomas Hebble, executive vice president, and Angel Guerzon, senior vice president, were sentenced to prison for concealing that the bank financed the sale of notes secured by non-performing mortgages. This fraudulently took the loans off the bank’s books.

Roundtrip Transactions Creating the Illusion of Capital Infusions In these schemes a bank’s books fraudulently reflect that an investor infused capital into the bank by buying stock. The capital infusion is not genuine because the buyer actually used the bank’s own money to purchase the stock. The three Orion Bank executives and bank borrower Francesco Mileto were sentenced to prison for concealing the bank’s financing of the sale of Orion stock to Mileto’s associates. Their fraud created the illusion of a $15 million capital infusion into the bank.

Delay and Pray Schemes In a typical “delay and pray” scheme, bankers with knowledge of facts relating to the likelihood of loans not being repaid delay recognizing those facts in their bank’s books. This scheme, as with all the schemes above, typically involves falsification of the bank’s books and records, and fraudulently concealing the status of loans from regulators to make it appear that loans are current or that they are likely to be repaid.

v In some instances bank insiders personally benefit from the fraud. BOC CEO Edward Woodard and his bank officer son Troy Brandon Woodard were charged with having the bank fund fraudulent draws for construction on a bank branch when the true costs were for renovating the son’s residence. quarterly report to congress I July 25, 2012 9

As a result of an ongoing SIGTARP investigation, Ebrahim Shabudin, execu- tive vice president, and Thomas Yu, senior vice president, of TARP recipient United Commercial Bank (“UCB”) of San Francisco, California, were charged with hiding the bank’s true financial condition from investors, depositors, regulators, Treasury, and the bank’s auditor. According to the indictment, the objective of the fraud scheme was to conceal, delay, and avoid publicly reporting the bank’s number of impaired loans and the bank’s true loan loss. The indictment charged that the defendants used a variety of fraudulent accounting maneuvers and techniques to conceal that they falsified the bank’s books and records. It is alleged that they delayed downgrading the risk ratings of certain loans and falsified the bank’s books and records, falsely describing or omitting information necessary to describe the likelihood that certain loans would be repaid and the value of the collateral and repossessed assets. UCB was the first TARP bank to fail. Taxpayers will suffer a complete loss on the $298 million TARP investment. The FDIC estimates that deposit insurance fund losses will be $2.5 billion.

Preventing Fraud and Bringing Accountability Banks and their regulators have an opportunity to implement lessons learned from the schemes SIGTARP uncovered in the Bank of the Commonwealth and other cases. They can proactively detect and prevent fraudulent practices before a bank fails and bring accountability where fraud is found. As was evident in the BOC case, these schemes can impact the safety and soundness of the bank and may ultimately contribute to the bank’s failure. Bank examiners should therefore be on the alert to detect these and other schemes SIGTARP has uncovered and be vigilant in enforcement. Banks should not wait for Government action. Banks themselves must embrace the importance of self-regulation through effective corporate governance, risk management, and a “checks and balances” system of controls. Bank executives should expound these principles by virtue of their leadership and fiduciary duties. Banks and bank regulators should report fraud to law enforcement. Banks and their regulators must demonstrate strong will, capability, and commitment to detecting and preventing bank failures and fraud. In doing so, they can reassure American taxpayers of accountability and increase market confidence in our banking system. SIGTARP is committed to uncovering fraud related to TARP and bringing justice and accountability to the American taxpayers. Confidence and public trust in banks and banking regulators are fundamental to ensuring stability in our financial system. 10 special inspector general I troubled asset relief program

Oversight Activities of SIGTARP SIGTARP actively strives to fulfill its audit and investigative functions. Since its inception, SIGTARP has issued 19 published reports on audits and evaluations as of June 30, 2012. Two audit reports have been published since the end of last quarter: “Factors Affecting Implementation of the Hardest Hit Fund Program” and “The Net Present Value Test’s Impact on the Home Affordable Modification Program.” Section 1 of this report, “The Office of the Special Inspector General for the Troubled Asset Relief Program,” discusses these two recently released reports. SIGTARP is a white-collar law enforcement agency. As of July 12, 2012, SIGTARP had more than 150 ongoing criminal and civil investigations, many in partnership with other law enforcement agencies in order to leverage resources throughout the Government. SIGTARP takes its law enforcement mandate seriously, working hard to deliver the accountability the American people demand and deserve. SIGTARP’s investigations have delivered substantial results, including:

• criminal charges against 91 individuals, including 64 senior officers (CEOs, owners, founders, or senior executives) of their organizations • criminal convictions of 67 defendants, of whom 28 have been sentenced to prison (others are awaiting sentencing) • civil cases against 51 individuals (including 37 senior officers) and 26 entities (in some instances an individual will face both criminal and civil charges) • orders of restitution and forfeiture and civil judgments entered for more than $4 billion. This includes restitution orders entered for $3.7 billion, forfeiture orders entered for $126.9 million, and civil judgments and other orders entered for $281.9 million. Although the ultimate recovery of these amounts is not known, SIGTARP has already assisted in the recovery of $160.8 million • savings of $553 million in TARP funds that SIGTARP prevented from going to the now-failed Colonial Bank

Although much of SIGTARP’s investigative activity remains confidential, over the past quarter there have been significant public developments in several of SIGTARP’s investigations. See Section 1 of this report, “The Office of the Special Inspector General for the Troubled Asset Relief Program,” for a description of recent developments, including those involving Bank of the Commonwealth, Colonial BancGroup, Inc./Taylor, Bean & Whitaker; FirstCity Bank, Orion Bank, First Community Bank, and others. quarterly report to congress I July 25, 2012 11

SIGTARP Recommendations on the Operation of TARP One of SIGTARP’s oversight responsibilities is to provide recommendations to Treasury and the banking regulators related to TARP to facilitate effective oversight and transparency and to prevent fraud, waste, and abuse. SIGTARP has made 105 recommendations. Section 5 of this report, “SIGTARP Recommendations,” provides updates on existing recommendations and summarizes the implementation of previous recommendations. This quarter, Section 5 includes discussions of SIGTARP’s recommendations to Treasury included in its audit report “Factors Affecting Implementation of the Hardest Hit Fund Program,” released April 12, 2012, and in its audit report “The Net Present Value Test’s Impact on the Home Affordable Modification Program,” released June 18, 2012. Section 5 also provides an update on an earlier SIGTARP recommendation regarding information security in the Hardest Hit Fund program.

Report Organization The report is organized as follows:

• Section 1 discusses the activities of SIGTARP. • Section 2 details how Treasury has spent TARP funds so far and contains an explanation or update of each program. • Section 3 discusses American International Group, Inc. (“AIG”), which remains in TARP as the largest TARP investment. • Section 4 describes the operations and administration of the Office of Financial Stability, the office within Treasury that manages TARP. • Section 5 discusses SIGTARP’s recommendations with respect to TARP.

The report also includes numerous appendices containing, among other things, figures and tables detailing all TARP investments through June 30, 2012, except where otherwise noted. 12 special inspector general I troubled asset relief program The Office of the Special Section 1 Inspector General for the Troubled Asset Relief Program 14 special inspector general I troubled asset relief program quarterly report to congress I July 25, 2012 15

SIGTARP Creation and Statutory Authority The Office of the Special Inspector General for the Troubled Asset Relief Program (“SIGTARP”) was created by Section 121 of the Emergency Economic Stabiliza- tion Act of 2008 (“EESA”) and amended by the Special Inspector General for the Troubled Asset Relief Program Act of 2009 (“SIGTARP Act”). Under EESA and the SIGTARP Act, SIGTARP has the responsibility, among other things, to conduct, supervise, and coordinate audits and investigations of the purchase, management, and sale of assets under the Troubled Asset Relief Program (“TARP”) or as deemed appropriate by the Special Inspector General. SIGTARP is required to report quar- terly to Congress to describe SIGTARP’s activities and to provide certain informa- tion about TARP over that preceding quarter. EESA gives SIGTARP the authorities listed in Section 6 of the Inspector General Act of 1978, including the power to obtain documents and other information from Federal agencies and to subpoena reports, documents, and other information from persons or entities outside the Government. Under the authorizing provisions of EESA, SIGTARP is to carry out its duties until the Government has sold or transferred all assets and terminated all insurance contracts acquired under TARP. In other words, SIGTARP will remain “on watch” as long as TARP assets remain outstanding.

SIGTARP Oversight Activities Since the April 2012 Quarterly Report SIGTARP continues to fulfill its oversight role on multiple parallel tracks: investigating allegations of fraud, waste, and abuse related to TARP; conducting oversight over various aspects of TARP and TARP-related programs and activities through 19 published audits and evaluations, and 105 recommendations as of June 30, 2012; and promoting transparency in TARP and the Government’s response to the financial crisis as it relates to TARP.

SIGTARP Investigations Activity SIGTARP is a white-collar law enforcement agency. As of July 12, 2012, SIGTARP had more than 150 ongoing criminal and civil investigations, many in partnership with other law enforcement agencies in order to leverage resources throughout the Government. SIGTARP takes its law enforcement mandate seriously, working hard to deliver the accountability the American people demand and deserve. SIGTARP’s investigations have delivered substantial results, including:

• criminal charges against 91 individuals, including 64 senior officers (CEOs, owners, founders, or senior executives) of their organizations • criminal convictions of 67 defendants, of whom 28 have been sentenced to prison (others are awaiting sentencing) 16 special inspector general I troubled asset relief program

• civil cases against 51 individuals (including 37 senior officers) and 26 entities (in some instances an individual will face both criminal and civil charges) • orders of restitution and forfeiture and civil judgments entered for more than $4 billion. This includes restitution orders entered for $3.7 billion, forfeiture orders entered for $126.9 million, and civil judgments and other orders entered for $281.9 million. Although the ultimate recovery of these amounts is not known, SIGTARP has already assisted in the recovery of $160.8 million • savings of $553 million in TARP funds that SIGTARP prevented from going to the now-failed Colonial Bank

SIGTARP investigates white-collar fraud related to TARP. These investiga- tions include, for example, accounting fraud, securities fraud, insider trading, bank fraud, mortgage fraud, mortgage modification fraud, false statements, obstruction of justice, money laundering, and tax crimes. Although the majority of SIGTARP’s investigative activity remains confidential, over the past quarter there have been significant public developments in several SIGTARP investigations.

The Bank of the Commonwealth SIGTARP agents, along with its law enforcement partners, arrested four former executives of Bank of the Commonwealth (“BOC”), including CEO and chairman of the board Edward Woodard, his son Troy Brandon Woodard, executive vice presidents Simon Hounslow and Steven Fields, along with two bank customers, Thomas Arney and Dwight Etheridge. On July 11, 2012, a Federal grand jury sitting in the Eastern District of Virginia returned a 25-count indictment against the six individuals for their alleged roles in a massive fraud scheme that contributed to the failure of the bank. Each charge contained in the indictment carries a maximum penalty of 30 years in prison, if convicted. BOC was a community bank headquartered in Norfolk, Virginia, that failed in September 2011. It was the eighth largest bank failure in the country that year, and the largest bank failure in Virginia since 2008. Six other defendants have been charged (five of whom pled guilty) in this case for a total of 12 defendants. The FDIC estimates that BOC’s failure will cost the deposit insurance fund more than $268 million. SIGTARP has been investigating this case because in November 2008, BOC sought $28 million in TARP funds. BOC’s Federal banking regulator asked the bank to withdraw the TARP application. The four senior bank officers were charged on July 11, 2012, with fraud schemes to conceal past-due loans and remove foreclosed property from the bank’s books. The indictment details how friends of the bank received sweetheart deals in return for helping mask the bank’s true financial condition. The indictment also details how bank insiders benefitted personally from various schemes. According to the indictment, BOC more than doubled its assets from 2005 to 2009. This was largely through brokered deposits, a financial tool that allows inves- tors to pool their money and receive higher rates of returns. Because of the high quarterly report to congress I July 25, 2012 17

volatility of these deposits, an institution must remain well-capitalized to accept and renew brokered deposits. The indictment alleges that BOC funded and administered many loans dur- ing this period without following industry standards or the bank’s own internal controls, and by 2008, the volume of the bank’s troubled loans and foreclosed real estate soared. From 2008 to 2011, BOC executives (Edward Woodard, Hounslow and Fields) allegedly utilized various methods to fraudulently mask the bank’s true financial condition out of fear that the bank’s declining health would negatively impact investor and customer confidence and affect the bank’s ability to accept and renew brokered deposits. To fraudulently hide BOC’s troubled assets, bank insiders allegedly overdrew demand deposit accounts to make loan payments, extended new loans or additional principal on existing loans to cover payment shortfalls, changed the terms of loan agreements to make loans appear current, and used funds from related entities (sometimes without authorization from the borrower) to make loan payments. In addition, the BOC executives allegedly hid millions of dollars of non-performing loans from the bank’s board of directors. The BOC executives also allegedly provided preferential treatment to troubled borrowers, including Arney, Etheridge, and others, to purchase bank-owned proper- ty. The borrowers were already having difficulty making payments on their existing loans and the financing allowed the borrowers to convert these non-earning assets into earning assets. In some instances, according to the indictment, these new loans exceeded the purchase price of the property, which resulted in the borrowers obtaining cash at closing that they used to make payments on their other loans at the bank and for their own personal purposes. In addition, BOC executives caused the bank to fund loans to troubled borrowers to purchase or attempt to purchase properties owned by Edward Woodard and Troy Brandon Woodard. Additionally, the indictment alleges that Edward Woodard and Hounslow caused the bank to fund three loans totaling $11 million without approval of the board of directors and falsely represented in bank records that the board had approved the loans. BOC subsequently charged off $9 million of these loans as a loss. In addition, Edward Woodard and Troy Brandon Woodard allegedly caused BOC to pay fraudulent invoices purportedly for construction costs for a bank branch when the true costs were incurred for renovations to Troy Brandon Woodard’s personal residence. Six other individuals have been charged (five of whom pled guilty) in this ongo- ing investigation:

• On April 12 and July 12, 2012, respectively, business partners Eric H. Menden and George P. Hranowskyj pled guilty to engaging in a fraud scheme that contributed to the failure of BOC. Menden and Hranowskyj admitted to performing favors for BOC insiders by using the proceeds of loans provided by BOC insiders to purchase BOC-owned properties and properties owned by BOC insiders. Menden and Hranowskyj further admitted to submitting construction draw requests to the bank for amounts owed to subcontractors 18 special inspector general I troubled asset relief program

that were inflated or for work that was not completed. Menden and Hranowskyj admitted knowing the loan proceeds obtained from these draw requests were to be used solely for renovating the property but instead they used the proceeds for their own personal purposes. At the time the bank failed, Menden and Hranowskyj owed the bank approximately $41 million and the total loss attributed to the loans outlined in court was over $13 million. Menden and Hranowskyj also pled guilty to a separate six year tax fraud scheme that cost state and Federal Government over $12 million and investors more than $8 million. At sentencing on September 26, 2012, Menden faces a maximum of 15 years in Federal prison and possible restitution of up to $49 million. Hranowskyj, scheduled to be sentenced on October 15, 2012, faces a maximum of 25 years in Federal prison. • On May 9, 2012, Jeremy C. Churchill, a BOC vice president and commercial loan officer, pled guilty to conspiracy to commit bank fraud. According to court documents, Churchill admitted that, under the direction of a BOC co- conspirator, Churchill submitted loan requests to the bank to provide more than $1 million to Tivest Development and Construction LLC (“Tivest”) and Genesis Staffing, Inc. (“Genesis”), companies owned by Etheridge, who was having difficulty keeping current on $8 million in loans he guaranteed at the bank. BOC approved these loan requests based on false representations by Churchill and a BOC co-conspirator that the funds would be used to pay pre-development costs for an office tower project and operational costs at Genesis. To the contrary, Etheridge allegedly used the proceeds to make payments on other loans at the bank. BOC subsequently fully charged off these $1 million in loans as a loss. Churchill also admitted to requesting that BOC provide a $4.1 million loan to Tivest to be used to purchase an incomplete condominium project from the owners who were delinquent on their loan at the bank. BOC would have suffered a substantial loss had it foreclosed on this property. Churchill admitted that he and a bank co-conspirator used approximately half the loan proceeds to pay down the underlying loan on the property. Churchill faces a maximum penalty of five years in prison when he is sentenced on August 24, 2012. • On May 15, 2012, Recardo Lewis, a former vice president at Tivest, pled guilty to conspiracy to commit bank fraud. Lewis, allegedly at the direction of Etheridge, submitted eight draw requests to the bank on construction loans that fraudulently inflated the amounts owed to contractors and included costs for work that was not completed. Etheridge allegedly used the funds from these draws to make interest payments on other loans at the bank, to operate other businesses, and for other personal purposes. BOC subsequently charged off approximately $1.3 million of this $4.1 million loan as a loss. Lewis faces a maximum penalty of five years in prison when he is sentenced on September 19, 2012. • On September 15, 2011, Natallia Green, a former employee of Menden and Hranowskyj, pled guilty to making a false statement to BOC in a loan application. According to court documents, on August 12, 2010, Green submitted an application to the bank requesting a home loan in the amount of quarterly report to congress I July 25, 2012 19

$108,000 to purchase a piece of property owned by the bank. Green admitted that she knowingly lied in her application by falsely stating that she had $29,000 in cash in banks and admitted that she provided an altered bank statement to support her false assertion. On January 25, 2012, Green was sentenced to five years’ probation, and was ordered to pay $106,519 in restitution. • On August 10, 2011, Maria Pukhova, a former employee of Menden and Hranowskyj, was charged with making a false statement on a loan application to BOC. The information alleges that, on April 30, 2010, Pukhova defrauded the bank by making false representations on a loan application.

This ongoing investigation is being conducted by SIGTARP, the United States Attorney’s Office for the Eastern District of Virginia, the Federal Bureau of Investigation (“FBI”), the Internal Revenue Service Criminal Investigation (“IRS- CI”), and the Federal Deposit Insurance Corporation Office of Inspector General (“FDIC OIG”).

The Colonial BancGroup, Inc./Taylor, Bean & Whitaker On June 15, 2012, Delton de Armas, the former chief financial officer of Taylor, Bean & Whitaker (“TBW”), was sentenced by the U.S. District Court for the Eastern District of Virginia to five years in prison. De Armas previously pled guilty to conspiracy to commit bank and wire fraud and making false statements for his role in a $2.9 billion fraud scheme that led to the failures of TBW and Colonial Bank (“Colonial”). As previously reported, Lee Bentley Farkas, the former chairman of TBW, was convicted at trial in 2011 of 14 counts of conspiracy, and bank, securities, and wire fraud, and sentenced to 30 years imprisonment. On June 20, 2012, the U.S. Court of Appeals for the Fourth Circuit upheld Farkas’ conviction. Colonial Bank was initially approved to receive $553 million in TARP funding that SIGTARP prevented from going to the bank. De Armas admitted that he and others engaged in a scheme to defraud finan- cial institutions that had invested in TBW’s wholly-owned lending facility, Ocala Funding (“Ocala”). Shortly after Ocala was established, de Armas learned that inad- equate assets were backing its loans. This collateral deficit increased to more than $700 million by June 2008. De Armas knew that a subordinate sent false collateral reports to Ocala investors that misrepresented the collateral deficit. De Armas acknowledged that he and former TBW chief executive officer Paul Allen also provided false explanations to investors and regulators about the deficit in Ocala’s collateral. De Armas further admitted that he directed a subordinate to inflate an accounts receivable balance on the books of TBW, which inflated TBW’s financial statements. De Armas admitted knowing that these false financial statements were provided to the Government National Mortgage Association (“Ginnie Mae”) and the Federal Home Loan Mortgage Corporation (“Freddie Mac”) for their determi- nation to renew TBW’s authority to sell and service securities guaranteed by Ginnie Mae and Freddie Mac. De Armas also admitted to reviewing and editing a letter sent by Allen to Ginnie Mae that contained false statements regarding the reason for TBW’s delay in providing audited financial statements to Ginnie Mae. 20 special inspector general I troubled asset relief program

Six additional defendants pled guilty and were sentenced to prison in 2011 for their roles in the fraud scheme. Allen was sentenced to 40 months in prison; Catherine Kissick, the former senior vice president of Colonial Bank, was sen- tenced to eight years in prison; Desiree Brown, the former treasurer of TBW, was sentenced to six years in prison; Raymond Bowman, the former president of TBW, was sentenced to 30 months in prison; Sean Ragland, a former senior financial analyst at TBW, was sentenced to three months in prison; and Teresa Kelly, the former operations supervisor in Colonial Bank’s Mortgage Warehouse Lending Division, was sentenced to three months in prison. This case was investigated by SIGTARP, the FBI, FDIC OIG, the Department of Housing and Urban Development Office of Inspector General (“HUD OIG”), the Federal Housing Finance Agency Office of Inspector General (“FHFA OIG”), the Securities and Exchange Commission (“SEC”), and IRS-CI, and was prosecut- ed by the U.S. Department of Justice Criminal Division’s Fraud Section and the U.S. Attorney’s Office for the Eastern District of Virginia.

FirstCity Bank On June 26, 2012, Clayton A. Coe, the former vice president and senior commercial loan officer at FirstCity Bank (“FirstCity”), pled guilty in U.S. District Court for the Northern District of Georgia to bank fraud and to making a false statement on his tax return. Coe faces a maximum sentence of 33 years in prison and a fine of up to $1.1 million at his sentencing on September 18, 2012. In February 2009, FirstCity unsuccessfully sought $6.1 million in Federal Government assistance through TARP. FirstCity failed and was seized by Federal and state authorities on March 20, 2009. According to court documents, as senior commercial loan officer, Coe was primarily responsible for recommending to FirstCity’s loan committee whether to approve commercial loans to real estate developers. Coe admitted to defrauding FirstCity by causing FirstCity’s loan committee to approve an $800,000 loan to a borrower in connection with a real estate development transaction that provided a personal financial benefit to Coe. Coe concealed from FirstCity’s loan committee that the borrower used the loan proceeds to purchase land lots from a company owned by Coe and his wife and that the Coes had purchased these lots from the true owner at a lower sales price on the same day the loan to the borrower closed. Coe also admitted to failing to report to the Internal Revenue Service $476,000 in commissions he earned for loans he originated as FirstCity’s senior commercial loan officer. As previously reported, on October 21, 2011, Mark A. Conner, the former president, chief executive officer, and chairman of FirstCity, pled guilty to con- spiracy to commit bank fraud and perjury. Conner is scheduled to be sentenced on August 9, 2012, and faces a maximum of 12 years in Federal prison, a lifetime ban from the banking industry, a requirement to forfeit $7 million, and an order to pay significant restitution to the FDIC and victim banks. Robert E. Maloney, FirstCity’s former in-house counsel, has also been charged with conspiracy to commit bank fraud, making false entries in the records of an FDIC-insured financial institution, quarterly report to congress I July 25, 2012 21

and conspiracy to commit money laundering. A trial date has not been set for Maloney. The case is being investigated by SIGTARP, the United States Attorney’s Office for the Northern District of Georgia, the FBI, IRS-CI, and FDIC OIG.

Orion Bank On June 12, 2012, Jerry J. Williams, former president, chief executive officer, and board chairman of Orion Bank (“Orion Bank”) and its holding company, Orion Bancorp, Inc., was sentenced by the U.S. District Court for the Middle District of Florida to 72 months in Federal prison. As previously reported, in February 2012, Williams pled guilty to conspiracy to commit bank fraud and making false statements to Federal regulators arising from his participation in a bank fraud scheme involving Orion Bank. In October 2008, Orion Bancorp unsuccessfully sought $64 million in TARP funds. As part of the sentence, the court ordered Williams to pay $5.76 million in restitution to victims and ordered an additional hearing to determine restitution to be paid by Williams to FDIC. Williams admitted that, after Orion Bank failed to raise capital as instructed by Federal banking regulators, he conspired with two other Orion Bank executives, Thomas Hebble (former executive vice president), Angel Guerzon (former senior vice president), and a former Orion Bank borrower, Francesco Mileto, to mislead state and Federal regulators into believing that Orion Bank was financially healthier than it truly was. The conspirators committed their scheme in part by restructuring distressed assets of Orion Bank to fraudulently create the illusion that certain of the bank’s non-performing loans were performing loans. The conspirators furthered their scheme by secretly financing the sale of Orion Bancorp stock to Mileto, which created the false impression to regulators of a legitimate capital infusion that considerably improved the bank’s capital position. Williams admitted to providing regulators with false documents and statements about Orion Bank’s capital position and amount of capital raised. As previously reported, Hebble, Guerzon, and Mileto pled guilty to their partici- pation in the fraud and received prison sentences of 30 months, 24 months, and 65 months, respectively. Hebble and Guerzon were also each ordered to pay $33.5 million in restitution to FDIC and Mileto was ordered to pay $65.2 million in restitution to FDIC ($33.5 million of which is to be paid jointly and severally with Guerzon and Hebble). The court also ordered forfeiture of $2 million as to Mileto. Florida’s Office of Financial Regulation closed Orion Bank on November 13, 2009, and appointed FDIC as receiver. FDIC estimates that Orion Bank’s failure will cost the deposit insurance fund more than $600 million. The case is being investigated by SIGTARP, the U.S. Attorney’s Office for the Middle District of Florida, the FBI, IRS-CI, the Federal Reserve Board Office of Inspector General (“FRB OIG”), and FDIC OIG. 22 special inspector general I troubled asset relief program

First Community Bank On April 26, 2012, Reginald R. Harper pled guilty in the U.S. District Court for the Eastern District of Louisiana to conspiracy to commit bank fraud. Harper’s co-conspirator, Troy A. Fouquet, previously pled guilty on March 15, 2012. The charges against Harper and Fouquet arose from their orchestration of a fraudulent scheme to conceal delinquent, non-performing loans at First Community Bank of Hammond, Louisiana (“First Community Bank”) by creating new “sham” loans. Harper was the former president, chief executive officer, and loan officer of First Community Bank. Fouquet was a Louisiana real estate developer. Harper arranged for First Community Bank to provide more than $2 million in loans to Fouquet in 2004 to purchase land and build houses on the land. However, they were unable to identify a sufficient number of qualified buyers for the houses. In response, Harper and Fouquet devised various cover-up schemes to avoid reporting the delinquent loans made by Harper to Fouquet. For example, they used “nominee” loans and “straw” borrowers to apply for new loans from First Community Bank, which Harper authorized, and then used the proceeds to pay off the original loans made to Fouquet. Harper and Fouquet’s misconduct caused First Community Bank to suffer severe financial losses. As a result of Harper’s and Fouquet’s fraudulent activities, First Community Bank submitted a false “call report” (a report meant to disclose the bank’s true financial condition) to its regulator, which later affected the bank’s application for TARP funds. First Community Bank ultimately withdrew its TARP application, despite being approved to receive $3.3 million in TARP funds. At sentencing, Fouquet and Harper each face a maximum of five years in Federal prison and a fine. Harper and Fouquet are scheduled to be sentenced on October 25, 2012. The case is being investigated by SIGTARP, the U.S. Attorney’s Office for the Eastern District of Louisiana, and the FBI.

John Farahi and David Tamman (New Point Financial Services, Inc.) On June 4, 2012, John Farahi pled guilty in the U.S. District Court for the Central District of California to charges of mail fraud, loan fraud, selling unregistered securities, and conspiracy to obstruct justice, all relating to his ownership and operation of an investment firm known as New Point Financial Services, Inc. (“New Point”). Farahi is scheduled to be sentenced on January 14, 2013. He faces a maximum penalty of 75 years in Federal prison, a fine of up to $1.75 million, and possible restitution of approximately $7 million. Farahi was the former co-owner and president of New Point. Farahi admitted that, from 2005 until 2009, he operated a Ponzi scheme through New Point in which he convinced potential investors to invest their money with him by falsely assuring them their money would be invested in safe investments. Farahi also told investors that New Point would invest in the corporate bonds of companies backed by TARP and other Government programs and that the investors risked losing their money only if the U.S. government failed. Many of the investors who approached New Point about investing were members of the Iranian-Jewish community who quarterly report to congress I July 25, 2012 23

had listened to Farahi’s daily Farsi-language investment radio show. Farahi admit- ted that New Point generally did not place the investors’ money in safe investments. Instead, Farahi used investor money to support his lavish lifestyle, to make pay- ments to previous New Point investors in order to perpetuate the Ponzi scheme, and to finance and cover trading losses on speculative options trades. Farahi acknowledged that the scheme caused investor losses of more than $7 million, while prosecutors reserved the right to argue to the court that losses to victims exceeded $20 million. Facing massive trading losses at the end of 2008, Farahi borrowed millions of dollars through lines of credit at banks, including TARP recipient banks Bank of America and U.S. Bank. Farahi admitted to making false statements to these banks about his financial situation in connection with these borrowings. Farahi also admitted to illegally selling unregistered securities and then conspiring with David Tamman, New Point’s former attorney, to obstruct an investigation by the SEC into Farahi’s illegal sale of the unregistered securities. As previously reported, Tamman was indicted in December 2011 for his role in allegedly obstructing the SEC inves- tigation. Tamman is scheduled to go on trial on October 23, 2012. This case is being investigated by SIGTARP, the United States Attorney’s Office for the Central District of California, and the FBI.

Frederic Alan Gladle and Glen Alan Ward (aka Brandon Michaels) On May 3, 2012, Frederic Alan Gladle was sentenced by the U.S. District Court for the Western District of Texas to 61 months in Federal prison, following his previous guilty plea to bankruptcy fraud and aggravated identity theft. The charges stem from Gladle’s operation of a foreclosure-rescue scam involving more than 1,100 distressed homeowners and several banks, including TARP banks. As part of the sentence, the court also ordered Gladle to pay $214,259 in restitution and to forfeit $87,901. Gladle admitted that, from 2007 to 2011, he promised homeowners whose properties were being foreclosed upon that, in exchange for a monthly fee, he would postpone the foreclosure for at least six months. After collecting fees from a homeowner, Gladle would have the homeowner execute a deed granting a small interest in their property to a random debtor in bankruptcy whose name Gladle found in bankruptcy records. Neither the homeowner nor the bankruptcy debtor was aware of Gladle’s misuse of the debtor’s bankruptcy petition. Gladle further defrauded the bank that had issued the loan to the homeowner by providing the bank a copy of the debtor’s bankruptcy petition showing that the debtor owned an interest in the homeowner’s property that the lender was attempting to foreclose upon. Upon receipt of these documents, the lender was legally obligated to and did terminate the foreclosure proceeding against the homeowner. As a result, multiple lenders, including TARP recipient banks Bank of America, Wells Fargo Bank and U.S. Bank, incurred costs and delays while attempting to collect money that was owed to them. Gladle admitted that he collected more than $1.6 million in fees from homeowners through this scam. 24 special inspector general I troubled asset relief program

A defendant charged in the Northern and Central Districts of California for a separate, similar foreclosure-rescue scheme, Glen Alan Ward, was arrested in Canada in May 2012. Ward has been a fugitive sought by U.S. federal authorities since 2000. According to court documents, Ward (aka Brandon Michaels) is alleged to have worked with and taught Gladle how to perpetrate the foreclosure-rescue scheme. Ward is currently being detained in Canada pending his extradition to the United States. The case was investigated by SIGTARP, the United States Attorney’s Office for the Central District of California, the FBI, and the U.S. Trustee’s Office.

American Home Recovery On May 17, 2012, after a 10-day jury trial in U.S. District Court for the Southern District of New York, Isaak Khafisov was found guilty of conspiracy, mail fraud and wire fraud for perpetrating a scheme to defraud distressed homeowners and lenders. At sentencing on September 6, 2012, Khafisov faces a maximum sentence of 80 years in Federal prison. According to court documents and statements made during court proceedings, around spring 2008, Khafisov founded a mortgage modification business named American Home Recovery (“AHR”). Khafisov and AHR salespeople made false assertions to fraudulently induce distressed homeowners to pay AHR thousands of dollars in up-front fees for mortgage modifications. Specifically, Khafisov and AHR informed homeowners that they had been “pre-approved” for a mortgage modifica- tion by their lenders; that AHR would ensure participation in the TARP-funded Making Home Affordable program; and that AHR could obtain better interest rates and lower monthly fees on their mortgage. Khafisov and AHR also falsely promised to return the up-front fees if AHR did not secure a mortgage modification desired by the homeowner. They also falsely claimed that AHR was affiliated with govern- ment agencies and programs established by the Economic Stimulus Act of 2008 and that AHR possessed unique expertise in mortgage modifications and had special relationships with lenders. Khafisov also directed distressed homeowners to stop paying their mortgages and to pay fees to AHR instead. After receiving up-front fees from the distressed homeowners, Khafisov and AHR did little or no work to try to renegotiate the homeowners’ mortgages. As a result, many AHR clients were foreclosed upon by lenders and lost hundreds of thousands of dollars in fees. Jaime Cassuto and David Cassuto founded AHR with Khafisov. As previously reported, they each entered a guilty plea on April 2, 2012, relating to this mortgage modification scheme. In March 2011, Raymond Pampillonio, a former AHR em- ployee, also pled guilty in connection with this scheme. This case is being investigated by SIGTARP, the U.S. Attorney’s Office for the Southern District of New York, and the FBI.

The Shmuckler Group, LLC On April 10, 2012, Howard R. Shmuckler pled guilty in the U.S. District Court for the Eastern District of Virginia to wire fraud relating to his ownership and operation of a fraudulent mortgage modification business known as The Shmuckler quarterly report to congress I July 25, 2012 25

Group, LLC (“TSG”). Shmuckler admitted to falsely portraying himself to TSG clients as an attorney licensed to practice in Virginia and to misrepresenting to clients that TSG’s loan modification success rate was 97%. Shmuckler also assured clients that their loans would be successfully modified. False representations by Shmuckler and TSG employees induced homeowners to pay TSG fees ranging from $2,500 to $25,000. Court records indicate that Shmuckler instructed clients to terminate contact with their mortgage companies and to stop making payments to their lenders. TSG never facilitated a modification of the mortgages referenced in the statement of facts admitted to by Shmuckler. On June 25, 2012, Shmuckler was sentenced to 90 months in Federal prison, a sentence that will run consecutive to his current term of imprisonment that resulted from a conviction in the U.S. District Court for the District of Columbia. Restitution to FDIC will be set by the court at a later date. As previously reported, on November 18, 2010, the Prince George’s County State’s Attorney’s Office in Maryland obtained a 30-count indictment against Shmuckler for conspiracy, theft, and operating a business without a license, in con- nection with a mortgage modification scam. On February 3, 2012, Shmuckler ap- peared before a judge in the Circuit Court for Prince George’s County, Maryland, where he waived his right to a jury trial and consented to certain facts in connec- tion with the mortgage modification scam. At the next hearing, which had been postponed pending Shmuckler’s sentencing by the Eastern District of Virginia, the Maryland judge will rule on the charge. Shmuckler faces a maximum sentence of 15 years on the theft charge. The case brought in Federal court in Virginia resulted from a joint investiga- tion conducted by SIGTARP, the FBI, FDIC OIG, and the U.S. Attorney’s Office for the Eastern District of Virginia. The case brought in state court in Maryland resulted from a joint investigation by SIGTARP, the Office of the State’s Attorney for Prince George’s County, and the Maryland Department of Labor Licensing and Regulation’s Financial Regulation Division.

CFSA Home Solutions On May 16, 2012, Andrew M. Phalen pled guilty to felony charges for his role in connection with a mortgage modification scheme. On June 6, 2012, Phalen was sentenced by the Superior Court of California to one year in jail and five years of supervised probation and prohibited by the Court from associating with the other four defendants in the case and from engaging in services relating to loan modification, refinancing, and foreclosure. As previously reported, Phalen, Jacob J. Cunningham, Justine D. Koelle, Dominic A. Nolan, and John D. Silva were arrested in California on March 2, 2012, and charged with allegedly operating a mortgage modification scheme that defrauded hundreds of victims. According to court documents, between January 2009 and March 2012, the defendants allegedly enticed homeowners to participate in a fraudulent loan modification program by making numerous false misrepresentations to homeowners through advertisements, websites, promotional letters, and direct conversations. The misrepresentations allegedly included statements that: (1) HAMP would apply 26 special inspector general I troubled asset relief program

to homeowners’ circumstances; (2) the defendants had a 100% success rate in obtaining mortgage modifications for homeowners; and (3) homeowners would be refunded their paid fees if the defendants could not modify a homeowner’s loan. To evade detection by law enforcement, the defendants are accused of changing the names, phone numbers, and addresses of sham companies they operated. One company name the defendants used was CSFA Home Solutions. Cunningham, Koelle, Nolan, and Silva have been charged with multiple felony counts of violating California state law, including conspiracy to charge illegal up- front fees for mortgage modifications, conspiracy to commit forgery, grand theft by false pretenses, theft from an elder, and money laundering. The charges are cur- rently pending. The case is being investigated by SIGTARP, Orange County, California, District Attorney’s Office, U.S. Secret Service (“Secret Service”), Huntington Beach Police Department, California Department of Real Estate, Orange County Probation Department, Orange County Sheriff’s Department, Costa Mesa Police Department, Irvine Police Department, and Santa Ana Police Department.

Flahive Law Corporation On May 16, 2012, Michael Kent Johnson entered a plea of no contest to misdemeanor conspiracy for his participation in a fraudulent loan modification scheme perpetrated through the Flahive Law Corporation (“FLC”). FLC was a law firm operated by Gregory and Cynthia Flahive. Johnson acted as the firm’s managing attorney. Johnson is required to serve three years of probation and 200 hours of community service, to pay restitution of $10,560, and to not participate in loan modification services. As previously reported, Johnson, Gregory Flahive, and Cynthia Flahive were arrested by SIGTARP agents and its law enforcement partners on March 8, 2012, pursuant to an indictment returned by a California grand jury. According to the indictment and court documents, from January 2009 to December 2010, FLC promoted its loan modification services to homeowners through advertisements, including a television infomercial. FLC falsely represented that experienced lawyers would negotiate with banks on behalf of homeowners seeking modifica- tions, including under HAMP, misrepresented that FLC’s law firm status would give them extra leverage when negotiating with such banks, and overstated FLC’s rate of success in obtaining loan modifications on behalf of homeowners. FLC al- legedly collected up-front fees of up to $2,500 from homeowners for loan modifica- tion services that were never performed. Johnson admitted to creating and using manipulative fee agreements in order to collect up-front fees from homeowners for loan modification service. Gregory Flahive and Cynthia Flahive are scheduled to go on trial on September 10, 2012. The case is being investigated by SIGTARP, the California Attorney General, Folsom Police Department, Rancho Cordova Police Department, and the El Dorado Sheriff’s Department. quarterly report to congress I July 25, 2012 27

Legacy Home Loans and Real Estate As previously reported, on December 1, 2011, Magdalena Salas, Angelina Mireles, and Julissa Garcia, the owner, manager, and CEO, respectively, of Legacy Home Loans and Real Estate (“Legacy Home Loans”) in Stockton, California, were arrested on charges of conspiracy, grand theft, and false advertising for a mortgage modification scam. On July 10, 2012, all three defendants pled guilty in the San Joaquin County, California, Superior Court to conspiracy to collect upfront fees for mortgage modifications. Salas also pled guilty to felony foreclosure fraud. According to the charges and other information presented in court, the defen- dants collected thousands of dollars in up-front fees from distressed homeowners in Central California after making false promises to obtain loan modifications for the homeowners. The defendants falsely promised homeowners that they would receive loan modifications regardless of their financial situation through Federal Government programs allegedly referred to as the “Obama Plan.” The defendants also allegedly falsely overstated their success rate, made false money-back guaran- tees, and falsely represented that attorneys would work on the modifications. The defendants advertised similar false promises in flyers, billboards, television and ra- dio, in English and Spanish. The modification services promised by the defendants allegedly were never carried out and many clients ended up losing their homes. On July 11, 2012, the three defendants were sentenced to probation and ordered to obey all laws, pay restitution, and complete 240 hours of community service. Salas was also ordered not to engage in any professional services requiring a license that she does not possess. The court will determine the restitution to be paid by the defendants at a hearing scheduled for August 30, 2012. The case is being investigated by SIGTARP, the California Attorney General’s office, the San Joaquin District Attorney’s office, the California Department of Real Estate, and the Stockton Police Department.

Oxford Collection Agency On May 11, 2012, Richard Pinto and his son, Peter Pinto, each pled guilty in the U.S. District Court for the District of Connecticut to using their debt collection company, Oxford Collection Agency, Inc. (“Oxford”), to defraud business clients and a TARP-recipient bank. The Pintos both pled guilty to wire fraud and conspiracy to commit wire fraud, bank fraud, and money laundering, and face a maximum of 35 years in Federal prison and a fine of up to $20 million at sentenc- ing, which is scheduled for September 13, 2012. According to court documents and statements made in court, Richard Pinto was chairman of the board of directors at Oxford and Peter Pinto was Oxford’s president and chief executive officer. From January 2007 through March 2011, Oxford had agreements with business clients to collect debts from debtors, to report such collections to the clients and to remit the collected payments back to the clients. The clients would pay Oxford a portion of the monies collected by Oxford as a fee. The Pintos admitted to collecting funds from debtors on behalf of clients and failing to remit those funds to the clients. The Pintos also admitted to 28 special inspector general I troubled asset relief program

creating false documents and employing other deceptive means to cover up their failure to remit collected funds to clients and their improper use of the funds. The Pintos further admitted to causing Oxford to secure a line of credit from TARP-recipient Webster Bank without disclosing to the bank that Oxford was defrauding its clients and had significant outstanding payroll taxes. In the ensu- ing years, according to court documents and statements made in court, the Pintos continued to defraud Webster Bank by inducing the bank to increase the line of credit to $6 million by withholding Oxford’s true financial condition and submitting falsified financial records to the bank. The Pintos laundered funds from the line of credit by remitting those funds to clients in order to maintain the clients’ business and thereby continue the scheme against the clients. The fraudulent scheme has led victims to lose more than $10 million. The case is being investigated by SIGTARP, IRS-CI, the FBI, the U.S. Attorney’s Office for the District of Connecticut, and the Connecticut Securities, Commodities and Investor Fraud Task Force.

Lynn Nunes On April 24, 2012, Lynn Nunes, a New York mortgage broker, pled guilty in the U.S. District Court for the Eastern District of New York to conspiracy to commit fraud against mortgage lenders, including subsidiaries of TARP recipient banks Wells Fargo & Company, SunTrust Banks, Inc., and JPMorgan Chase & Co. From January 2005 through October 2010, Nunes and others recruited persons interested in purchasing property but who had insufficient assets and income to secure a mortgage. Nunes prepared fraudulent mortgage applications for the potential purchasers by falsely inflating their bank account balances and income to make the applicants appear more creditworthy. Nunes submitted these falsified loan applications to the mortgage lenders, which issued mortgage loans in reliance on the false applications. The lenders suffered losses on the properties when many of the purchasers subsequently defaulted on the mortgage loans. The case is being investigated by SIGTARP, the United States Attorney’s Office for the Eastern District of New York, and the FBI.

Robin Brass On April 25, 2012, Robin B. Brass pled guilty in the U.S. District Court for the District of Connecticut to mail fraud for defrauding investors of more than $1 million. Brass is scheduled to be sentenced on July 27, 2012, and faces a maximum sentence of 20 years in Federal prison and a fine of up to $250,000. Brass admitted to devising a scheme to defraud investors by taking their money and failing to invest it as promised. From March 2009 through November 2011, Brass successfully solicited funds from investors by falsely representing herself as a highly successful investment advisor, guaranteeing investors against losses, and promising them a good rate of return on their investment. Brass used some of the investor funds to pay off other investors (to keep the scheme going) and to pay personal expenses for herself and her family, including her mortgage at Bank quarterly report to congress I July 25, 2012 29

of America, a TARP-recipient bank. To perpetuate the fraud scheme, Brass sent fraudulent account statements to investors that made it appear that their invest- ments were performing well. The case was investigated by SIGTARP, the United States Attorney’s Office for the District of Connecticut, U.S. Postal Inspection Service (“USPIS”), the FBI, and with assistance from the State of Connecticut Department of Banking as part of the Connecticut Securities, Commodities and Investor Fraud Task Force.

Joint Task Force to Combat Mortgage Modification Scams As previously reported, SIGTARP formed a joint task force (“Task Force”) with the Consumer Financial Protection Bureau (“CFPB”) and Treasury to leverage resources in investigating, combating, and shutting down mortgage modification scams related to the Home Affordable Modification Program (“HAMP”), and to provide awareness to vulnerable homeowners. The Task Force issued its initial consumer fraud alert in December 2011 to educate homeowners on how to recognize and avoid these scams. Since that time, SIGTARP has learned that mortgage modification fraudsters are targeting the Armed Services community. On May 24, 2012, the Task Force issued an additional fraud alert to combat the rise in mortgage modification scams specifically targeting members of the Armed Services community who are seeking to apply for mortgage assistance through HAMP. The fraud alert warns servicemembers about the existence of these scams and advises them how to report fraud. The alert also provides servicemembers with a list of resources available to obtain more information and to obtain assistance with mortgage-related questions. The alert is reproduced in the back of this report.

SIGTARP Audit Activity SIGTARP has initiated 28 audits and three evaluations since its inception. As of June 30, 2012, SIGTARP has issued 19 reports on audits and evaluations. Among the ongoing audits and evaluations in process are reviews of: (i) Treasury’s and the Federal banking regulators’ evaluation of applications submitted by recipients of TARP funds to exit TARP by refinancing into the Small Business Lending Fund; (ii) the Special Master’s 2012 decisions on executive compensation at American International Group, Inc., General Motors Corporation, and Ally Financial, Inc.; and (iii) Treasury’s role in General Motors’ decision to top up the pension plan for hourly workers of Delphi Corporation.

Recent Audits Released

Factors Affecting Implementation of the Hardest Hit Fund Program On April 12, 2012, SIGTARP released the audit report, “Factors Affecting Implementation of the Hardest Hit Fund Program.” Conducted in response to a request by Congressman Darrell Issa, this audit assessed the TARP program the Hardest Hit Fund (“HHF”). 30 special inspector general I troubled asset relief program

SIGTARP found that after two years, the Hardest Hit Fund has experienced significant delay in providing help to homeowners due to several factors including a lack of comprehensive planning by Treasury and a delay and limitation in participa- tion in the program by large servicers and the Government-sponsored enterprises (“GSEs”) (Fannie Mae and Freddie Mac). As of December 31, 2011, the latest data available when the report was issued, the Hardest Hit Fund had spent only $217.4 million to provide assistance to 30,640 homeowners — approximately 3% of the TARP funds allocated to HHF and approximately 7% of the minimum number of homeowners that the state HFAs estimate helping over the life of the program, which ends in 2017. Nearly all (98%) of the help provided to homeowners under the Hardest Hit Fund has been related to unemployment assistance or reinstatement of past due amounts, the only types of assistance for which the GSEs had directed servicers to participate. The great bulk (78%) of the HHF help to homeowners has been for unemployment assistance. Unless there is a drastic change in the assistance the GSEs and their conservator, the Federal Housing Finance Agency, will support, the Hardest Hit Fund may be much narrower in scope and scale than what was origi- nally expected due to the lack of servicer and GSE support for certain programs. Without significant change, while the Hardest Hit Fund may be able to reach unemployed homeowners as was originally intended, it is likely to be limited in addressing negative equity for homeowners who are underwater. SIGTARP found that Treasury consistently applied its criteria to choose states to participate in the first three rounds of funding for HHF. However, in the second round, it was unclear why Treasury determined that states with high percentages of their population in counties with an unemployment rate greater than 12% were economically distressed, but that states with 11% unemployment were not. The cutoff for Treasury’s selection of states in Round Two was not transparent. For the fourth round, no new states were selected. Rather, Treasury nearly doubled the funds four days before the expiration of Treasury’s TARP investment authority. Treasury determined that the five categories of assistance it approved were compliant with TARP’s requirements but did not define “innovative” or perform an analysis of whether the proposed programs were innovative or duplicative of other programs. Treasury has not set measurable goals and metrics that would allow Treasury, the public, and Congress to measure the progress and success of HHF. Treasury does require states to estimate the number of households to be assisted by their HHF programs, but this number has limited usefulness because states can, and have, changed estimates, creating a shifting baseline that makes it difficult to measure performance against expectations. The states’ estimated number of home- owners to be assisted by the Hardest Hit Fund has steadily decreased over the last year. Treasury has not adopted this estimate or even reported it. It is not too late for Treasury to set measurable goals, including at a minimum, adopting the HFAs’ collective estimate or developing its own goal of how many homeowners Treasury expects HHF to help. Treasury can also do more to improve transparency by pub- lishing aggregate information on the program. quarterly report to congress I July 25, 2012 31

SIGTARP found that several factors contributed to the Hardest Hit Fund’s significant delay in getting assistance to homeowners. HHF lacked comprehensive planning by Treasury, which rushed out the program without appropriate collabora- tion of key stakeholders. Several HFAs told SIGTARP that their primary challenge was the lack of large servicer participation. Without large servicers, the HFAs could not reach a large portion of struggling homeowners. One great shortcoming in HHF’s implementation was Treasury’s lack of timely action to enlist large servicer support for and participation in state HHF programs while leaving it to the HFAs to negotiate with servicers. Treasury failed to recognize the lack of bargaining power that states had for recruiting servicers. Large servicers did not participate for nine months, citing the administrative burden of 50 different programs, lack of program uniformity, and lack of GSE guidance. Servicers cited the need for GSE guidance before they could begin participating in the program. Treasury did not gain GSE support for HHF programs for eight months. Treasury, responsible for HHF oversight and accountable for HHF results, should have been, and still should be, the driving force to ensure that the GSEs and large servicers support the HFAs’ programs. In order to reach the number of homeowners that the HFAs collectively esti- mate helping through HHF, there needs to be a dramatic increase in the number of homeowners helped. As was clear in the beginning of HHF, states need Treasury’s help and support to increase the number of homeowners helped, and Treasury should do everything it can to ensure the program’s success. Treasury should set measurable goals, measure progress against those goals, and develop an action plan to ensure that the next five years result in the Hardest Hit Fund fulfilling TARP’s goal to preserve homeownership.

The Net Present Value Test’s Impact on the Home Affordable Modification Program On June 18, 2012, SIGTARP released the audit report “The Net Present Value Test’s Impact on the Home Affordable Modification Program.” Conducted in response to a request by Senator Jeff Merkley and eight other Senators, the audit examined whether servicers are correctly applying the Net Present Value (“NPV”) test to determine which homeowners qualify for HAMP. The NPV test estimates whether a mortgage modification is in the best interest of the investor. As reported in the audit, more than 160,000 HAMP-eligible homeowners have been turned down for a HAMP mortgage modification by their mortgage servicer based on the results of the NPV test. SIGTARP’s audit report identified concerns, based upon its most recent analysis from its sample, with the NPV test that may stand as barriers to homeowners get- ting much-needed help from HAMP.

• Treasury’s practice of protecting investors by allowing them to add a “risk premium” to the NPV test calculation: SIGTARP found in its analysis of a judgmental sample of HAMP applications that the discretion Treasury gave to servicers to override the baseline discount rate in the NPV test by adding 32 special inspector general I troubled asset relief program

a risk premium (of up to 2.5%) reduces the number of otherwise qualified homeowners Treasury helps through HAMP. Only four servicers add a risk premium, including Bank of America, N.A., and Wells Fargo Bank, N.A. More than 100 servicers do not add a risk premium. In a SIGTARP analysis of 51 denied HAMP applications, SIGTARP found that if the servicer had not used a risk premium, more than half (27) of the homeowners in SIGTARP’s sample would have tested positive in the NPV test (which would require the servicer to offer a HAMP modification). • Errors inputting homeowner information and failure to maintain documentation in SIGTARP’s sample: SIGTARP found in its sample that servicers made errors using NPV inputs and did not properly maintain records of all NPV inputs during the period of our review. Within SIGTARP’s judgmental sample of 149 HAMP applications, SIGTARP found that the servicers could provide both accurate inputs and documentation for only two HAMP applications. SIGTARP found that servicers failed to comply with HAMP guidelines on maintaining records on NPV inputs. Because of the servicers’ failure to maintain documentation of the NPV inputs, SIGTARP was unable to determine how many homeowners from its sample may have been wrongly denied a HAMP modification. • Errors in calculating homeowner gross income and in other areas in SIGTARP’s sample: In 2010 and 2011, SIGTARP also found servicer errors or lack of documentation in calculating the homeowner’s gross income and other key inputs in the NPV test. • Poor communication with homeowners on denial of HAMP modifications in SIGTARP’s sample: In a sample of 26 denial letters sent by three servicers, SIGTARP also found that servicers had poor communication with homeowners on the denial of a HAMP modification due to the NPV test. SIGTARP found that all but two of the letters in its sample failed to comply with at least one requirement of HAMP guidelines. Treasury told SIGTARP that it has recently made improvements in that area.

SIGTARP Hotline One of SIGTARP’s primary investigative priorities is to operate the SIGTARP Hotline and provide a simple, accessible way for the American public to report concerns, allegations, information, and evidence of violations of criminal and civil laws in connection with TARP. The SIGTARP Hotline has received and analyzed more than 30,825 Hotline contacts. These contacts run the gamut from expressions of concern over the economy to serious allegations of fraud involving TARP, and a number of SIGTARP’s investigations were generated in connection with Hotline tips. The SIGTARP Hotline can receive information anonymously. SIGTARP honors all applicable whistleblower protections and will provide confidentiality to the fullest extent possible. SIGTARP urges anyone aware of waste, fraud, or abuse involving TARP programs or funds, whether it involves the Federal Government, state and local entities, private firms, or individuals, to contact its representatives at 877-SIG-2009 or www.sigtarp.gov. quarterly report to congress I July 25, 2012 33

Communications with Congress One of the primary functions of SIGTARP is to ensure that members of Congress remain adequately and promptly informed of developments in TARP initiatives and of SIGTARP’s oversight activities. To fulfill that role, the Special Inspector General and her staff meet regularly with and brief members and Congressional staff.

• On July 10, 2012, the Special Inspector General, Christy Romero, testified before the U.S. House Committee on Oversight and Reform Subcommittee on TARP, Financial Services and Bailouts of Public and Private Programs regarding TARP investments in the automotive industry and SIGTARP’s audit of the decision making relating to General Motors’ topping-up the pensions of certain hourly employees of Delphi Corporation. • On April 26, 2012, the Special Inspector General, Christy Romero, submitted written testimony to the U.S. Senate Committee on Homeland Security and Governmental Affairs Subcommittee on Oversight of Government Management, the Federal Workforce and the District of Columbia at a hearing entitled: “Financial Literacy: Empowering Americans to Prevent the Next Financial Crisis.” Ms. Romero provided testimony on SIGTARP’s efforts to raise public awareness of mortgage modification scams and to shut down these scams. • On April 24, 2012, SIGTARP’s Chief of Staff, Mia Levine, presented briefings open to all Senate and House staff, respectively, on SIGTARP’s April 2012 Quarterly Report.

Copies of written Congressional testimony are posted at www.sigtarp.gov/pages/ testimony.aspx.

The SIGTARP Organization SIGTARP leverages the resources of other agencies, and, where appropriate and cost-effective, obtains services through SIGTARP’s authority to contract.

Hiring As June 30, 2012, SIGTARP had 165 employees, plus two detailees from FHFA OIG and one from the FBI. SIGTARP’s employees hail from private sector businesses and many Federal agencies, including the Air Force Office of Special Investigations, the Army Criminal Investigation Command, the Army Office of Chief Legislative Liaison, the Congressional Oversight Panel for TARP, the Department of Defense, the Department of Energy-Office of Inspector General, the FBI, FDIC OIG, the Financial Crisis Inquiry Commission, the Government Accountability Office, the Government Printing Office, the Department of Homeland Security-Office of the Inspector General, IRS-CI, the Department of Justice, the Naval Criminal Investigative Service, the Nuclear Regulatory Commission, the Office of the Director of National Intelligence, the Secret Service, the SEC, the Small Business Administration-Office of Inspector General, the Department of State, the Department of Transportation, the Department of 34 special inspector general I troubled asset relief program

Transportation-Office of Inspector General, the Department of Treasury-Office of Inspector General, Treasury Inspector General for Tax Administration, and USPIS. The SIGTARP organization chart as of July 2, 2012 can be found in Appendix I: “Organizational Chart.”

Figure 1.1 Budget SIGTARP ESTIMATED FY 2012 On February 14, 2011, the Administration submitted to Congress Treasury’s OPERATING PLAN fiscal year 2012 budget request, which included SIGTARP’s funding request for ($ MILLIONS, PERCENTAGE OF $41.8 MILLION) $47.4 million. The fiscal year 2012 House mark and Senate mark both provided approximately $41.8 million. H.R. 2055/Public Law 112-74 Consolidated Other Services Appropriations Act, 2012, provides $41.8 million in annual appropriations. $2.4, 6% Figure 1.1 provides a detailed breakdown of SIGTARP’s FY 2012 budget that Advisory Services reflects a total operating plan of $41.8 million, which includes spending from $3.1 SIGTARP’s initial funding. 7% On February 13, 2012, the Administration submitted to Congress Treasury’s Interagency fiscal year 2013 budget request, which included SIGTARP’s funding request for Agreements 19% Salaries $8.1 64% and $40.2 million.

$26.7 Figure 1.2 provides a detailed breakdown of SIGTARP’s fiscal year 2013 budget, which reflects a total operating plan of $46.8 million. This would include Travel $1.5, 4% $40.2 million in requested annual appropriation and portions of SIGTARP’s initial funding.

Figure 1.2 Physical and Technical SIGTARP Infrastructure SIGTARP FY 2013 SIGTARP’s headquarters are in Washington, DC, with regional offices in New York PROPOSED BUDGET City, Los Angeles, San Francisco, and Atlanta. SIGTARP posts all of its reports, ($ MILLIONS, PERCENTAGE OF $46.8 MILLION) testimony, audits, and contracts on its website, www.sigtarp.gov. Since its inception

Other Services through June 30, 2012, SIGTARP’s website has had more than 58.4 million $2.2, 5% web “hits,” and there have been more than 5.3 million downloads of SIGTARP’s i Advisory Services quarterly reports. In addition to these web “hits,” SIGTARP’s website has recorded $3.2 32,968 page views since April 1, 2012, according to Treasury’s new tracking system. 7%

Interagency 21% Salaries Agreements 64% and $9.9 $30.2

Travel $1.3, 3%

i In October 2009, Treasury started to encounter challenges with its web analytics tracking system and as a result, migrated to a new system in January 2010. SIGTARP has calculated the total number of website “hits” reported herein based on three sets of numbers:

• Numbers reported to SIGTARP as of September 30, 2009 • Archived numbers provided by Treasury for the period of October through December 2009 • Numbers generated from Treasury’s new system for the period of January 2010 through June 2012

Starting April 1, 2012, a new tracking system has been introduced that tracks a different metric, “page views,” which are not to be confused with “hits” from the previous system. Moving forward, page views will be the primary metric to gauge use of the website. Section 2 TARP Overview 36 special inspector general I troubled asset relief program quarterly report to congress I July 25, 2012 37

This section summarizes how the U.S. Department of the Treasury (“Treasury”) has managed the Troubled Asset Relief Program (“TARP”). This section also reviews TARP’s overall finances and provides updates on established TARP component programs.

TARP Funds Update Initial authorization for TARP funding came through the Emergency Economic Stabilization Act of 2008 (“EESA”), which was signed into law on October 3, 2008.1 EESA appropriated $700 billion to “restore liquidity and stability to the financial system of the United States.”2 On December 9, 2009, the Secretary of the Treasury (“Treasury Secretary”) exercised the powers granted him under Section 120(b) of EESA and extended TARP through October 3, 2010.3 In accordance with Section 106(e) of EESA, Treasury may expend TARP funds after October 3, 2010, as long as it does so pursuant to obligations entered into before that date.4 The Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd- Frank Act”), which became law (Public Law 111-203) on July 21, 2010, amended the timing and amount of TARP funding.5 The upper limit of the Treasury Secretary’s authority to purchase and guarantee assets under TARP was reduced to $475 billion from the original $700 billion. Treasury’s investment authority under TARP expired on October 3, 2010. This means that Treasury could not make new obligations after that date. However, Obligations: Definite commitments dollars that have already been obligated to existing programs may still be expended. that create a legal liability for the As of October 3, 2010, Treasury had obligated $474.8 billion to 13 announced Government to pay funds. programs. Subsequent to the expiration of Treasury’s investment authority, Treasury has deobligated funds previously designated for some programs. As of June 30, Deobligations: An agency’s cancellation 2012, $467.2 billion is obligated to TARP programs.6 Of that amount, $416.1 or downward adjustment of previously billion had been spent and $45.8 billion remained obligated and available to incurred obligations. be spent.7 Taxpayers are owed $109.1 billion as of June 30, 2012. According to Treasury, as of June 30, 2012, it had written off or realized losses of $15.6 billion that taxpayers will never get back, leaving $93.5 billion in TARP funds outstand- ing.8 These amounts do not include $4.5 billion in TARP funds spent on housing programs, which are designed as a Government subsidy, with no repayments to taxpayers expected. Table 2.1 details those write-offs and realized losses, but does not include $20.3 million in realized losses at a June 25 to June 27, 2012, auction of the TARP investment at seven banks because the sales closed after June 30, 2012. 38 special inspector general I troubled asset relief program

Table 2.1 TREASURY’S STATEMENT OF REALIZED LOSSES AND WRITE-OFFS IN TARP, AS OF 6/30/2012 ($ MILLIONS) TARP TARP Realized Loss Program Institution Investment or Write-Off Date Description Realized Losses Sold 98,461 shares and equity stake in the UAW Retiree Autos Chrysler $1,888 $1,328 4/30/2010 trust for $560,000,000 and collected $48,055,721 for the sale of collateral Autos GMa 49,500 4,337d 11/17/2010 Sale of common stock at a loss 1,918 5/24/2011 SSFI AIGa,b 67,835 1,984 3/13/2012 Sale of common stock at a loss 1,621 5/10/2012 Sale of subordinated CPP FBHC Holding Company 3 2 3/9/2010 debentures at a loss First Federal Bancshares of CPP 17 11 5/3/2010 Sale of preferred stock at a loss Arkansas, Inc. CPP The Bank of Currituck 4 2 12/3/2010 Sale of preferred stock at a loss CPP Treaty Oak Bancorp, Inc. 3 3 2/15/2011 Sale of preferred stock at a loss Exchange of preferred stock at CPP Central Pacific Financial Corp. 135 32d 6/22/2011 a loss CPP Cadence Financial Corporation 44 6 3/4/2011 Sale of preferred stock at a loss First Community Bank CPP 11 3 5/31/2011 Sale of preferred stock at a loss Corporation of America CPP Cascade Financial Corporation 39 23 6/30/2011 Sale of preferred stock at a loss CPP Green Bankshares, Inc. 72 4 9/7/2011 Sale of preferred stock at a loss CPP Santa Lucia Bancorp 4 1 10/21/2011 Sale of preferred stock at a loss MainSource Financial CPP 57 4d 4/3/2012 Sale of preferred stock at a loss Group, Inc. Seacoast Banking Corporation CPP 50 9d 4/3/2012 Sale of preferred stock at a loss of Florida CPP Wilshire Bancorp, Inc. 62 4d 4/3/2012 Sale of preferred stock at a loss Banner Corporation/Banner CPP 124 14d 4/3/2012 Sale of preferred stock at a loss Bank CPP First Financial Holdings Inc. 65 8d 4/3/2012 Sale of preferred stock at a loss CPP WSFS Financial Corporation 53 4d 4/3/2012 Sale of preferred stock at a loss CPP Central Pacific Financial Corp. 135 30d 4/4/2012 Sale of common stock at a loss CPP Ameris Bancorp 52 4d 6/19/2012 Sale of preferred stock at a loss CPP United Bancorp, Inc. 21 4d 6/19/2012 Sale of preferred stock at a loss CPP First Capital Bancorp, Inc. 11 1d 6/19/2012 Sale of preferred stock at a loss CPP First Defiance Financial Corp. 37 1d 6/19/2012 Sale of preferred stock at a loss CPP LNB Bancorp, Inc. 25 3d 6/19/2012 Sale of preferred stock at a loss CPP Farmers Capital Corporation 30 8d 6/19/2012 Sale of preferred stock at a loss CPP Taylor Capital Group, Inc. 105 11d 6/19/2012 Sale of preferred stock at a loss Total Realized Losses $11,379

Continued on next page quarterly report to congress I July 25, 2012 39

TREASURY’S STATEMENT OF REALIZED LOSSES AND WRITE-OFFS IN TARP, AS OF 6/30/2012 ($ MILLIONS) (CONTINUED) TARP TARP Realized Loss Program Institution Investment or Write-Off Date Description Write-Offs Accepted $1.9 billion as full Autos Chrysler $3,500 $1,600 5/14/2010 repayment for the debt of $3.5 billion CPP CIT Group Inc. 2,330 2,330 12/10/2009 Bankruptcy CPP Pacific Coast National Bancorp 4 4 2/11/2010 Bankruptcy CPP South Financial Group, Inc.c 347 217 9/30/2010 Sale of preferred stock at a loss CPP TIB Financial Corpc 37 25 9/30/2010 Sale of preferred stock at a loss Total Write-Offs $4,176

Total of Realized Losses and Write-Offs $15,555

Notes: Numbers may not total due to rounding. Total realized losses and write-offs does not include $20.3 million in realized losses for Treasury’s interests in seven CPP banks that were sold at auction June 25-27, 2012, because the sales closed after June 30, 2012. a Since this company remains in TARP, a final determination of realized loss incurred on Treasury’s investment cannot be calculated until the investments have been fully divested. b Treasury has sold a total of 459 million AIG common shares at an average price of $29.47 per share, consisting of 392,922,121 TARP shares and 202,499,020 non- TARP shares based upon the Treasury’s pro-rata holding of those shares. The non-TARP shares are those received from the trust created by the Federal Reserve Bank of New York for the benefit of the Treasury. Receipts for non-TARP common stock totaled $5,968,645,637 and are not included in TARP collections. The realized loss reflects the price at which TARP sold common shares in AIG and TARP’s cost basis of $43.53 per common share. c According to Treasury, in the time since these transactions were classified as write-offs, Treasury has changed its practices and now classifies sales of preferred stock at a loss as realized losses. d Treasury changed its reporting methodology in calculating realized losses, effective June 30, 2012. Disposition expenses are no longer included in calculating realized losses.

Sources: Treasury, Transactions Report, 6/27/2012; Treasury, Section 105(a) Report, 7/10/2012; Treasury Press Release, “Treasury Announces Agreement to Exit Remaining Stake in Chrysler Group LLC,” 6/2/2011, www.treasury.gov/press-center/press-releases/Pages/tg1199.aspx, accessed 6/28/2012; Treasury, response to SIGTARP data call, 7/5/2012.

With the expiration of TARP funding authorization, no new expenditures may be made through 10 TARP programs because all obligated dollars have been spent. For three programs — the housing programs, the Term Asset-Backed Securities Loan Facility (“TALF”), and the Public-Private Investment Program (“PPIP”) — $45.8 billion in TARP dollars that were obligated but unspent as of June 30, 2012, are available to be spent. Table 2.2 provides a breakdown of program obligations, changes in obligations, expenditures, principal repaid, amounts still owed to taxpay- ers, and obligations available to be spent as of June 30, 2012. Table 2.2 lists 10 TARP sub-programs, instead of all 13, because it excludes the Capital Assistance Program (“CAP”), which was never funded, and summarizes three programs under “Automotive Industry Support Programs.” 40 special inspector general I troubled asset relief program

Table 2.2 Obligations, Expenditures, PRINCIPAL REPAID, AMOUNTS STILL OWED TO TAXPAYERS, and Obligations Available to be Spent ($ Billions) Obligation After Current Still Owed to Available Dodd-Frank Obligation Expenditure Principal Repaid Taxpayers to Be Spent Program (As of 10/3/2010) (As of 6/30/2012) (As of 6/30/2012) (As of 6/30/2012) (As of 6/30/2012)a (As of 6/30/2012) Housing Support $45.6 $45.6 $4.5 $— $— $41.1 Programsb Capital Purchase Program 204.9 204.9 204.9 191.1c 13.8 0.0 Community Development 0.6 0.6 0.2 0.0* 0.6 0.0 Capital Initiatived Systemically Significant 69.8 67.8e 67.8 31.9 36.0 0.0 Failing Institutions Targeted Investment 40.0 40.0 40.0 40.0 0.0 0.0 Program Asset Guarantee Program 5.0 5.0 0.0 0.0 0.0 0.0 Term Asset-Backed 4.3 1.4f 0.1 0.0 0.1 1.3 Securities Loan Facility Public-Private Investment 22.4 21.9 18.5 4.4g 14.1 3.4h Program Unlocking Credit for Small 0.4 0.4 0.4 0.4 0.0 0.0 Businesses Automotive Industry 81.8i 79.7j 79.7 35.2 44.5 0.0 Support Programs Total $474.8 $467.2 $416.1k $302.9 $109.1 $45.8

Notes: Numbers may not total due to rounding. a Amount taxpayers still owed includes amounts disbursed and still outstanding, plus write-offs and realized losses totaling $15.6 billion. It does not include $4.5 billion in TARP dollars spent on housing programs. These programs are designed as Government subsidies, with no repayments to taxpayers expected. Realized losses do not reflect $20.3 million in losses incurred at a June 25-27, 2012, auction of Treasury’s interests in seven banks, which settled after June 30, 2012. b Housing support programs were designed as a Government subsidy, with no repayment to taxpayers expected. c Does not include $204.4 million in proceeds from CPP auction held June 25-27, 2012, but not settled until after June 30, 2012. Includes $363.3 million in non-cash conversions from CPP to CDCI. Includes $2.2 billion for CPP banks that exited TARP through SBLF. d CDCI obligation amount of $570.1 million. There are no remaining dollars to be spent on CDCI. Of the total obligation, $363.3 million was related to CPP conversions for which no additional CDCI cash was expended; this is not counted as an expenditure, but it is counted as money still owed to taxpayers. Another $100.7 million was expended for new CDCI expenditures for previous CPP participants. Of the total obligation, only $106 million went to non-CPP institutions. e Treasury deobligated $2 billion of an equity facility for AIG that was never drawn down. f Treasury deobligated $2.9 billion in TALF funding, bringing the total obligation to $1.4 billion. g On April 10, 2012, Treasury changed its reporting methodology to reclassify as repayments of capital to the Government $958 million in receipts previously categorized as PPIP equity distributions. That $958 million is included in this repayment total. h Total obligation of $22.4 billion and expenditure of $18.5 billion for PPIP includes $356.3 million of the initial obligation to The TCW Group, Inc. (“TCW”) that was funded. TCW subsequently repaid the funds that were invested in its PPIF; however, these dollars are not included in the amount available to be spent. Current obligation of $21.9 billion results because Invesco terminated its investment period on September 26, 2011, without fully drawing down all committed equity and debt. The undrawn debt of $550 million was deobligated, but the undrawn equity was not. i Includes $80.7 billion for Automotive Industry Financing Program, $0.6 billion for Auto Warranty Commitment Program, and $0.4 billion for Auto Supplier Support Program. j Treasury deobligated $2.1 billion of a Chrysler credit facility that was never drawn down. k The $5 billion reduction in exposure under AGP is not included in the expenditure total because this amount was not an actual cash outlay.

* Amount less than $50 million.

Sources: Treasury, Transactions Report, 6/27/2012; Treasury, Daily TARP Update, 7/2/2012; Treasury, response to SIGTARP data call, 7/5/2012. quarterly report to congress I July 25, 2012 41

Cost Estimates Several Government agencies are responsible under EESA for generating cost estimates for TARP, including the Office of Management and Budget (“OMB”), the Congressional Budget Office (“CBO”), and Treasury, whose estimated costs are audited each year by the Government Accountability Office (“GAO”). Cost estimates have decreased from CBO’s March 2009 cost estimate of a $356 billion loss and OMB’s August 2009 cost estimate of a $341 billion loss.9 On February 13, 2012, OMB issued the Administration’s fiscal year 2013 budget, which included a TARP lifetime cost estimate of $67.8 billion, based upon figures from November 30, 2011.10 That was an increase from its estimate of $53.2 billion based on June 30, 2011 data.11 Much of the difference is due to a lower val- ue for Treasury’s common stock holdings in AIG, GM, and Ally Financial compared with November 2010. This estimate assumes that all $45.6 billion of obligated funds for housing will be spent. It also assumes that PPIP will make a profit of $2 billion and CPP will make a profit of $6.7 billion, including principal repayments and revenue from dividends, warrants, interest, and fees. On March 28, 2012, CBO issued an updated TARP cost estimate based on its evaluation of data as of February 22, 2012. CBO estimated the ultimate cost of TARP would be $32 billion, down $2 billion from its estimate of $34 billion in December 2011.12 This decrease came primarily from an increase in the market value of Treasury’s investments in AIG and GM, partially offset by added costs from new initiatives in TARP housing programs. CBO estimated that only $16 billion of obligated funds for housing will be spent. On November 10, 2011, Treasury issued its September 30, 2011, fiscal year audited agency financial statements for TARP, which contained a cost estimate of $70 billion.13 This estimate is an increase from Treasury’s March 31, 2011, esti- mate of $49 billion. According to Treasury, “These costs fluctuate in large part due to changes in the market prices of common stock for AIG and GM and the esti- mated value of the Ally [Financial] stock.”14 According to Treasury, the largest losses from TARP are expected to come from housing programs and from assistance to AIG and the automotive industry.15 The most recent TARP program cost estimates from each agency are listed in Table 2.3. 42 special inspector general I troubled asset relief program

TABLE 2.3

Cost (gain) of TARP Programs ($ Billions) Treasury Estimate, TARP Audited Agency Financial Program Name OMB Estimate CBO Estimate Statement Report issued: 2/13/2012 3/28/2012 11/10/2011 Data as of: 11/30/2011 2/22/2012 9/30/2011 Housing Support Programs $46 $16 $46 CPP (7) (17) (13) SSFI 24 22 24 TIP and AGP (7) (8) (8) TALF 0 0 0 PPIP (2) 0 (2.4) Automotive Industry Support 25 19 24 Programsa Otherb * * * Total $78 $32c $70d Interest on Reestimatese (10)

Adjusted Total $68d

Notes: Numbers may not total due to rounding. a Includes AIFP, ASSP, and AWCP. b Consists of CDCI and UCSB, both of which are estimated between a cost of $500 million and a gain of $500 million. c The estimate is before administrative costs and interest effects. d The estimate includes interest on reestimates but excludes administrative costs. e Cumulative interest on reestimates is an adjustment for interest effects on changes in TARP subsidy costs from original subsidy estimates; such amounts are a component of the deficit impacts of TARP programs but are not a direct programmatic cost.

Sources: OMB Estimate—OMB, “OMB Report under the Emergency Economic Stabilization Act, Section 202,” 11/8/2011, www. whitehouse.gov/sites/default/files/omb/reports/emergency-economic-stabilization-act-of-2008.pdf, accessed 6/28/2012; CBO Estimate—CBO, “Report on the Troubled Asset Relief Program—March 2012,” 3/28/2012, www.cbo.gov/sites/default/files/cbofiles/ attachments/03-28-2012TARP.pdf, accessed 6/28/2012; Treasury Estimate—Treasury, “Office of Financial Stability–Troubled Asset Relief Program Agency Financial Report Fiscal Year 2011,” 11/10/2011, www.treasury.gov/initiatives/financial-stability/briefing-room/ reports/agency_reports/Documents/2011_OFS_AFR_11-11-11.pdf, accessed 6/28/2012.

Financial Overview of TARP Treasury had obligated $474.8 billion of the $475 billion ceiling under the Dodd- Frank Act, but in 2011 and 2012 deobligated funds for several programs, reducing obligations to $467.2 billion as of June 30, 2012. Of the total obligations, $416.2 billion was expended as of June 30, 2012.16 There remains approximately $45.8 billion still available to be spent.17 According to Treasury, as of June 30, 2012, 306 TARP recipients (including 302 banks and credit unions, two auto companies, and two former PPIP manag- ers) had paid back all of their principal or repurchased shares, sometimes at a loss to Treasury, and 24 TARP recipients had partially repaid their principal or repur- chased their shares, for a total of $302.5 billion.18 Some of these institutions repaid TARP by refinancing into other TARP programs or other Government programs such as the Small Business Lending Fund (“SBLF”). According to Treasury, one quarterly report to congress I July 25, 2012 43

PPIP manager, Invesco, has fully repaid its debt and equity, but retains some capi- FIGURE 2.1 tal to wind down operations. These repayments also include five PPIP managers CURRENT TARP EXPENDITURES, who have made partial payments over the lifetime of the program. Taxpayers are REPAYMENTS, AND AMOUNT still owed $109.1 billion as of June 30, 2012. According to Treasury, it has incurred OWED ($ BILLIONS) write-offs of $4.2 billion and realized losses of $11.4 billion as of June 30, 2012, which taxpayers will never get back, leaving $93.5 billion in TARP funds outstand- $500 ing (not including $4.5 billion in TARP funds spent as a subsidy for TARP housing 400 programs).19 Figure 2.1 provides a snapshot of the cumulative expenditures, repay- $416.1 ments, and amount owed as of June 30, 2012. According to Treasury, as of June 300 30, 2012, the Government had also collected $41.1 billion in interest, dividends, $302.9 and other income, including $9.2 billion in proceeds from the sale of warrants and 200 20 stock received as a result of exercised warrants. 100 Most of the outstanding TARP money is in the form of equity ownership in 410 $109.1 institutions as of June 30, 2012 (325 banks in CPP, 82 banks and credit unions in 0 TARP TARP Amount CDCI, plus AIG, GM, and Ally Financial). Treasury (and therefore the taxpayer) Expenditures Repaymentsa Owedb remains a shareholder in companies that have not repaid the Government.

Treasury’s equity ownership is largely in two forms — common and preferred stock Notes: As of 6/30/2012. Numbers may not total due — although it also has received debt in the form of senior subordinated debentures. to rounding. a Repayments include $191.1 billion for CPP, $40 billion As of June 30, 2012, obligated funds totaling $45.8 billion were still available to for TIP, $35.2 billion for Auto Programs, $4.4 billion for PPIP, and $31.9 billion for SSFI. The $191.1 billion for be drawn down by TARP recipients under three of TARP’s 13 announced pro- CPP repayments does not include $204.4 million in 21 proceeds from CPP auction held June 25-27, 2012, but grams. TARP’s component programs fall into four categories, depending on the includes $363.3 million in non-cash conversion from type of assistance offered: CPP to CDCI and $2.2 billion for banks that re nanced from TARP into SBLF. The $31.9 billion payment for SSFI includes amounts applied to (i) pay accrued preferred returns and (ii) redeem the outstanding • Housing Support Programs — These programs are intended to help liquidation amount. b Amount owed includes $15.6 billion that Treasury has homeowners who are having trouble making their mortgage payments by written off or realized losses, but does not include $20.3 million in losses realized after June 30, 2012, providing incentives for foreclosure alternatives. in an auction of the investment in seven CPP banks. It — These programs share a common does not include $4.5 billion spent for housing • Financial Institution Support Programs programs, which were designed as a Government stated goal of stabilizing financial markets and improving the economy. subsidy, with no repayment to taxpayers expected. • Asset Support Programs — These programs attempt to support asset values Sources: Treasury, Transactions Report, 6/27/2012; Treasury, Daily TARP Update, 7/2/2012; Treasury, and market liquidity by providing funding to certain holders or purchasers of response to SIGTARP data call, 7/5/2012. assets. • Automotive Industry Support Programs — These programs are intended to stabilize the U.S. automotive industry and promote market stability.

Common Stock: Equity ownership entitling Preferred Stock: Equity ownership that Senior Subordinated Debentures: Debt an individual to share in corporate usually pays a fixed dividend before instrument ranking below senior debt but earnings and voting rights. distributions for common stock owners above equity with regard to investors’ but only after payments due to debt claims on company assets or earnings. holders. It typically confers no voting rights. Preferred stock also has priority over common stock in the distribution of assets when a bankrupt company is liquidated. 44 special inspector general I troubled asset relief program

Some TARP programs are scheduled to last as late as 2019. Table 2.4 provides details of those exit dates.

Table 2.4 TARP Program SCHEDULE TARP Program Scheduled Program Dates Term Asset-Backed Securities Loan Facility 2015 maturity of last loan Public-Private Investment Program 2017 for fund manager to sell securities (with possibility to extend to 2019) Home Affordable Modification Program 2019 for incentives on modifications Hardest Hit Fund 2017 for states to use TARP funds

Other TARP programs have no scheduled ending date; TARP money will remain invested until recipients pay Treasury back or until Treasury is able to sell its investments in the companies. Table 2.5 provides details on the status of the remaining Treasury investments under those programs.

Table 2.5 TARP INVESTMENTS IN FINANCIAL INSTITUTIONS TARP Program Remaining Treasury Investment Capital Purchase Program Preferred stock in 325 banks Community Development Capital Initiative Preferred stock in 82 banks/credit unions Systemically Significant Failing Institutions 61% stake in AIG Automotive Industry Financing Program 32% stake in GM 74% stake in Ally Financial

Housing Support Programs The stated purpose of TARP’s housing support programs is to help homeowners and financial institutions that hold troubled housing-related assets. Although Treasury originally committed to use $50 billion in TARP funds for these programs, it obligated only $45.6 billion.22 As of June 30, 2012, $4.5 billion, or 10% of this amount, has been expended. However, some of these expended funds remain as cash on hand or administrative expenses with the state Housing Finance Agencies participating in the Hardest Hit Fund program.

• Making Home Affordable (“MHA”) Program — According to Treasury, this umbrella program for Treasury’s foreclosure mitigation efforts is intended to “help bring relief to responsible homeowners struggling to make their mortgage payments, while preventing neighborhoods and communities from suffering the negative spillover effects of foreclosure, such as lower housing prices, increased crime, and higher taxes.”23 MHA, for which Treasury has obligated $29.9 billion of TARP funds, consists of the Home Affordable Modification Program (“HAMP”), which includes HAMP Tier 1 and HAMP Tier 2, which both modify first-lien mortgages to reduce payments, the Federal Housing Administration (“FHA”) HAMP loan modification option for FHA-insured quarterly report to congress I July 25, 2012 45

mortgages (“Treasury/FHA-HAMP”), the U.S. Department of Agriculture Office of Rural Development (“RD”) HAMP (“RD-HAMP”), the Home Affordable Foreclosure Alternatives (“HAFA”) program, and the Second Lien Modification Program (“2MP”).24 HAMP in turn encompasses various initiatives in addition to the modification of first-lien mortgages, including Home Price Decline Protection (“HPDP”), the Principal Reduction Alternative (“PRA”), and the Home Affordable Unemployment Program (“UP”).25 Additionally, the overall MHA obligation of $29.9 billion includes $2.7 billion to support the Treasury/ FHA Second-Lien Program (“FHA2LP”), which complements the FHA Short Refinance program (discussed later) and is intended to support the extinguishment of second-lien loans.26 Treasury made several changes to MHA in the first half of 2012. Notably, the application period for HAMP was extended by a year to December 31, 2013, and investor incentives for principal reduction were doubled for 2MP and tripled for PRA. Additionally, on June 1, 2012, HAMP was expanded under “HAMP Tier 2” to open HAMP to non-owner-occupied rental properties and to borrowers with a wider range of debt-to-income ratios.27 For more detailed information, see the “Housing Support Programs” discussion in this section. As of June 30, 2012, MHA had expended $3.4 billion of TARP money.28 As of that date, there were 393,887 active permanent first-lien modifications under the completed TARP-funded portion of HAMP, an increase of 12,994 active permanent modifications over the past quarter.29 Total expenditures in incen- tives and payments for HAFA were $237.2 million in connection with 52,998 deed-in-lieu and short sale transactions. Expenditures in incentives and pay- ments for 2MP were $192.1 million in connection with 18,974 full extinguish- ments, 4,547 partial extinguishments, and 63,769 permanent modifications of second liens.30 For more detailed information, including participation numbers for each of the MHA programs and subprograms, see the “Housing Support Programs” discussion in this section. • FHA Short Refinance Program — Treasury has allocated $8.1 billion of TARP funding to this program to purchase a letter of credit to provide loss protection on refinanced first liens. Additionally, to facilitate the refinancing of non-FHA mortgages into new FHA-insured loans under this program, Treasury has allocated approximately $2.7 billion in TARP funds for incentive payments to servicers and holders of existing second liens for full or partial principal extinguishments under the related FHA2LP; these funds are part of the overall MHA funding of $29.9 billion, as noted above.31 As of June 30, 2012, there have been 1,437 refinancings under the program.32 For more detailed information, see the “Housing Support Programs” discussion in this section. • Housing Finance Agency (“HFA”) Hardest Hit Fund (“HHF”) — The stated purpose of this program was to provide TARP funding for “innovative measures to help families in the states that have been hit the hardest by the aftermath of the housing bubble.”33 Treasury obligated $7.6 billion for this program.34 As of June 30, 2012, $1.1 billion had been drawn down by the states from HHF. However, as of March 31, 2012, only $351 million has been spent assisting 46 special inspector general I troubled asset relief program

43,580 homeowners, with the remaining funds used for administrative expenses and cash-on-hand.35 For more detailed information, see the “Housing Support Programs” discussion in this section.

Financial Institution Support Programs Treasury primarily invested capital directly into financial institutions including banks, bank holding companies, and, if deemed by Treasury critical to the financial Systemically Significant Institutions: system, some systemically significant institutions.36 Term referring to any financial institution whose failure would impose • Capital Purchase Program (“CPP”) — Under CPP, Treasury directly significant losses on creditors and purchased preferred stock or subordinated debentures in qualifying financial counterparties, call into question the institutions (“QFIs”).37 CPP was intended to provide funds to “stabilize and financial strength of similar institutions, strengthen the U.S. financial system by increasing the capital base of an disrupt financial markets, raise array of healthy, viable institutions, enabling them [to] lend to consumers and borrowing costs for households and business[es].”38 Treasury invested $204.9 billion in 707 institutions through businesses, and reduce household CPP, which closed to new funding on December 29, 2009.39 As of June 30, wealth. 2012, 325 of those institutions remained in CPP.40 Of the 382 that have exited CPP, 165, or 43.2%, did so through other Government programs — 28 of Qualifying Financial Institutions (“QFIs”): them through TARP’s CDCI and 137 through SBLF, a non-TARP program.41 Private and public U.S.-controlled Only 164 of the banks that exited, or 42.9%, fully repaid CPP otherwise.42 In banks, savings associations, bank addition, three CPP banks merged with other CPP banks, Treasury sold its holding companies, certain savings investments in 33 institutions at a loss, and 17 institutions or their subsidiary and loan holding companies, and banks failed, meaning Treasury lost its entire investment in those banks.43 mutual organizations. As of June 30, 2012, taxpayers were still owed $13.8 billion related to CPP. According to Treasury, it had write-offs and realized losses of $2.8 billion in Community Development Financial the program, leaving $11.1 billion in TARP funds outstanding.44 According to Institutions (“CDFIs”): Financial Treasury, $191.1 billion of the CPP principal (or 93.3%) had been repaid as of institutions eligible for Treasury funding June 30, 2012. That repayment tally includes $245 million in proceeds from an to serve urban and rural low-income auction held June 11 through June 13, 2012, of Treasury’s preferred stock in communities through the CDFI Fund. seven banks, but does not include $204.4 million in proceeds from an auction CDFIs were created in 1994 by the held from June 25 through June 27, 2012, of preferred stock in seven other Riegle Community Development and banks because the sales closed after June 30, 2012. The repayment amount Regulatory Improvement Act. These also includes $363.3 million in preferred stock that was converted from CPP entities must be certified by Treasury; investments into CDCI and therefore still represents outstanding obligations certification confirms that they target to TARP, and $2.2 billion that was refinanced in 2011 into SBLF, a non- at least 60% of their lending and other TARP Government program.45 Treasury continues to manage its portfolio of economic development activities CPP investments, including, for certain struggling institutions, converting its to areas underserved by traditional preferred equity ownership into a more junior form of equity ownership, often financial institutions. at a discount to par value (which may result in a loss) in an attempt to preserve some value that might be lost if these institutions were to fail. For more detailed information, see the “Capital Purchase Program” discussion in this section. • Community Development Capital Initiative (“CDCI”) — Under CDCI, Treasury used TARP money to buy preferred stock in or subordinated debt from Community Development Financial Institutions (“CDFIs”). Treasury intended for CDCI to “improve access to credit for small businesses in the country’s quarterly report to congress I July 25, 2012 47

hardest-hit communities.”46 Under CDCI, TARP made capital investments in the preferred stock or subordinated debt of eligible banks, bank holding companies, thrifts, and credit unions.47 Eighty-four institutions received $570.1 million in funding under CDCI.48 However, 28 of these institutions converted their existing CPP investment into CDCI ($363.3 million of the $570.1 million) and 10 of those that converted received combined additional funding of $100.7 million under CDCI.49 Only $106 million of CDCI money went to institutions that were not already TARP recipients. As of June 30, 2012, 82 institutions remain in CDCI. • Systemically Significant Failing Institutions (“SSFI”) Program — SSFI enabled Treasury to invest in systemically significant institutions to prevent them from failing.50 Only one firm received SSFI assistance: American International Group, Inc. (“AIG”), which remained in SSFI as of June 30, 2012. The Government’s rescue of AIG involved several different funding facilities provided by the Federal Reserve Bank of New York (“FRBNY”) and Treasury, with various changes to the transactions over time. The rescue of AIG was led by FRBNY and the Board of Governors of the Federal Reserve System (“Federal Reserve”). With the passage of EESA in October 2008, Treasury took on a greater role in the AIG rescue as the Government expanded and restructured its aid. There were two TARP investments in AIG. On November 25, 2008, Treasury bought $40 billion of AIG’s preferred stock, the proceeds of which were used to repay a portion of AIG’s debt to FRBNY. Then, on April 17, 2009, Treasury obligated approximately $29.8 billion to an equity capital facility that AIG was allowed to draw on as needed.51 On January 14, 2011, AIG executed its previously announced Recapitalization Plan with the Government. According to Treasury, the intent of the restructuring was to facilitate the repayment of AIG’s government loans and investments and to promote AIG’s transition from a majority government owned and supported entity to a financially sound and independent entity.52 Under the Recapitalization Plan, AIG fully repaid FRBNY’s revolving credit facility, purchased the remainder of FRBNY’s preferred equity interests in two AIG subsidiaries (which it then transferred to Treasury), and Treasury converted its preferred stock holdings (along with the preferred stock holdings held by the AIG Trust) into an approximately 92.1% common equity ownership stake in AIG. The three main steps of the Recapitalization Plan are briefly described below. çç AIG repaid and terminated its revolving credit facility with FRBNY with cash proceeds that it had received from sales of equity interests in two Special Purpose Vehicle (“SPV”): companies: American International Assurance Co., Ltd. (“AIA”) and A legal entity, often off-balance- 53 American Life Insurance Company (“ALICO”). sheet, that holds transferred assets çç AIG applied cash proceeds from the AIA IPO and ALICO sale to retire presumptively beyond the reach of the a portion of FRBNY’s preferred interests in the special purpose vehicle entities providing the assets, and that 54 (“SPV”) that held ALICO. AIG next drew down an additional $20.3 billion is legally isolated from its sponsor or in available TARP funds from the equity capital facility to repurchase the parent company. 48 special inspector general I troubled asset relief program

remainder of FRBNY’s preferred interests in the ALICO SPV and all of FRBNY’s preferred interests in the AIA SPV. AIG then transferred the preferred interests to Treasury. AIG designated its remaining $2 billion TARP equity capital facility to a new Series G standby equity commitment available for general corporate purposes, which has been subsequently terminated without drawdown. çç AIG issued common stock in exchange for the preferred shares held by Treasury and the AIG Trust. The conversion resulted in Treasury holding a common equity ownership in AIG of approximately 92.1%.55 On May 27, 2011, Treasury sold 200 million shares of AIG’s common stock for $5.8 billion in proceeds, which decreased Treasury’s equity ownership to 77%. On March 8, 2012, Treasury sold approximately 206.9 million shares of AIG’s common stock for $6 billion in proceeds, which further decreased Treasury’s equity ownership to 70%. On May 6, 2012, Treasury sold approxi- mately 188.5 million shares of AIG’s common stock for $5.8 billion in proceeds. This sale decreased Treasury’s equity ownership to 61%.56 Through two payments in February 2011 and March 2011, AIG fully repaid the Government’s preferred interests in the ALICO SPV. Through a series of repayments between February 2011 and March 2012, AIG fully repaid the Government’s preferred interests in the AIA SPV. As of June 30, 2012, taxpayers were still owed $36 billion related to AIG’s bailout. According to Treasury’s TARP books and records, taxpayers have realized losses on the TARP investment from an accounting standpoint of $5.5 billion on Treasury’s sale of AIG stock. However, given the January 2011 restructuring of the FRBNY and Treasury investment, according to Treasury, the Government overall has made a gain thus far on the stock sales. According to Treasury, this leaves $30.4 billion in TARP funds outstanding. In return, for that investment, Treasury holds 61% of AIG’s common stock (1.06 billion shares). For more detailed information on the Recapitalization Plan, the sale of AIG common stock, and other AIG transactions, see the “Systemically Significant Failing Institutions Program” discussion in this section. For discussion of how AIG has changed while in TARP, see Section 3, “AIG Remains in TARP as the Largest TARP Investment.” • Targeted Investment Program (“TIP”) — Through TIP, Treasury invested in financial institutions it deemed critical to the financial system.57 There were two expenditures under this program, totaling $40 billion — the purchases of $20 Senior Preferred Stock: Shares that billion each of senior preferred stock in Citigroup Inc. (“Citigroup”) and Bank give the stockholder priority dividend of America Corp. (“Bank of America”).58 Treasury also accepted common stock and liquidation claims over junior warrants from each, as required by EESA. Both banks fully repaid Treasury preferred and common stockholders. for its TIP investments.59 Treasury auctioned its Bank of America warrants on March 3, 2010, and auctioned its Citigroup warrants on January 25, 2011.60 For more information on these two transactions, see the “Targeted Investment Program and Asset Guarantee Program” discussion in this section. quarterly report to congress I July 25, 2012 49

• Asset Guarantee Program (“AGP”) — AGP was designed to provide insurance-like protection for a select pool of mortgage-related or similar assets held by participants whose portfolios of distressed or illiquid assets threatened market confidence.61 Treasury, the Federal Deposit Insurance Corporation (“FDIC”), and the Federal Reserve offered certain loss protections in connection with $301 billion in troubled Citigroup assets.62 In exchange for providing the loss protection, Treasury received $4 billion of preferred stock that was later converted to trust preferred securities (“TRUPS”), and FDIC received $3 billion.63 On December 23, 2009, in connection with Citigroup’s TIP repayment, Citigroup and the Government terminated the AGP agreement Illiquid Assets: Assets that cannot be and the Government suffered no loss. For more information on this program, quickly converted to cash. including more detailed information on the agreements between Treasury, Citigroup, and FDIC, regarding these TRUPS, see the “Targeted Investment Trust Preferred Securities (“TRUPS”): Program and Asset Guarantee Program” discussion in this section. Securities that have both equity and debt characteristics, created by Asset Support Programs establishing a trust and issuing debt to it. The stated purpose of these programs was to support the liquidity and market value Asset-Backed Securities (“ABS”): Bonds of assets owned by financial institutions. These assets included various classes of backed by a portfolio of consumer asset-backed securities (“ABS”) and several types of loans. Treasury’s asset support or corporate loans, e.g., credit card, programs sought to bolster the balance sheets of financial firms and help free auto, or small-business loans. Financial capital so that these firms could extend more credit to support the economy. companies typically issue ABS backed by existing loans in order to fund new • Term Asset-Backed Securities Loan Facility (“TALF”) — TALF was loans for their customers. originally designed to increase credit availability for consumers and small businesses through a $200 billion Federal Reserve loan program. TALF provided Commercial Mortgage-Backed investors with non-recourse loans secured by certain types of ABS, including Securities (“CMBS”): Bonds backed by credit card receivables, auto loans, equipment loans, student loans, floor one or more mortgages on commercial plan loans, insurance-premium finance loans, loans guaranteed by the Small real estate (e.g., office buildings, rental Business Administration (“SBA”), residential mortgage servicing advances, and apartments, hotels). commercial mortgage-backed securities (“CMBS”).64 TALF closed to new loans in June 2010.65 TALF ultimately provided $71.1 billion in Federal Reserve financing. Of that amount, $4.5 billion remained outstanding as of June 30, 2012.66 FRBNY made 13 rounds of TALF loans with non-mortgage-related ABS as collateral, totaling approximately $59 billion, with $3.4 billion of TALF borrowings outstanding as of June 30, 2012.67 FRBNY also made 13 rounds of TALF loans with CMBS as collateral, totaling $12.1 billion, with $1.1 billion in loans outstanding as of June 30, 2012.68 Treasury originally obligated $20 billion of TARP funds to support this program by providing loss protection to the loans extended by FRBNY in the event that a borrower surrendered the ABS collateral and walked away from the loan.69 Treasury has since reduced its obligation for TALF to $1.4 billion.70 As of June 30, 2012, there had been no surrender of collateral.71 As of June 30, 2012, $2.3 million in TARP funds had been allocated under TALF for administrative expenses.72 For more information on these activities, see the “TALF” discussion in this section. 50 special inspector general I troubled asset relief program

• Public-Private Investment Program (“PPIP”) — PPIP’s goal was to restart Legacy Securities: Real estate-related credit markets by using a combination of private equity, matching Government securities originally issued before equity, and Government debt to purchase legacy securities, i.e., CMBS and 2009 that remained on the balance non-agency residential mortgage-backed securities (“non-agency RMBS”).73 sheets of financial institutions because Under the program, nine Public-Private Investment Funds (“PPIFs”) managed of pricing difficulties that resulted from by private asset managers invested in non-agency RMBS and CMBS. Treasury market disruption. obligated $22.4 billion in TARP funds to the program, which was decreased to $21.9 billion after Invesco Legacy Securities Master Fund, L.P. (“Invesco”) Non-Agency Residential Mortgage- terminated its investment period.74 As of June 30, 2012, seven PPIFs remained Backed Securities (“non-agency active after one PPIP manager withdrew from the program and Invesco sold all RMBS”): Financial instrument backed investments and is winding down the PPIF. As of June 30, 2012, the PPIFs had by a group of residential real estate drawn down $18.5 billion in debt and equity financing from Treasury funding mortgages (i.e., home mortgages for out of the total obligation, which includes $4.4 billion that has been repaid.75 residences with up to four dwelling As the PPIFs continue to make purchases, they will continue to have access to units) not guaranteed or owned by draw down the remaining funding through the end of their investment periods, a Government-sponsored enterprise the last of which will expire in December 2012.76 Following the expiration of the (“GSE”) (Fannie Mae or Freddie Mac) or investment period, the fund managers will have five years to manage and sell a Government agency. the investment portfolio in the PPIF and return proceeds to private investors and taxpayers. This period may be extended up to a maximum of two years. For details about the program structure and fund-manager terms, see the “Public- Private Investment Program” discussion in this section. • Unlocking Credit for Small Businesses (“UCSB”)/Small Business Administration (“SBA”) Loan Support Initiative — In March 2009, Treasury officials announced that Treasury would buy up to $15 billion in securities backed by SBA loans under UCSB.77 Treasury obligated a total of $400 million for UCSB and made purchases of $368.1 million in 31 securities under the program. Treasury sold the last of its UCSB securities on January 24, 2012, ending the program with a net investment gain of about $9 million.78 For more information on the program, see the discussion of “Unlocking Credit for Small Businesses/Small Business Administration Loan Support” in this section.

Automotive Industry Financing Program (“AIFP”) TARP’s automotive industry support through AIFP aimed to “prevent a significant disruption of the American automotive industry, which would pose a systemic risk to financial market stability and have a negative effect on the economy of the United States.”79 As of June 30, 2012, General Motors Company (“GM”) and Ally Financial Inc. (“Ally Financial”), formerly GMAC Inc., remain in TARP. Taxpayers are still owed $44.5 billion. This includes about $27 billion for the TARP investment in GM and $14.7 billion for the TARP investment in Ally Financial, for which Treasury holds common stock in GM and Ally Financial. This amount also includes a $2.9 billion loss taxpayers suffered on the TARP investment in Chrysler. Chrysler Financial fully repaid the TARP investment.80 Through AIFP, Treasury made emergency loans to Chrysler Holding LLC (“Chrysler”), Chrysler Financial Services Americas LLC (“Chrysler Financial”), and GM. Additionally, Treasury bought senior preferred stock from Ally Financial and quarterly report to congress I July 25, 2012 51

assisted Chrysler and GM during their bankruptcy restructurings. Treasury obligat- ed $84.8 billion to AIFP, then reduced the total obligation to $81.8 billion (includ- ing approximately $2.1 billion in loan commitments to New Chrysler that were nev- er drawn down).81 As of June 30, 2012, $79.7 billion had been disbursed through AIFP and Treasury had received $35.2 billion in principal repayments, preferred stock redemption proceeds, and stock sale proceeds. As of June 30, 2012, Treasury had received approximately $22.5 billion related to its GM investment, $7.6 billion related to its Chrysler investment, $2.5 billion related to its Ally Financial/GMAC investment, and $1.5 billion related to its Chrysler Financial investment.82 As of June 30, 2012, Treasury had also received approximately $4.8 billion in dividends and interest under AIFP and its two subprograms, ASSP and AWCP.83 In return for a total of $49.5 billion in loans to GM, Treasury received $6.7 billion in debt in GM (which was subsequently repaid), in addition to $2.1 billion in preferred stock and a 60.8% common equity stake.84 As of June 30, 2012, Treasury has an $849.2 million claim against Old GM’s bankruptcy, a bankruptcy that recently terminated.85 Treasury does not expect any significant additional pro- ceeds from this claim.86 On December 2, 2010, GM closed an initial public offer- ing (“IPO”) in which Treasury sold a portion of its ownership stake for $18.1 billion in gross proceeds, reducing its ownership percentage to 33.3%.87 On December 15, 2010, GM repurchased the $2.1 billion in preferred stock from Treasury. On January 31, 2011, Treasury’s ownership in GM was diluted from 33.3% to 32% as a result of GM contributing 61 million of its common shares to fund GM’s hourly and salaried pension plans.88 As of June 30, 2012, Treasury had received $22.5 billion in principal repayments, proceeds from preferred stock redemptions, and proceeds from the sale of common stock from GM, including approximately $136.6 million in repayments related to its right to recover proceeds from Old GM.89 Treasury provided approximately $12.5 billion in loan commitments to Chrysler, Inc. (“Old Chrysler”), and Chrysler Group LLC (“New Chrysler”), of which $2.1 billion was never drawn down.90 Treasury also received a 9.9% equity stake, which was diluted to 8.6% in April 2011 after Fiat increased its ownership interest by meeting certain performance metrics. Upon full repayment of New Chrysler’s TARP debt obligations on May 24, 2011, Fiat simultaneously exercised an equity call option, which increased its stake in New Chrysler to 46% from 30%. As a result, Treasury’s equity stake in New Chrysler was diluted and further decreased to 6.6%.91 On July 21, 2011, Treasury sold to Fiat for $500 million Treasury’s remain- ing equity ownership interest in New Chrysler.92 Treasury also sold to Fiat for $60 million Treasury’s rights to receive proceeds under an agreement with the United Auto Workers (“UAW”) retiree trust pertaining to the trust’s shares in New Chrysler on a fully diluted basis.93 Treasury retains the right to recover certain proceeds from Old Chrysler’s bankruptcy but according to Treasury, it is unlikely to recover its full investment. Treasury invested a total of $17.2 billion in Ally Financial. On December 30, 2010, Treasury’s investment was restructured to provide for a 73.8% com- mon equity stake, $2.7 billion in TRUPS (including amounts received in war- rants that were immediately converted into additional securities), and $5.9 billion 52 special inspector general I troubled asset relief program

in mandatorily convertible preferred shares.94 Treasury sold the $2.7 billion in TRUPS on March 2, 2011.95 On March 31, 2011, Ally Financial announced that it had filed a registration statement with the Securities and Exchange Commission (“SEC”) for a proposed IPO of common stock owned by Treasury. On a number of subsequent occasions, Ally Financial disclosed additional details about its proposed IPO in amended registration statements filed with the SEC. Concurrent with the proposed IPO, Treasury plans to convert $2.9 billion of its existing $5.9 billion of mandatorily convertible preferred shares (“MCP”) into common stock.96 Treasury will exchange the remaining $3 billion of its MCP into so-called tangible equity units, a type of preferred stock, and will offer a portion of these tangible equity units alongside the proposed common equity offering.97 On May 14, 2012, Ally Financial announced that its mortgage subsidiary, Residential Capital, LLC, and certain of its subsidiaries filed for bankruptcy court relief under Chapter 11 of the U.S. Bankruptcy Code, and that it was exploring strategic alternatives for its international operations, which include auto finance, insurance, and banking and deposit operations in Canada, Mexico, Europe, the U.K. and South America. Treasury provided a $1.5 billion loan to Chrysler Financial, which was fully repaid with interest in July 2009.98 For details on assistance to these companies, see the “Automotive Industry Support Programs” discussion in this section. AIFP also included two subprograms:

• Auto Supplier Support Program (“ASSP”) — According to Treasury, this program was intended to provide auto suppliers “with the confidence they need to continue shipping their parts and the support they need to help access loans to pay their employees and continue their operations.”99 Under the program, which ended in April 2010, Treasury made loans for GM ($290 million) and Chrysler ($123.1 million) that were fully repaid with $115.9 million in interest, fees and other income.100 For more information, see the “Auto Supplier Support Program” discussion in this section. • Auto Warranty Commitment Program (“AWCP”) — This program was designed to bolster consumer confidence by guaranteeing Chrysler and GM vehicle warranties during the companies’ restructuring through bankruptcy. It ended in July 2009 after Chrysler fully repaid its AWCP loan of $280.1 million with interest and GM repaid just the principal — $360.6 million — of its loan.101 For more information, see the “Auto Warranty Commitment Program” discussion in this section. quarterly report to congress I July 25, 2012 53

The following tables and figures summarize the status of TARP and TARP- related initiatives:

• Table 2.6 — total funds subject to SIGTARP oversight as of June 30, 2012 • Table 2.7 — obligations/expenditures by program as of June 30, 2012 • Table 2.8 and Table 2.9 — summary of TARP terms and agreements • Table 2.10 — summary of largest warrant positions held by Treasury, by program, as of June 30, 2012 • Table 2.11 — summary of dividends, interest payments, and fees received, by program, as of June 30, 2012

For a report of all TARP purchases, obligations, expenditures, and revenues, see Appendix C: “Reporting Requirements.” 54 special inspector general I troubled asset relief program

TABLE 2.6

TOTAL FUNDS SUBJECT TO SIGTARP OVERSIGHT, AS OF 6/30/2012 ($ Billions) Numbers in parentheses represent repayments and reductions in exposure TARP Funding TARP Total after Dodd- Funding as of Program Brief Description or Participant Funding Frank 6/30/2012 Housing Support Programs Modification of mortgage loans $70.6a $45.6b $45.6

Capital Purchase Program (“CPP”) Investments in 707 banks; received $191.1 billion in 204.9 204.9 204.9 principal repayments, including $363.3 million in non- c c c CLOSED cash conversion from CPP to CDCI (191.1) (191.1) (191.1)

Community Development Capital Investments in Community Development Financial Initiative (“CDCI”) Institutions (“CDFIs”), received $350,000 in principal 0.6 0.6 0.6 CLOSED repayment Systemically Significant Failing 69.8 69.8 67.8 Institutions (“SSFI”) AIG Investment; received $34.7 billion in repayments and reductions in exposure (34.7)d (34.7)d (34.7)d CLOSED Targeted Investment Program (“TIP”) 40.0 40.0 40.0 Citigroup, Bank of America Investments CLOSED (40.0) (40.0) (40.0) Asset Guarantee Program (“AGP”) 301.0 5.0 5.0 Citigroup, ring-fence asset guarantee CLOSED (301.0) (5.0) (5.0)

Term Asset-Backed Securities FRBNY non-recourse loans for purchase of asset-backed 71.1 4.3e 1.4e Loan Facility (“TALF”) securities (0.0) (0.0) (0.0)

Investments in legacy mortgage-backed securities using f g Public-Private Investment Program 29.8 22.4 21.9 private and Government equity, along with Government (“PPIP”) debt (4.4) (4.4) (4.4) Unlocking Credit for Small Businesses 0.4h 0.4h 0.4h (“UCSB”) Purchase of securities backed by SBA loans (0.4) (0.4) (0.4) CLOSED GM, Chrysler, Ally Financial Inc. (formerly GMAC), Automotive Industry Financing Program Chrysler Financial; received $34.2 billion in loan 80.7 80.7 79.7 (“AIFP”) repayments, preferred stock redemptions and proceeds (36.2) (36.2) (36.2) CLOSED from the sale of common stock; terminated Chrysler’s $2.1 billion in undrawn loan commitments Auto Suppliers Support Program 0.4i 0.4i 0.4 (“ASSP”) Government-backed protection for auto parts suppliers; received $0.4 billion in loan repayments (0.4) (0.4) (0.4) CLOSED Auto Warranty Commitment Program Government-backed protection for warranties of cars 0.6 0.6 0.6 (“AWCP”) sold during the GM and Chrysler bankruptcy restructuring (0.6) (0.6) (0.6) CLOSED periods Total Obligations $869.9 $474.8 $467.2

Notes: Numbers may not total due to rounding. a Program was initially announced as a $75 billion initiative with $50 billion funded through TARP. Treasury reduced the commitment from $50 billion to an obligation of $45.6 billion; therefore, including the $25 billion estimated to be spent by the GSEs, the total program amount is $70.6 billion. b Treasury reduced its commitment from $50 billion to an obligation of $45.6 billion. c Does not include $204.4 million in proceeds from CPP auction held June 25-27, 2012, but not settled until after June 30, 2012. d The $34.7 billion in reduced exposure and repayment for SSFI includes amounts applied to pay (i) accrued preferred returns, (ii) redeem the outstanding liquidation amount, and (iii) the cancellation of the series G capital facility. Does not include AIG investment proceeds from the sale of AIG stock that Treasury received from the AIG credit facility trust in the January 2011 recapitalization. e Treasury reduced obligation from $20 billion to $4.3 billion in 2010, then further reduced obligation from $4.3 billion to $1.4 billion in 2012. f PPIP funding includes $7.4 billion of private-sector equity capital. Includes $0.4 billion of initial obligations to The TCW Group, Inc., which has been repaid. g Treasury reduced its commitment from $30 billion to approximately $22.4 billion in debt and equity obligations to the Public-Private Investment Funds. Invesco terminated its investment period on September 26, 2011, without fully drawing down all committed equity and debt. h Treasury reduced commitment from $15 billion to an obligation of $400 million. i Treasury’s original commitment under this program was $5 billion, which was reduced to $3.5 billion effective 7/1/2009. Of the $3.5 billion available, only $413 million was borrowed.

Sources: Treasury, Transactions Report, 6/27/2012; Treasury, Daily TARP Update, 7/2/2012; Treasury Press Release, “U.S. Government Finalizes Terms of Citi Guarantee Announced in November,” 1/16/2009, www.treasury.gov/press-center/press-releases/Pages/hp1358.aspx, accessed 6/28/2012; FRBNY, response to SIGTARP data call, 7/5/2012; Treasury, “Making Home Affordable Updated Detailed Program Description,” 3/4/2009, www.treasury.gov/press-center/press-releases/Documents/housing_fact_sheet.pdf, accessed 6/28/2012; Treasury, Legacy Securities Public-Private Investment Program, Program Update – Quarter Ended March 31, 2012, 4/19/2012, www.treasury.gov/initiatives/financial-stability/programs/Credit%20Market%20Programs/ppip/Documents/PPIP%20 Report%20-%20Q1-12.pdf, accessed 7/10/2012. quarterly report to congress I July 25, 2012 55

TABLE 2.7

OBLIGATION/EXPENDITURE LEVELS BY PROGRAM, as of 6/30/2012 ($ Billions) Amount Percent (%) Authorized Under EESA $700.0 Released Immediately 250.0 52.6% Released Under Presidential Certificate of Need 100.0 21.1% Released Under Presidential Certificate of Need & Resolution to Disapprove Failed 350.0 73.7% Helping Families Save Their Home Act of 2009 (1.2) -0.3% The Dodd-Frank Act (223.8) -47.1% Total Released $475.0 100.0%

Obligations Current Current Repaid/ Less: Obligations by after Dodd- Obligations as Obligation as % Reduced Obligation Treasury under TARPa Frank Act of 6/30/2012 of Released Exposure Outstandingb Section Reference Making Home Affordable $29.9 $29.9 6.4% (“MHA”) Housing Finance Agency: $7.6 $7.6 1.6% “Housing Support Programs” Hardest Hit Fund (“HHF”) FHA Short Refinance $8.1 $8.1 1.7% Program Housing Support $45.6 $45.6 9.8% — $45.6 Programs Total Capital Purchase “Financial Institution Support $204.9 $204.9 43.9% ($191.1)c Program (“CPP”) Programs” CPP Total $204.9 $204.9 43.9% ($191.1)c $13.8 Community Development “Financial Institution Support $0.6 $0.6 0.1% * Capital Initiative (“CDCI”) Programs” CDCI Total $0.6 $0.6 0.1% $0.0 $0.6 Systemically Significant Failing Institutions (“SSFI”) Program: “Financial Institution Support Programs” American International $69.8 $67.8 14.5% ($34.7) Group, Inc. (“AIG”)d SSFI Total $69.8 $67.8 14.5% ($34.7) $33.1 Targeted Investment Program (“TIP”): “Financial Institution Support Bank of America $20.0 $20.0 4.3% ($20.0) Programs” Corporation Citigroup, Inc. $20.0 $20.0 4.3% ($20.0) TIP Total $40.0 $40.0 8.6% ($40.0) — Asset Guarantee Program (“AGP”): “Financial Institution Support Programs” Citigroup, Inc.e $5.0 $5.0 1.1% ($5.0) AGP Total $5.0 $5.0 1.1% ($5.0) — Term Asset-Backed Securities Loan Facility (“TALF”): “Asset Support Programs” TALF LLC $4.3 $1.4 0.3% ($0.0) TALF Total $4.3 $1.4 0.3% ($0.0) $1.4 Continued on next page 56 special inspector general I troubled asset relief program

OBLIGATION/EXPENDITURE LEVELS BY PROGRAM ($ Billions) (CONTINUED) Obligations Current Current Repaid/ Less: Obligations by after Dodd- Obligations as Obligation as % Reduced Obligation Treasury under TARPa Frank Act of 6/30/2012 of Released Exposure Outstandingb Section Reference Legacy Securities Public-Private Investment Program (“PPIP”): AG GECC PPIF Master $3.7 $3.7 0.8% ($0.8) Fund, L.P. AllianceBernstein Legacy Securities $3.5 $3.5 0.7% ($1.1) Master Fund, L.P. BlackRock PPIF, L.P. $2.1 $2.1 0.4% — Invesco Legacy Securities Master $2.6 $2.0 0.4% ($1.7) Fund, L.P.f Marathon Legacy “Asset Support Programs” Securities Public- $1.4 $1.4 0.3% — Private Investment Partnership, L.P. Oaktree PPIP Fund, $3.5 $3.5 0.7% ($0.2) L.P. RLJ Western Asset Public/Private Master $1.9 $1.9 0.4% * Fund, L.P. UST/TCW Senior Mortgage Securities $0.4 $0.4 0.1% ($0.4) Fund, L.P.g Wellington Management Legacy $3.4 $3.4 0.7% ($0.1) Securities PPIF Master Fund, LP PPIP Totalh $22.4 $21.9 4.7% ($4.4) $17.5 Unlocking Credit for Small Businesses $0.4 $0.4 0.1% ($0.4) “Asset Support Programs” (“UCSB”) UCSB Total $0.4 $0.4 0.1% ($0.4) * Automotive Industry Financing Program (“AIFP”): General Motors $49.5 $49.5 10.6% ($22.5) Corporation (“GM”) “Automotive Industry Support Ally Financial $17.2 $17.2 3.7% ($2.5) Programs” (formerly GMAC) Chrysler Holding LLCi $12.5 $10.5 2.2% ($9.7) Chrysler Financial Services Americas $1.5 $1.5 0.3% ($1.5) LLC AIFP Total $80.7 $78.7 16.8% ($36.2) $42.5 Continued on next page quarterly report to congress I July 25, 2012 57

OBLIGATION/EXPENDITURE LEVELS BY PROGRAM ($ Billions) (CONTINUED) Obligations Current Current Repaid/ Less: Obligations by after Dodd- Obligations as Obligation as % Reduced Obligation Treasury under TARPa Frank Act of 6/30/2012 of Released Exposure Outstandingb Section Reference Automotive Supplier Support Program (“ASSP”): “Automotive Industry Support GM Suppliers Programs” $0.3 $0.3 0.1% ($0.3) Receivables LLCj Chrysler Holding LLC $0.1 $0.1 0.0% ($0.1) ASSP Totalj $0.4 $0.4 0.1% ($0.4) — Automotive Warranty Commitment Program (“AWCP”): “Automotive Industry Support General Motors Programs” $0.4 $0.4 0.1% ($0.4) Corporation (“GM”) Chrysler Holding LLC $0.3 $0.3 0.0% ($0.3) AWCP Total $0.6 $0.6 0.1% ($0.6) — TARP Obligations Subtotal $474.8 $467.2 100% TARP Repayments/ Reductions in Exposure Subtotal ($312.8) TARP Obligations Outstanding Subtotal $154.4

Notes: Numbers may not total due to rounding. a From a budgetary perspective, what Treasury has obligated to spend (e.g., signed agreements with TARP fund recipients). b Figure does not subtract losses incurred from failed banks. c Does not include $204.4 million in proceeds from CPP auction held June 25-27, 2012, but not settled until after June 30, 2012. Does include $363.3 million non-cash conversion from CPP to CDCI. d The $34.7 billion in reduced exposure and repayment for SSFI includes amounts applied to pay (i) accrued preferred returns, (ii) redeem the outstanding liquidation amount, and (iii) the cancellation of the series G capital facility. Does not include AIG investment proceeds from the sale of AIG stock that Treasury received from the AIG credit facility trust in the January 2011 recapitalization. e Treasury committed $5 billion to Citigroup under AGP; however, the funding was conditional based on losses that could potentially be realized and may potentially never be expended. This amount was not an actual outlay of cash. f Invesco paid the remainder of its debt, $284.5 million, to Treasury on March 14, 2012. g The TCW Group, Inc. repaid the funds invested in its PPIF, which is now liquidated. h Treasury selected nine fund management firms to establish PPIFs. One PPIP manager, TCW, subsequently withdrew. According to Treasury, the current PPIP obligation is $21.9 billion, and includes $365.25 million of an initial obligation to TCW that was funded. TCW repaid the funds. i The $9.7 billion in repayments and reductions in exposure includes (i) loan repayments from New Chrysler, (ii) proceeds related to the liquidation of Old Chrysler, (iii) a settlement payment for a loan to Chrysler Holding, (iv) termination of New Chrysler’s ability to draw the remaining $2.1 billion under a loan facility made available in May 2009, and (v) proceeds related to the sale to Fiat of Treasury’s remaining equity ownership stake in New Chrysler and the sale to Fiat of Treasury’s rights to receive proceeds under an agreement with the United Auto Workers (“UAW”) retiree trust pertaining to the trust’s shares in New Chrysler. j Represents an SPV created by the manufacturer. Balance represents the maximum loan amount, which will be funded incrementally. Treasury’s original commitment under this program was $5 billion, but subsequently reduced to $3.5 billion effective 7/1/2009. Of the $3.5 billion available, only $413 million was borrowed.

*Amount less than $50 million.

Sources: Emergency Economic Stabilization Act, P.L. 110-343, 10/3/2008; Library of Congress, “A joint resolution relating to the disapproval of obligations under the Emergency Economic Stabilization Act of 2008,” 1/15/2009, http://thomas.loc.gov/cgi-bin/bdquery/D?d111:5:./list/bss/d111SJ.lst::, accessed 6/28/2012; Helping Families Save Their Homes Act of 2009, P.L. 111-22, 5/20/2009; Treasury, Transactions Report, 6/27/2012; Treasury, Transactions Report-Housing Programs, 7/2/2012; Treasury, response to SIGTARP data call, 7/5/2012; Treasury, Section 105(a) Report, 7/10/2012. 58 special inspector general I troubled asset relief program

TABLE 2.8 Debt Agreements, as of 6/30/2012 TARP Date of Cost Description of Interest/ Term of Program Company Agreement Assigned Investment Investment Information Dividends Agreement Each QFI may issue senior Senior securities with an aggregate 7.7% for first 5 Subordinated principal amount of 1% – 3% of years; 13.8% 30 years Securities its risk-weighted assets, but not thereafter CPP – Originally to exceed $25 billion. 1/14/2009a $0.5 billion S-Corps 52 QFIs Senior Treasury will receive warrants Subordinated to purchase an amount equal Security Warrants to 5% of the senior securities 13.8% 30 years that are exercised purchased on the date of immediately investment. Each QCU may issue CDCI Senior Securities with an CDCI – Subordinated aggregate principal amount equal 2% for first 8 years, CDCI – Credit Credit All Debt for Credit to not more than 3.5% of its total 9% thereafter Unions Unions Unions assets and not more than 50% of the capital and surplus of the QCU. Each QFI may issue CDCI Senior Securities with an aggregate principal amount equal to not more than 5% of (i), if the QFI is a Certified Entity the risk-weighted assets of the QFI, or (ii), if the 3.1% for first 8 CDCI – Subordinated CDCI – QFI is not a Certified Entity, the years, 13.8% S-Corps Debt for S-corps S-Corps sum of the RWAs of each of the thereafter Certified Entities, in each case less the aggregate capital or, as the case may be, principal amount of any outstanding TARP assistance of the QFI. The debt obligation for each fund Debt Obligation Each of the loans will be funded matures at 9/30/2009 with Contingent PPIP All $20 billion incrementally, upon demand by LIBOR + 1% the earlier and later Interest the fund manager. of the Promissory Note dissolution of the fund or 10 years. Notes: Numbers may be affected by rounding. a Announcement date of CPP S-Corporation Term Sheet.

Sources: Treasury, “Loan and Security Agreement By and Between General Motors Corporation as Borrower and The United States Department of Treasury as Lender Dated as of December 31, 2008,” 12/31/2008; OFS, response to SIGTARP draft report, 1/30/2009; Treasury, Transactions Report, 9/30/2010; Treasury, response to SIGTARP data call, 10/7/2010; Treasury’s “TARP Community Development Capital Initiative Program Agreement, CDFI Bank/Thrift Senior Preferred Stock, Summary of CDCI Senior Preferred Terms,” 4/26/2010; Treasury’s “TARP Community Development Capital Initiative CDFI Credit Unions Senior Securities Summary of Terms of CDCI Senior Securities,” 4/26/2010; Treasury’s “TARP’s Community Development Capital Initiative CDFI Subchapter S Corporation Senior Securities Summary of Terms of CDCI Senior Securities,” 4/26/2010; Treasury, “Legacy Securities Public-Private Investment Partnership Summary of Indictive Terms and Conditions,” 7/8/2009. quarterly report to congress I July 25, 2012 59

TABLE 2.9 Equity Agreements, as of 6/30/2012 TARP Date of Cost Description Term of Program Company Agreement Assigned of Investment Investment Information Dividends Agreement Senior 1-3% of risk-weighted assets, 5% for first Preferred not to exceed $25 billion for 5 years, 9% Perpetual Equity each QFI thereafter CPP – Originally 286 10/14/2008a $200.1 Public QFIs and later billion Common Stock 15% of senior preferred — Up to 10 years Purchase amount Warrants 1-3% of risk-weighted assets, 5% for first Preferred not to exceed $25 billion for 5 years, 9% Perpetual Equity each QFI thereafter

CPP – Originally 369 11/17/2008b Preferred $4 billion Private QFIs and later Stock Purchase 5% of preferred amount 9% Perpetual Warrants that are exercised immediately Preferred 5% of risk-weighted assets 2% for first $780.2 Equity for CDCI All for banks and bank holding 8 years, 9% Perpetual million banks & thrift companies thereafter institutions Non- Cumulative $41.6 billion aggregate 10% Perpetual Preferred liquidation preference Equity 2% of issued and outstanding American $41.6 common stock on investment SSFI International 4/17/2009 c date of 11/25/2008; the billion Common Group, Inc. warrant was originally for Stock 53,798,766 shares and had a — Up to 10 years Purchase $2.50 exercise price, but after Warrants the 6/30/2009 split, it is for 2,689,938.30 shares and has an exercise price of $50. Up to $29.8 billion aggregate Non- liquidation preference. As of Perpetual (life of Cumulative 9/30/2009, the aggregate 10% the facility is 5 Preferred American liquidation preference was $3.2 years) $29.8 Equity SSFI International 4/17/2009 billion. billiond Group, Inc. Common 150 common stock warrants Stock outstanding; $0.0002 exercise — Up to 10 years Purchase price Warrants Continued on next page 60 special inspector general I troubled asset relief program

Equity Agreements, as of 6/30/2012 (continued) TARP Date of Cost Description Term of Program Company Agreement Assigned of Investment Investment Information Dividends Agreement Exchanged preferred Series F shares for $16.9 billion of AIA Preferred Units, $3.4 billion in ALICO Junior Preferred Interests, and 167.6 million AIA Preferred shares of Common stock at units, ALICO an exercise price of $43.53. Junior Following the repayments to $29.8 Preferred Treasury on March 8, 2012, — Up to 10 years billione American Interests, for $6 billion, March 15, SSFI International 1/14/2011 Common 2012, for $1.5 billion, March Group, Inc. Stock 22, 2012, for $1.5 billion, and May 6, 2012, for $5.8 billion, AIG successfully retired the remainder if Treasury’s preferred equity interests in the AIA SPV. Exchanged preferred Series Common D shares for 924.5 million $41.6 billionf — Perpetual Stock shares of common stock at an exercise price of $45 8 years with the Membership Each membership interest will 9/30/2009 and possibility of PPIP All $10 billion interest in a be funded upon demand from — later extension for 2 partnership the fund manager. additional years Mandatorily Converts to Convertible common equity $5 billion 9% Preferred interest after 7 Stock years Ally Financial AIFP Inc. (formerly 12/29/2008 $5 billion Preferred GMAC) Stock Converts to Purchase common equity 5% of original preferred amount 9% Warrants that interest after 7 are exercised years immediately Mandatorily Converts to Convertible common equity $4.5 billion 9% Preferred interest after 7 Stockg years Preferred Ally Financial Stock Converts to AIFP Inc. (formerly 5/21/2009 $7.5 billion Purchase common equity GMAC) 5% of original preferred amount 9% Warrants that interest after 7 are exercised years immediately Common $3 billion — Perpetual Equity Interesth Continued on next page quarterly report to congress I July 25, 2012 61

Equity Agreements, as of 6/30/2012 (continued) TARP Date of Cost Description Term of Program Company Agreement Assigned of Investment Investment Information Dividends Agreement This equity interest was obtained by exchanging a Ally Financial Common prior debt obligation with AIFP Inc. (formerly 5/29/2009 $0.9 billion — Perpetual Equity Interest General Motors. See “Debt GMAC) Agreements” table for more information. Trust Preferred $2.5 billion 8% Securities Ally Financial Trust Preferred Redeemable upon AIFP Inc. (formerly 12/30/2009 $2.5 billion purchase the repayment of GMAC) warrants that 5% of trust preferred amount — the debenture are exercised immediately Mandatorily Convertible $1.3 billion 9% Preferred Stock Converts to Ally Financial common equity AIFP Inc. (formerly 12/30/2009 $1.3 billion Preferred interest after 7 GMAC) Stock Purchase years 5% of preferred amount — Warrants that are exercised immediately Ally Financial Common AIFP Inc. (formerly 12/30/2009 $5.5 billion $5.5 billion — Perpetual Equity Interesth GMAC) Notes: Numbers may be affected by rounding. a Announcement date of CPP Public Term Sheet. b Announcement date of CPP Private Term Sheet. c AIG exchanged Treasury’s $40 billion investment in cumulative preferred stock (obtained on 11/25/2008) for non-cumulative preferred stock, effectively cancelling the original $40 billion investment. d The Equity Capital Facility was announced as a $30 billion commitment, but Treasury reduced this amount by the value of the AIGFP Retention Payment amount of $165 million. e On 1/14/2011, (A) Treasury exchanged $27.84 billion of Treasury’s investment in AIG’s Fixed Rate Non-Cumulative Perpetual Preferred Stock (Series F) which is equal to the amount funded (including amounts drawn at closing) under the Series F equity capital facility, for (i) the transferred SPV preferred interests and (ii) 167,623,733 shares of AIG Common Stock, and (B) Treasury exchanged $2 billion of undrawn Series F for 20,000 shares of preferred stock under the new Series G Cumulative Mandatory Convertible Preferred Stock equity capital facility under which AIG has the right to draw up to $2 billion. The Series G equity capital facility was subsequently terminated without drawdown. f On 1/14/2011, Treasury exchanged an amount equivalent to the $40 billion initial investment plus capitalized interest from the April 2009 exchange (see note 1 above) of Fixed Rate Non-Cumulative Perpetual Preferred Stock (Series E) for 924,546,133 shares of AIG Common Stock. g On 12/31/2009, Treasury exchanged $5.25 billion of preferred stock, which it acquired on December 29, 2009, into mandatorily convertible preferred stock (“MCP”). h On 12/31/2010, Treasury converted $5.5 billion of its existing MCP, which was invested in May 2009, into common equity. Treasury’s equity ownership of Ally Financial Inc. (formerly GMAC) increased from 56% to 74% due to this conversion.

Sources: Treasury, “TARP Capital Purchase Program Agreement, Senior Preferred Stock and Warrants, Summary of Senior Preferred Terms,” 10/14/2008; Treasury, “TARP Capital Purchase Program Agreement, (Non-Public QFIs, excluding S Corps and Mutual Organizations) Preferred Securities, Summary of Warrant Terms,” 11/17/2008; Treasury, “Securities Purchase Agreement dated as of November 25, 2008 between American International Group, Inc. and United States Department of Treasury,” 11/25/2008; Treasury, “TARP AIG SSFI Investment, Senior Preferred Stock and Warrant, Summary of Senior Preferred Terms,” 11/25/2008; Treasury, “Securities Purchase Agreement dated as of January 15, 2009 between Citigroup, Inc. and United States Department of Treasury,” 1/15/2009; Treasury, “Citigroup, Inc. Summary of Terms, Eligible Asset Guarantee,” 11/23/2008; “Securities Purchase Agreement dated as of January 15, 2009 between Bank of America Corporation and United States Department of Treasury,” 1/15/2009; Treasury, “Bank of America Summary of Terms, Preferred Securities,” 1/16/2009; Treasury, “GMAC LLC Automotive Industry Financing Program, Preferred Membership Interests, Summary of Preferred Terms,” 12/29/2008; Treasury, Transactions Report, 3/31/2011; Treasury, response to SIGTARP data call, 10/7/2010; Treasury, “TARP Community Development Capital Initiative Program Agreement, CDFI Bank/Thrift Senior Preferred Stock, Summary of CDCI Senior Preferred Terms,” 4/26/2010; Treasury, “TARP Community Development Capital Initiative CDFI Credit Unions Senior Securities Summary of Terms of CDCI Senior Securities,” 4/26/2010; Treasury, “TARP’s Community Development Capital Initiative CDFI Subchapter S Corporation Senior Securities Summary of Terms of CDCI Senior Securities,” 4/26/2010; Treasury, “Treasury Converts Nearly Half of Its Ally Preferred Shares to Common Stock,” 12/30/2010; Ally Financial Inc. (GOM), 8−K, 12/30/2010; Treasury, Transactions Report, 7/2/2012; Treasury, “Master Transaction Agreement for American International Group. INC, ALICO Holdings LLC, AIA Aurora LLC, Federal Reserve Bank of New York, United States Treasury, and AIG Credit Facility Trust,” 12/8/2010; Treasury, “Legacy Securities Public-Private Investment Partnership Summary of Indictive Terms and Conditions,” 7/8/2009. 62 special inspector general I troubled asset relief program

TABLE 2.10 LARGEST POSITIONS IN WARRANTS HELD BY TREASURY, BY PROGRAM, AS OF 6/30/2012 Current Number of Warrants Stock Price as of Participant Investment Date Outstanding Strike Price 6/29/2012 Capital Purchase Program (“CPP”) Synovus Financial Corp. 12/19/2008 15,510,737 $9.36 $1.98 Flagstar Bancorp, Inc. 1/16/2009 6,451,379 $6.20 $0.84 Zions Bancorporation 11/14/2008 5,789,909 $36.27 $19.42 Popular, Inc. 12/5/2008 2,093,284 $67.00 $16.61 Cathay General Bancorp 12/5/2008 1,846,378 $20.96 $16.51 Citizens Republic Bancorp, Inc. 12/12/2008 1,757,813 $25.60 $17.13 International Bancshares Corporation 12/23/2008 1,326,238 $24.43 $19.51 M&T Bank Corporationc 12/5/2008 1,218,522 $73.86 $82.00 PrivateBancorp, Inc. 2/27/2009 645,013 $28.35 $14.76 United Community Banks, Inc. 12/5/2008 219,908 $61.39 $8.57 Systemically Significant Failing Institutions (“SSFI”) Program AIGa 11/25/2008 2,689,938 $50.00 $32.09 AIGa 4/17/2009 150 $0.00b $32.09

Notes: Numbers may be affected by rounding. a All warrant and stock data for AIG are based on the 6/30/2009 reverse stock split of 20 for 1. b Strike price is $0.00002. c M&T Bank Corporation assumed additional warrant positions in conjunction with two acquired CPP investments. These additional positions are 407,542 shares at a strike price of $55.76 and 95,383 shares at a strike price of $518.96.

Sources: Treasury, Transactions Report, 6/27/2012; Treasury, Dividends and Interest Report, 7/11/2012; Treasury, response to SIGTARP data call, 7/10/2012; Market Data, Bloomberg L.P., accessed 7/9/2012.

TABLE 2.11 DIVIDENDS, INTEREST, DISTRIBUTIONS, AND OTHER INCOME PAYMENTS, AS OF 6/30/2012 Dividends Interest Distributionsa Other Incomeb Total CPPc $11,561,231,819 $106,750,371 $— $14,527,500,194 $26,195,482,384 CDCI 13,031,228 6,196,474 — — 19,227,702 SSFId — — — 457,105,652 457,105,652 TIP 3,004,444,444 — — 1,427,190,941 4,431,635,385 AGP 442,964,764 — — 2,589,197,045 3,032,161,809 PPIP — 275,850,318 694,785,028 24,078,780 994,714,126 UCSB — 13,347,352 — 29,201,848 42,549,200 AIFPe 3,140,957,051 1,665,336,675 — 530,000,000 5,336,293,726 ASSP — 31,949,931 — 84,000,000 115,949,931 Total $18,162,629,306 $2,099,431,121 $694,785,028 $19,668,274,460 $40,625,119,915

Notes: Numbers may not total due to rounding. a Distributions are investment proceeds from the PPIF’s trading activities allocated to the partners, including Treasury, not later than 30 days after the end of each quarter. b Other income includes Citigroup common stock gain for CPP, Citigroup payment for AGP, warrant sales, additional note proceeds from the auto programs and the Consumer and Business Lending Initiative/SBA 7(a) programs, principal repayments on the SBA 7(a) program, and repayments associated with the termination of the TCW fund for PPIP. c Includes $13 million fee received as part of the Popular exchange. d Pursuant to the recapitalization plan on 1/14/2011, AIG had an additional obligation to Treasury of $641,275,676 to reflect the cumulative unpaid interest which further converted into AIG common stock. Other income from SSFI includes $165 million in fees and approximately $292.1 million representing return on securities held in the AIA and ALICO SPVs. e includes AWCP.

Sources: Treasury, Transactions Report, 6/27/2012; Treasury, Section 105(a) Report, 7/10/2012; Treasury, Dividends and Interest Report, 7/11/2012; Treasury, response to SIGTARP data call, 7/10/2012. quarterly report to congress I July 25, 2012 63

Housing Support Programs On February 18, 2009, the Administration announced a foreclosure prevention plan that became the Making Home Affordable (“MHA”) program, an umbrella Government-Sponsored Enterprises program for the Administration’s homeowner assistance and foreclosure prevention (“GSEs”): Private corporations created efforts.102 MHA initially consisted of the Home Affordable Modification Program and chartered by the Government to (“HAMP”), a Treasury program that uses TARP funds to provide incentives for reduce borrowing costs and provide mortgage servicers to modify eligible first mortgages, and two initiatives at the liquidity in the market, the liabilities Government-sponsored enterprises (“GSEs”) that use non-TARP funds.103 HAMP of which are not officially considered was originally intended “to help as many as three to four million financially direct taxpayer obligations. On struggling homeowners avoid foreclosure by modifying loans to a level that is September 7, 2008, the two largest affordable for borrowers now and sustainable over the long term.”104 On June 1, GSEs, the Federal National Mortgage 2012, HAMP expanded the pool of homeowners potentially eligible to be assisted Association (“Fannie Mae”) and through the launch of HAMP Tier 2; however, Treasury has not estimated the the Federal Home Loan Mortgage number of homeowners that HAMP Tier 2 is intended to assist.105 Corporation (“Freddie Mac”), were Treasury over time expanded MHA to include sub-programs designed to placed into Federal conservatorship. overcome obstacles to sustainable HAMP modifications. Treasury also allocated They are currently being financially TARP funds to support two additional housing support efforts: a Federal Housing supported by the Government. Administration (“FHA”) refinancing program and TARP funding for 19 state housing finance agencies, called the Housing Finance Agency Hardest Hit Fund Loan Servicers: Companies that (“Hardest Hit Fund” or “HHF”). perform administrative tasks on Not all housing support programs are funded, or completely funded, by TARP. monthly mortgage payments until the Of the originally anticipated $75 billion cost for MHA, $50 billion was to be loan is repaid. These tasks include funded by TARP, with the remainder funded by the GSEs.106 Treasury has obligated billing, tracking, and collecting monthly TARP funds of $45.6 billion, which includes $29.9 billion for MHA incentive pay- payments; maintaining records of ments, $8.1 billion for FHA Short Refinance, and $7.6 billion for the Hardest Hit payments and balances; allocating Fund.107 Housing support programs include the following initiatives: and distributing payment collections to investors in accordance with • Home Affordable Modification Program (“HAMP”) — HAMP is intended each mortgage loan’s governing to use incentive payments to encourage loan servicers (“servicers”) and documentation; following up investors to modify eligible first-lien mortgages so that the monthly payments on delinquencies; and initiating of homeowners who are currently in default or generally at imminent risk of foreclosures. default will be reduced to affordable and sustainable levels. Incentive payments for modifications to loans owned or guaranteed by the GSEs are paid by the Investors: Owners of mortgage loans GSEs, not TARP.108 As of June 30, 2012, there were 818,803 active permanent or bonds backed by mortgage loans HAMP modifications, 393,887 of which were under TARP, with the remainder who receive interest and principal under the GSE portion of the program.109 While HAMP generally refers to payments from monthly mortgage the first-lien mortgage modification program, it also includes the following payments. Servicers manage the subprograms: cash flow from borrowers’ monthly çç Home Price Decline Protection (“HPDP”) — HPDP is intended to payments and distribute them to encourage additional investor participation and HAMP modifications in investors according to Pooling and areas with recent price declines by providing TARP-funded incentives to Servicing Agreements (“PSAs”). offset potential losses in home values.110 As of June 30, 2012, there were 133,182 loan modifications under HPDP.111 64 special inspector general I troubled asset relief program

çç Principal Reduction Alternative (“PRA”) — PRA is intended to encourage the use of principal reduction in modifications for eligible borrowers whose homes are worth significantly less than the remaining outstanding balances of their first-lien mortgage loans. It provides TARP-funded incentives to offset a portion of the principal reduction provided by the investor.112 As of June 30, 2012, 60,778 homeowners received permanent modifications through PRA.113 çç Home Affordable Unemployment Program (“UP”) — UP is intended to offer assistance to unemployed homeowners through temporary forbearance of all or a portion of their payments.114 As of May 31, 2012, 7,235 borrowers are participating in UP.115 • Home Affordable Modification Program Tier 2 (“HAMP Tier 2”) — HAMP Tier 2 is an expansion of HAMP to permit HAMP modifications on non- owner-occupied “rental” properties, and to allow borrowers with a wider range of debt-to-income ratios to receive modifications.116 The expanded program Short Sale: Sale of a home for less became effective on June 1, 2012. There are no borrowers with HAMP Tier 2 than the unpaid mortgage balance. A active permanent modifications as of June 30, 2012. The first Tier 2 trial will be borrower sells the home and the lender eligible for permanent modification beginning in September 2012. accepts the proceeds as full or partial • Home Affordable Foreclosure Alternatives (“HAFA”) — HAFA is intended satisfaction of the unpaid mortgage to provide incentives to servicers, investors, and borrowers to pursue short sales balance, thus avoiding the foreclosure and deeds-in-lieu of foreclosure for borrowers in cases in which the borrower process. is unable or unwilling to enter or sustain a modification. Under this program, the servicer releases the lien against the property and the investor waives all Deed-in-Lieu of Foreclosure: Instead rights to seek a deficiency judgment against a borrower who uses a short sale or of going through foreclosure, the deed-in-lieu when the property is worth less than the outstanding amount of the 117 borrower voluntarily surrenders the mortgage. As of June 30, 2012, there were 52,998 short sales and deeds-in- 118 deed to the home to the home lender, lieu under HAFA. as satisfaction of the unpaid mortgage • Second-Lien Modification Program (“2MP”) — 2MP is intended to modify balance. second-lien mortgages when a corresponding first lien is modified under HAMP by a participating servicer.119 As of June 30, 2012, 17 servicers are participating in 2MP.120 These servicers represent approximately 55% to 60% of the second- lien servicing market.121 As of June 30, 2012, there were 63,769 active permanently modified second liens in 2MP.122 • Agency-Insured Programs — These programs are similar in structure to HAMP, but apply to eligible first-lien mortgages insured by FHA or guaranteed by the Department of Agriculture’s Office of Rural Development (“RD”) and the Department of Veterans Affairs (“VA”).123 Treasury provides TARP-funded incentives to encourage modifications under the FHA and RD modification programs. As of June 30, 2012, there were seven RD-HAMP permanent modifications and 6,013 FHA-HAMP permanent modifications.124 • Treasury/FHA Second-Lien Program (“FHA2LP”) — In FHA2LP, Treasury uses TARP funds to provide incentives to servicers and investors who agree to principal reduction or extinguishment of second liens associated with an FHA refinance.125 As of June 30, 2012, no second liens had been extinguished under the program.126 quarterly report to congress I July 25, 2012 65

• FHA Short Refinance Program — This program, which is partially supported by TARP funds, is intended to provide borrowers who are current on their Underwater Mortgage: Mortgage loan mortgage an opportunity to refinance existing underwater mortgage loans that on which a homeowner owes more are not currently insured by FHA into FHA-insured mortgages with lower than the home is worth, typically as principal balances. Treasury has provided a TARP-funded letter of credit for up a result of a decline in the home’s to $8 billion in loss coverage on these newly originated FHA loans. As of June value. Underwater mortgages are also 30, 2012, 1,437 loans had been refinanced under FHA Short Refinance.127 referred to as having negative equity. • Housing Finance Agency Hardest Hit Fund (“HHF”) — A TARP-funded program, HHF is intended to fund foreclosure prevention programs run by state housing finance agencies in states hit hardest by the decrease in home prices and in states with high unemployment rates. Eighteen states and Washington, DC, received approval for aid through the program.128 As of March 31, 2012, the latest data available, 43,580 borrowers had received assistance under HHF.129

Status of TARP Funds Obligated to Housing Support Programs Treasury obligated $45.6 billion to housing support programs, of which $4.5 billion, or 10%, has been expended as of June 30, 2012.130 However, some of the expended funds remain as cash on hand or paid for administrative expenses at state housing finance agencies (“HFAs”) participating in the Hardest Hit Fund program. Treasury has capped the aggregate amount available to pay servicer, borrower, and investor incentives under MHA programs at $29.9 billion, of which $3.4 billion, or 11%, has been spent.131 Treasury allocated $8.1 billion for FHA Short Refinance, of which $6.6 million has been spent on administrative expenses. Treasury allocated $7.6 billion to the Hardest Hit Fund. As of March 31, 2012, only 5% of those funds have gone to help 43,580 homeowners. HFAs have drawn down $1.1 billion, as of June 30, 2012, but not all of that has gone to assist homeowners.132 Table 2.12 shows the breakdown in expenditures and estimated funding alloca- tions for these housing support programs. 66 special inspector general I troubled asset relief program

TABLE 2.12 TARP Allocations and Expenditures by housing Support programs, AS OF 6/30/2012 ($ BILLIONS) ALLOCATIONS EXPENDITURES MHA HAMP First Lien Modification $19.1 $2.7 PRA Modification 2.0 0.1 HPDP 1.6 0.3 UP —a — HAMP Total $22.7 $3.0 HAFA 4.2 0.2 2MP 0.1 0.2 Treasury FHA-HAMP 0.2 —b RD-HAMP —c — FHA2LP 2.7 — MHA Total $29.9 $3.4 FHA Short Refinance 8.1d 0.1 HHF (Drawdown by States)e 7.6 1.1 Total $45.6 $4.5

Notes: Numbers may not total due to rounding. According to Treasury, these numbers are “approximate.” a Treasury does not allocate TARP funds to UP. b Treasury has expended $0.01 billion for the Treasury FHA-HAMP program. c Treasury has allocated $0.02 billion to the RD-HAMP program. As of June 30, 2012, $1,834 has been expended for RD-HAMP. d This amount includes up to $117 million in fees Treasury will incur for the availability and usage of the $8 billion letter of credit. e Not all of the funds drawn down by HFAs have been used to assist homeowners. As of March 31, 2012, the latest data available, only $350.8 million was spent to assist homeowners.

Source: Treasury, response to SIGTARP data call, 7/9/2012. quarterly report to congress I July 25, 2012 67

As of June 30, 2012, Treasury had active agreements with 105 servicers. That compares with 145 servicers that had agreed to participate in MHA as of October 3, 2010.133 According to Treasury, of the $29.9 billion obligated to participating servicers under their Servicer Participation Agreements (“SPAs”), as of June 30, 2012, only $3.4 billion (11%) has been spent, broken down as follows: $3 billion had been spent on completing permanent modifications of first liens (393,887 of which remain active); $192.1 million under 2MP on completing 18,974 full extinguishments, 4,547 partial extinguishments (principal reductions), and 63,769 permanent modifications of second liens under 2MP; and $237.2 million on incen- tives for 52,998 short sales or deeds-in-lieu of foreclosure under HAFA.134 Of the combined amount of incentive payments, according to Treasury, approximately $1.2 billion went to pay servicer incentives, $1.6 billion went to pay investor incen- tives, and $644 million went to pay borrower incentives.135 As of June 30, 2012, Treasury had disbursed approximately $1.1 billion of the $7.6 billion allocated to HFAs participating in HHF, more than half of which sits as cash on hand with HFAs or is used for administrative expenses.136 The remaining $8.1 billion has been obligated under FHA Short Refinance to purchase a letter of credit to provide up to $8 billion in first loss coverage and to pay $117 million in fees for the letter of credit. According to Treasury, it has not paid any claims for defaults on the 1,437 loans refinanced under the program. However, Treasury has pre-funded a reserve account with $50 million to pay future claims and spent $6.6 million on adminis- trative expenses.137 The breakdown of TARP-funded expenditures related to hous- ing support programs (not including the GSE-funded portion of HAMP) are shown in Table 2.13. 68 special inspector general I troubled asset relief program

TABLE 2.13

Breakdown of TARP Expenditures, As of 6/30/2012 ($ MILLIONs) MHA TARP Expenditures HAMP HAMP First Lien Modification Incentives Servicer Incentive Payment $503.0 Servicer Current Borrower Incentive Payment 16.4 Annual Servicer Incentive Payment 534.9 Investor Current Borrower Incentive Payment 51.2 Investor Monthly Reduction Cost Share 1,057.8 Annual Borrower Incentive Payment 492.2 HAMP First Lien Modification Incentives Total $2,655.5 PRA $63.2 HPDP $251.9 UP —a HAMP Program Incentives Total $2,970.6 HAFA Incentives Servicer Incentive Payment $70.5 Investor Reimbursement 25.8 Borrower Relocation 140.9 HAFA Incentives Total $237.2 Second-Lien Modification Program Incentives 2MP Servicer Incentive Payment $41.0 2MP Annual Servicer Incentive Payment 7.1 2MP Annual Borrower Incentive Payment 6.5 2MP Investor Cost Share 50.0 2MP Investor Incentive 87.5 Second-Lien Modification Program Incentives Total $192.1 Treasury/FHA-HAMP Incentives Annual Servicer Incentive Payment $5.1 Annual Borrower Incentive Payment 4.7 Treasury/FHA-HAMP Incentives Total $9.8 RD-HAMP —b FHA2LP — MHA Incentives Total $3,410.0 FHA Short Refinance (Loss-Coverage) $56.6 HHF Disbursements (Drawdowns by State HFAs) $1,071.6 Total Expenditures $4,537.9

Notes: Numbers may not total due to rounding. a TARP funds are not used to support the UP program, which provides forbearance of a portion of the homeowner’s mortgage payment. b RD-HAMP expenditures equal $1,834 as of June 30, 2012.

Source: Treasury, response to SIGTARP data call, 7/10/2012. quarterly report to congress I July 25, 2012 69

HAMP According to Treasury, HAMP was intended “to help as many as three to four million financially struggling homeowners avoid foreclosure by modifying loans to a level that is affordable for borrowers now and sustainable over the long term.”138 Although HAMP contains several subprograms, the term “HAMP” is most often used to refer to the HAMP First-Lien Modification Program, described below.

HAMP First-Lien Modification Program The HAMP First-Lien Modification Program, which went into effect on April 6, 2009, modifies the terms of first-lien mortgages to provide borrowers with lower monthly payments. A HAMP modification consists of two phases: a trial Trial Modification: Under HAMP, a modification that was originally designed to last three months, followed by a period of at least three months in permanent modification. Treasury continues to pay incentives for five years.139 In which a borrower is given a chance designing HAMP, the Administration envisioned a “shared partnership” between to establish that he or she can make the Government and investors to bring distressed borrowers’ first lien monthly lower monthly mortgage payments and payments down to an “affordable” and sustainable level — defined by Treasury in qualify for a permanent modification. the case of HAMP Tier 1 as 31% of the borrower’s monthly gross income.140 The program description immediately below refers only to the original HAMP program, which after the launch of HAMP Tier 2 has been renamed “HAMP Tier 1.”

HAMP Modification Statistics As of June 30, 2012, a total of 818,803 mortgages were in active permanent modifications under both TARP (non-GSE) and GSE HAMP. Some 71,110 were in active trial modifications. For borrowers receiving permanent modifications, 97.4% received an interest rate reduction, 60% received a term extension, 31.3% received principal forbearance, and 9.7% received principal forgiveness.141 HAMP modification activity, broken out by TARP and GSE loans, is shown in Table 2.14.

TABLE 2.14 Cumulative HAMP modification activity by TARP/GSE, as of 6/30/2012 Trials Trials Trials Trials Converted to Permanents Permanents Started Cancelled Active Permanent Cancelled Active TARP 899,407 347,352 40,059 511,996 118,109 393,887 GSE 984,333 421,807 31,051 531,475 106,559 424,916 Total 1,883,740 769,159 71,110 1,043,471 224,668 818,803 Source: Treasury, response to SIGTARP data call, 7/20/2012.

Starting a HAMP Modification Borrowers may request participation in HAMP.142 Borrowers who have missed two or more payments must be solicited for participation by their servicers.143 Before offering the borrower a trial modification, also known as a trial period plan (“TPP”), the servicer must verify the accuracy of the borrower’s income and other eligibility criteria. In order to verify the borrower’s eligibility for a modification under the program, borrowers must submit the following documents as part of an “initial package.”144 70 special inspector general I troubled asset relief program

For more information on the RMA • an MHA “request for mortgage assistance” (“RMA”) form, which provides the form and what constitutes hardship, servicer with the borrower’s financial information, including the cause of the see SIGTARP’s April 2011 Quarterly borrower’s hardship; Report, page 62. • signed and completed requests for Federal tax return transcripts or the most For more information on the recent Federal income tax return, including all schedules and forms; Verification Policy, see SIGTARP’s • income verification documentation, such as recent pay stubs or evidence of April 2011 Quarterly Report, page 63. other sources of income; and • Dodd-Frank certification (either as part of the RMA form or as a standalone document) that the borrower has not been convicted in the past 10 years of any of the following in connection with a mortgage or real estate transaction: felony larceny, theft, fraud, or forgery; money laundering, or tax evasion.

In order for a loan to be eligible for a HAMP modification, the borrower’s initial package, consisting of the four documents described above, must be submitted by the borrower on or before December 31, 2013. Additionally, in order to be eligible for incentive payments, the permanent modification must be effective on or before September 30, 2014.145 Participating servicers verify monthly gross income for the borrower and the borrower’s household, as well as other eligibility criteria.146 Then, in the case of HAMP Tier 1, the servicer follows the “waterfall” of modification steps prescribed by HAMP guidelines to calculate the reduction in the borrower’s monthly mortgage payment needed to achieve a 31% debt-to-income (“DTI”) ratio, that is, a payment equal to 31% of his or her monthly gross income.147 In the first step, the servicer capitalizes any unpaid interest and fees i.e.( , adds them to the outstanding principal balance). Second, the servicer reduces the inter- est rate in incremental steps to as low as 2%. If the 31% DTI ratio threshold has still not been reached, in the third step the servicer extends the term of the mort- gage to a maximum of 40 years from the modification date. If these steps are still insufficient to reach the 31% threshold, the servicer may forbear principal (defer its due date), subject to certain limits.148 The forbearance amount is not interest bear- ing and results in a lump-sum payment due upon the earliest of the sale date of the property, the payoff date of the interest-bearing mortgage balance, or the maturity date of the mortgage.149 Servicers are not required to forgive principal under HAMP. However, servicers may forgive principal in order to lower the borrower’s monthly payment to achieve the HAMP Tier 1 DTI ratio goal of 31% on a stand-alone basis, at any point in the HAMP waterfall described above, or as part of PRA.150 For more about the HAMP NPV test, After completing these modification calculations, all loans that meet HAMP see the June 18, 2012, SIGTARP eligibility criteria and are either deemed generally to be in imminent default or audit report “The NPV Test’s Impact delinquent by two or more payments must be evaluated using a standardized net on HAMP.” present value (“NPV”) test that compares the NPV result for a modification to the NPV result for no modification.151 The NPV test compares the expected cash flow from a modified loan with the expected cash flow from the same loan with no modifications to determine which option will be more valuable to the mortgage investor. A positive NPV test result indicates that a modified loan is more valuable quarterly report to congress I July 25, 2012 71

to the investor than the existing loan. In that case, under HAMP rules, the servicer must offer the borrower a mortgage modification. If the test generates a negative result, modification is optional.152 Servicers cannot refuse to evaluate a borrower for a modification simply because the outstanding loan currently has a low loan-to- Loan-to-Value (“LTV”) Ratio: Lending value (“LTV”) ratio, meaning the borrower owes less than the value of the home. risk assessment ratio that mortgage The lower the LTV ratio is, the higher the probability that a foreclosure will be lenders examine before approving a more profitable to an investor than a modification. mortgage; calculated by dividing the Since September 1, 2011, 19 of the 20 largest mortgage servicers participating outstanding amount of the loan by in MHA (i.e., those servicers that had Program Participation Caps of $75 million the value of the collateral backing the or more as of May 18, 2011) have been required to assign a single point of contact loan. Loans with high LTV ratios are to borrowers potentially eligible for evaluation under HAMP, HAFA, or UP.153 The generally seen as higher risk because single point of contact has the primary responsibility for communicating with the the borrower has less of an equity borrower about options to avoid foreclosure, his/her status in the process, coordi- stake in the property. nation of receipt of documents, and coordination with other servicer personnel to promote compliance with MHA timelines and requirements throughout the entire delinquency, imminent default resolution process, or foreclosure.154

How HAMP First-Lien Modifications Work Treasury originally intended that HAMP trial modifications would last three months. Historically, many trial modifications have lasted longer. According to Treasury, as of June 30, 2012, of a combined total of 71,110 active trials under both GSE and TARP (non-GSE) HAMP, 11,440, or 16.1%, had lasted more than six months.155 This is a decrease from the 19% that SIGTARP reported last quarter.156 Borrowers in trial modifications may qualify for conversion to a permanent modification as long as they make the required modified payments on time and provide proper documentation, including a signed modification agreement.157 The terms of permanent modifications under HAMP Tier 1 remain fixed for at least five years.158 After five years, the loan’s interest rate can increase if the modified interest rate had been reduced below the 30-year conforming fixed interest rate on the date of the initial modification. The interest rate can rise incrementally by up to 1% per year until it reaches that rate.159 Otherwise, the modified interest rate remains permanent. If the borrower misses a payment during the trial or is denied a permanent modification for any other reason, the borrower is, in effect, left with the original terms of the mortgage. The borrower is responsible for the difference between the original mortgage payment amount and the reduced trial payments that were made during the trial. In addition, the borrower may be liable for late fees that were generated during the trial. In other words, a borrower can be assessed late fees for failing to make the original pre-modification scheduled payments during the trial period, even though under the trial modification the borrower is not required to make these payments. Late fees are waived only for borrowers who receive a per- manent modification.160 Since May 1, 2011, if a borrower is denied a HAMP Tier 1 permanent modi- fication because of missed trial payments, the servicer must re-calculate the 72 special inspector general I troubled asset relief program

borrower’s income using the original income documentation to ensure that the trial payment was correctly calculated. The servicer is not required to re-run the calculation if the borrower missed a trial payment because of a significant change in circumstances resulting in a reduction in income. If the re-calculation shows that the borrower’s trial payment exceeded the proper payment by 10% or more, the servicer must offer the borrower a new trial period with the correct payment.161

What Happens When a HAMP Modification Is Denied: Servicer Obligations and Borrower Rights Treasury has issued a series of guidance governing both the obligations of servicers and the rights of borrowers in connection with the denial of loan modification requests. Borrowers must receive a Non-Approval Notice if they are rejected for a HAMP modification. A borrower who is not approved for HAMP Tier 1 is automatically considered for HAMP Tier 2. If the servicer offers the borrower a Tier 2 trial, no Non-Approval notice would be issued on the HAMP Tier 1. The Non-Approval Notice is sent only if the Tier 2 is not offered. Borrowers can request reconsideration or re-evaluation if they believe one or more NPV analysis inputs is incorrect or if they experience a change in circumstance. Servicers are obligated to have written procedures and personnel in place to respond to borrower inquiries and disputes that constitute “escalated cases” in a timely manner.162 Treasury’s web-based NPV calculator at www.CheckMyNPV.com can be used by borrowers prior to applying for a HAMP modification or after a denial For more information on HAMP of a HAMP modification. Borrowers can enter the NPV input values listed in servicer obligations and borrower rights, see SIGTARP’s April 2011 the HAMP Non-Approval Notice received from their servicer, or substitute with Quarterly Report, pages 67-76. estimated NPV input values, to compare the estimated outcome provided by CheckMyNPV.com against that on the Non-Approval Notice.

Modification Incentives Originally, servicers received a one-time incentive fee payment of $1,000 for each permanent modification completed under HAMP, and additional compensation of $500 if the borrower was current but at imminent risk of default before enrolling in the trial plan. Effective for new HAMP trials on or after October 1, 2011, Treasury changed the flat $1,000 incentive to a sliding scale based on the length of time the loan was delinquent as of the effective date of the TPP. For loans less than or equal to 120 days delinquent, servicers receive $1,600.163 For loans 121-210 days delinquent, servicers receive $1,200. For loans more than 210 days delinquent, servicers receive only $400. Additionally, under this system, the $500 borrower incentive for being current on the loan is no longer paid. For borrowers whose monthly mortgage payment was reduced through HAMP by 6% or more, servicers also receive incentive payments of up to $1,000 annually for three years if the borrower remains in good standing (defined as less than three full monthly payments delinquent).164 For HAMP Tier 1, borrowers whose monthly mortgage payment is reduced through HAMP by 6% or more and who make monthly payments on time earn quarterly report to congress I July 25, 2012 73

an annual principal reduction of up to $1,000.165 The principal reduction accrues monthly and is payable for each of the first five years as long as the borrower remains in good standing.166 An investor is entitled to compensation under HAMP Tier 1, for up to five years, equal to one-half of the dollar difference between the borrower’s monthly payment (principal and interest) under the modification, based on 31% of monthly gross income, and the lesser of (1) the borrower’s monthly principal and inter- est at 38% or (2) the borrower’s pre-modification monthly principal and interest payment.167 Under HAMP Tier 2 modifications of owner-occupied properties, if applicable, investors also earn an extra one-time, up-front payment of $1,500 for modifying a loan that was current before the trial period (i.e., at risk of imminent default) and whose monthly payment was reduced by at least 6%.168 As of June 30, 2012, of the $29.9 billion in TARP funds allocated to the 105 servicers participating in MHA, approximately 89.6% was allocated to the 10 larg- est servicers.169 Table 2.15 outlines these servicers’ relative progress in implement- ing the HAMP modification programs.

TABLE 2.15 TARP INCENTIVE PAYMENTS BY 10 LARGEST SERVICERS, AS OF 6/30/2012

Incentive Incentive Incentive Payments Payments Payments Total Incentive SPA Cap Limit to Borrowers to Investors to Servicers Payments

Bank of America, N.A.a $8,108,092,562 $120,691,028 $299,568,357 $212,318,268 $632,577,652

Wells Fargo Bank, N.A.b 5,121,436,025 93,044,464 227,894,233 166,925,508 487,864,205

JPMorgan Chase Bank, NAc 3,770,020,191 145,696,464 269,205,338 232,731,483 647,633,285

Ocwen Loan Servicing, LLCd 2,670,711,437 52,434,101 144,352,452 109,027,924 305,814,477

OneWest Bank 1,836,213,784 25,975,117 87,841,858 47,391,810 161,208,785

GMAC Mortgage, LLC 1,500,173,461 28,423,250 80,202,635 55,138,210 163,764,096

Homeward Residential 1,306,356,674 31,654,995 99,560,346 69,454,750 200,670,091

CitiMortgage Inc 1,050,340,843 35,034,563 116,114,690 70,121,075 221,270,328

Select Portfolio Servicing 851,284,429 34,417,040 74,497,723 59,049,968 167,964,731

National City Bank 558,602,227 1,171,443 4,218,459 2,706,837 8,096,738

Total $26,773,231,663 $568,542,465 $1,403,456,090 $1,024,865,832 $2,996,864,388

Notes: Numbers may not total due to rounding. a Bank of America, N.A. includes the former Countrywide Home Loans Servicing, Wilshire Credit Corp. and Home Loan Services. b Wells Fargo Bank, N.A. includes Wachovia Mortgage, FSB. c JPMorgan Chase Bank, NA includes EMC Mortgage. d Ocwen Loan Servicing, LLC includes the former Litton Loan Servicing, LP.

Source: Treasury, Transactions Report-Housing, 7/2/2012. 74 special inspector general I troubled asset relief program

HAMP Tier 2 On June 1, 2012, Treasury launched an expansion of HAMP, “HAMP Tier 2,” which permits HAMP modifications on non-owner-occupied “rental” properties, and allows borrowers with a wider range of debt-to-income situations to receive modifications.170 Before this, only owner-occupied homes were eligible for HAMP — rental properties had been expressly excluded.171 Treasury’s stated policy objectives for HAMP Tier 2 are that it “will provide critical relief to both renters and those who rent their homes, while further stabilizing communities from the blight of vacant and foreclosed properties.”172 A borrower may have up to three loans with HAMP Tier 2 modifications, as well as a single HAMP Tier 1 modification on the mortgage for his or her primary residence.173 Even though Treasury announced the HAMP Tier 2 expansion in January, on June 1, 2012, the program’s launch date, only three of the 10 largest servicers had For SIGTARP’s recommendations for fully implemented HAMP Tier 2.174 According to Treasury, as of June 30, 2012, a the improvement of HAMP Tier 2, see SIGTARP’s April 2012 Quarterly total of 51 of the 105 servicers with active MHA servicer agreements had fully im- Report, pages 185-189. plemented HAMP Tier 2. Some of the largest servicers, including Bank of America, N.A., and JPMorgan Chase Bank, NA, have reported that they will not have fully implemented HAMP Tier 2 until August 2012 or September 2012, respectively.175

HAMP Tier 2 Eligibility HAMP Tier 2 expands the eligibility criteria related to a borrower’s debt-to-income ratio and also allows modifications on loans secured by “rental” properties. Owner- occupied loans that are ineligible for a HAMP Tier 1 modification due to excessive forbearance or negative NPV are also eligible for Tier 2. Vacant rental properties are permitted in the program, as are those occupied by legal dependents, parents, or grandparents, even if no rent is charged. The program is not, however, according to Treasury, intended for vacation homes, second homes, or properties that are rented only seasonally. Additionally, loans on rental properties must be at least two payments delinquent – those in imminent default are not eligible.176 However, Treasury does not require that the property be rented. Treasury requires only that a borrower certify intent to rent the property to a tenant on a year- round basis for at least five years, or make “reasonable efforts” to do so; and does not intend to use the property as a second residence for at least five years.177 According to Treasury, servicers are not typically required to obtain third party verifications of the borrower’s rental property certification when evaluating a borrower for HAMP.178 To be considered for HAMP Tier 2, borrowers must satisfy several basic HAMP requirements: the loan origination date must be on or before January 1, 2009; the borrower must have a documented hardship; the property must conform to the MHA definition of a “single-family residence” (1-4 dwelling units, including condominiums, co-ops, and manufactured housing); the property must not be condemned; and the loan must fall within HAMP’s unpaid principal balance limita- tions.179 If a borrower satisfies these requirements, and in addition, the loan has never been previously modified under HAMP, the servicer is required to solicit the borrower for HAMP Tier 2. In certain other cases, the borrower may still be eligible for HAMP Tier 2, but the servicer is not required to solicit the borrower.180 quarterly report to congress I July 25, 2012 75

How HAMP Tier 2 Modifications Work As with HAMP Tier 1, HAMP Tier 2 evaluates borrowers using an NPV test that considers the value of the loan to the investor before and after a modification. Owner-occupant borrowers are evaluated for both HAMP Tier 1 and Tier 2 in a single process. If a borrower is eligible for both modifications, he or she will receive a HAMP Tier 1 modification.181 As discussed above, HAMP Tier 1 modifications are structured using a waterfall of incremental steps that may stop as soon as the 31% post-modification DTI ratio target is reached. In HAMP Tier 2, the proposed permanent modification must meet two affordability requirements: (1) a post-modification DTI ratio of not less than 25% or greater than 42% and (2) a reduction of the monthly principal and in- terest payment by 10%. If the borrower was previously in a HAMP Tier 1 modifica- tion (either trial or permanent), then the new payment must be at least 10% below the previously modified payment. Because HAMP Tier 2 does not target a specific DTI ratio, the HAMP Tier 2 waterfall is not a series of incremental steps, but a consistent set of actions that are applied to the loan. After these actions are applied, if the result of the NPV test is positive and the modification also achieves the DTI and payment reduction goals, the servicer must offer the borrower a HAMP Tier 2 modification. If the result of the HAMP Tier 2 NPV test is negative, modification is optional.182 As in the HAMP Tier 1 waterfall, the first step in structuring a HAMP Tier 2 modification is to capitalize any unpaid interest and fees. The second step changes the interest rate to the “Tier 2 rate,” which is the current Freddie Mac Primary Mortgage Market Survey rate plus a 0.5% risk adjustment. The third step extends the term of the loan by up to 40 years from the modification effective date. Finally, if the loan’s pre-modification mark-to-market LTV ratio is greater than 115%, the servicer forbears principal in an amount equal to the lesser of (1) an amount that would create a post-modification LTV ratio of 115%, or (2) an amount equal to 30% of the post-modification principal balance. Unlike HAMP Tier 1, there is no excessive forbearance limit in HAMP Tier 2. The HAMP Tier 2 guidelines also in- clude several exceptions to this waterfall to allow for investor restrictions on certain types of modification.183 The HAMP Tier 2 NPV model also evaluates the loan using an “alternative modification waterfall” in addition to the one described here. This waterfall uses principal reduction instead of forbearance. However, as in HAMP Tier 1, principal reduction is optional. Servicers may also reduce principal on HAMP Tier 2 modifi- cations using PRA.184 HAMP Tier 2 incentives are the same as those for HAMP Tier 1, with some exceptions, notably that HAMP Tier 2 modifications do not pay annual borrower or servicer incentives.185

Home Price Decline Protection (“HPDP”) HPDP provides investors with incentives for modifications of loans on properties located in areas where home prices have recently declined and where investors are concerned that price declines may persist. HPDP incentive payments are linked 76 special inspector general I troubled asset relief program

to the rate of recent home price decline in a local housing market, as well as the unpaid principal balance and mark-to-market LTV ratio of the mortgage loan.186 HPDP is intended to address the fears of investors who may withhold their consent to loan modifications because of potential future declines in the value of the homes that secure the mortgages, should the modification fail and the loan go into foreclosure. Under HPDP, Treasury has published a standard formula, based on the princi- pal balance of the mortgage, the recent decline in area home prices during the six months before the start of the HAMP modification, and the LTV ratio, that will determine the size of the incentive payment.187 The HPDP incentive payments accrue monthly over a 24-month period and are paid annually on the first and second anniversaries of the initial HAMP trial period. Accruals are discontinued if the borrower loses good standing under HAMP because they are delinquent by three mortgage payments. As of June 30, 2012, according to Treasury, approxi- mately $252 million in TARP funds had been paid for incentives on 133,182 loan modifications under HPDP.188

Principal Reduction Alternative (“PRA”) PRA is intended to encourage principal reduction in HAMP loan modifications for underwater borrowers by providing mortgage investors with incentive payments in exchange for lowering the borrower’s principal balance. PRA is an alternative method to the standard HAMP modification waterfall for structuring a HAMP modification. Although servicers are required to evaluate every non-GSE HAMP- eligible borrower with an LTV of 115% or greater for PRA, whether to actually offer principal reduction or not is up to the servicer.189 Because the GSEs, Fannie Mae and Freddie Mac, have refused to participate in PRA, the program applies only to loans modified under TARP-funded HAMP.190 On January 27, 2012, Treasury offered to pay PRA incentives for the GSEs from TARP by tripling the incentives it pays to investors, subsidizing up to 63% of princi- pal reductions.191 According to Treasury, as of June 30, 2012, there were 60,778 active permanent modifications in PRA.192 According to Treasury, 87% of borrowers who received PRA modifications were seriously delinquent on their mortgages at the start of the trial modification.193 Borrowers receiving PRA modifications were also significantly further under- water before modification than was the overall HAMP population. According to Treasury, PRA borrowers had a pre-modification median LTV ratio of 157%. After modification, however, PRA borrowers lowered their LTVs to a median ratio of 115%.194 According to Treasury, PRA modifications reduced principal balances by a median amount of $69,586 or 31.4%, thereby lowering the LTV ratio. On the other hand, according to the data, HAMP modifications without the PRA feature on average increased the principal balance. Treasury attributes this increase to the capitalization of unpaid interest and fees.195 Borrowers in PRA appear to fare better after modification than the overall population of HAMP borrowers, who overwhelmingly have received the HAMP quarterly report to congress I July 25, 2012 77

modification without the PRA feature. According to Treasury, as of June 30, 2012, servicers had started 89,444 PRA trial modifications, of which 15,501 were active as of that date, 67,083 had converted to permanent modifications, and 6,860 (or 7.7%) were subsequently disqualified from the program or the loan was paid off.196 According to Treasury, of the PRA trials that converted to permanent modifications, 60,778 were still active as of June 30, 2012, and 6,305 (9.4%) had either redefault- ed or were paid off. Although not directly comparable, the redefault rate for HAMP permanent modifications is 23.1%.197

Who Is Eligible Borrowers who meet all HAMP eligibility requirements and who owe more than 115% of their home’s market value (LTV >115%) are eligible for PRA.198 The principal balance used in this LTV calculation includes any amounts that would be capitalized under a HAMP modification.199 Eligible borrowers are evaluated by running NPV tests. There are standard and alternative NPV tests for HAMP Tier 1 and HAMP Tier 2. If the standard waterfall produces a positive NPV result, the servicer must offer a HAMP modification (with or without principal reduction). If the PRA waterfall using principal reduction produces a positive NPV result, the servicer may, but is not required to, offer a modification using principal reduction.200

How PRA Works For HAMP Tier 1, the PRA waterfall uses principal forbearance (which later becomes principal reduction) prior to interest rate reduction as the second step in structuring the modification. Under PRA, the servicer determines the modified mortgage payment by first capitalizing unpaid interest and fees as in a standard HAMP modification. After capitalization, the servicer reduces the loan balance through principal forbearance until either a DTI ratio of 31% or an LTV ratio of 115% is achieved. No interest will be collected on the forborne amount. If an LTV ratio of 105% to 115% is achieved first, the servicer then applies the remaining HAMP waterfall steps (interest rate reduction, term extension, forbearance) until the 31% DTI ratio is reached. If the principal balance has been reduced by more than 5%, the servicer is allowed additional flexibility in implementing the remaining waterfall steps. Principal reduction is not immediate; it is earned over three years. On each of the first three anniversaries of the modification, one-third of the PRA forborne principal is forgiven. Therefore, after three years the borrower’s principal balance is permanently reduced by the amount that was placed in PRA forbearance.201

Who Gets Paid For PRA trials effective on or after March 1, 2012, Treasury will triple the amount of these incentives paid to investors. Under PRA, the mortgage investors now earn an incentive of $0.18 to $0.63 per dollar of principal reduced, depending on delinquency status of the loan and the level to which the outstanding LTV ratio was 78 special inspector general I troubled asset relief program

reduced.202 For loans that are more than six months delinquent, investors receive TABLE 2.16 only $0.18 per dollar of principal reduction, regardless of LTV.203 The incentive PRA incentives to investors per schedule in Table 2.16 applies only to loans that have been six months delinquent dollar of First Lien principal or less within the previous year. reduced Under certain conditions an investor may enter into an agreement with the bor- Mark-to-Market 105% 115% rower to share any future increase in the value of the property.204 Loan-to-Value to to > 140% According to Treasury, as of June 30, 2012, Treasury had paid a total of $63.2 Ratio (“LTV”) 205 Rangea 115% 140% million in PRA incentives. Incentive Amounts $0.63 $0.45 $0.30 Home Affordable Unemployment Program (“UP”) Notes: This incentive structure applies to loans less than or UP, which was announced on March 26, 2010, provides temporary assistance to equal to six months past due. For loans that were more than 206 six months delinquent within the previous year, investors unemployed borrowers. Under the program, unemployed borrowers who meet receive $0.18 per dollar of principal reduced in compensation, regardless of the LTV ratio. These incentives are effective for certain qualifications can receive forbearance for a portion of their mortgage trials beginning on or after 3/1/2012. a The mark-to-market LTV is based on the pre-modified principal payments. Originally, the forbearance period was a minimum of three months, balance of the first-lien mortgage plus capitalized interest and unless the borrower found work during this time. However, on July 7, 2011, after a fees divided by the market value of the property. SIGTARP recommendation to extend the term, Treasury announced that it would Source: Treasury, “Supplemental Directive 12-01: Making Home Affordable Program – Principal Reduction Alternative and increase the minimum UP forbearance period from three months to 12 months. Second Lien Modification Program Investor Incentives Update,” 2/16/2012, www.hmpadmin.com/portal/news/docs/2012/ As of May 31, 2012, which according to Treasury is the latest data available, 7,235 hampupdate021612.pdf, accessed 6/28/2012. borrowers were actively participating in UP.207

Who Is Eligible Borrowers who are approved to receive unemployment benefits and who also request assistance under HAMP must be evaluated by servicers for an UP forbearance plan and, if eligible, offered one. As of June 1, 2012, a servicer may consider a borrower for UP whose loan is secured by a vacant or tenant-occupied property and still must consider owner-occupied properties. The servicer must consider a borrower for UP regardless of the borrower’s monthly mortgage payment ratio and regardless of whether the borrower had a payment default on a HAMP trial plan or lost good standing under a permanent HAMP modification. Servicers are not required to offer an UP forbearance plan to borrowers who are more than 12 months delinquent at the time of the UP request.208 Alternatively, the servicers may evaluate unemployed borrowers for HAMP and offer a HAMP trial period plan instead of an UP forbearance plan if, in the servicer’s business judgment, HAMP is the better loss mitigation option. If an unemployed borrower is offered a trial period plan but requests UP forbearance instead, the servicer may then offer UP, but is not required to do so.209 Eligible borrowers may request a HAMP trial period plan after the UP forbear- ance plan is completed. If an unemployed borrower in bankruptcy proceedings requests consideration for HAMP, the servicer must first evaluate the borrower for UP, subject to any required bankruptcy court approvals.210 A borrower who has been determined to be ineligible for HAMP may request assessment for an UP forbearance plan if he or she meets all the eligibility criteria.211 If a borrower who is eligible for UP declines an offer for an UP forbearance plan, the servicer is not required to offer the borrower a modification under HAMP or 2MP while the bor- rower remains eligible for an UP forbearance plan.212 quarterly report to congress I July 25, 2012 79

How UP Works For qualifying homeowners, the mortgage payments during the forbearance period are lowered to no more than 31% of monthly gross income, which includes unemployment benefits.213 If the borrower regains employment, but because of reduced income still has a hardship, the borrower must be considered for HAMP. For more information on additional If the borrower is eligible, any payments missed prior to and during the period of UP eligibility criteria, see SIGTARP’s April 2011 Quarterly Report, pages the UP forbearance plan are capitalized as part of the normal HAMP modification 80-81. process.214 If the UP forbearance period expires and the borrower is ineligible for HAMP, the borrower may be eligible for MHA foreclosure alternatives, such as HAFA.215

Home Affordable Foreclosure Alternatives (“HAFA”) HAFA provides $4.2 billion in incentives to servicers, borrowers, and subordinate lien holders to encourage a short sale or deed-in-lieu of foreclosure as an alternative to foreclosure.216 Under HAFA, the servicer forfeits the ability to pursue Deficiency Judgment: Court order a deficiency judgment against a borrower when the proceeds from the short sale authorizing a lender to collect all or or deed-in-lieu are less than the outstanding amount on the mortgage.217 HAFA part of an unpaid and outstanding debt incentives include a $3,000 relocation incentive payment to borrowers or tenants, resulting from the borrower’s default a $1,500 incentive payment to servicers, and incentive payments to subordinate on the mortgage note securing a debt. mortgage lien holders of up to $2,000 in exchange for a release of the lien and the A deficiency judgment is rendered borrower’s liability.218 The program was announced on November 30, 2009.219 after the foreclosed or repossessed Treasury allows each servicer participating in HAFA to determine its own poli- property is sold when the proceeds are cies for borrower eligibility and many other aspects of how it operates the program, insufficient to repay the full mortgage but requires the servicers to post criteria and program rules on their websites. debt. According to Treasury, as of June 30, 2012, two servicers had not yet complied with this requirement. Servicers must notify eligible borrowers in writing about the availability of the HAFA program and allow the borrower a minimum of 14 calen- dar days to apply.220 Servicers are not required by Treasury to verify a borrower’s financial information or determine whether the borrower’s total monthly payment exceeds 31% of his or her monthly gross income.221 Effective March 9, 2012, Treasury no longer required properties in HAFA to be occupied, allowing vacant properties to enter the program. However, borrower relocation incentives will be paid only on occupied properties.222 As of June 30, 2012, approximately $237.2 million from TARP had been paid to investors, borrowers, and servicers in connection with 52,998 short sales or deeds-in-lieu of foreclosure transfers completed under HAFA.223 As of May 31, For more information about relocation 2012, the latest data available, Treasury reported that the nine largest servicers incentives and borrower requirements alone had completed 241,837 short sales and deeds-in-lieu outside HAMP for bor- related to primary residences in rowers whose HAMP trial modifications had failed, borrowers who had chosen not HAFA, see SIGTARP’s January 2012 to participate, or were ineligible for the program.224 The greater volume of activity Quarterly Report, pages 70-71. outside HAFA may be explained, in part, by the fees and deficiency judgments that servicers are able to collect from the borrower in non-HAFA transactions, which are not available within HAFA. 80 special inspector general I troubled asset relief program

Second-Lien Modification Program (“2MP”) According to Treasury, 2MP, which was announced on August 13, 2009, is designed to provide modifications to the loans of borrowers with second mortgages of at least $5,000 with monthly payments of at least $100 that are serviced by a participating 2MP servicer, or full extinguishment of second mortgages below those thresholds. When a borrower’s first lien is modified under HAMP and the servicer of the second lien is a 2MP participant, that servicer must offer to modify or may extinguish the borrower’s second lien. Treasury pays the servicer a lump sum for full extinguishment of the second-lien principal or in exchange for a partial extinguishment (principal reduction) and modification of the remainder of the second lien.225 Second-lien servicers are not required to verify any of the borrower’s financial information and do not perform a separate NPV analysis.226 Servicing Advances: If borrowers’ There is no minimum principal balance for a full extinguishment of a second payments are not made promptly lien under 2MP. For a second-lien modification under 2MP, the servicer first capi- and in full, servicers are contractually talizes any accrued interest and servicing advances, then reduces the interest rate obligated to advance the required to 1% to 2% for the first five years. After the five-year period, the rate increases to monthly payment amount in full to the match the rate on the HAMP-modified first lien. When modifying the second lien, investor. Once a borrower becomes the servicer must, at a minimum, extend the term to match the term of the first current or the property is sold or lien, but can also extend the term up to a maximum of 40 years. To the extent that acquired through foreclosure, the there is forbearance or principal reduction for the modified first lien, the second- servicer is repaid all advanced funds. lien holder must forbear or forgive at least the same percentage on the second lien.227 The servicer receives a $500 incentive payment upon modification of a second lien. If the loan is in good standing and a borrower’s monthly second-lien payment is reduced by 6% or more, the servicer is eligible for an annual incentive payment TABLE 2.17 of $250 per year for up to three years, and the borrower is eligible for an annual 228 2mp compensation per dollar of principal reduction payment of up to $250 per year for up to five years. Investors Second-Lien principal Reduced receive modification incentive payments equal to an annualized amount of 1.6% of (for 2MP modifications with the unmodified principal balance, paid on a monthly basis for up to five years.229 an effective date on or after In addition, investors also receive incentives for fully or partially extinguishing the 6/1/2012) second lien on 2MP modifications. On February 16, 2012, Treasury doubled the Combined Loan- 115% amount of these incentives on 2MP modifications effective on or after June 1, to-Value (“CLTV”) < 115% to > 140% 2012. The current incentive schedule for loans six months delinquent or less is Ratio Rangea 140% shown in Table 2.17. For loans that have been more than six months delinquent Incentive within the previous 12 months, investors are paid $0.12 for each dollar of principal Amounts $0.42 $0.30 $0.20 reduced, regardless of the combined LTV ratio.230 Notes: This incentive structure applies to loans less than or equal to six months past due. For loans that were more than According to Treasury, as of June 30, 2012, 119,938 HAMP modifications had six months delinquent within the previous year, investors second liens that were eligible for 2MP. As of that date, there were 63,769 active receive $0.12 per dollar of principal reduced in compensation, regardless of the CLTV ratio. permanent modifications of second liens.231 New 2MP modifications sharply a Combined Loan-to-Value is the ratio of the sum of the outstanding principal balance of the HAMP-modified first peaked in March 2011 and have been generally declining since then. Most of the lien and the outstanding principal balance of the unmodified second lien divided by the property value determined in activity under the program has been modifications to the terms of the second liens. connection with the permanent HAMP modification. Median principal reduction was $8,674 for partial extinguishments of second liens Source: Treasury, “Supplemental Directive 12-03: Making Home and $61,641 for full extinguishments of second liens.232 According to Treasury, Affordable Program – Handbook Mapping for MHA Extension and Expansion and Administrative Clarifications on Tier 2,” as of June 30, 2012, approximately $192.1 million in TARP funds had been paid 4/17/2012, www.hmpadmin.com//portal/programs/docs/ hamp_servicer/sd1203.pdf, accessed 7/14/2012. quarterly report to congress I July 25, 2012 81

to servicers and investors in connection with 110,173 second-lien full and partial extinguishments and modifications under 2MP.233

Agency-Insured Loan Programs (FHA-HAMP, RD-HAMP, and VA-HAMP) Some mortgage loans insured or guaranteed by the Federal Housing Administration (“FHA”), Department of Veterans Affairs (“VA”), or the U.S. Department of Agriculture Rural Development (“RD”) are eligible for modification under programs similar to HAMP Tier 1 that reduce borrowers’ monthly mortgage payments to 31% of their monthly gross income. Borrowers are eligible to receive a maximum $1,000 annual incentive for five years and servicers are eligible to receive a maximum $1,000 annual incentive from Treasury for three years on mortgages in which the monthly payment was reduced by at least 6%.234 As of June 30, 2012, according to Treasury, approximately $9.8 million in TARP funds had been paid to servicers and borrowers in connection with 6,013 permanent Treasury/FHA- HAMP modifications. According to Treasury, only $1,834 of TARP funds has been spent on the seven modifications under RD-HAMP.235 Treasury does not provide incentive compensation related to VA-HAMP.236

Treasury/FHA Second-Lien Program (“FHA2LP”) FHA2LP, which was launched on September 27, 2010, provides incentives for partial or full extinguishment of non-GSE second liens of at least $2,500 originated on or before January 1, 2009, associated with an FHA refinance.237 Borrowers must also meet the eligibility requirements of FHA Short Refinance. TARP has allocated For more information concerning $2.7 billion for incentive payments to (1) investors ranging from $0.10 to $0.21 FHA2LP eligibility, see SIGTARP’s based on the LTV of pre-existing second-lien balances that are partially or fully April 2011 Quarterly Report, pages extinguished under FHA2LP, or they may negotiate with the first-lien holder for a 85-87. portion of the new loan, and (2) servicers, in the amount of $500 for each second- lien mortgage in the program.238 According to Treasury, as of June 30, 2012, it had not made any incentive payments under FHA2LP, and no second liens had been extinguished.239

MHA Servicer Assessments Since June 2011, Treasury has published quarterly Servicer Assessments of the 10 largest mortgage servicers participating in MHA. The most recent assessment covering the first quarter of 2012 was published on June 6, 2012. During the fourth quarter of 2011, Ocwen Loan Servicing, LLC acquired the servicing portfolio of Litton Loan Servicing, LP (“Litton”), another top 10 servicer.240 At that time, Treasury changed from assessing the 10 largest MHA servicers to assessing only nine servicers.241 Servicer Assessments focus on compliance with the requirements of the MHA program and on program results. The compliance assessment portion is based on the findings of servicer compliance reviews conducted by Treasury’s compliance agent. These findings are divided into three performance categories: Identifying and 82 special inspector general I troubled asset relief program

Contacting Homeowners; Homeowner Evaluation and Assistance; and Program Management, Reporting, and Governance. These categories in turn contain several quantitative and qualitative metrics, which Treasury scores using benchmarks set by Treasury.242 The servicers are also rated on the effectiveness of their internal controls in each of the three categories. Because not all of the performance metrics Treasury examines are reassessed each quarter, some assessment data is typically carried over from the prior quarter.243 Program results are reported for Aged Trials as a Percentage of Active Trials; Conversion Rate for Trials Started On or After June 1, 2010; Average Calendar Days to Resolve Escalated Cases; and Percentage of Missing Modification Status Reports. The servicer’s performance in each of the four metrics is not scored and Treasury has not set benchmarks. Treasury compares servicer performance to the best and worst performances among the other servicers.244 Treasury issues overall servicer ratings indicating whether the servicer requires minor improvement, moderate improvement, or substantial improvement. In the first quarter 2012 MHA servicer assessment, Treasury determined that three servicers needed minor improvement (OneWest Bank, Select Portfolio Servicing, and Wells Fargo Bank, N.A.) and that six servicers needed moderate improvement: Homeward Residential (formerly known as American Home Mortgage Servicing, Inc.); Bank of America, N.A.; CitiMortgage, Inc; GMAC Mortgage, LLC; JPMorgan Chase Bank, NA; and Ocwen Loan Servicing, LLC.245 Prior to this quarter, Treasury had withheld MHA incentives from JPMorgan Chase Bank, NA, (“JPMorgan”) and Bank of America, N.A. However, as part of the “robo-signing” settlement between the Federal Government, state Attorneys For more information on MHA General, and major servicers, Treasury released all MHA incentives that it was Servicer Assessments, see Section 5: 246 “SIGTARP Recommendations” of withholding. The only additional incentives reported as newly withheld from this report. any servicers for the first quarter of 2012, according to Treasury, total $6,000 and $2,000 withheld from JPMorgan and Ocwen, respectively, and will be withheld until certain data is verified.247

FHA Short Refinance Program On March 26, 2010, Treasury and HUD announced the FHA Short Refinance program, which gives borrowers the option of refinancing an underwater, non- FHA-insured mortgage into an FHA-insured mortgage at 97.75% of the home’s value. Treasury has allocated TARP funds of (1) up to $8 billion to provide loss protection to FHA through a letter of credit; and (2) up to $117 million in fees for the letter of credit.248 FHA Short Refinance is voluntary for servicers. Therefore, not all underwater borrowers who qualify may be able to participate in the program.249 As of June 30, 2012, according to Treasury, 1,437 loans had been refinanced under the program.250 As of June 30, 2012, Treasury has not paid any claims for defaults under the program. According to Treasury, to its knowledge, no FHA Short Refinance Loans have defaulted; however, it is possible that one or more loans have defaulted but FHA has not yet evaluated the claims.251 Treasury has deposited $50 million into a reserve account for future claims.252 It has also quarterly report to congress I July 25, 2012 83

spent approximately $6.6 million on administrative expenses associated with the letter of credit.253

Who Is Eligible To be eligible for FHA Short Refinance, a homeowner must be current on the existing first-lien mortgage or have made three successful trial period payments; be For more information concerning in a negative equity position; occupy the home as a primary residence; qualify for FHA Short Refinance eligibility, see the new loan under standard FHA underwriting and credit score requirements and SIGTARP’s April 2011 Quarterly have an existing loan that is not insured by FHA.254 According to the Department Report, pages 85-87. of Housing and Urban Development (“HUD”), it evaluates the credit risk of the loans.255

How FHA Short Refinance Works Servicers must first determine the current value of the home using a third-party appraisal by a HUD-approved appraiser. The borrower is then reviewed for credit risk and, if necessary, referred for a review to confirm that the borrower’s total monthly mortgage payments on all liens after the refinance is not greater than 31% of the borrower’s monthly gross income and the borrower’s total household debt is not greater than 50%.256 Next, the lien holders must forgive principal that is more than 115% of the value of the home. In addition, the original first-lien lender must forgive at least 10% of the unpaid principal balance of the first-lien loan, in exchange for a cash payment for 97.75% of the current home value from the proceeds of the refinance. The lender may maintain a subordinate second lien for up to 17.25% of that value (for a total balance of 115% of the home’s value).257 If a borrower defaults, the letter of credit purchased by TARP compensates the investor for a first percentage of losses, up to specified amounts.258 FHA is poten- tially responsible for the remaining approximately 86.6% of potential losses on each mortgage, until the earlier of either (1) the time that the $8 billion letter of credit is exhausted, or (2) 10 years from the issuance of the letter of credit (October 2020), at which point FHA will bear all of the remaining losses.259

Housing Finance Agency Hardest Hit Fund (“HHF”) On February 19, 2010, the Administration announced a housing support program known as the Hardest Hit Fund. Under HHF, TARP dollars would fund “innovative measures” developed by 19 state housing finance agencies (“HFAs”) and approved by Treasury to help families in the states that have been hit the hardest by the aftermath of the housing bubble.260 The first round of HHF allocated $1.5 billion of the amount initially allocated for MHA initiatives. According to Treasury, these funds were designated for five states where the average home price had decreased more than 20% from its peak. The five states were Arizona, California, Florida, Michigan, and Nevada.261 Plans to use these funds were approved by Treasury on June 23, 2010.262 On March 29, 2010, Treasury expanded HHF to include five additional states and increased the program’s potential funding by $600 million, bringing total funding to $2.1 billion. The additional $600 million was designated for North 84 special inspector general I troubled asset relief program

Carolina, Ohio, Oregon, Rhode Island, and South Carolina. Treasury indicated that these states were selected because of their high concentrations of people living in economically distressed areas, defined as counties in which the unemployment rate exceeded 12%, on average, in 2009.263 Plans to use these funds were approved by Treasury on August 3, 2010.264 On August 11, 2010, Treasury pledged a third round of HHF funding of $2 billion to states with unemployment rates at or above the national average.265 The states designated to receive funding were Alabama, California, Florida, Georgia, Illinois, Indiana, Kentucky, Michigan, Mississippi, Nevada, New Jersey, North Carolina, Ohio, Oregon, Rhode Island, South Carolina, Tennessee, and Washington, DC.266 Treasury approved third round proposals on September 23, 2010.267 On September 29, 2010, a fourth round of HHF funding of an additional $3.5 billion was made available to existing HHF participants.268 Treasury approved state programs and allocated the $7.6 billion in TARP funds in five categories of assistance:269

• $4.4 billion for unemployment assistance • $1.4 billion allocated for principal reduction • $817 million for reinstatement of past-due amounts • $83 million for second-lien reduction • $45 million for transition assistance, including short sales and deed-in-lieu of foreclosure

Each state’s HFA reports program results (i.e., number of applications approved or denied and assistance provided) on a quarterly basis on its own state website. Treasury does not publish the data either by individual HFA or in the aggregate. Treasury indicated that states can reallocate funds between programs and modify existing programs as needed, with Treasury approval, until funds are expended or returned to Treasury after December 31, 2017. According to Treasury, since December 31, 2011, eight states have reallocated funds, modified or eliminated existing programs, or established new HHF programs with Treasury approval, bringing the total number of HHF programs in 18 states and Washington, DC, as of June 30, 2012, to 56.270 Table 2.18 shows the obligation of funds and funds drawn for states participat- ing in the four rounds of HHF as of June 30, 2012. As of that date, according to Treasury, the states had drawn down $1.1 billion under the program. According to Treasury, the states had spent only a limited portion of the amount drawn on assisting borrowers; see Table 2.18. More than half of the amount drawn is held as unspent cash-on-hand with HFAs or is used for administrative expenses.271 quarterly report to congress I July 25, 2012 85

TABLE 2.18 HHF Funding Obligated and drawdowns by State, as of 6/30/2012 Recipient Amount Obligated Amount Drawn* Alabama $162,521,345 $28,000,000 Arizona 267,766,006 21,255,000 California 1,975,334,096 217,490,000 Florida 1,057,839,136 89,800,000 Georgia 339,255,819 38,200,000 Illinois 445,603,557 96,500,000 Indiana 221,694,139 22,000,000 Kentucky 148,901,875 24,000,000 Michigan 498,605,738 47,317,776 Mississippi 101,888,323 7,641,624 Nevada 194,026,240 17,922,000 New Jersey 300,548,144 22,513,704 North Carolina 482,781,786 128,000,000 Ohio 570,395,099 96,100,000 Oregon 220,042,786 107,501,070 Rhode Island 79,351,573 26,000,000 South Carolina 295,431,547 40,000,000 Tennessee 217,315,593 31,315,593 Washington, DC 20,697,198 10,034,860 Total $7,600,000,000 $1,071,591,627

Source: Treasury, response to SIGTARP data call, 7/5/2012.

*Amount drawn includes funds for program expenses (direct assistance to borrowers), administrative expenses, and cash-on-hand.

As of March 31, 2012, the latest data available, HHF had provided $350.8 million in assistance to 43,580 homeowners.272 Each state estimates the number of For more information on HHF, borrowers to be helped in its programs. Treasury allows the HFAs to change this see SIGTARP’s April 12, 2012, estimate. The aggregate of these estimated ranges has decreased in the last year. audit report, “Factors Affecting As of March 31, 2012, the 19 state HFAs collectively estimate helping between Implementation of the Hardest Hit 452,034 and 476,672 homeowners over the life of the program.273 Table 2.19 pro- Fund Program.” vides this estimate as well as the actual number of borrowers helped by state using data as of March 31, 2012. 86 special inspector general I troubled asset relief program

TABLE 2.19 HHF Estimated and Actual Number of Borrowers Assisted and assistance provided, by state, as of 3/31/2012 Estimated Number of Participating Households to Actual Borrowers be Assisted by Receiving Assistance Assistance Provided Recipient 12/31/2017* as of 3/31/2012** as of 3/31/2012** Alabama 8,500 1,579 $10,113,978 Arizona 3,207 484 9,262,887 California 88,774 6,681 58,554,423 Florida 106,000 4,745 20,849,632 Georgia 18,300 872 4,535,143 Illinois 17,000 to 29,000 1,569 16,926,236 Indiana 13,392 546 3,635,792 Kentucky 5,342 to 13,000 1,519 11,296,861 Michigan 38,687 4,165 15,086,894 Mississippi 3,800 398 3,064,124 Nevada 10,371 891 5,188,469 New Jersey 6,900 171 970,886 North Carolina 22,290 5,258 48,922,052 Ohio 57,300 5,020 48,353,363 Oregon 13,630 4,579 49,879,568 Rhode Island 2,921 1,340 10,299,394 South Carolina 21,600 to 26,100 2,233 19,726,540 Tennessee 13,500 1,267 10,858,838 Washington, DC 520 to 1,000 263 3,305,577 Total 452,034 to 476,672 43,580 $350,820,656

* Source: Estimates are from the latest HFA Participation Agreements as of 3/31/2012. Later amendments are not included for consistency with Quarterly Performance reporting.

States report the Estimated Number of Participating Households individually for each HHF program they operate. This column shows the totals of the individual program estimates for each state. Therefore, according to Treasury, these totals do not necessarily translate into the number of unique households that the states expect to assist because some households may participate in more than one HHF program.

** Sources: First quarter 2012 HFA Performance Data quarterly reports and First Quarter 2012 HFA Aggregate Quarterly Report. Both sources are as of 3/31/2012.

As of March 31, 2012, 76% of the HHF assistance received by homeowners was for unemployment assistance. The remaining assistance can be broken down to 20% for reinstatement of past due amounts, 4% for principal reduction, 1% for second-lien reduction, and 0.1% for transition assistance.274 quarterly report to congress I July 25, 2012 87

Financial Institution Support Programs Treasury created six TARP programs through which it made capital investments or asset guarantees in exchange for equity in participating financial institutions. Mandatorily Convertible Preferred Three of the programs, the Capital Purchase Program (“CPP”), the Community Stock (“MCP”): A type of preferred Development Capital Initiative (“CDCI”), and the Capital Assistance Program share (ownership in a company that (“CAP”), were open to all qualifying financial institutions (“QFIs”). The other generally entitles the owner of the three, the Systemically Significant Failing Institutions (“SSFI”) program, the shares to collect dividend payments) Targeted Investment Program (“TIP”), and the Asset Guarantee Program (“AGP”), that can be converted to common were available on a case-by-case basis to institutions that needed assistance beyond stock under certain parameters at the that available through CPP. With the expiration of TARP funding authorization, no discretion of the company — and must new investments can be made through these six programs. be converted to common stock by a To help improve the capital structure of some struggling TARP recipients, certain time. Treasury has agreed to modify its investment in certain cases by converting the pre- ferred stock it originally received into other forms of equity, such as common stock or mandatorily convertible preferred stock (“MCP”).275

Capital Purchase Program Treasury’s stated goal for CPP was to invest in “healthy, viable institutions” as a way to promote financial stability, maintain confidence in the financial system, and enable lenders to meet the nation’s credit needs.276 CPP was a voluntary program open to all QFIs through an application process. QFIs included U.S.-controlled banks, savings associations, and certain bank and savings and loan holding companies.277 Under CPP, Treasury used TARP funds predominantly to purchase preferred equity interests in QFIs. The QFIs issued Treasury senior preferred shares that pay a 5% annual dividend for the first five years and a 9% annual dividend thereafter. In addition to the senior preferred shares, publicly traded QFIs issued Treasury war- rants to purchase common stock with an aggregate market price equal to 15% of the senior preferred share investment. Privately held QFIs issued Treasury warrants to purchase additional senior preferred stock worth 5% of Treasury’s initial pre- ferred stock investment.278 In total, Treasury invested $204.9 billion of TARP funds in 707 QFIs through CPP.279 As of June 30, 2012, 325 of those 707 institutions remained in CPP, accord- For discussion of SIGTARP’s ing to Treasury.280 Of the 382 that have exited CPP, 165, or 43.2%, did so through recommendations on TARP exit paths other government programs — 28 of them through TARP’s CDCI and 137 through for community banks, see SIGTARP’s 281 October 2011 Quarterly Report, pages the Small Business Lending Fund (“SBLF”), a non-TARP program. Only 164 of 167-169. the banks that exited, or 42.9%, fully repaid CPP otherwise.282 In addition, three CPP banks merged with other CPP banks; Treasury sold its investments in 33 institutions at a loss; and 17 institutions or their subsidiary banks failed, meaning Treasury lost its entire investment in those banks.283 88 special inspector general I troubled asset relief program

Status of Funds Subordinated Debentures: Form of According to Treasury, through CPP, Treasury purchased $204.9 billion in debt security that ranks below other preferred stock and subordinated debentures from 707 QFIs in 48 states, the loans or securities with regard to District of Columbia, and Puerto Rico. Although the 10 largest investments claims on assets or earnings. accounted for $142.6 billion of the program, CPP made many smaller investments: 331 of 707 recipients received $10 million or less.284 Table 2.20 shows the distribution of investments by amount.

TABLE 2.20 CPP INVESTMENT SIZE BY INSTITUTION, AS OF 6/30/2012 Originala Outstandingb $10 billion or more 6 0 $1 billion to $10 billion 19 0 $100 million to $1 billion 57 17 Less than $100 million 625 308 Total 707 325

Notes: Data based on the institutions’ total CPP investments. There are more than 30 institutions that have received multiple transactions through CPP. a These numbers are based on total Treasury CPP investment since 10/28/2008. b Amount does not include those investments that have already been repaid, sold to a third party at a discount, merged out of the CPP portfolio, exchanged their CPP investments for an investment under CDCI, or are related to institutions that filed for bankruptcy protection or had a subsidiary bank fail. Figures are based on total investments outstanding. Included in those figures are the six banks that were converted to common shares at a discount. The outstanding amount represented is the original par value of the investment. Treasury does not include in the number of banks with outstanding CPP investments those institutions that have repaid their CPP principal but still have warrants outstanding.

Source: Treasury, response to SIGTARP data call, 7/5/2012.

As of June 30, 2012, 325 banks remained in CPP and taxpayers were still owed $13.8 billion related to CPP. According to Treasury, it had write-offs and realized losses of $2.8 billion in the program, leaving $11.1 billion in TARP funds outstand- ing. According to Treasury, $191.1 billion of the CPP principal (or 93.3%) had been repaid as of June 30, 2012. That repayment tally includes $245 million in proceeds from an auction held from June 11 through June 13, 2012, of preferred stock in seven banks, but does not include $204.4 million in proceeds from an auction held from June 25 through June 27, 2012, of preferred stock in another seven banks. The repayment amount also includes $363.3 million in preferred stock that was converted from CPP investments into CDCI and therefore still represents out- standing obligations to TARP, and $2.2 billion that was refinanced in 2011 into SBLF, a non-TARP Government program.285 As of June 30, 2012, Treasury had received approximately $11.7 billion in interest and dividends from CPP recipients. Treasury also had received $7.7 billion through the sale of CPP warrants that were obtained from TARP recipients.286 Figure 2.2 provides a snapshot of CPP funds outstanding and associated repayments. For a complete list of CPP share repur- chases, see Appendix D: “Transaction Detail.” quarterly report to congress I July 25, 2012 89

FIGURE 2.2 SNAPSHOT OF CPP FUNDS REPAID AND OWED TO TAXPAYERS, BY QUARTER ($ BILLIONS)

198.8 203.2 204.6 204.9 204.9 204.9 204.9 204.9 204.9 204.9 204.9 204.9 204.9 204.9 200 0.4 70.1 70.7 121.9 135.8 146.9 152.8 167.9 179.1 180.6 184.9 185.5 186.9 191.1 198.4 177.5 177.5

150

133.1 133.9 115.0 115.0 100

83.0 69.1 50 58.0 52.1 37.0 25.9 24.3 20.0 19.5 18.0 13.8 0 Q308 Q408 Q109 Q209 Q309 Q409 Q110 Q210 Q310 Q410 Q111 Q211 Q311 Q411 Q112 Q212

CPP Funds Repaid at Quarter’s End CPP Funds Owed to Taxpayers at Quarter’s End

Notes: Numbers may be affected by rounding. Data presented for calendar quarters.

Source: Treasury, Transactions Report, 6/27/2012.

CPP Banks Exiting TARP by Refinancing into SBLF On September 27, 2010, the President signed into law the Small Business Jobs Act of 2010 (“Jobs Act”), which created the non-TARP program SBLF for Treasury capital investments in institutions with less than $10 billion in total assets.287 The Jobs Act specifically contemplated that some CPP institutions could apply to exit TARP by refinancing into SBLF. According to Treasury, it received a total of 935 SBLF applications, of which 320 were TARP recipients under CPP (315) or CDCI (5).288 Treasury approved the exit of 137 CPP participants from TARP, which included refinancing Treasury’s TARP preferred stock into $2.7 billion in SBLF preferred stock.289 An institution was not eligible for the program if at the time of application it was on the FDIC’s problem bank list or if it had been removed from that list in the 90 days preceding its application to SBLF.290 Treasury consulted with Federal and, where applicable, state regulators about the bank’s financial condition and whether it was eligible to receive funding from SBLF.291 90 special inspector general I troubled asset relief program

For SIGTARP’s recommendations In order for these 137 banks to exit TARP, the following conditions had to be to Treasury about applying SBLF met:292 to TARP recipients, see SIGTARP’s January 2011 Quarterly Report, pages 185-192. • Banks that refinanced into SBLF were required to end participation in CPP or CDCI. For further discussion of Treasury • Banks that used SBLF to refinance their CPP or CDCI investments were policies regarding missed dividend required to redeem all outstanding preferred stock issued under those programs payments and of how Treasury adjusts on or before the date of Treasury’s SBLF investment. Banks could use the SBLF dividend rates of SBLF banks, see SIGTARP’s April 2011 Quarterly funding to meet this requirement. Report, pages 128-129. • Banks were required to be in material compliance with all the terms, conditions, and covenants of CPP or CDCI in order to refinance through SBLF. For a discussion of the impact of TARP • Banks were required to be current in their dividend payments and to pay any and SBLF on community banks, see accrued and unpaid dividends due to Treasury under CPP or CDCI. In addition, SIGTARP’s April 2012 Quarterly report, pages 145-167. banks could not have missed more than one previous dividend payment under CPP or CDCI (defined as a payment submitted more than 60 days late).

Table 2.21 is a list of the 137 banks that exited TARP by refinancing into SBLF. quarterly report to congress I July 25, 2012 91

Table 2.21 CPP BANKS THAT EXITED TARP BY REFINANCING INTO SBLF CPP Principal CPP Warrant SBLF Principal Institution Investment Disposition Proceeds TARP Exit Date Investment 1st Enterprise Banka $10,400,000 $220,000 9/1/2011 $16,400,000 Adbanc, Inc. 12,720,000 636,000 7/21/2011 21,905,000 AMB Financial Corp. 3,674,000 184,000 9/22/2011 3,858,000 AmeriBank Holding Company 2,492,000 125,000 9/15/2011 5,347,000 AmeriServ Financial, Inc. 21,000,000 825,000 8/11/2011 21,000,000 Avenue Financial Holdings, Inc. 7,400,000 370,000 9/15/2011 18,950,000 BancIndependent, Inc. 21,100,000 1,055,000 7/14/2011 30,000,000 Bancorp Financial, Inc. 13,669,000 410,000 8/18/2011 14,643,000 Bank of Commerce Holdings 17,000,000 125,000 9/27/2011 20,000,000 BankFirst Capital Corporation 15,500,000 775,000 9/8/2011 20,000,000 Banner County Ban Corporation 795,000 40,000 7/28/2011 2,427,000 Bern Bancshares, Inc. 985,000 50,000 9/1/2011 1,500,000 Birmingham Bloomfield Bancshares, Inc.a 3,379,000 82,000 7/28/2011 4,621,000 BNC Financial Group, Inc. 4,797,000 240,000 8/4/2011 10,980,000 BOH Holdings, Inc. 10,000,000 500,000 7/14/2011 23,938,350 Brotherhood Bancshares, Inc. 11,000,000 550,000 9/15/2011 16,000,000 Cache Valley Banking Companya 9,407,000 238,000 7/14/2011 11,670,000 California Bank of Commerce 4,000,000 200,000 9/15/2011 11,000,000 Cardinal Bancorp II, Inc. 6,251,000 313,000 9/8/2011 6,251,000 Catskill Hudson Bancorp, Inc.a 6,500,000 263,000 7/21/2011 9,681,000 Center Bancorp, Inc. 10,000,000 245,000 9/15/2011 11,250,000 Central Bancorp, Inc. 10,000,000 2,525,000 8/25/2011 10,000,000 Central Valley Community Bancorp 7,000,000 185,017 8/18/2011 7,000,000 Centric Financial Corporation 6,056,000 182,000 7/14/2011 7,492,000 Centrix Bank & Trust 7,500,000 375,000 7/28/2011 24,500,000 Citizens Community Bank 3,000,000 150,000 7/28/2011 4,000,000 Citizens South Banking Corporation 20,500,000 225,157 9/22/2011 20,500,000 CoBiz Financial Inc. 64,450,000 143,677 9/8/2011 57,366,000 Codorus Valley Bancorp, Inc. 16,500,000 526,604 8/18/2011 25,000,000 Columbine Capital Corp. 2,260,000 113,000 9/22/2011 6,050,000 Community Bank Shares of Indiana, Inc. 19,468,000 1,100,870 9/15/2011 28,000,000 Community First Bancshares Inc. 20,000,000 1,000,000 8/18/2011 30,852,000 Community Partners Bancorp 9,000,000 460,000 8/11/2011 12,000,000 Community Trust Financial Corporation 24,000,000 1,200,000 7/6/2011 48,260,000 D. L. Evans Bancorp 19,891,000 995,000 9/27/2011 29,891,000 Deerfield Financial Corporation 2,639,000 132,000 9/8/2011 3,650,000 Continued on next page 92 special inspector general I troubled asset relief program

CPP BANKS THAT EXITED TARP BY REFINANCING INTO SBLF (Continued) CPP Principal CPP Warrant SBLF Principal Institution Investment Disposition Proceeds TARP Exit Date Investment DNB Financial Corporation $11,750,000 $458,000 8/4/2011 $13,000,000 Eagle Bancorp, Inc. 38,235,000 2,794,422 7/14/2011 56,600,000 Emclaire Financial Corp. 7,500,000 51,113 8/18/2011 10,000,000 Encore Bancshares, Inc. 34,000,000 637,071 9/27/2011 32,914,000 Enterprise Financial Services Group, Inc. 4,000,000 200,000 8/25/2011 5,000,000 Equity Bancshares, Inc. 8,750,000 438,000 8/11/2011 16,372,000 Farmers State Bankshares, Inc. 700,000 40,000 7/21/2011 700,000 FCB Bancorp, Inc. 9,294,000 465,000 9/22/2011 9,759,000 Financial Security Corporation 5,000,000 250,000 7/21/2011 5,000,000 Financial Services of Winger, Inc. 3,742,000 112,000 9/1/2011 4,069,000 First Bancorp 65,000,000 924,462 9/1/2011 63,500,000 First Bank of Charleston, Inc. 3,345,000 167,000 7/21/2011 3,345,000 First Bankers Trustshares, Inc. 10,000,000 500,000 9/8/2011 10,000,000 First Busey Corporation 100,000,000 63,677 8/25/2011 72,664,000 First California Financial Group, Inc 25,000,000 599,042 7/14/2011 25,000,000 First Colebrook Bancorp, Inc. 4,500,000 225,000 9/22/2011 8,623,000 First Financial Bancshares, Inc. 3,756,000 113,000 9/22/2011 3,905,000 First Guaranty Bancshares, Inc. 20,699,000 1,030,000 9/22/2011 39,435,000 First Menasha Bancshares, Inc. 4,797,000 240,000 9/15/2011 10,000,000 First Merchants Corporation 116,000,000 367,500 9/22/2011 90,782,940 First NBC Bank Holding Company 17,836,000 892,000 8/4/2011 37,935,000 First Northern Community Bancorp 17,390,000 375,000 9/15/2011 22,847,000 First Resource Banka 5,017,000 130,000 9/15/2011 5,083,000 First Texas BHC, Inc. 13,533,000 677,000 9/15/2011 29,822,000 Florida Business BancGroup, Inc. 9,495,000 475,000 9/22/2011 15,360,000 FNB Bancorp 12,000,000 600,000 9/15/2011 12,600,000 Fortune Financial Corporation 3,100,000 155,000 9/15/2011 3,255,000 Grand Capital Corporation 4,000,000 200,000 9/8/2011 5,200,000 GrandSouthBancorporationa 15,319,000 450,000 9/8/2011 15,422,000 Great Southern Bancorp 58,000,000 6,436,364 8/18/2011 57,943,000 Guaranty Bancorp, Inc. 6,920,000 346,000 9/15/2011 7,000,000 Gulfstream Bancshares, Inc. 7,500,000 375,000 8/18/2011 7,500,000 Heartland Financial USA, Inc. 81,698,000 1,800,000 9/15/2011 81,698,000 Heritage Bankshares, Inc. 10,103,000 303,000 8/11/2011 7,800,000 Highlands Bancorp, Inc.a 5,450,000 155,000 9/22/2011 6,853,000 Horizon Bancorp 25,000,000 1,750,551 8/25/2011 12,500,000 Howard Bancorp, Inc. 5,983,000 299,000 9/22/2011 12,562,000 Continued on next page quarterly report to congress I July 25, 2012 93

CPP BANKS THAT EXITED TARP BY REFINANCING INTO SBLF (Continued) CPP Principal CPP Warrant SBLF Principal Institution Investment Disposition Proceeds TARP Exit Date Investment Illinois State Bancorp, Inc.a $10,272,000 $406,000 9/22/2011 $13,368,000 Katahdin Bankshares Corp. 10,449,000 522,000 8/18/2011 11,000,000 Liberty Bancshares, Inc. (AR) 57,500,000 2,875,000 7/21/2011 52,500,000 Liberty Bancshares, Inc. (MO) 21,900,000 1,095,000 8/18/2011 22,995,000 Magna Bank 13,795,000 690,000 8/18/2011 18,350,000 McLeod Bancshares, Inc. 6,000,000 300,000 8/18/2011 6,000,000 Medallion Banka 21,498,000 645,000 7/21/2011 26,303,000 Mercantile Capital Corp. 3,500,000 175,000 8/4/2011 7,000,000 Merchants and Manufacturers Bank 3,510,000 176,000 9/8/2011 6,800,000 Corporation Merchants and Planters Bancshares, Inc. 1,881,000 94,000 9/8/2011 2,000,000 MidSouth Bancorp, Inc. 20,000,000 206,557 8/25/2011 32,000,000 Moneytree Corporation 9,516,000 476,000 9/15/2011 9,992,000 Monument Bank 4,734,000 237,000 8/11/2011 11,355,000 MutualFirst Financial, Inc. 32,382,000 900,194 8/25/2011 28,923,000 New Hampshire Thrift Bancshares, Inc. 10,000,000 737,100 8/25/2011 20,000,000 Nicolet Bankshares, Inc. 14,964,000 748,000 9/1/2011 24,400,000 Northway Financial, Inc. 10,000,000 500,000 9/15/2011 23,593,000 Oak Valley Bancorp 13,500,000 560,000 8/11/2011 13,500,000 Pacific Coast Bankers’ Bancshares 11,600,000 580,000 7/28/2011 11,960,000 Pathfinder Bancorp, Inc. 6,771,000 537,633 9/1/2011 13,000,000 Penn Liberty Financial Corp. 9,960,000 498,000 9/1/2011 20,000,000 Peoples Bancorp 18,000,000 900,000 8/4/2011 18,000,000 PFSB Bancorporation, Inc. 1,500,000 71,000 8/25/2011 1,500,000 PlainsCapital Corporation 87,631,000 4,382,000 9/27/2011 114,068,000 Providence Bank 4,000,000 175,000 9/15/2011 4,250,000 Puget Sound Bank 4,500,000 225,000 8/11/2011 9,886,000 QCR Holdings, Inc. 38,237,000 1,100,000 9/15/2011 40,090,000 Redwood Capital Bancorp 3,800,000 190,000 7/21/2011 7,310,000 Redwood Financial, Inc. 2,995,000 150,000 8/18/2011 6,425,000 Regent Capital Corporation 2,655,000 133,000 7/21/2011 3,350,000 Salisbury Bancorp, Inc. 8,816,000 205,000 8/25/2011 16,000,000 SBT Bancorp, Inc. 4,000,000 200,000 8/11/2011 9,000,000 Seacoast Commerce Bank 1,800,000 90,000 9/1/2011 4,000,000 Security Business Bancorp 5,803,000 290,000 7/14/2011 8,944,500 Security California Bancorp 6,815,000 341,000 9/15/2011 7,200,000 Security State Bancshares, Inc. 12,500,000 625,000 9/22/2011 22,000,000 Continued on next page 94 special inspector general I troubled asset relief program

CPP BANKS THAT EXITED TARP BY REFINANCING INTO SBLF (Continued) CPP Principal CPP Warrant SBLF Principal Institution Investment Disposition Proceeds TARP Exit Date Investment Southern Heritage Bancshares, Inc. $4,862,000 $243,000 9/8/2011 $5,105,000 Southern Illinois Bancorp, Inc. 5,000,000 250,000 8/25/2011 9,000,000 Southern Missouri Bancorp, Inc.b 9,550,000 7/21/2011 20,000,000 Sovereign Bancshares, Inc. 18,215,000 911,000 9/22/2011 24,500,000 Steele Street Bank Corporation 11,019,000 331,000 9/1/2011 11,350,000 Stewardship Financial Corporation 10,000,000 107,398 9/1/2011 15,000,000 Summit State Bank 8,500,000 315,000 8/4/2011 13,750,000 Sword Financial Corporation 13,644,000 682,000 9/15/2011 17,000,000 TCB Corporation 9,720,000 292,000 9/8/2011 8,640,000 The ANB Corporation 20,000,000 1,000,000 8/25/2011 37,000,000 The Elmira Savings Bank, FSBb 9,090,000 8/25/2011 14,063,000 The Landrum Company 15,000,000 750,000 8/18/2011 20,000,000 The Private Bank of California 5,450,000 273,000 9/1/2011 10,000,000 The State Bank of Bartley 1,697,000 51,000 9/22/2011 2,380,000 The Victory Bancorp, Inc.a 2,046,000 61,000 9/22/2011 3,431,000 TowneBankb 76,458,000 9/22/2011 76,458,000 Triad Bancorp, Inc. 3,700,000 185,000 9/22/2011 5,000,000 Tri-County Financial Corporation 15,540,000 777,000 9/22/2011 20,000,000 Two Rivers Financial Group, Inc. 12,000,000 600,000 9/1/2011 23,240,000 UBT Bancshares, Inc. 8,950,000 450,000 8/11/2011 16,500,000 Union Bank & Trust Companya 6,191,000 160,000 9/22/2011 6,200,000 United Financial Banking Companies, Inc. 5,658,000 283,000 9/15/2011 3,000,000 Valley Financial Group, Ltd. 1,300,000 65,000 9/22/2011 2,000,000 Veritex Holdings, Inc.(Fidelity Resources 3,000,000 150,000 8/25/2011 8,000,000 Company) W.T.B. Financial Corporation 110,000,000 5,500,000 9/15/2011 89,142,000 WashingtonFirst Bankshares, Inc.a 13,475,000 332,000 8/4/2011 17,796,000 Western Alliance Bancorporation 140,000,000 415,000 9/27/2011 141,000,000 York Traditions Bank 4,871,000 244,000 7/14/2011 5,115,000 Total $2,240,465,000 $77,321,409 $2,689,763,790 Notes: Banks are not required to repurchase warrants from Treasury that were provided as a condition of receiving funds under CPP. a Institution received multiple investments under CPP. b As of the drafting of this report, Treasury still held warrants to purchase common stock in this institution.

Sources: Treasury, Transactions Report, 6/27/2012, www.treasury.gov/initiatives/financial-stability/briefing-room/reports/tarp-transactions/DocumentsTARPTransactions/07-02-12%20Transactions%20 Report%20as%20of%2006-27-12_INVESTMENT.pdf, accessed 7/5/2012; Treasury, SBLF Transactions Report, 9/28/2011, www.treasury.gov/resource-center/sb-programs/DocumentsSBLFTransactions/ SBLF_Bi-Weekly_Transactions_Report_THRU_09272011.pdf, accessed 6/29/2012. quarterly report to congress I July 25, 2012 95

Program Administration Table 2.22 Although Treasury’s investment authority for CPP has ended, Treasury still has Missed dividend/interest significant responsibilities for managing the existing CPP portfolio, including the payments by QFIS, 9/30/2009 to 6/30/2012 following: ($ millions) Value of • collecting dividends and interest payments on outstanding investments Quarter Number Unpaid • monitoring the performance of outstanding investments End of QFIs Amountsa,b,c • disposing of warrants as investments are repaid 9/30/2009 38 $75.7 • selling or restructuring Treasury’s investment in some troubled financial 12/31/2009 43 137.4 institutions 3/31/2010 67 182.0 • selecting observers for recipients that have missed five quarterly dividend 6/30/2010d 109 209.7 payments 9/30/2010 137 211.3 • potentially selecting directors for recipients that have missed six or more 12/31/2010 155 276.4 quarterly dividend payments 3/31/2011 173 277.3 Dividends and Interest 6/30/2011 188 320.8 As of June 30, 2012, Treasury had received $11.7 billion in dividends on its CPP 9/30/2011 193 356.9 investments.293 However, as of that date, 203 QFIs had unpaid dividend or interest 12/31/2011 197 377.0 payments to Treasury totaling approximately $455 million, an increase from the 3/31/2012 200 416.0 200 QFIs that had unpaid dividend (or interest) payments totaling approximately 6/30/2012 203 455.0 $416 million as of March 31, 2012. Approximately $21.1 million of the unpaid Notes: a Includes unpaid cumulative dividends, non-cumulative amounts are non-cumulative, meaning that the institution has no legal obligation dividends, and Subchapter S interest payments 294 but does not include interest accrued on unpaid to pay Treasury unless the institution declares a dividend. Table 2.22 shows the cumulative dividends. number of QFIs and total unpaid amount of dividend and interest payments by b Excludes institutions that missed payments but (i) had fully caught up on missed payments at the end of the quarter from September 30, 2009, to June 30, 2012. quarter reported in column 1 or (ii) had repaid their investment amounts and exited CPP. c Includes institutions that missed payments and (i) entered into a recapitalization or restructuring Treasury’s Policy on Missed Dividend and Interest Payments with Treasury, (ii) for which Treasury sold the CPP investment to a third party or otherwise disposed of According to Treasury, it “evaluates its CPP investments on an ongoing basis with the investment to facilitate the sale of the institution to the help of outside advisors, including external asset managers. The external asset a third party without receiving full repayment of unpaid dividends, (iii) filed for bankruptcy relief, or (iv) had a managers provide a valuation for each CPP investment” that results in Treasury subsidiary bank fail. d Includes four QFIs and their missed payments not assigning the institution a credit score.295 For those that have unfavorable credit reported in Treasury’s Capital Purchase Program Missed Dividends & Interest Payments Report as of scores, including any institution that has missed more than three dividend (or 6/30/2010 but reported in Treasury’s Dividends and Interest Report as of the same date. The four QFIs are interest) payments, Treasury has stated that the “asset manager dedicates more CIT, Pacific CoastN ational Bancorp, UCBH Holdings, resources to monitoring the institution and may talk to the institution on a more Inc., and Midwest Banc Holdings, Inc. frequent basis.”296 Sources: Treasury, Dividends and Interest Report, 7/11/2012; Treasury, responses to SIGTARP Under the terms of the preferred shares or subordinated debentures held by data calls, 10/7/2009, 1/12/2010, 4/8/2010, 6/30/2010, 10/11/2011,1/5/2012, 4/5/2012, Treasury as a result of its CPP investments, in certain circumstances, such as 7/5/2012, and 7/10/2012; SIGTARP Quarterly Report to Congress, 1/30/2010, 4/20/2010, 7/21/2010, when a participant misses six dividend (or interest) payments, Treasury has the and 10/26/2010. right to appoint up to two additional members to the institution’s board of direc- tors.297 Treasury has stated that it will prioritize the institutions for which it ap- points directors based on “the size of its investment, Treasury’s assessment of the extent to which new directors may make a contribution and Treasury’s ability to find appropriate directors for a given institution.”298 These directors will not repre- sent Treasury, but rather will have the same fiduciary duties to shareholders as all other directors. They will be compensated by the institution in a manner similar to 96 special inspector general I troubled asset relief program

other directors.299 Treasury has engaged an executive search firm to identify suit- able candidates for board of directors’ positions and has begun interviewing such candidates.300 According to Treasury, it continues to prioritize institutions for nominating directors in part based on whether its investment exceeds $25 million.301 When Treasury’s right to nominate a new board member becomes effective, it evaluates the institution’s condition and health and the functioning of its board to determine whether additional directors are necessary.302 As of June 30, 2012, Treasury had made director appointments to the boards of directors of 11 CPP banks.303 According to Treasury, on April 19, 2012, it appointed James Kane to the board of Bridgeview Bancorp, Inc., Bridgeview, Illinois (“Bridgeview”).304 Bridgeview received $38 million under CPP and had missed nine quarterly dividend payments prior to the director appointment.305 According to Treasury, on April 25, 2012, it appointed Dennis Battles to the board of Centrue Financial Corporation, St. Louis, Missouri (“Centrue”).306 Centrue received $32.7 million under CPP and had missed 12 quarterly dividend payments prior to the director appointment.307 According to Treasury, on June 12, 2012, it appointed Randall Howard to the board of First Trust Corporation, New Orleans, Louisiana (“First Trust”).308 First Trust received $18 million under CPP and had missed nine quarterly dividend pay- ments prior to the director appointment.309 For institutions that miss five or more dividend (or interest) payments, Treasury has stated that it would seek consent from such institutions to send observers to the institutions’ board meetings.310 According to Treasury, the observers would be selected from the Office of Financial Stability (“OFS”) and assigned to “gain a bet- ter understanding of the institution’s condition and challenges and to observe how the board is addressing the situation.”311 Their participation would be “limited to inquiring about distributed materials, presentations, and actions proposed or taken during the meetings, as well as addressing any questions concerning” their role.312 The findings of the observers are taken into account when Treasury evaluates whether to appoint individuals to an institution’s board of directors.313 As of June 30, 2012, Treasury had assigned observers to 49 current CPP recipients.314 SIGTARP and Treasury do not use the same methodology to report unpaid dividend and interest payments. For example, Treasury generally excludes institu- tions from its “non-current” reporting: (i) that have completed a recapitalization, restructuring, or exchange with Treasury (though Treasury does report such institu- tions as non-current during the pendency of negotiations); (ii) for which Treasury sold the CPP investment to a third party, or otherwise disposed of the investment to facilitate the sale of the institution to a third party; (iii) that filed for bankruptcy relief; or (iv) that had a subsidiary bank fail.315 SIGTARP generally includes such activity in Table 2.23 under “Value of Unpaid Amounts” with the value set as of the date of the bankruptcy, restructuring, or other event that relieves the institu- tion of the legal obligation to continue to make dividend and interest payments. If a completed transaction resulted in payment to Treasury for all unpaid dividends and interest, SIGTARP does not include the institution’s obligations under unpaid quarterly report to congress I July 25, 2012 97

amounts. SIGTARP, unlike Treasury, does not include in its table institutions that have “caught up” by making previously missed dividend and interest payments.316 According to Treasury, as of June 30, 2012, 117 QFIs had missed at least six divi- dend (or interest) payments (up from 101 last quarter) and 23 banks had missed five dividend (or interest) payments totaling $413 million.317 Table 2.23 lists CPP recipients that had unpaid dividend (or interest) payments as of June 30, 2012. For a complete list of CPP recipients and institutions making dividend or interest pay- ments, see Appendix D: “Transaction Detail.” 98 special inspector general I troubled asset relief program

Table 2.23 CPP RELATED MISSED DIVIDEND AND INTEREST PAYMENTS, AS OF 6/30/2012 Observer Number Assigned Dividend or of Missed to Board of Value of Missed Value of Unpaid Company Payment type Payments Directors1 Payments2 Amounts2,3,4 Saigon National Bank Non-Cumulative 14 $286,423 $286,423 Anchor BanCorp Wisconsin, Inc. Cumulative 13 n 18,104,167 18,104,167 Blue Valley Ban Corp Cumulative 13 3,534,375 3,534,375 Lone Star Bank Non-Cumulative 13 ü 548,432 548,432 OneUnited Bank Non-Cumulative 13 ü 1,960,238 1,960,238 United American Bank Non-Cumulative 13 1,534,402 1,534,402 Centrue Financial Corporation Cumulative 12 n 4,900,200 4,900,200 Dickinson Financial Corporation II Cumulative 12 ü 23,879,760 23,879,760 First Banks, Inc. Cumulative 12 n 48,297,900 48,297,900 Georgia Primary Bank Non-Cumulative 12 ü 745,288 745,288 Grand Mountain Bancshares, Inc. Cumulative 12 ü 496,460 496,460 Idaho Bancorp Cumulative 12 ü 1,128,150 1,128,150 Pacific City Financial Corporation Cumulative 12 2,648,700 2,648,700 Premier Service Bank Non-Cumulative 12 ü 650,972 650,972 Royal Bancshares of Pennsylvania, Inc. Cumulative 12 n 4,561,050 4,561,050 Citizens Commerce Bancshares, Inc. Cumulative 11 944,213 944,213 FC Holdings, Inc. Cumulative 11 ü 3,153,645 3,153,645 Northern States Financial Corporation Cumulative 11 ü 2,366,513 2,366,513 Omega Capital Corp. Cumulative 11 422,098 422,098 Pathway Bancorp Cumulative 11 558,498 558,498 Premierwest Bancorp Cumulative 11 n 5,692,500 5,692,500 Ridgestone Financial Services, Inc. Cumulative 11 ü 1,633,638 1,633,638 Rising Sun Bancorp Cumulative 11 896,665 896,665 Rogers Bancshares, Inc. Cumulative 11 n 3,746,875 3,746,875 Syringa Bancorp Cumulative 11 ü 1,199,000 1,199,000 Alliance Financial Services, Inc.* Interest 10 2,517,000 2,517,000 BNCCORP, Inc. Cumulative 10 ü 2,737,750 2,737,750 Cecil Bancorp, Inc. Cumulative 10 ü 1,445,000 1,445,000 Central Virginia Bankshares, Inc. Cumulative 10 1,423,125 1,423,125 Citizens Bancshares Co. (MO) Cumulative 10 ü 3,405,000 3,405,000 Citizens Republic Bancorp, Inc. Cumulative 10 n 37,500,000 37,500,000 City National Bancshares Corporation Cumulative 10 1,179,875 1,179,875 Community 1st Bank Non-Cumulative 10 323,994 323,994 Fidelity Federal Bancorp Cumulative 10 879,074 879,074 First Security Group, Inc. Cumulative 10 n 4,125,000 4,125,000 First Sound Bank Non-Cumulative 10 925,000 925,000 First Southwest Bancorporation, Inc. Cumulative 10 749,375 749,375 Intermountain Community Bancorp Cumulative 10 3,375,000 3,375,000 Continued on next page quarterly report to congress I July 25, 2012 99

CPP RELATED MISSED DIVIDEND AND INTEREST PAYMENTS, AS OF 6/30/2012 (Continued) Observer Number Assigned Dividend or of Missed to Board of Value of Missed Value of Unpaid Company Payment type Payments Directors1 Payments2 Amounts2,3,4 Intervest Bancshares Corporation Cumulative 10 n $3,125,000 $3,125,000 Investors Financial Corporation of Interest 10 839,000 839,000 Pettis County, Inc.* Monarch Community Bancorp, Inc. Cumulative 10 848,125 848,125 Tennessee Valley Financial Cumulative 10 408,750 408,750 Holdings, Inc. U.S. Century Bank Non-Cumulative 10 ü 6,844,700 6,844,700 Bridgeview Bancorp, Inc. Cumulative 9 n,ü 4,659,750 4,659,750 Commonwealth Business Bank Non-Cumulative 9 944,325 944,325 First Community Bancshares, Inc (KS) Cumulative 9 ü 1,814,850 1,814,850 First Trust Corporation* Interest 9 n,ü 3,391,958 3,391,958 Gold Canyon Bank Non-Cumulative 9 190,508 190,508 Goldwater Bank, N.A.** Non-Cumulative 9 384,780 314,820 Gregg Bancshares, Inc. Cumulative 9 101,115 101,115 Madison Financial Corporation Cumulative 9 413,348 413,348 Midtown Bank & Trust Company** Non-Cumulative 9 711,475 640,328 Millennium Bancorp, Inc.** Cumulative 9 989,175 890,258 Northwest Bancorporation, Inc. Cumulative 9 ü 1,287,563 1,287,563 Patapsco Bancorp, Inc. Cumulative 9 735,750 735,750 Plumas Bancorp Cumulative 9 ü 1,344,263 1,344,263 Prairie Star Bancshares, Inc. Cumulative 9 343,350 343,350 Premier Bank Holding Company Cumulative 9 1,164,938 1,164,938 Santa Clara Valley Bank, N.A. Non-Cumulative 9 355,613 355,613 Stonebridge Financial Corp. Cumulative 9 ü 1,345,635 1,345,635 TCB Holding Company Cumulative 9 ü 1,438,493 1,438,493 1st FS Corporation Cumulative 8 ü 1,636,900 1,636,900 BNB Financial Services Corporation Cumulative 8 817,500 817,500 Boscobel Bancorp, Inc* Interest 8 937,248 937,248 Capital Commerce Bancorp, Inc. Cumulative 8 555,900 555,900 Harbor Bankshares Corporation** Cumulative 8 850,000 680,000 Market Bancorporation, Inc. Cumulative 8 224,540 224,540 Pacific International Bancorp Inc Cumulative 8 650,000 650,000 Pinnacle Bank Holding Company Cumulative 8 478,320 478,320 Premier Financial Corp* Interest 8 1,065,238 1,065,238 Provident Community Bancshares, Inc. Cumulative 8 926,600 926,600 The Queensborough Company Cumulative 8 ü 1,308,000 1,308,000 Western Community Bancshares, Inc. Cumulative 8 794,700 794,700 Continued on next page 100 special inspector general I troubled asset relief program

CPP RELATED MISSED DIVIDEND AND INTEREST PAYMENTS, AS OF 6/30/2012 (Continued) Observer Number Assigned Dividend or of Missed to Board of Value of Missed Value of Unpaid Company Payment type Payments Directors1 Payments2 Amounts2,3,4 Bankers’ Bank of the West Cumulative 7 ü $1,549,868 $1,205,453 Bancorp, Inc. CalWest Bancorp Cumulative 7 444,098 444,098 Central Federal Corporation Cumulative 7 632,188 632,188 CSRA Bank Corp. Cumulative 7 228,900 228,900 First Financial Service Corporation Cumulative 7 ü 1,750,000 1,750,000 First United Corporation Cumulative 7 ü 2,625,000 2,625,000 Florida Bank Group, Inc. Cumulative 7 ü 1,952,493 1,952,493 Great River Holding Company* Interest 7 1,233,330 1,233,330 Liberty Shares, Inc. Cumulative 7 ü 1,648,080 1,648,080 Marine Bank & Trust Company Non-Cumulative 7 286,125 286,125 Old Second Bancorp, Inc. Cumulative 7 ü 6,387,500 6,387,500 Pacific Commerce Bank** Non-Cumulative 7 419,184 363,866 Private Bancorporation, Inc. Cumulative 7 758,485 758,485 Regent Bancorp, Inc** Cumulative 7 1,088,020 952,018 Spirit BankCorp, Inc. Cumulative 7 ü 2,861,250 2,861,250 Tidelands Bancshares, Inc Cumulative 7 ü 1,264,200 1,264,200 Bank of the Carolinas Corporation Cumulative 6 ü 988,425 988,425 Coastal Banking Company, Inc. Cumulative 6 746,250 746,250 Community Financial Shares, Inc. Cumulative 6 569,865 474,888 Eastern Virginia Bankshares, Inc. Cumulative 6 ü 1,800,000 1,800,000 Greer Bancshares Incorporated Cumulative 6 816,975 816,975 HCSB Financial Corporation Cumulative 6 ü 967,125 967,125 Highlands Independent Cumulative 6 547,725 547,725 Bancshares, Inc. HMN Financial, Inc. Cumulative 6 ü 1,950,000 1,950,000 Monadnock Bancorp, Inc. Cumulative 6 149,970 149,970 Naples Bancorp, Inc. Cumulative 6 327,000 327,000 National Bancshares, Inc. Cumulative 6 ü 2,016,255 2,016,255 Patriot Bancshares, Inc. Cumulative 6 ü 2,128,620 2,128,620 Princeton National Bancorp, Inc. Cumulative 6 ü 1,881,225 1,881,225 Reliance Bancshares, Inc. Cumulative 6 ü 3,270,000 3,270,000 Security State Bank Holding-Company* Interest 6 ü 2,029,487 1,352,991 SouthCrest Financial Group, Inc. Cumulative 6 ü 1,054,575 1,054,575 Southern Community Financial Corp. Cumulative 6 ü 3,206,250 3,206,250 White River Bancshares Company Cumulative 6 1,373,400 1,373,400 AB&T Financial Corporation Cumulative 5 218,750 218,750 Atlantic Bancshares, Inc. Cumulative 5 136,025 136,025 Continued on next page quarterly report to congress I July 25, 2012 101

CPP RELATED MISSED DIVIDEND AND INTEREST PAYMENTS, AS OF 6/30/2012 (Continued) Observer Number Assigned Dividend or of Missed to Board of Value of Missed Value of Unpaid Company Payment type Payments Directors1 Payments2 Amounts2,3,4 Metropolitan Bank Group, Inc (Archer Cumulative 5 $7,959,128 $5,035,523 Bank)*** Bank of George Non-Cumulative 5 182,075 182,075 BCB Holding Company, Inc. Cumulative 5 116,188 116,188 Carrollton Bancorp Cumulative 5 575,063 575,063 Central Bancorp, Inc. Cumulative 5 1,532,813 1,532,813 Citizens Bank & Trust Company Non-Cumulative 5 163,500 163,500 Clover Community Bankshares, Inc. Cumulative 5 204,375 204,375 CoastalSouth Bancshares, Inc. Cumulative 5 1,054,938 1,054,938 Community Bankers Trust Corporation Cumulative 5 1,547,000 1,105,000 Community First, Inc. Cumulative 5 1,213,000 970,400 Community Pride Bank Corporation* Interest 5 446,270 446,270 First Place Financial Corp. Cumulative 5 4,557,938 4,557,938 Mid-Wisconsin Financial Services, Inc. Cumulative 5 681,250 681,250 Suburban Illiniois Bancorp, Inc.* Interest 5 1,573,125 1,573,125 Timberland Bancorp, Inc. Cumulative 5 1,664,100 691,910 Valley Community Bank Non-Cumulative 5 374,688 374,688 Village Bank and Trust Financial Corp. Cumulative 5 921,125 921,125 Yadkin Valley Financial Corporation Cumulative 5 3,082,000 3,082,000 Allied First Bancorp, Inc. Cumulative 4 199,070 199,070 Brogan Bankshares, Inc.* Interest 4 201,360 201,360 Coloeast Bankshares, Inc. Cumulative 4 545,000 545,000 First Intercontinental Bank Non-Cumulative 4 348,700 348,700 GulfSouth Private Bank Non-Cumulative 4 395,250 395,250 Maryland Financial Bank Non-Cumulative 4 92,650 92,650 NCAL Bancorp Cumulative 4 545,000 545,000 RCB Financial Corporation Cumulative 4 469,120 469,120 Southwest Bancorp, Inc. Cumulative 4 3,500,000 3,500,000 Standard Bancshares, Inc. Cumulative 4 3,270,000 3,270,000 The Connecticut Bank and Trust Non-Cumulative 4 246,673 N/A Company Bank of Commerce Non-Cumulative 3 122,625 122,625 Carolina Trust Bank Non-Cumulative 3 150,000 150,000 Delmar Bancorp Cumulative 3 367,875 367,875 First Reliance Bancshares, Inc. Cumulative 3 627,360 627,360 Indiana Bank Corp. Cumulative 3 53,655 53,655 Northwest Commercial Bank Non-Cumulative 3 81,450 81,450 Porter Bancorp, Inc. Cumulative 3 1,312,500 1,312,500 Randolph Bank & Trust Company Non-Cumulative 3 254,580 254,580 Continued on next page 102 special inspector general I troubled asset relief program

CPP RELATED MISSED DIVIDEND AND INTEREST PAYMENTS, AS OF 6/30/2012 (Continued) Observer Number Assigned Dividend or of Missed to Board of Value of Missed Value of Unpaid Company Payment type Payments Directors1 Payments2 Amounts2,3,4 Alarion Financial Services, Inc. Cumulative 2 $177,520 $177,520 Blue Ridge Bancshares, Inc. Cumulative 2 327,000 327,000 Carolina Bank Holdings, Inc.** Cumulative 2 800,000 400,000 Colony Bankcorp, Inc. Cumulative 2 700,000 700,000 Flagstar Bancorp, Inc. Cumulative 2 6,666,425 6,666,425 Fresno First Bank Non-Cumulative 2 33,357 33,357 Ojai Community Bank Non-Cumulative 2 56,680 56,680 SouthFirst Bancshares, Inc. Cumulative 2 75,210 75,210 US Metro Bank** Non-Cumulative 2 159,818 77,960 Worthington Financial Holdings, Inc. Cumulative 2 74,120 74,120 BancTrust Financial Group, Inc. Cumulative 1 625,000 625,000 Community West Bancshares Cumulative 1 195,000 195,000 Exchange Bank Non-Cumulative 1 585,875 585,875 OneFinancial Corporation* Interest 1 351,000 351,000 Plato Holdings Inc.* Interest 1 51,817 51,817 Severn Bancorp, Inc. Cumulative 1 292,413 292,413 Exchanges, Sales, Recapitalizations, and Failed Banks with Missing Payments Independent Bank Corporation***,9 Cumulative 9 ü 9,542,371 7,742,371 Citizens Bancorp**** Cumulative 9 1,275,300 1,275,300 Broadway Financial Corporation*** Cumulative 8 ü 1,500,000 1,500,000 One Georgia Bank**** Non-Cumulative 8 605,328 605,328 Integra Bank Corporation**** Cumulative 7 7,313,775 7,313,775 Cascade Financial Corporation***** Cumulative 7 3,409,875 3,409,875 Fort Lee Federal Savings Bank**** Non-Cumulative 6 106,275 106,275 FPB Bancorp, Inc. (FL)**** Cumulative 6 435,000 435,000 Central Pacific Financial Corp.***,9 Cumulative 6 10,125,000 10,125,000 FNB United Corp.*** Cumulative 6 3,862,500 — First Federal Bancshares of Arkansas, Cumulative 5 1,031,250 1,031,250 Inc.***** First BanCorp (PR)*** Cumulative 5 ü 42,681,526 — Pacific Capital Bancorp***,9 Cumulative 5 ü 13,547,550 — CB Holding Corp.**** Cumulative 4 224,240 224,240 Pierce County Bancorp**** Cumulative 4 370,600 370,600 First Community Bank Corporation of Cumulative 4 534,250 534,250 America***** Green Bankshares, Inc.***** Cumulative 4 3,613,900 3,613,900 Santa Lucia Bancorp***** Cumulative 4 200,000 200,000 Community Bank of the Bay6 Non-Cumulative 4 72,549 72,549 Continued on next page quarterly report to congress I July 25, 2012 103

CPP RELATED MISSED DIVIDEND AND INTEREST PAYMENTS, AS OF 6/30/2012 (Continued) Observer Number Assigned Dividend or of Missed to Board of Value of Missed Value of Unpaid Company Payment type Payments Directors1 Payments2 Amounts2,3,4 The Bank of Currituck***** Non-Cumulative 4 $219,140 $219,140 Hampton Roads Bankshares, Inc.*** Cumulative 4 4,017,350 4,017,350 Sterling Financial Corporation (WA)***,9 Cumulative 4 18,937,500 18,937,500 Midwest Banc Holdings, Inc.5 Cumulative 4 4,239,200 4,239,200 TIB Financial Corp*****,7 Cumulative 4 1,850,000 1,850,000 Blue River Bancshares, Inc.**** Cumulative 3 ü 204,375 204,375 Legacy Bancorp, Inc.**** Cumulative 3 206,175 206,175 Sonoma Valley Bancorp**** Cumulative 3 353,715 353,715 Superior Bancorp Inc.**** Cumulative 3 2,587,500 2,587,500 Tennessee Commerce Bancorp, Cumulative 3 1,125,000 1,125,000 Inc.**** Commerce National Bank***** Non-Cumulative 3 150,000 150,000 Treaty Oak Bancorp, Inc.***** Cumulative 3 135,340 135,340 The South Financial Group, Inc.*****,7 Cumulative 3 13,012,500 13,012,500 CIT Group Inc.****,8 Cumulative 2 29,125,000 29,125,000 Pacific Coast National Bancorp**** Cumulative 2 112,270 112,270 Colonial American Bank***** Non-Cumulative 2 15,655 15,655 FBHC Holding Company*,***** Interest 2 123,127 123,127 Gateway Bancshares, Inc.***** Cumulative 2 163,500 163,500 Cadence Financial Corporation***** Cumulative 2 550,000 550,000 Metropolitan Bank Group, Inc. (NC Cumulative 1 1,400,225 1,119,005 Bancorp, Inc.)*** Tifton Banking Company**** Non-Cumulative 1 51,775 51,775 UCBH Holdings, Inc.**** Cumulative 1 3,734,213 3,734,213 Total $524,276,922 $455,077,966

Notes: Numbers may not total due to rounding. Approximately $21.1 million of the $455 million in unpaid CPP dividend/interest payments are non-cumulative and Treasury has no legal right to missed dividends that are non-cumulative.

* Missed interest payments occur when a Subchapter S recipient fails to pay Treasury interest on a subordinated debenture in a timely manner. ** Partial payments made after the due date. *** Completed an exchange with Treasury. For an exchange of mandatorily convertible preferred stock or trust preferred securities, dividend payments normally continue to accrue. For an exchange of mandatorily preferred stock for common stock, no additional preferred dividend payments will accrue. **** Filed for bankruptcy or subsidiary bank failed. For completed bankruptcy proceedings, Treasury’s investment was extinguished and no additional dividend payments will accrue. For bank failures, Treasury may elect to file claims with bank receivers to collect current and/or future unpaid dividends. ***** Treasury sold or is selling its CPP investment to the institution or a third party. No additional preferred dividend payments will accrue after a sale, absent an agreement to the contrary. n Treasury has appointed one or more directors to the Board of Directors.

1 For First BanCorp and Pacific CapitalB ancorp, Treasury had a contractual right to assign an observer to the board of directors. For the remainder, Treasury obtained consent from the institution to assign an observer to the board of directors. 2 Includes unpaid cumulative dividends, non-cumulative dividends, and Subchapter S interest payments but does not include interest accrued on unpaid cumulative dividends. 3 Excludes institutions that missed payments but (i) have fully caught-up or exchanged new securities for missed payments, or (ii) have repaid their investment amounts and exited the Capital Purchase Program. 4 Includes institutions that missed payments and (i) completed an exchange with Treasury for new securities, (ii) purchased their CPP investment from Treasury, or saw a third party purchase its CPP investment from Treasury, or (iii) are in, or have completed bankruptcy proceedings or its subsidiary bank failed. 5 For Midwest Banc Holdings, Inc., the number of missed payments is the number last reported from SIGTARP Quarterly Report to Congress 4/20/2010, prior to bankruptcy filing; missed payment amounts are from Treasury’s response to SIGTARP data call, 10/13/2010. 6 Treasury reported four missed payments by Community Bank of the Bay before it was allowed to transfer from CPP to CDCI. Upon transfer, Treasury reset the number of missed payments to zero. 7 For South Financial Group, Inc. and TIB Financial Corp, the number of missed payments and unpaid amounts reflect figures Treasury reported prior to the sale. 8 For CIT Group Inc., the number of missed payments is from the number last reported from SIGTARP Quarterly Report to Congress 1/30/2010, shortly after the bankruptcy filing; missed payment amounts are from Treasury’s response to SIGTARP data call, 10/13/2010. 9 Completed exchanges: - The exchange between Treasury and Hampton Roads, and the exchange between Treasury and Sterling Financial did not account for unpaid dividends. The number of missed payments and unpaid amounts reflect the figures Treasury reported prior to the exchange. - The exchange between Treasury and Central Pacific Financial Corp., and the exchange between Treasury and Pacific Capital Bancorp did account for unpaid dividends, thereby eliminating any unpaid amounts. The number of missed payments reflects the amount Treasury reported prior to the exchange.

Sources: Treasury, Dividends and Interest Report, 7/11/2012; Treasury, responses to SIGTARP data call, 1/7/2011, 4/6/2011, 7/8/2011, 10/11/2011, 1/10/2012, 4/5/2012, and 7/10/2012; SIGTARP Quarterly Report to Congress, 1/30/2010, 4/20/2010, 4/28/2011, 7/28/2011, 10/27/2011, 1/25/2012, 4/25/2012, and 7/25/2012. 104 special inspector general I troubled asset relief program

Warrant Disposition As required by EESA, Treasury received warrants when it invested in troubled For more information on warrant assets from financial institutions, with an exception for certain small institutions. disposition, see SIGTARP’s audit With respect to financial institutions with publicly traded securities, these warrants report of May 10, 2010, “Assessing Treasury’s Process to Sell Warrants gave Treasury the right, but not the obligation, to purchase a certain number of Received from TARP Recipients.” shares of common stock at a predetermined price.318 Because the warrants rise in value as a company’s share price rises, they permit Treasury (and the taxpayer) to benefit from a firm’s potential recovery.319 For publicly traded institutions, the warrants received by Treasury under CPP Exercise Price: Preset price at which allowed Treasury to purchase additional shares of common stock in a number a warrant holder may purchase each equal to 15% of the value of the original CPP investment at a specified exercise share. For warrants in publicly traded price.320 Treasury’s warrants constitute assets with a fair market value that Treasury institutions issued through CPP, this estimates using relevant market quotes, financial models, and/or third-party valua- was based on the average stock price tions.321 As of June 30, 2012, Treasury had not exercised any of these warrants.322 during the 20 days before the date For privately held institutions, Treasury received warrants to purchase additional that Treasury granted preliminary CPP preferred stock or debt in an amount equal to 5% of the CPP investment. Treasury participation approval. exercised these warrants immediately.323 Unsold and unexercised warrants expire 10 years from the date of the CPP investment.324

Repurchase of Warrants by Financial Institutions Upon repaying its CPP investment, a recipient may seek to negotiate with Treasury to buy back its warrants. As of June 30, 2012, 108 publicly traded institutions had bought back $3.8 billion worth of warrants, of which $51.1 million was purchased this quarter. As of that same date, 106 privately held institutions, the warrants of which had been immediately exercised, bought back the resulting additional preferred shares for a total of $45.1 million, of which $1.3 million was bought back this quarter.325 Table 2.24 lists publicly traded institutions that repaid TARP and repurchased warrants in the quarter ended June 30, 2012. Table 2.25 lists privately held institutions that had done so in the same quarter.326 quarterly report to congress I July 25, 2012 105

Table 2.24 CPP WARRANT SALES AND REPURCHASES (PUBLIC) FOR THE QUARTER ENDING 6/30/2012 Number of Amount of Warrants Repurchase Repurchase Date Company Repurchased ($Thousands) 5/2/2012 Regions Financial Corporation 48,253,677 $45,000.0 5/2/2012 Park National Corporation 227,376 2,842.4 5/2/2012 MB Financial, Inc. 506,024 1,518.1 4/19/2012 The Connecticut Bank and Trust Companya 175,742 792.8 6/20/2012 Wilshire Bancorp, Inc. 949,460 760.0 4/4/2012 Peapack-Gladstone Financial Corporation 150,296 110.0 5/30/2012 Seacoast Banking Corporation of Florida 589,623 55.0 Total 50,852,198 $51,078.3

Notes: Numbers may not total due to rounding. This table represents warrants for common stock issued to Treasury by publicly traded TARP recipients. Treasury may hold one warrant for millions of underlying shares rather than millions of warrants of an individual financial institution. a Warrant sales to third parties.

Sources: Treasury, Transactions Report, 6/27/2012; Treasury, responses to SIGTARP data call, 1/4/2011, 1/7/2011, 4/6/2011, 7/8/2011, 10/7/2011, 10/11/2011, 1/11/2012, 4/5/2012, and 7/9/2012.

Table 2.25 CPP WARRANT SALES AND REPURCHASES (PRIVATE) FOR THE QUARTER ENDING 6/30/2012 Number of Amount of Warrants Repurchase Repurchase Date Company Repurchased ($Thousands) 4/24/2012 Peoples Bancorporation, Inc. 633,000 $633.0 6/27/2012 Beach Business Bank 300,000 300.0 4/13/2012 Gateway Bancshares, Inc. 300,000 300.0 4/4/2012 Titonka Bancshares, Inc. 106,000 106.0 Total 1,339,000 $1,339.0

Notes: Numbers may not total due to rounding. This table represents the preferred shares held by Treasury as a result of the exercise of warrants issued by non-publicly traded TARP recipients. These warrants were exercised immediately upon the transaction date. Treasury may hold one warrant for millions of underlying shares rather than millions of warrants of an individual financial institution.

Sources: Treasury, Transactions Report, 6/27/2012; Treasury, response to SIGTARP data call, 7/9/2012. 106 special inspector general I troubled asset relief program

Treasury Warrant Auctions Dutch Auction: A type of auction in If Treasury and the repaying QFI cannot agree upon the price for the institution which multiple bidders bid for different to repurchase its warrants, Treasury may conduct a public or private offering quantities of the asset; the price the to auction the warrants.327 As of June 30, 2012, the combined proceeds from seller accepts is set at the lowest bid Treasury’s public and private warrant auctions totaled $5.4 billion.328 of the group of high bidders whose collective bids fulfill the amount of Public Warrant Auctions shares offered. As an example, three In November 2009, Treasury began using a modified Dutch auction to sell the investors place bids to own a portion warrants publicly.329 On the announced auction date, potential investors (which of 100 shares offered by the issuer: may include the CPP recipient) submit bids to the auction agent that manages the sale (for CPP-related warrants, Deutsche Bank) at specified increments above • Bidder A wants 50 shares at $4/ a minimum price set by Treasury.330 Once the auction agent receives all bids, it share. determines the final price and distributes the warrants to the winning bidders.331 • Bidder B wants 50 shares at $3/ Treasury did not conduct any public warrant auctions this quarter.332 Through share. June 30, 2012, Treasury had held 24 public auctions for warrants it received under • Bidder C wants 50 shares at $2/ CPP, TIP, and AGP, raising a total of approximately $5.4 billion.333 Final closing share. information for all public auctions is shown in Table 2.26.

The seller selects Bidders A and B as the two highest bidders, and their collective bids consume the 100 shares offered. The winning price is $3, which is what both bidders pay per share. Bidder C’s bid is not filled. Treasury uses a modified version of a Dutch Auction in the dispensation of its warrants and in some sales of preferred stock.

Auction Agent: Firm (such as an investment bank) that buys a series of securities from an institution for resale. quarterly report to congress I July 25, 2012 107

TABLE 2.26 PUBLIC TREASURY WARRANT AUCTIONS, AS OF 6/30/2012 Number of Minimum Selling Proceeds to Treasury Auction Date Company Warrants Offered Bid Price Price ($ Millions) Bank of America A Auction (TIP)a 150,375,940 $7.00 $8.35 $1,255.6 3/3/2010 Bank of America B Auction (CPP)a 121,792,790 1.50 2.55 310.6 12/10/2009 JPMorgan Chase 88,401,697 8.00 10.75 950.3 5/20/2010 Wells Fargo and Company 110,261,688 6.50 7.70 849.0 9/21/2010 Hartford Financial Service Group, Inc. 52,093,973 10.50 13.70 713.7 4/29/2010 PNC Financial Services Group, Inc. 16,885,192 15.00 19.20 324.2 Citigroup A Auction (TIP & AGP)a 255,033,142 0.60 1.01 257.6 1/25/2011 Citigroup B Auction (CPP)a 210,084,034 0.15 0.26 54.6 9/16/2010 Lincoln National Corporation 13,049,451 13.50 16.60 216.6 5/6/2010 Comerica Inc. 11,479,592 15.00 16.00 183.7 12/3/2009 Capital One 12,657,960 7.50 11.75 148.7 2/8/2011 Wintrust Financial Corporation 1,643,295 13.50 15.80 26.0 6/2/2011 Webster Financial Corporation 3,282,276 5.50 6.30 20.4 SunTrust A Auctionb 6,008,902 2.00 2.70 16.2 9/22/2011 SunTrust B Auctionb 11,891,280 1.05 1.20 14.2 3/9/2010 Washington Federal, Inc. 1,707,456 5.00 5.00 15.6 3/10/2010 Signature Bank 595,829 16.00 19.00 11.3 12/15/2009 TCF Financial 3,199,988 1.50 3.00 9.6 3/11/2010 Texas Capital Bancshares, Inc. 758,086 6.50 6.50 6.7 2/1/2011 Boston Private Financial Holdings, Inc. 2,887,500 1.40 2.20 6.4 5/18/2010 Valley National Bancorp 2,532,542 1.70 2.20 5.6 11/30/2011 Associated Banc-Corpc 3,983,308 0.50 0.90 3.6 6/2/2010 First Financial Bancorp 465,117 4.00 6.70 3.1 6/9/2010 Sterling Bancshares Inc. 2,615,557 0.85 1.15 3.0 Total 1,083,686,595 $5,406.3

Notes: Numbers may not total due to rounding. a Treasury held two auctions each for the sale of Bank of America and Citigroup warrants. b Treasury held two auctions for SunTrust’s two CPP investments dated 11/14/2008 (B auction) and 12/31/2008 (A auction). c According to Treasury, the auction grossed $3.6 million and netted $3.4 million.

Sources: The PNC Financial Services Group, Inc., “Final Prospectus Supplement,” 4/29/2010, www.sec.gov/Archives/edgar/data/713676/000119312510101032/d424b5.htm, accessed 6/28/2012; Valley National Bancorp, “Final Prospectus Supplement,” 5/18/2010, www.sec.gov/Archives/edgar/data/714310/000119312510123896/d424b5.htm, accessed 6/28/2012; Comerica Incorporated, “Final Prospectus Supplement,” 5/6/2010, www.sec.gov/Archives/edgar/data/28412/000119312510112107/d424b5.htm, accessed 6/28/2012; Wells Fargo and Company, “Definitive Prospectus Supplement,” 5/20/2010, www.sec.gov/Archives/edgar/data/72971/000119312510126208/d424b5.htm, accessed 6/28/2012; First Financial Bancorp, “Prospectus Supplement,” 6/2/2010, www.sec.gov/Archives/edgar/data/708955/000114420410031630/v187278_424b5.htm, accessed 6/28/2012; Sterling Bancshares, Inc., “Prospectus Supplement,” 6/9/2010, www.sec.gov/Archives/edgar/data/891098/000119312510136584/dfwp.htm, accessed 6/28/2012; Signature Bank, “Prospectus Supplement,” 3/10/2010, files.shareholder.com/downloads/ SBNY/1456015611x0x358381/E87182B5-A552-43DD-9499-8B56F79AEFD0/8-K__Reg_FD_Offering_Circular.pdf, accessed 6/28/2012; Texas Capital Bancshares, Inc., “Prospectus Supplement,” 3/11/2010, www.sec.gov/Archives/edgar/data/1077428/000095012310023800/d71405ae424b5.htm, accessed 6/28/2012; Bank of America, “Form 8-K,” 3/3/2010, www.sec.gov/Archives/edgar/ data/70858/000119312510051260/d8k.htm, accessed 6/28/2012; Bank of America, “Prospectus Supplement,” 3/1/2010, www.sec.gov/Archives/edgar/data/70858/000119312510045775/ d424b2.htm, accessed 6/28/2012; Washington Federal, Inc., “Prospectus Supplement,” 3/9/2010, www.sec.gov/Archives/edgar/data/936528/000119312510052062/d424b5.htm, accessed 6/28/2012; TCF Financial, “Prospectus Supplement,” 12/16/2009, www.sec.gov/Archives/edgar/data/814184/000104746909010786/a2195869z424b5.htm, accessed 6/28/2012; JPMorgan Chase, “Prospectus Supplement,” 12/11/2009, www.sec.gov/Archives/edgar/data/19617/000119312509251466/d424b5.htm, accessed 6/28/2012; Capital One Financial, “Prospectus Supplement,” 12/3/2009, www.sec.gov/Archives/edgar/data/927628/000119312509247252/d424b5.htm, accessed 6/28/2012; Treasury, Transactions Report, 7/2/2012; Hartford Financial Services Group, Prospectus Supplement to Prospectus filed with the SEC 8/4/2010, www.sec.gov/Archives/edgar/data/874766/000095012310087985/y86606b5e424b5.htm, accessed 6/28/2012; Hartford Financial Agreement, 8/21/2010, www.sec.gov/Archives/edgar/data/874766/000095012310087985/y86606b5e424b5.htm, accessed 6/28/2012; Treasury, “Treasury Announces Pricing of Public Offering to Purchase Common Stock of The Hartford Financial Services Group, Inc.,” 9/22/2010, www.treasury.gov/press-center/press-releases/Pages/tg865.aspx, accessed 6/28/2012; Lincoln National Corporation, Prospectus Supplement to Prospectus filed with SEC 3/10/2009, www.sec.gov/Archives/edgar/data/59558/000119312510211941/d424b5.htm, accessed 6/28/2012; Lincoln National Corporation, 8-K, 9/22/2010, www.sec.gov/Archives/edgar/data/59558/000119312510214540/d8k.htm, accessed 6/28/2012; Treasury, Section 105(a) Report, 1/31/2011; Treasury, “Treasury Announces Public Offerings of Warrants to Purchase Common Stock of Citigroup Inc.,” 1/24/2011, www.treasury.gov/press-center/press-releases/Pages/tg1033.aspx, accessed 6/28/2012; Citigroup, Prospectus, 1/24/2011, www.sec.gov/Archives/edgar/data/831001/000095012311004665/y89177b7e424b7.htm, accessed 6/28/2012; Citigroup, Prospectus, 1/24/2011, www.sec. gov/Archives/edgar/data/831001/000095012311004665/y89177b7e424b7.htm, accessed 6/28/2012; Boston Private Financial Holdings, Inc., Prospectus, 1/28/2011, www.sec.gov/Archives/edgar/ data/821127/000119312511021392/d424b5.htm, accessed 6/28/2012; Boston Private Financial Holdings, Inc. 8-K, 2/7/2011, www.sec.gov/Archives/edgar/data/821127/000144530511000189/ tarpwarrant020711.htm, accessed 6/28/2012; Wintrust Financial Corporation, Prospectus, 2/8/2011, www.sec.gov/Archives/edgar/data/1015328/000095012311011007/c62806b5e424b5.htm, accessed 6/28/2012; Wintrust Financial Corporation, 8-K, 2/8/2011, www.sec.gov/Archives/edgar/data/1015328/000095012311013436/c62955e8vk.htm, accessed 6/28/2012; Treasury, Section 105(a) Report, 1/31/2011; Treasury, “Treasury Announces Public Offerings of Warrants to Purchase Common Stock of Citigroup Inc.,” 1/24/2011, www.treasury.gov/press-center/press-releases/Pages/ tg1033.aspx, accessed 6/28/2012; Treasury, Citigroup Preliminary Prospectus – CPP Warrants, 1/24/2011, www.sec.gov/Archives/edgar/data/831001/000095012311004666/y89178b7e424b7. htm, accessed 6/28/2012; Citigroup, Preliminary Prospectus – TIP & AGP Warrants, 1/24/2011, www.sec.gov/Archives/edgar/data/831001/000095012311004665/y89177b7e424b7.htm, accessed 6/28/2012; Treasury, responses to SIGTARP data call, 4/6/2011, 7/14/2011, 10/5/2011, 10/11/2011, and 1/11/2012; Treasury Press Release, “Treasury Department Announces Public Offerings of Warrants to Purchase Common Stock of Suntrust Banks, Inc.,” 9/21/2011, www.treasury.gov/press-center/press-releases/Pages/tg1300.aspx, accessed 6/28/2012; “Treasury Department Announces Public Offering of Warrants to Purchase Common Stock of Associated Banc-Corp,” 11/29/2011, www.treasury.gov/press-center/press-releases/Pages/tg1372.aspx, accessed 6/28/2012. 108 special inspector general I troubled asset relief program

Private Warrant Auctions Qualified Institutional Buyers (“QIB”): In late 2011, Treasury devised a new method for selling warrants. On November Institutions that under U.S. securities 17, 2011, Treasury conducted its first private auction to sell warrants of CPP law are permitted to buy securities participants. In the auction, Treasury sold its warrant positions in a group of 17 that are exempt from registration financial institutions listed in Table 2.27 for $12.7 million.334 Treasury stated that under investor protection laws and a private auction was necessary because the warrants did not meet the listing to resell those securities to other requirements for the major exchanges, it would be more cost-effective for these QIBs. Generally these institutions own smaller institutions, and that grouping the warrants of the 17 institutions in a and invest at least $100 million in single auction would raise investor interest in the warrants.335 The private auction securities, or are registered broker- was a discrete, or winner-takes-all, auction. The warrants were not registered under dealers that own or invest at least $10 the Securities Act of 1933 (the “Act”). As a result, Treasury stated that the warrants million in securities. were offered only in private transactions to “(1) ‘qualified institutional buyers’ as defined in Rule 144A under the Act, (2) the issuer, and (3) a limited number of Accredited Investors: Individuals or ‘accredited investors’ affiliated with the issuer.”336 Treasury did not conduct any institutions that by law are considered private warrant auctions this quarter. financially sophisticated enough so Table 2.27 that they can invest in ventures that are exempt from investor protection PRIVATE TREASURY WARRANT AUCTIONS ON 11/17/2011 laws. Under U.S. securities laws, these Number of Proceeds to Company Warrants Offered Treasury include many financial companies, pension plans, wealthy individuals, Eagle Bancorp, Inc. 385,434 $2,794,422 and top executives or directors of the Horizon Bancorp 212,188 1,750,551 issuing companies. Bank of Marin Bancorp 154,908 1,703,984 First Bancorp (of North Carolina) 616,308 924,462 Westamerica Bancorporation 246,698 878,256 Lakeland Financial Corp 198,269 877,557 F.N.B. Corporation 651,042 690,100 Encore Bancshares 364,026 637,071 LCNB Corporation 217,063 602,557 Western Alliance Bancorporation 787,107 415,000 First Merchants Corporation 991,453 367,500 1st Constitution Bancorp 231,782 326,576 Middleburg Financial Corporation 104,101 301,001 MidSouth Bancorp, Inc. 104,384 206,557 CoBiz Financial Inc. 895,968 143,677 First Busey Corporation 573,833 63,677 First Community Bancshares, Inc. 88,273 30,600 Total 6,822,837 $12,713,548

Source: “Treasury Announces Completion of Private Auction to Sell Warrant Positions,” 11/18/2011, www.treasury.gov/press- center/press-releases/Pages/tg1365.aspx, accessed 6/28/2012. quarterly report to congress I July 25, 2012 109

Restructurings, Recapitalizations, Exchanges, and Sales of CPP Investments Certain CPP institutions continue to experience high losses and financial difficulties, resulting in inadequate capital or liquidity. To avoid insolvency or improve the quality of their capital, these institutions may ask Treasury to convert its CPP preferred shares into a more junior form of equity or accept a lower valuation, resulting in Treasury taking a discount or loss. If a CPP institution is undercapitalized and/or in danger of becoming insolvent, it may propose to Undercapitalized: Condition in which a Treasury a restructuring (or recapitalization) plan to avoid failure (or to attract financial institution does not meet its private capital) and to “attempt to preserve value” for Treasury’s investment.337 regulator’s requirements for sufficient Treasury may also sell its investment in a troubled institution to a third party at capital to operate under a defined level a discount in order to facilitate that party’s acquisition of a troubled institution. of adverse conditions. Treasury has explained to SIGTARP that although it may incur partial losses on its investment in the course of these transactions, such an outcome may be deemed Due Diligence: Appropriate level of necessary to avoid the total loss of Treasury’s investment that would occur if the attention or care a reasonable person institution failed.338 should take before entering into an Under these circumstances, the CPP participant asks Treasury for a formal agreement or a transaction with review of its proposal. The proposal details the institution’s recapitalization plan another party. In finance, it often refers and may estimate how much capital the institution plans to raise from private to the process of conducting an audit investors and whether Treasury and other preferred shareholders will convert or review of the institution before their preferred stock to common stock. The proposal may also involve a proposed initiating a transaction. discount on the conversion to common stock, although Treasury would not realize any loss until it disposes of the stock.339 In other words, Treasury would not know whether a loss will occur, or the extent of such a loss, until it sells the common stock it receives as part of such an exchange. According to Treasury, when it receives such a request, it asks one of the external asset managers that it has hired to analyze the proposal and perform due diligence on the institution.340 The external asset manager interviews the institution’s managers, gathers non-public information, and conducts loan-loss estimates and capital structure analysis. The manager submits its evaluation to Treasury, which then decides whether to restruc- ture its CPP investment.341 Table 2.28 shows all realized losses and write-offs recorded by Treasury on CPP investments through June 30, 2012. Table 2.29 shows all restructurings, recapital- izations, exchanges, and sales of CPP investments through June 30, 2012. 110 special inspector general I troubled asset relief program

TABLE 2.28

Realized Losses and Write-Offs in CPP, as of 6/30/2012 ($ MILLIONS) TARP Realized Loss Institution Investment or Write-Off Date Description Realized Losses Sale of subordinated FBHC Holding Company $3 $2 3/9/2010 debentures at a loss First Federal Bancshares of 17 11 5/3/2010 Sale of preferred stock at a loss Arkansas, Inc. The Bank of Currituck 4 2 12/3/2010 Sale of preferred stock at a loss Treaty Oak Bancorp, Inc. 3 3 2/15/2011 Sale of preferred stock at a loss Exchange of preferred stock at Central Pacific Financial Corp. 135 32 2/18/2011 a loss Cadence Financial Corporation 44 6 3/4/2011 Sale of preferred stock at a loss First Community Bank Corporation 11 3 5/31/2011 Sale of preferred stock at a loss of America Cascade Financial Corporation 39 23 6/30/2011 Sale of preferred stock at a loss Green Bankshares, Inc. 72 4 9/7/2011 Sale of preferred stock at a loss Santa Lucia Bancorp 4 1 10/21/2011 Sale of preferred stock at a loss MainSource Financial Group, Inc. 57 4 4/3/2012 Sale of preferred stock at a loss Seacoast Banking Corporation of 50 9 4/3/2012 Sale of preferred stock at a loss Florida Wilshire Bancorp, Inc. 62 4 4/3/2012 Sale of preferred stock at a loss Banner Corporation/Banner Bank 124 14 4/3/2012 Sale of preferred stock at a loss First Financial Holdings Inc. 65 8 4/3/2012 Sale of preferred stock at a loss WSFS Financial Corporation 53 4 4/3/2012 Sale of preferred stock at a loss Central Pacific Financial Corp. 135 30 4/4/2012 Sale of common stock at a loss Ameris Bancorp 52 4 6/19/2012 Sale of preferred stock at a loss United Bancorp, Inc. 21 4 6/19/2012 Sale of preferred stock at a loss First Capital Bancorp, Inc. 11 1 6/19/2012 Sale of preferred stock at a loss First Defiance Financial Corp. 37 1 6/19/2012 Sale of preferred stock at a loss LNB Bancorp, Inc. 25 3 6/19/2012 Sale of preferred stock at a loss Farmers Capital Corporation 30 8 6/19/2012 Sale of preferred stock at a loss Taylor Capital Group, Inc. 105 11 6/19/2012 Sale of preferred stock at a loss Total CPP Realized Losses $192 Write-Offs CIT Group Inc. $2,330 $2,330 12/10/2009 Bankruptcy Pacific Coast National Bancorp 4 4 2/11/2010 Bankruptcy South Financial Group, Inc.1 347 217 9/30/2010 Sale of preferred stock at a loss TIB Financial Corp1 37 25 9/30/2010 Sale of preferred stock at a loss

Total CPP Write-Offs $2,576 Total of CPP Realized Losses and Write-offs $2,768 Notes: Numbers may not total due to rounding. Losses from the second lien auction have not been realized. 1 In the time since these transactions were classified as write-offs, Treasury has changed its practices and now classifies sales of preferred stock at a loss as realized losses.

Sources: Treasury, Transactions Report, 6/27/2012; Treasury, response to SIGTARP data call, 7/5/2012. quarterly report to congress I July 25, 2012 111

Recent Exchanges and Sales Millennium Bancorp, Inc. On April 3, 2009, Treasury invested $7.3 million in Millennium Bancorp, Inc., Edwards, Colorado (“Millennium”) through CPP in return for preferred stock and warrants.342 On April 20, 2012, Treasury entered into an agreement with CIC Bancshares, Inc. (“CIC”) to sell to CIC all of Treasury’s preferred stock investment in Millennium for $2.9 million.343 The closing of the sale is subject to certain conditions, including completion of the acquisition and merger of Millennium by CIC. If the sale is finalized, it will result in a loss of $4.4 million.344

Treasury Sold Its TARP Investments in 14 Banks at a Loss at Auction In two auctions this quarter, Treasury sold its TARP preferred stock investment in 14 banks. The first auction was held from June 11 through June 13, 2012, for seven banks.345 Treasury initially invested $280.6 million in the seven banks, but netted only $245 million in the auction, resulting in a $35.6 million loss. On November 21, 2008, Treasury invested $104.8 million in Taylor Capital Group, Rosemont, Illinois (“Taylor Capital”); its shares netted $92 million at auction. On November 21, 2008, Treasury invested $52 million in Ameris Bancorp, Moultrie, Georgia (“Ameris”); its shares netted $48 million at auction. On December 5, 2008, Treasury invested $37 million in First Defiance Financial Corp., Defiance, Ohio (“First Defiance”); its shares netted $35 million at auction. First Defiance repurchased 44.8% of its shares that were offered at auction at a discounted price.346 On January 9, 2009, Treasury invested $30 million in Farmers Capital Bank Corporation, Frankfort, Kentucky (“Farmers Capital”); its shares netted $22 million at auction. On December 12, 2008, Treasury invested $25.2 million in LNB Bancorp Inc., Lorain, Ohio (“LNB”); its shares netted $22 million at auction. On April 3, 2009, Treasury invested $11 million in First Capital Bancorp, Inc., Glen Ellen, Virginia (“First Capital Bancorp”); its shares netted $10 million at auction. First Capital repurchased 50% of its shares that were offered at auction at a discounted price.347 On January 16, 2009, Treasury invested $20.6 million in United Bancorp, Inc., Tecumseh, Michigan (“United Bancorp”); its shares netted $17 million at auction.348 The second auction was held from June 25 through June 27, 2012, for seven banks. Treasury initially invested $224.3 million in the seven banks, but only netted $204 million in the auction, resulting in a $20.3 million loss.349 On December 19, 2008, Treasury invested $48.2 million in Fidelity Southern Corporation, Atlanta, Georgia (“Fidelity Southern”); its shares netted $43 million at auction. On January 30, 2009, Treasury invested $33 million in Firstbank Corporation, Alma, Michigan (“Firstbank”); its shares netted $31 million at auction. Firstbank repurchased 48.5% of its shares that were offered at auction at a discounted price.350 On January 23, 2009, Treasury invested $23.2 million in First Citizens Banc Corp, Sandusky, Ohio (“First Citizens Banc”); its shares netted $21 million at auction. On January 16, 2009, Treasury invested $45 million in MetroCorp Bancshares, Inc., Houston, Texas (“MetroCorp”); its shares netted $43 million at auction. MetroCorp repur- chased 97.2% of its shares that were offered at auction at a discounted price.351 On 112 special inspector general I troubled asset relief program

December 23, 2008, Treasury invested $25.1 million in Peoples Bancorp of North Carolina, Inc., Newton, North Carolina (“Peoples Bancorp of NC”); its shares netted $23 million at auction. Peoples Bancorp of NC repurchased 53.5% of its shares that were offered at auction at a discounted price.352 On January 16, 2009, Treasury invested $32.5 million in Pulaski Financial Corp, Creve Coeur, Missouri (“Pulaski”); its shares netted $28 million at auction. On February 27, 2009, Treasury invested $17.3 million in Southern First Bancshares, Inc., Greenville, South Carolina (“Southern First”); its shares netted $15 million at auction.353 Southern First repurchased 5.8% of its shares that were offered at auction at a discounted price.354 quarterly report to congress I July 25, 2012 113

TABLE 2.29

TREASURY RESTRUCTURINGS, RECAPITALIZATIONS, EXCHANGES, & SALES, AS OF 6/30/2012 ($ MILLIONS) Investment Original Combined Company Date Investments Investments Investment Status Citigroup Inc. 10/28/2008 $2,500.0 Exchanged for common stock/warrants and sold Provident Bankshares 11/14/2008 151.5 Provident preferred stock exchanged for new M&T Bank M&T Bank Corporation 12/23/2008 600.0 1,081.5a Corporation preferred stock; Wilmington Trust preferred stock redeemed by M&T Bank Corporation Wilmington Trust Corporation 12/12/2008 330.0 Popular, Inc. 12/5/2008 935.0 Exchanged for trust preferred securities First BanCorp 1/6/2009 400.0 Exchanged for mandatorily convertible preferred stock South Financial Group, Inc. 12/5/2008 347.0 Sold Sterling Financial Corporation 12/5/2008 303.0 Exchanged for common stock Whitney Holding Corporation 6/3/2011 300.0 Sold Pacific Capital Bancorp 11/21/2008 180.6 Exchanged for common stock Wilmington Trust Corporation 5/13/2011 151.5 Sold Central Pacific Financial Corp. 1/9/2009 135.0 Exchanged for common stock Banner Corporation 11/21/2008 124.0 Sold at loss in auction

BBCN Bancorp, Inc. 11/21/2008 67.0 Exchanged for a like amount of securities of 122.0d Center Financial Corporation 12/12/2008 55.0 BBCN Bancorp, Inc. First Merchants 2/20/2009 116.0 Exchanged for trust preferred securities and preferred stock Taylor Capital Group 11/21/2008 104.8 Sold at loss in auction

Metropolitan Bank Group Inc. 6/26/2009 71.5 Exchanged for new preferred stock in 81.9b NC Bank Group, Inc. 6/26/2009 6.9 Metropolitan Bank Group, Inc. Hampton Roads Bankshares 12/31/2008 80.3 Exchanged for common stock Green Bankshares 12/23/2008 72.3 Sold Independent Bank Corporation 12/12/2008 72.0 Exchanged for mandatorily convertible preferred stock Superior Bancorp, Inc.c 12/5/2008 69.0 Exchanged for trust preferred securities First Financial Holdings Inc. 12/5/2008 65.0 Sold at loss in auction Wilshire Bancorp, Inc. 12/12/2008 62.2 Sold at loss in auction MainSource Financial Group, Inc. 1/16/2009 57.0 Sold at loss in auction WSFS Financial Corporation 1/23/2009 52.6 Sold at loss in auction Ameris Bancorp 11/21/2008 52.0 Sold at loss in auction Seacoast Banking Corporation of 12/19/2008 50.0 Sold at loss in auction Florida Fidelity Southern Corporation 12/19/2008 48.2 Sold at loss in auction MetroCorp Bancshares, Inc. 1/16/2009 45.0 Sold at loss in auction Cadence Financial Corporation 1/9/2009 44.0 Sold at loss in auction Capital Bank Corporation 12/12/2008 41.3 Sold Cascade Financial Corporation 6/30/2011 39.0 Sold at loss in auction TIB Financial Corp. 12/5/2008 37.0 Sold Continued on next page 114 special inspector general I troubled asset relief program

TREASURY RESTRUCTURINGS, RECAPITALIZATIONS, EXCHANGES, & SALES, AS OF 6/30/2012 ($ MILLIONS) (Continued) Investment Original Combined Company Date Investments Investments Investment Status First Defiance Financial Corp. 12/5/2008 $37.0 Sold at loss in auction Firstbank Corporation 1/30/2009 33.0 Sold at loss in auction Pulaski Financial Corp 1/16/2009 32.5 Sold at loss in auction Farmers Capital Bank Corporation 1/9/2009 30.0 Sold at loss in auction LNB Bancorp Inc. 12/12/2008 25.2 Sold at loss in auction Peoples Bancorp of North Carolina, 12/23/2008 25.1 Sold at loss in auction Inc. First Citizens Banc Corp 1/23/2009 23.2 Sold at loss in auction United Bancorp, Inc. 1/16/2009 20.6 Sold at loss in auction Southern First Bancshares, Inc. 2/27/2009 17.3 Sold at loss in auction First Federal Bankshares of 5/3/2011 16.5 Sold Arkansas, Inc. Broadway Financial Corporation 11/14/2008 15.0 Exchanged for common stock First Capital Bancorp, Inc. 4/3/2009 11.0 Sold at loss in auction First Community Bank Corporation 12/23/2008 10.7 Sold of America Bank of Currituck 2/6/2009 4.0 Sold Santa Lucia Bancorp 12/19/2008 4.0 Sold Treaty Oak Bancorp, Inc. 1/16/2009 3.3 Sold FBHC Holding Company 12/29/2009 3.0 Sold Fidelity Resources Company 6/26/2009 3.0 Exchanged for preferred stock in Veritex Holding Berkshire Bancorp 6/12/2009 2.9 Exchanged for preferred stock in Customers Bancorp Notes: Numbers may be affected by rounding. a M&T Bank Corporation (“M&T”) has redeemed the entirety of the preferred shares issued by Wilmington Trust Corporation plus accrued dividends. In addition, M&T has also repaid $370 million of Treasury’s original $600 million investment. As of June 30, 2012, Treasury’s remaining principal investment in M&T is $381.5 million. b The new investment amount of $81.9 million includes the original investment amount in Metropolitan Bank Group, Inc. or $71.5 million plus the original investment amount in NC Bank Group, Inc. or $6.9 million plus unpaid dividends of $3.5 million. c The subsidiary bank of Superior Bancorp, Inc. failed on April 15, 2011. All of Treasury’s TARP investment in Superior Bancorp is expected to be lost. d The new investment amount of $122 million includes the original investment amount in BBCN Bancorp, Inc. (formerly Nara Bancorp, Inc.) of $67 million and the original investment of Center Financial Corporation of $55 million.

Sources: Treasury, Transactions Report, 6/27/2012; Treasury responses to SIGTARP data call, 10/11/2011, 4/5/2012, 7/5/2012; SIGTARP, October Quarterly Report, 10/26/2010; Treasury, Section 105(a) Report, 9/30/2010; Treasury Press Release, “Taxpayers Receive $10.5 Billion in Proceeds Today from Final Sale of Treasury Department Citigroup Common Stock,” 12/10/2010; Treasury Press Release, “Treasury Announces Pricing of Citigroup Common Stock Offering,” 12/7/2010; Treasury, Section 105(a) Report, 7/10/2012; Treasury Press Release, “Treasury Announces Intent to Sell Warrant Positions in Public Dutch Auctions,” 1/14/2011; Broadway Financial Corporation, 8-K, 2/17/2011, www.sec.gov/Archives/edgar/data/1001171/000119312511039152/ d8k.htm, accessed 6/28/2012; FDIC and Texas Department of Banking, In the Matter of Treaty Oak Bank, Consent Order, 2/5/2010, www.fdic.gov/bank/individual/enforcement/2010-02-34.pdf, accessed 6/28/2012; Fort Worth Business Press, “Shareholders Approve Sale of Treaty Bank to Fort Worth Investors,” www.timesleader.com/FwBp/news/breaking/Shareholders-approve-sale-of- Treaty-Oak-bank-to-Fort-Worth-investors.html, accessed 6/28/2012; Central Pacific Financial Corp., 8-K, 11/4/2010, www.sec.gov/Archives/edgar/data/701347/000070134710000055/form8-k. htm, accessed 6/28/2012; Central Pacific Financial Corp., 8-K, 2/17/2011, www.sec.gov/Archives/edgar/data/701347/000110465911008879/a11-6350_18k.htm, accessed 6/28/2012; Central Pacific Financial Corp., 8-K, 2/22/2011, www.sec.gov/Archives/edgar/data/701347/000110465911008879/a11-6350_18k.htm, accessed 7/5/2012; Scottrade, Central Pacific Financial Corp., 2/18/2011, research.scottrade.com/qnr/Public/Stocks/Snapshot?symbol=cpf, accessed 6/28/2012; Cadence Financial Corporation, 8-K, 3/4/2011, www.sec.gov/Archives/ edgar/data/742054/000089882211000148/kbody.htm, accessed 6/28/2012; M&T Bank Corporation, 10-K, 2/19/2010, www.sec.gov/Archives/edgar/data/36270/000095012310014582/ l38289e10vk.htm, accessed 6/28/2012; Green Bankshares Inc., 9/8/2011, www.sec.gov/Archives/edgar/data/764402/000089882211000784/grnb-nafhmerger8k.htm, accessed 6/28/2012; Customers Bancorp, Inc., 8-K, 9/22/2011, www.sec.gov/Archives/edgar/data/1488813/000095015911000609/form8k.htm, accessed 6/28/2012; Santa Lucia Bancorp, 8-K, 10/6/2011, www.sec.gov/Archives/edgar/data/1355607/000114420411057585/v237144_8k.htm, accessed 6/28/2012; BBCN Bancorp, Inc., 8-K, 11/30/2011, www.sec.gov/Archives/edgar/ data/1128361/000119312511330628/d265748d8k.htm, accessed 6/28/2012. quarterly report to congress I July 25, 2012 115

CPP Recipients: Bankrupt or with Failed Subsidiary Banks Despite Treasury’s stated goal of limiting CPP investments to “healthy, viable institutions,” a number of CPP participants went bankrupt or had a subsidiary bank fail, as indicated in Table 2.30.355

TABLE 2.30

CPP RECIPIENTS: BANKRUPT OR WITH FAILED SUBSIDIARY BANKS, AS OF 6/30/2012 ($ MILLIONS) Initial Invested Investment Bankruptcy/ Company Amount Date Status Failure Datea Subsidiary Bank Bankruptcy proceedings completed with no recovery of Treasury’s CIT Bank CIT Group Inc., New York, NY $2,330.0 12/31/2008 11/1/2009 investment; subsidiary bank remains Salt Lake City, UT active UCBH Holdings Inc., United Commercial 298.7 11/14/2008 In bankruptcy; subsidiary bank failed 11/6/2009 San Francisco, CA Bank, San Francisco, CA Bankruptcy proceedings completed Pacific Coast Pacific Coast National Bancorp, 4.1 1/16/2009 with no recovery of Treasury’s 11/13/2009 National Bank San Clemente, CA investment; subsidiary bank failed San Clemente, CA Midwest Bank and Midwest Banc Holdings, Inc., 89.4b 12/5/2008 In bankruptcy; subsidiary bank failed 5/14/2010 Trust Company, Melrose Park, IL Elmwood Park, IL Sonoma Valley Bancorp, Sonoma Valley Bank 8.7 2/20/2009 Subsidiary bank failed 8/20/2010 Sonoma, CA Sonoma, CA Pierce County Bancorp, Pierce Commercial Bank 6.8 1/23/2009 Subsidiary bank failed 11/5/2010 Tacoma, WA Tacoma, WA Tifton Banking Company, 3.8 4/17/2009 Failed 11/12/2010 N/A Tifton, GA Legacy Bancorp, Inc., Legacy Bank 5.5 1/30/2009 Subsidiary bank failed 3/11/2011 Milwaukee, WI Milwaukee, WI Superior Bancorp, Inc., Superior Bank 69.0 12/5/2008 Subsidiary bank failed 4/15/2011 Birmingham, AL Birmingham, AL Integra Bank Corporation, Integra Bank 83.6 2/27/2009 Subsidiary bank failed 7/29/2011 Evansville, IN Evansville, IN One Georgia Bank, Atlanta, GA 5.5 5/8/2009 Failed 7/15/2011 N/A FPB Bancorp, First Peoples Bank 5.8 12/5/2008 Subsidiary bank failed 7/15/2011 Port Saint Lucie, FL Port Saint Lucie, FL Citizens Bank of Citizens Bancorp, 10.4 12/23/2008 Subsidiary bank failed 9/23/2011 Northern California Nevada City, CA Nevada City, CA CB Holding Corp., Country Bank, 4.1 5/29/2009 Subsidiary bank failed 10/14/2011 Aledo, IL Aledo, IL Tennessee Commerce Bancorp, Inc., Tennessee Commerce 30.0 12/19/2008 Subsidiary bank failed 1/27/2012 Franklin, TN Bank, Franklin, TN Continued on next page 116 special inspector general I troubled asset relief program

CPP RECIPIENTS: BANKRUPT OR WITH FAILED SUBSIDIARY BANKS, AS OF 6/30/2012 ($ MILLIONS) (Continued) Initial Invested Investment Bankruptcy/ Company Amount Date Status Failure Datea Subsidiary Bank Blue River Bancshares, Inc., SCB Bank, $5.0 3/6/2009 Subsidiary bank failed 2/10/2012 Shelbyville, IN Shelbyville, IN Fort Lee Federal Savings Bank 1.3 5/22/2009 Failed 4/20/2012 N/A Total $2,961.7 Notes: Numbers may not total due to rounding. a Date is the earlier of the bankruptcy filing by holding company or the failure of subsidiary bank. b The amount of Treasury’s investment prior to bankruptcy was $89,874,000. On 3/8/2010, Treasury exchanged its $84,784,000 of preferred stock in Midwest Banc Holdings, Inc. (MBHI) for $89,388,000 of MCP, which is equivalent to the initial investment amount of $84,784,000, plus $4,604,000 of capitalized previously accrued and unpaid dividends.

Sources: Treasury, Transactions Report, 6/27/2012; Treasury, response to SIGTARP data call, 7/5/2012; FDIC, “Failed Bank List,” no date, www.fdic.gov/bank/individual/failed/banklist.html, accessed 6/28/2012; FDIC, “Institution Directory,” no date, www2.fdic.gov/idasp/main.asp, accessed 6/28/2012; CIT, “CIT Board of Directors Approves Proceeding with Prepackaged Plan of Reorganization with Overwhelming Support of Debt holders,” 11/1/2009, news.cit.com/portal/site/cit/index.jsp?ndmViewId=news_view&newsId=20091101005053&newsLang=en, accessed 6/28/2012; Pacific Coast National Bancorp, 8-K, 12/17/2009, www.sec.gov/Archives/edgar/data/1302502/000092708909000240/pcnb-8k122209.htm, accessed 6/28/2012; Sonoma Valley Bancorp, 8-K, 8/20/2010, www.sec.gov/Archives/edgar/data/1120427/000112042710000040/form8k_receivership.htm, accessed 6/28/2012; Midwest Banc Holdings, Inc., 8-K, 8/20/2010, www.sec.gov/Archives/edgar/ data/1051379/000095012310081020/c60029e8vk.htm, accessed 6/28/2012; UCBH Holdings, Inc., 8-K, 11/6/2009, www.sec.gov/Archives/edgar/data/1061580/000095012309062531/ f54084e8vk.htm, accessed 6/28/2012; FDIC Press Release, “Heritage Bank, Olympia, Washington, Assumes All of the Deposits of Pierce Commercial Bank, Tacoma, Washington,” 11/5/2010, www. fdic.gov/news/news/press/2010/pr10244.html, accessed 6/28/2012; FDIC Press Release, “Ameris Bank, Moultrie, Georgia, Acquires All of the Deposits of Two Georgia Institutions,” 11/12/2010, www.fdic.gov/news/news/press/2010/pr10249.html, accessed 6/28/2012; Federal Reserve Board Press Release, 5/10/2010, www.federalreserve.gov/newsevents/press/enforcement/20100510b. htm, accessed 6/28/2012; Board of Governors of the Federal Reserve System, Written Agreement by and among Legacy Bancorp, Inc., Legacy Bank, Federal Reserve Bank of Chicago, and State of Wisconsin Department of Financial Institutions, Madison, Wisconsin, www.federalreserve.gov/newsevents/press/enforcement/enf20100505b1.pdf, accessed 6/28/2012; FDIC Press Release, “Seaway Bank and Trust Company, Chicago, Illinois Assumes All of the Deposits of Legacy Bank, Milwaukee, Wisconsin,” 3/11/2011, www.fdic.gov/news/news/press/2011/pr11055.html, accessed 6/28/2012; FDIC Press Release, “Superior Bank, N.A., Birmingham, Alabama, Assumes All of the Deposits of Superior Bank, Birmingham, Alabama,” 4/15/2011, www.fdic.gov/news/news/press/2011/pr11073. html, accessed 6/28/2012; FDIC Press Release, “Old National Bank, Evansville, Indiana, Assumes All of the Deposits of Integra Bank, National Association, Evansville, Indiana,” 7/29/2011, www.fdic.gov/ news/news/press/2011/pr11128.html, accessed 6/28/2012; FDIC Press Release, “Old National Bank, Evansville, Indiana, Assumes All of the Deposits of Integra Bank, National Association, Evansville, Indiana,” 7/29/2011, www.fdic.gov/news/news/press/2011/pr11128.html, accessed 6/28/2012; FDIC Press Release, “Ameris Bank, Moultrie, Georgia, Acquires All the Deposits of Two Georgia Institutions,” 7/15/2011, www.fdic.gov/news/news/press/2011/pr11120.html, accessed 6/28/2012; FDIC Press Release, “Premier American Bank, National Association, Miami, Florida, Assumes All of the Deposits of First Peoples Bank, Port Saint Lucie, Florida,” 7/15/2011, www.fdic.gov/news/news/press/2011/pr11121.html, accessed 6/28/2012; FDIC Press Release, “Tri Counties Bank, Chico, California, Assumes All of the Deposits of Citizens Bank of Northern California, Nevada City, California,” 9/23/2011, www.fdic.gov/news/news/press/2011/pr11154.html, accessed 6/28/2012; FDIC Press Release, “Tri Counties Bank, Chico, California, Assumes All of the Deposits of Citizens Bank of Northern California, Nevada City, California,” 9/23/2011, www.fdic.gov/news/news/press/2011/ pr11154.html, accessed 6/28/2012; FDIC Press Release, “Old National Bank, Evansville, Indiana, Assumes All of the Deposits of Integra Bank, National Association, Evansville, Indiana,” 7/29/2011, www. fdic.gov/news/news/press/2011/pr11128.html, accessed 6/28/2012; FDIC Press Release, “Ameris Bank, Moultrie, Georgia, Acquires All the Deposits of Two Georgia Institutions,” 7/15/2011, www. fdic.gov/news/news/press/2011/pr11120.html, accessed 6/28/2012; FDIC, In the Matter of First Peoples Bank, Docket No. FDIC-09-717b, Consent Order, 3/18/2010, www.fdic.gov/bank/individual/ enforcement/2010-03-09.pdf, accessed 6/28/2012; FDIC, In the Matter of Citizens Bank of Northern California, Nevada City, California, Order No. FDIC-11-358PCAS, Supervisory Prompt Corrective Action Directive, 6/28/2011, www.fdic.gov/bank/individual/enforcement/2011-06-029.pdf, accessed 6/28/2012 ; “Blackhawk Bank & Trust, Milan, Illinois, Assumes All of the Deposits of Country Bank, Aledo, Illinois” 10/14/2011, www.fdic.gov/news/news/press/2011/pr11167.html, accessed 6/28/2012 ; FDIC Press Release, “Republic Bank & Trust Company, Assumes all of the Deposits of Tennessee Commerce Bank, Franklin, Tennessee,” 1/27/2012, www.fdic.gov/news/news/press/2012/pr12011.html, accessed 7/10/2012; FDIC Press Release ,“First Merchants Bank, National Association, Muncie, Indiana, Assumes All of the Deposits of SCB Bank, Shelbyville, Indiana,” 2/10/2012, www.fdic.gov/news/news/press/2012/pr12018.html, accessed 6/28/2012; FDIC Press Release, “Alma Bank, Astoria, New York, Assumes All of the Deposits of Fort Lee Federal Savings Bank, FSB, Fort Lee, New Jersey,” www.fdic.gov/news/news/press/2012/pr12043.html, accessed 7/5/2012. quarterly report to congress I July 25, 2012 117

Closure of Fort Lee Federal Savings Bank On May 22, 2009, Treasury invested $1.3 million in Fort Lee Federal Savings Bank, Fort Lee, New Jersey (“Fort Lee”) through CPP in return for preferred stock and warrants.356 On April 20, 2012, the Office of the Comptroller of the Currency (“OCC”) closed Fort Lee and named the Federal Deposit Insurance Corporation (“FDIC”) as receiver.357 FDIC entered into a purchase and assumption agreement with Alma Bank, Astoria, New York, to assume all of Fort Lee’s deposits. FDIC estimates that the cost of Fort Lee’s failure to the deposit insurance fund will be $14 million. All of Treasury’s investment in Fort Lee is expected to be lost.358 118 special inspector general I troubled asset relief program

Community Development Capital Initiative The Administration announced the Community Development Capital Initiative (“CDCI”) on October 21, 2009. According to Treasury, it was intended to help small businesses obtain credit.359 Under CDCI, TARP made $570.1 million in investments in the preferred stock or subordinated debt of 84 eligible banks, bank Community Development Financial holding companies, thrifts, and credit unions certified as Community Development Institutions (“CDFIs”): Financial Financial Institutions (“CDFIs”) by Treasury. According to Treasury, these lower- institutions eligible for Treasury funding cost capital investments were intended to strengthen the capital base of CDFIs to serve urban and rural low-income and enable them to make more loans in low and moderate-income communities.360 communities through the CDFI Fund. CDCI was open to certified, qualifying CDFIs or financial institutions that applied CDFIs were created in 1994 by the for CDFI status by April 30, 2010.361 Riegle Community Development and According to Treasury, CPP-participating CDFIs that were in good standing Regulatory Improvement Act. These could exchange their CPP investments for CDCI investments.362 CDCI closed to entities must be certified by Treasury; new investments on September 30, 2010.363 certification confirms they target at As of June 30, 2012, 82 institutions remain in CDCI. One institution repaid least 60% of their lending and other the Government this quarter and one institution previously had its subsidiary bank economic development activities fail.364 to areas underserved by traditional financial institutions. Terms for Senior Securities and Dividends An eligible bank, bank holding company, or thrift could apply to receive capital in Risk-Weighted Assets: Risk-based an amount up to 5% of its risk-weighted assets. A credit union (which is a member- measure of total assets held by owned, nonprofit financial institution with a capital and governance structure a financial institution. Assets are different from that of for-profit banks) could apply for Government funding of assigned broad risk categories. The up to 3.5% of its total assets — roughly equivalent to the 5% of risk-weighted amount in each risk category is then assets for banks.365 Participating credit unions and subchapter S corporations multiplied by a risk factor associated (“S corporations”) issued subordinated debt to Treasury in lieu of the preferred with that category. The sum of the stock issued by other CDFI participants.366 Many CDFI investments have an resulting weighted values from each of initial dividend rate of 2%, which increases to 9% after eight years. Participating the risk categories is the bank’s total S corporations pay an initial rate of 3.1%, which increases to 13.8% after eight risk-weighted assets. years.367 A CDFI participating in CPP had the opportunity to request to convert those shares into CDCI shares, thereby reducing the annual dividend rate it pays Subchapter S Corporations (“S the Government from 5% to as low as 2%.368 According to Treasury, CDFIs were corporations”): Corporate form that not required to issue warrants because of the de minimis exception in EESA, which passes corporate income, losses, grants Treasury the authority to waive the warrant requirement for qualifying deductions, and credit through to institutions in which Treasury invested $100 million or less. shareholders for Federal tax purposes. If during the application process a CDFI’s primary regulator deemed it to be un- Shareholders of S corporations report dercapitalized or to have “quality of capital issues,” the CDFI had the opportunity the flow-through of income and losses to raise private capital to achieve adequate capital levels. Treasury would match the on their personal tax returns and are private capital raised on a dollar-for-dollar basis, up to a total of 5% of the financial taxed at their individual income tax institution’s risk-weighted assets. In such cases, private investors had to agree to rates. assume any losses before Treasury.369

CDCI Investment Update Treasury invested $570.1 million in 84 institutions under the program — 36 banks or bank holding companies and 48 credit unions.370 Of the 36 investments in banks quarterly report to congress I July 25, 2012 119

and bank holding companies, 28 were conversions from CPP (representing $363.3 million of the total $570.1 million); the remaining eight were not CPP participants. Treasury provided an additional $100.7 million in CDCI funds to 10 of the banks converting CPP investments. Only $106 million of the total CDCI funds went to institutions that were not in CPP. As of June 30, 2012, Treasury had received approximately $19.2 million in dividends and interest from CDCI recipients.371 Only one CDCI participant had repaid TARP as of June 30, 2012. Greater Kinston Credit Union, Kinston, North Carolina (“Greater Kinston”) repurchased its shares at par on April 10, 2012, for $350,000.372 As of June 30, 2012, four institutions (Community Bank of the Bay, First American International Corporation, First Vernon Bancshares, Inc., and PGB Holdings, Inc.) had unpaid dividend or interest payments to Treasury totaling $707,650.373 A list of all CDCI investments is included in Appendix D: “Transaction Detail.” 120 special inspector general I troubled asset relief program

Systemically Significant Failing Institutions Program According to Treasury, the Systemically Significant Failing Institutions (“SSFI”) program was established to “provide stability and prevent disruptions to financial markets from the failure of a systemically significant institution.”374 Through SSFI, between November 2008 and April 2009, Treasury invested $67.8 billion in TARP funds in American International Group, Inc. (“AIG”), the program’s sole participant.375 As of June 30, 2012, taxpayers were still owed more than half of the original TARP investment. Taxpayers are owed $36 billion of the $67.8 billion.376 According to Treasury’s TARP books and records, taxpayers have realized losses on the TARP investment from an accounting standpoint of $5.5 billion on Treasury’s sale of AIG stock.377 However, given the January 2011 restructuring of the Federal For more information on AIG and how Reserve Bank of New York (“FRBNY”) and Treasury investment, according to the company has changed under TARP, Treasury, the Government overall has made a gain thus far on the stock sales.378 see Section 3, “AIG Remains in TARP According to Treasury, this leaves $30.4 billion in TARP funds outstanding.379 In as the Largest TARP Investment.” return for that investment, Treasury holds 61% of AIG’s common stock (1.06 billion shares).380 The Government’s rescue of AIG involved several different funding facilities provided by FRBNY and Treasury, with various changes to the transactions over time. The rescue of AIG was initially led by FRBNY and the Board of Governors of the Federal Reserve System (“Federal Reserve”). Prior to Treasury’s investment in Revolving Credit Facility: Line of AIG, FRBNY extended an $85 billion revolving credit facility to AIG in September credit for which borrowers pay a 2008. With the passage of EESA on October 3, 2008, Treasury, through SSFI, took commitment fee, allowing them to on a greater role in AIG’s bailout as the Government expanded and later restruc- repeatedly draw down funds up to a tured its aid. guaranteed maximum amount. The The amount and types of Treasury’s outstanding AIG investments have changed amount of available credit decreases over time as a result of the execution of AIG’s January 2011 Recapitalization Plan and increases as funds are borrowed (discussed in greater detail in this section, which resulted in the termination of and then repaid. FRBNY’s revolving credit facility, the transfer of FRBNY’s preferred SPV interests to Treasury, and the conversion of preferred shares into common stock), preferred Credit Default Swap (“CDS”): A contract equity interest repayments, and Treasury’s sale of common stock. These various where the seller receives payments investments, as well as their stages and restructurings, are described below. from the buyer in return for agreeing to Treasury’s preferred equity interests have been fully retired.381 pay the buyer when a particular credit event occurs, such as when the credit FRBNY Revolving Credit Facility rating on a bond is downgraded or a In September 2008, FRBNY extended an $85 billion revolving credit facility to loan goes into default. The buyer does AIG, which was secured by AIG’s assets, in an effort to stabilize the company. In not need to own the asset covered by return, AIG committed 79.8% of its voting equity to a trust for the sole benefit of the contract, meaning the swap can the United States Treasury (the “AIG Trust”).382 While the $85 billion revolving serve essentially as a bet against the credit facility was necessary to address the company’s severe liquidity shortage underlying bond or loan. resulting from collateral calls related to the company’s credit default swap (“CDS”) business and securities lending activities, because the entire facility was drawn upon, AIG’s leverage ratios increased significantly. The rapid deterioration in AIG’s CDS and securities lending businesses, combined with this increased leverage, put downward pressure on its credit rating.383 Federal officials feared that future downgrades in AIG’s credit rating could have “catastrophic” effects on quarterly report to congress I July 25, 2012 121

the company, forcing it into bankruptcy.384 FRBNY and Treasury determined that this possibility posed a threat to the nation’s financial system and decided that additional transactions were necessary to modify the revolving credit facility.385

Restructurings of AIG Assistance In November 2008 and March 2009, FRBNY and Treasury took several actions to Cumulative Preferred Stock: Stock stabilize AIG’s operations.386 requiring a defined dividend payment. If the company does not pay the dividend Initial TARP Investment on schedule, it still owes the missed First, on November 25, 2008, Treasury purchased $40 billion in AIG preferred dividend to the stock’s owner. shares under TARP, the proceeds of which went directly to FRBNY to pay down a portion of the outstanding balance of the existing revolving credit facility. In Special Purpose Vehicle (“SPV”): return, Treasury received AIG Series D cumulative preferred stock and warrants A legal entity, often off-balance- to purchase AIG common stock.387 After that payment, the total amount available sheet, that holds transferred assets to AIG under FRBNY’s revolving credit facility was reduced from $85 billion to presumptively beyond the reach of the $60 billion. entities providing the assets, and that is legally isolated from its sponsor or Creation of Maiden Lane II & III parent company. Second, also in November 2008, FRBNY created Maiden Lane II, a special purpose vehicle (“SPV”), to take significant mortgage-backed securities off AIG’s Collateralized Debt Obligation (“CDO”): books. FRBNY lent $19.5 billion to Maiden Lane II to fund the purchase of A security that entitles the purchaser residential mortgage-backed securities (“RMBS”) associated with AIG’s securities to some part of the cash flows from a lending program. This RMBS was in the securities-lending portfolios of several of portfolio of assets such as mortgage- AIG’s U.S.-regulated insurance subsidiaries. backed securities, bonds, loans, or Finally, also in November 2008, FRBNY created Maiden Lane III, another other CDOs. SPV, to which FRBNY lent $24.3 billion to buy from AIG’s counterparties some of the collateralized debt obligations (“CDOs”) underlying the CDS contracts written Non-Cumulative Preferred Stock: by AIG. Preferred stock with a defined dividend, without the obligation to pay Second TARP Investment missed dividends. On March 2, 2009, Treasury and FRBNY announced a restructuring of Govern- ment assistance to AIG that, according to Treasury, was designed to strengthen the Equity Capital Facility: Commitment company’s capital position.388 These measures included the conversion of Treasury’s to invest equity capital in a firm first TARP investment and Treasury’s commitment to fund a second TARP invest- under certain future conditions. An ment in AIG. equity facility when drawn down is On April 17, 2009, AIG and Treasury signed a securities exchange agreement an investment that increases the under which Treasury exchanged the Series D cumulative preferred stock, which provider’s ownership stake in the required AIG to make quarterly dividend and interest payments, for $41.6 bil- company. The investor may be able to lion (including $1.6 billion in missed dividend payments) of less valuable Series E recover the amount invested by selling non-cumulative preferred stock, which required AIG to make dividend and inter- its ownership stake to other investors est payments only if AIG’s board of directors declared a dividend. Additionally, on at a later date. April 17, 2009, Treasury committed to fund an equity capital facility under which AIG could draw down up to $29.8 billion in exchange for Series F non-cumulative preferred stock (that had similar terms to the Series E) and additional warrants, of which AIG drew down $27.8 billion.389 122 special inspector general I troubled asset relief program

Creation of Additional Special Purpose Vehicles and Sale of Assets Under SPVs The March 2009 restructuring measures also included an authorization for FRBNY to acquire up to $26 billion of preferred equity interests in two SPVs, AIA Aurora LLC (“AIA SPV”) and ALICO Holdings LLC (“ALICO SPV”). The creation of the SPVs also facilitated the independence of these two subsidiaries in anticipation of a sale or initial public offering (“IPO”).390 Treasury received payments for its interest in the SPVs and no longer holds an investment in the two SPVs. Under the transaction’s original terms, with limited exceptions, all proceeds from the voluntary sale, public offering, or other liquidation of the assets or busi- nesses held by the SPVs had to be used first to fully redeem FRBNY’s interests in the SPVs and then to reduce the outstanding principal balance of AIG’s revolving credit facility. On December 1, 2009, FRBNY received $16 billion in preferred equity interests in the AIA SPV and $9 billion in the ALICO SPV.391 AIG later com- pleted an IPO of 8.1 billion shares of AIA Group Limited and a sale of 1.72 billion shares of AIA and applied the $26.5 billion in total proceeds to amounts owed to FRBNY and Treasury.392 On November 1, 2010, AIG sold ALICO to MetLife, Inc., for $16.2 billion, For a more detailed description of the $7.2 billion of which was paid in cash and $9 billion in equity interests in MetLife. disposition of Treasury’s interest in the SPVs, see SIGTARP’s April 2012 These equity interests were initially held in the ALICO SPV and were sold on Quarterly Report, pages 112-113. March 8, 2011, for $9.6 billion.393

TARP Dividend Payments When AIG failed to pay dividends for four consecutive quarters on the Series E preferred stock, this gave Treasury the right to appoint to AIG’s board the greater of either two directors or a number (rounded upward) of directors equal to 20% of all AIG directors.394 On April 1, 2010, Treasury appointed Donald H. Layton and Ronald A. Rittenmeyer as directors of AIG.395 On May 10, 2012, AIG announced that, due to his appointment as chief executive officer of the Federal Home Loan Mortgage Corporation (“Freddie Mac”), Layton had submitted his resignation as an AIG director.396 On July 11, 2012, a retired AIG director, Morris W. Offit, was reelected to the board.397

AIG Recapitalization Plan On January 14, 2011, AIG executed its Recapitalization Plan with the Govern- ment, which resulted in extinguishing FRBNY’s revolving credit facility, retiring For a more detailed description of FRBNY’s remaining interests in the SPVs and transferring those interests to the AIG Recapitalization Plan, see Treasury, and increasing Treasury’s TARP investment in AIG. AIG repaid $20.7 SIGTARP’s January 2011 Quarterly billion owed to FRBNY’s revolving credit facility with proceeds from the AIA IPO Report, pages 135-139. and ALICO sale. AIG drew down $20.3 billion in TARP funds under a Series F equity capital facility to purchase certain of FRBNY’s interests in the ALICO SPV and AIA SPV and transferred those interests to Treasury. AIG exchanged all prior outstanding preferred shares held by the Government and issued new common stock to Treasury representing a 92.1% interest in AIG. Treasury also created a new $2 billion Series G equity capital facility, which was never drawn down.398 quarterly report to congress I July 25, 2012 123

For the period November 25, 2008, to January 14, 2011, AIG had failed to pay a total of $7.9 billion in dividend payments.399 After the Recapitalization Plan was executed, AIG no longer had an obligation to pay dividends.

Treasury’s Equity Ownership Interest in AIG As part of the Recapitalization Plan, AIG extinguished all prior outstanding preferred shares held by the Government, comprising $41.6 billion of Series E preferred shares and $7.5 billion drawn from the Series F equity capital facility. In exchange, it issued 1.655 billion shares of common stock (which included 563 million Series C shares held by the AIG Trust for the benefit of the U.S. Treasury), representing 92.1% of the common stock of AIG.400 The AIG Trust was then terminated. AIG issued 10-year warrants to its existing non-Government common shareholders to purchase up to a cumulative total of 75 million shares of common stock at a strike price of $45 per share.401 On May 27, 2011, Treasury sold 200 million shares of AIG common stock for $29.00 per share.402 The total proceeds to Treasury from the sale were $5.8 billion. In addition, the undrawn Series G equity capital facility was terminated and AIG cancelled all Series G preferred stock.403 On March 8, 2012, Treasury sold approxi- mately 206.9 million shares of AIG common stock for $29.00 per share.404 The total proceeds to Treasury from the sale were $6 billion. On May 6, 2012, Treasury sold approximately 188.5 million shares of AIG’s common stock for $30.50 per share, for $5.8 billion in proceeds (including 24.6 million shares sold pursuant to the exercise in full of the underwriters’ over-allotment option).405 As of June 30, 2012, Treasury owned 1.06 billion shares of AIG’s common stock, representing an ownership stake of 61%.406 According to Treasury’s TARP books and records, tax- payers have realized losses on the TARP investment from an accounting standpoint of $5.5 billion on Treasury’s sale of AIG stock.407 However, given the January 2011 restructuring of the FRBNY and Treasury investment, according to Treasury, the Government overall has made a gain thus far on the stock sales.408 Under an agreement with Treasury, until Treasury’s ownership of AIG’s voting securities falls below 33%, AIG will have to obtain Treasury’s consent to the terms, conditions, and pricing of any equity offering. AIG is required to pay Treasury’s ex- penses for the registration of shares and underwriting fees, up to 1% of the amount offered by Treasury.409

FRBNY’s Sales of Maiden Lane II Securities On February 28, 2012, FRBNY completed the final sale of securities in the Maiden 410 Lane II portfolio. FRBNY completed 12 sales of a total of 773 CUSIP numbers CUSIP number (“CUSIP”): Unique (“CUSIPs”) from the Maiden Lane II portfolio, with a face amount totaling $29 identifying number assigned to all 411 billion. registered securities in the United According to FRBNY, its management of the Maiden Lane II portfolio resulted States and Canada; the name in full repayment of the $19.5 billion loan extended by FRBNY to Maiden Lane II originated with the Committee on and generated a net gain for the benefit of the public of approximately $2.8 billion, Uniform Securities Identification 412 including $580 million in accrued interest on the loan. Procedures. 124 special inspector general I troubled asset relief program

Table 2.31 details the sales of securities in the Maiden Lane II portfolio.

Table 2.31 FRBNY Maiden LANE II Securities Sales Number of Current Face Amount Trade Date Bonds Sold of Bonds Solda 4/6/2011 42 $1,326,856,873 4/13/2011 37 626,080,072 4/14/2011 8 534,127,946 4/28/2011 8 1,122,794,209 5/4/2011 38 1,773,371,055 5/10/2011 74 427,486,898 5/12/2011 34 1,373,506,029 5/19/2011 29 878,641,682 6/9/2011 36 1,898,594,878 1/19/2012 161 7,005,379,336b 2/8/2012 154 6,223,369,695 2/28/2012 152 6,023,606,497 Total 773 $29,213,815,170

Notes: Numbers may not total due to rounding. a The current face amount represents the most recent balance of principal outstanding on the securities at the time of the offering. It does not reflect the market value of the bonds nor the price originally paid by Maiden Lane II LLC for the bonds. b According to FRBNY, the total face amount sold on the January 19, 2012, trade date differs slightly from the figure published in the FRBNY press release due to factor adjustments that reduced the face amount sold prior to the actual settlement date.

Sources: FRBNY, “Maiden Lane II LLC: Bid List Offering,” no date, www.newyorkfed.org/markets/MLII/maidenlane.cfm?showMore=1, accessed 6/28/2012; FRBNY, response to SIGTARP data call, 4/12/2012; FRBNY, response to SIGTARP vetting draft, 7/11/2012.

FRBNY’s Sales of Maiden Lane III Securities In April 2012, FRBNY announced that in light of improving market conditions, it had revised its investment objective for Maiden Lane III “to allow for the exploration of sales of the assets held in the portfolio” through its investment manager BlackRock Solutions.413 According to FRBNY, there is no fixed time frame for the sales. After each sale, FRBNY will provide the circulation date of the offering, bid submission deadline, CUSIP number(s) and current face amount offered, and, if a sale is executed, the name of the buyer and trade date of the sale.414 FRBNY also announced that, along with providing monthly reports that include a list of the assets sold during the month by current face amount, it will provide quarterly updates on total proceeds from sales and the total amount purchased by each counterparty.415 Finally, after Maiden Lane III sells its last security, FRBNY will provide a security-by-security listing that shows which entity purchased each security and the price it paid.416 In the quarter ended June 30, 2012, FRBNY completed eight sales of a total of 46 CUSIPs from the Maiden Lane III portfolio, with a face amount totaling $26.8 billion.417 Maiden Lane III continues to hold other securities. quarterly report to congress I July 25, 2012 125

According to FRBNY, on June 14, 2012, Maiden Lane III LLC fully repaid its liabilities to FRBNY, with interest.418 Table 2.32 details the sales of securities in the Maiden Lane III portfolio.

Table 2.32 FRBNY Maiden LANE III Securities Sales FOR THE QUARTER ENDING 6/30/2012 Number of Current Face Amount Trade Date Bonds Sold of Bonds Solda 4/26/2012 2 $7,500,000,000 5/10/2012 4 2,427,840,275 5/22/2012 6 690,567,610 5/24/2012 2 1,672,896,114 6/13/2012 3 1,925,643,949 6/15/2012 10 5,165,583,984 6/25/2012 11 4,240,009,909 6/28/2012 8 3,139,442,673 Total 46 $26,761,984,514

a The current face amount represents the most recent balance of principal outstanding on the securities at the time of the offering. It does not reflect the market value of the bonds nor the price originally paid by Maiden Lane III LLC for the bonds.

Sources: FRBNY, “Maiden Lane III LLC: Security Offerings,” no date, www.newyorkfed.org/markets/ml3_sec_offerings.html, accessed 6/28/2012; FRBNY, response to SIGTARP data call, 7/9/2012. 126 special inspector general I troubled asset relief program

Targeted Investment Program Treasury invested a total of $40 billion in two financial institutions, Citigroup Inc. (“Citigroup”) and Bank of America Corp. (“Bank of America”), through the Targeted Investment Program (“TIP”). Treasury invested $20 billion in Citigroup on December 31, 2008, and $20 billion in Bank of America on January 16, 2009, in return for preferred shares paying quarterly dividends at an annual rate of 8% and warrants from each institution.419 According to Treasury, TIP’s goal was to “strengthen the economy and protect American jobs, savings, and retirement security [where] the loss of confidence in a financial institution could result in significant market disruptions that threaten the financial strength of similarly situated financial institutions.”420 Both banks repaid TIP in December 2009.421 On March 3, 2010, Treasury auctioned the Bank of America warrants it received under TIP for $1.24 billion.422 On January 25, 2011, Treasury auctioned the Citigroup warrants it had received under TIP for $190.4 million.423

Asset Guarantee Program Under the Asset Guarantee Program (“AGP”), Treasury, the Federal Deposit Insurance Corporation (“FDIC”), the Federal Reserve, and Citigroup agreed to provide loss protection on a pool of Citigroup assets valued at approximately $301 billion. In return, as a premium, the Government received warrants to purchase Trust Preferred Securities (“TRUPS”): Citigroup common stock and $7 billion in preferred stock. The preferred stock was Securities that have both equity subsequently exchanged for trust preferred securities (“TRUPS”).424 and debt characteristics created by Treasury received $4 billion of the TRUPS and FDIC received $3 billion.425 establishing a trust and issuing debt Although Treasury’s asset guarantee was not a direct cash investment, it exposed to it. taxpayers to a potential TARP loss of $5 billion. On December 23, 2009, in con- nection with Citigroup’s TIP repayment, Citigroup and Treasury terminated the AGP agreement. Although at the time of termination the asset pool suffered a $10.2 billion loss, this number was below the agreed-upon deductible and the For a discussion of the basis of the 426 decision to provide Federal assistance Government suffered no loss. to Citigroup, see SIGTARP’s audit Treasury agreed to cancel $1.8 billion of the TRUPS issued by Citigroup, report, “Extraordinary Financial reducing the premium it received from $4 billion to $2.2 billion, in exchange for Assistance Provided to Citigroup, the early termination of the loss protection. FDIC retained all of its $3 billion in Inc.,” dated January 13, 2011. securities.427 Under the termination agreement, however, FDIC will transfer up to $800 million of those securities to Treasury if Citigroup’s participation in FDIC’s Temporary Liquidity Guarantee Program closes without a loss.428 On September 29, 2010, Treasury entered into an agreement with Citigroup to exchange the entire $2.2 billion in Citigroup TRUPS that it held under AGP for new TRUPS. Because the interest rate necessary to receive par value was below the interest rate paid by Citigroup to Treasury, Citigroup increased the principal amount of the securities sold by Treasury by an additional $12 million, thereby enabling Treasury to receive an additional $12 million in proceeds from the $2.2 billion sale of the Citigroup TRUPS, which occurred on September 30, 2010.429 On January 25, 2011, Treasury auctioned the Citigroup warrants it had received under AGP for $67.2 million.430 According to Treasury, it has realized a gain of quarterly report to congress I July 25, 2012 127

approximately $12.3 billion over the course of Citigroup’s participation in AGP, TIP, and CPP, including dividends, other income, and warrant sales.431 Bank of America announced a similar asset guarantee agreement with respect to approximately $118 billion in Bank of America assets, but the final agreement was never executed. Bank of America paid $425 million to the Government as a termination fee.432 Of this $425 million, $276 million was paid to Treasury, $92 million was paid to FDIC, and $57 million was paid to the Federal Reserve.433 128 special inspector general I troubled asset relief program

Asset Support Programs Three TARP programs have focused on supporting markets for specific asset classes: the Term Asset-Backed Securities Loan Facility (“TALF”), the Public- Private Investment Program (“PPIP”), and the Unlocking Credit for Small Businesses (“UCSB”) program. TALF was designed to support asset-backed securities (“ABS”) transactions Non-Recourse Loan: Secured loan by providing eligible borrowers $71.1 billion in non-recourse loans through the in which the borrower is relieved of Federal Reserve Bank of New York (“FRBNY”) to purchase non-mortgage-backed the obligation to repay the loan upon ABS and commercial mortgage-backed securities (“CMBS”). On June 28, 2012, surrendering the collateral. Treasury reduced its obligation in TALF from $4.3 billion to $1.4 billion, the amount of TARP funds available to manage collateral for the TALF loans in the Collateral: Asset pledged by a event that borrowers surrender collateral and walk away from the loans or if the 434 borrower to a lender until a loan is collateral is seized in the event of default. Of the $71.1 billion in TALF loans, 435 repaid. Generally, if the borrower $4.5 billion remains outstanding as of June 30, 2012. defaults on the loan, the lender gains PPIP uses a combination of private equity and Government equity and debt ownership of the pledged asset and through TARP to facilitate purchases of legacy mortgage-backed securities (“MBS”) may sell it to satisfy the debt. In TALF, held by financial institutions. In July 2009, Treasury announced the selection of the ABS or CMBS purchased with nine Public-Private Investment Fund (“PPIF”) managers. Treasury has obligated the TALF loan is the collateral that is $21.9 billion in TARP funds to the program. In January 2010, PPIP manager The posted with FRBNY. TCW Group Inc. (“TCW”) withdrew from the program. On April 3, 2012, PPIP manager Invesco announced it had sold all remaining securities in its portfolio and was in the process of winding up the fund.436 As of June 30, 2012, the remaining seven PPIP managers are purchasing investments and managing their portfolios. Through the UCSB loan support initiative, Treasury purchased $368.1 million in 31 SBA 7(a) securities, which are securitized small-business loans.437 According to Treasury, on January 24, 2012, Treasury sold its remaining securities and ended the program with a total investment gain of about $9 million for all the securities, including sale proceeds and payments of principal, interest, and debt.438

TALF TALF, which was announced in November 2008, issued loans collateralized by eligible ABS.439 According to FRBNY, TALF was “designed to increase credit availability and support economic activity by facilitating renewed issuance of consumer and business ABS.”440 TALF is divided into two parts:441

• a lending program, TALF, in which FRBNY originated and managed non- recourse loans to eligible borrowers using eligible ABS and CMBS as collateral. TALF’s lending program closed in 2010 • an asset disposition facility, TALF LLC, that purchases the collateral from FRBNY if borrowers choose to surrender it and walk away from their loans or if the collateral is seized in the event of default quarterly report to congress I July 25, 2012 129

The asset disposition facility, TALF LLC, is managed by FRBNY and remains in operation.442 TALF loans are non-recourse (unless the borrower has made any mis- representations or breaches warranties or covenants), which means that FRBNY cannot hold the borrower liable for any losses beyond the surrender of collateral for the TALF loan.443 TALF LLC’s funding first comes from a fee charged to FRBNY for the commit- ment to purchase any collateral surrendered by the borrowers. This fee is derived from the principal balance of each outstanding TALF program loan.444 TARP is obligated to lend to TALF LLC up to $1.4 billion to cover losses on TALF loans.445 TALF LLC may use TARP funds to purchase surrendered assets from FRBNY and to offset losses associated with disposing of the surrendered assets. As of June Nationally Recognized Statistical Rating 30, 2012, $4.5 billion in TALF loans was outstanding.446 “To date, the program Organization (“NRSRO”): Credit rating has experienced no losses and the Board continues to see it as highly unlikely that agency registered with the SEC. Credit recourse to TARP funds will be necessary,” the Federal Reserve Board of Governors rating agencies provide their opinion (“FRB”) said on June 28, 2012, after the amount of TARP money available as of the creditworthiness of companies credit protection was reduced to $1.4 billion.447 According to FRBNY, no TALF and the financial obligations issued borrowers have surrendered collateral in lieu of repayment and consequently no by companies. The ratings distinguish collateral has been purchased by TALF LLC since its inception.448 between investment grade and non– investment grade equity and debt Lending Program obligations. TALF’s lending program made secured loans to eligible borrowers.449 The loans were issued with terms of three or five years and were available for non-mortgage- backed ABS, newly issued CMBS, and legacy CMBS.450 The final maturity date of For a discussion of the credit rating loans in the TALF portfolio is March 30, 2015.451 agency industry and an analysis of To qualify as TALF collateral, the non-mortgage-backed ABS had to have un- the impact of NRSROs on TARP and the overall financial market, see derlying loans for automobile, student, credit card, or equipment debt; insurance SIGTARP’s October 2009 Quarterly premium finance; SBA-guaranteed small business loans; or receivables for residen- Report, pages 113–148. tial mortgage servicing advances (“servicing advance receivables”). Collateral was also required to hold the highest investment grade credit ratings from at least two 452 nationally recognized statistical rating organizations (“NRSROs”). TALF Agent: Financial institution that To qualify as TALF collateral, newly issued CMBS and legacy CMBS had is party to the TALF Master Loan to have been issued by an institution other than a non-Government-sponsored and Security Agreement and that enterprise (“GSE”) or an agency or instrumentality of the U.S. Government, offer occasionally acts as an agent for the principal and interest payments, not be junior to other securities with claims on the borrower. TALF agents include primary same pool of loans, and possess the highest long-term investment grade credit and nonprimary broker-dealers. rating from at least two rating agencies.453 Newly issued CMBS had to be issued on 454 or after January 1, 2009, while legacy CMBS were issued before that date. Haircut: Difference between the value of the collateral and the value of the Loan Terms loan (the loan value is less than the 455 TALF participants were required to use a TALF agent to apply for a TALF loan. collateral value). After the collateral (the particular asset-backed security financed by the TALF loan) was deemed eligible by FRBNY, the collateral was assigned a haircut. A haircut, “Skin in the Game”: Equity stake in an which represents the amount of money put up by the borrower (the borrower’s investment; down payment; the amount 456 “skin in the game”), was required for each TALF loan. Haircuts for non- an investor can lose. mortgage-backed ABS varied based on the riskiness and maturity of the collateral, 130 special inspector general I troubled asset relief program

and generally ranged between 5% and 16% for non-mortgage-backed ABS with average lives of five years or less.457 The haircut for legacy and newly issued CMBS was generally 15% but increased above that amount if the average life of the CMBS was greater than five years.458 FRBNY lent each borrower the amount of the market price of the pledged col- 459 Custodian Bank: Bank holding the lateral minus the haircut, subject to certain limitations. The borrower delivered collateral and managing accounts for the collateral to the custodian bank, which collects payments generated by the FRBNY; for TALF the custodian is Bank collateral and distributes them to FRBNY (representing the borrower’s payment of 460 of New York Mellon. interest on the TALF loan). Any excess payments from the collateral above the interest due and payable to FRBNY on the loan go to the TALF borrower.461

TALF Loan TALF provided $59 billion of loans to purchase non-mortgage-backed ABS during the lending phase of the program, which ended on March 11, 2010. As of June 30, 2012, $3.4 billion was outstanding.462 Table 2.33 lists all TALF loans collateralized by non-mortgage-backed ABS, by ABS sector.

Table 2.33 TALF Loans BACKED BY ABS (Non-mortgage-backed Collateral) ($ Billions) ABS Sector Auto Loans $12.8 Credit Card Receivables 26.3 Equipment Loans 1.6 Floor Plan Loans 3.9 Premium Finance 2.0 Servicing Advance Receivables 1.3 Small-Business Loans 2.2 Student Loans 8.9 Total $59.0

Notes: Numbers may be affected by rounding. Data as of 6/30/2012.

Sources: FRBNY, “Term Asset-Backed Securities Loan Facility: non-CMBS,” no date, www.newyorkfed.org/markets/talf_ operations.html, accessed 7/21/2012; FRBNY, “Term Asset-Backed Securities Loan Facility: non-CMBS,” no date, www. newyorkfed.org/markets/TALF_recent_operations.html, accessed 7/21/2012.

TALF provided $12.1 billion of loans to purchase CMBS during the lending phase of the program, which ended on June 28, 2010. Approximately 99% of the loan amount was used to purchase legacy CMBS, with 1% newly issued CMBS.463 As of June 30, 2012, $1.1 billion was outstanding.464 Table 2.34 includes all TALF CMBS loans. quarterly report to congress I July 25, 2012 131

Table 2.34

TALF LOANS BACKED BY CMBS ($ Billions) Type of Collateral Assets Newly Issued CMBS $ 0.1 Legacy CMBS 12.0 Total $12.1

Notes: Numbers may be affected by rounding. Data as of 6/30/2012.

Sources: FRBNY, “Term Asset-Backed Securities Loan Facility: CMBS,” no date, www.newyorkfed.org/markets/cmbs_operations. html, accessed 7/21/2012; FRBNY, “Term Asset-Backed Securities Loan Facility: CMBS,” no date, www.newyorkfed.org/ markets/CMBS_recent_operations.html, accessed 7/21/2012.

The Federal Reserve posted on its website detailed information on the 177 TALF borrowers, including:465

• the names of all the borrowers from TALF (some of which share a parent company) • each borrower’s city, state, and country • the name of any material investor in the borrower (defined as a 10% or greater beneficial ownership interest in any class of security of a borrower) • the amount of the loan • outstanding loan amount as of September 30, 2010 • the loan date • the loan maturity date • the date of full repayment (if applicable) • the date of loan assignment (if applicable) • the loan rate (fixed or floating) • the market value of the collateral associated with the loan at the time the loan was extended • the name of the issuer of the ABS collateral associated with the loan • the collateral asset and subclass

As of June 30, 2012, $66.5 billion in TALF loans had been repaid. According to FRBNY, the outstanding collateral on the remaining $4.5 billion in TALF loans was performing as expected.466

Asset Disposition Facility When FRBNY created TALF LLC, TARP loaned the facility $100 million. Of this initial funding, $15.8 million was allocated to cover administrative costs.467 TARP will continue to fund TALF LLC, as needed to cover losses, until TARP’s entire $1.4 billion obligation has been disbursed, all TALF loans are retired, or the loan commitment term expires. The last loan matures in 2015. Any additional funds, if needed, will be provided by a loan from FRBNY that will be collateralized by the assets of TALF LLC and will be senior to the TARP loan.468 Payments by TALF LLC from the proceeds of its holdings will be made in the following order:469 132 special inspector general I troubled asset relief program

• operating expenses of TALF LLC • principal due to FRBNY and funding of FRBNY’s senior loan commitment • principal due to Treasury • interest due to FRBNY • interest due to Treasury • other secured obligations

Any remaining money will be shared by Treasury (90%) and FRBNY (10%).470

Current Status As of June 30, 2012, TALF LLC had assets of $845 million, which included the $100 million in initial TARP funding.471 The remainder consisted of interest and other income and fees earned from permitted investments. From its February 4, 2009, formation through June 30, 2012, TALF LLC had spent approximately $2.3 million on administration.472 When TALF closed for new loans in June 2010, FRBNY’s responsibilities under the program shifted primarily to portfolio management, which includes the follow- ing duties:473

Excess Spread: Funds left over • maintaining documentation after required payments and other • overseeing the custodian that is responsible for holding ABS collateral contractual obligations have been met. • calculating and collecting principal and interest on TALF loans In TALF it is the difference between • disbursing excess spread to TALF borrowers in accordance with the governing the periodic amount of interest paid documents out by the collateral and the amount • monitoring the TALF portfolio of interest charged by FRBNY on the • collecting and managing collateral assets if a borrower defaults or surrenders the nonrecourse loan provided to the collateral in lieu of repayment borrower to purchase the collateral. • paying TALF LLC interest that borrowers pay FRBNY on TALF loans, in excess of FRBNY’s cost of funding quarterly report to congress I July 25, 2012 133

Public-Private Investment Program According to Treasury, the purpose of the Public-Private Investment Program Legacy Securities: Real estate-related (“PPIP”) is to purchase legacy securities from banks, insurance companies, mutual securities originally issued before funds, pension funds, and other eligible financial institutions as defined in EESA, 2009 that remained on the balance through Public-Private Investment Funds (“PPIFs”).474 PPIFs are partnerships, sheets of financial institutions because formed specifically for this program, that invest in mortgage-backed securities using of pricing difficulties that resulted from equity capital from private-sector investors combined with TARP equity and debt. market disruption. A private-sector fund management firm oversees each PPIF on behalf of these investors. According to Treasury, the aim of PPIP was to “restart the market for Equity: Investment that represents an legacy securities, allowing banks and other financial institutions to free up capital ownership interest in a business. and stimulate the extension of new credit.”475 PPIP originally included a Legacy Loans subprogram that would have involved purchases of troubled legacy loans with private and Treasury equity capital, as well as an FDIC guarantee for debt financing. TARP funds were never disbursed for this subprogram. Treasury selected nine fund management firms to establish PPIFs. One PPIP manager, The TCW Group, Inc., (“TCW”) subsequently withdrew, and another PPIP manager, Invesco, has sold all remaining securities in its PPIP fund. Private For more information on the selection investors and Treasury co-invested in the PPIFs to purchase legacy securities from of PPIP managers, see SIGTARP’s October 7, 2010, audit report entitled financial institutions. The fund managers raised private-sector capital. Treasury “Selecting Fund Managers for the matched the private-sector equity dollar-for-dollar and provided debt financing Legacy Securities Public-Private in the amount of the total combined equity. Each PPIP manager was also re- Investment Program.” quired to invest at least $20 million of its own money in the PPIF.476 Each PPIF is approximately 75% TARP funded. PPIP was designed as an eight-year program For more information on the withdrawal of TCW as a PPIP giving PPIP managers until 2017 to sell the assets in their portfolio. Under certain manager, see SIGTARP’s January circumstances, Treasury can terminate the program early or extend it for up to two 2010 Quarterly Report, page 88. additional years.477 Treasury, the PPIP managers, and the private investors share PPIF profits and losses on a pro rata basis based on their limited partnership interests. Treasury also received warrants in each PPIF that give Treasury the right to receive a portion of the fund’s profits that would otherwise be distributed to the private investors along with its pro rata share of program proceeds.478 The PPIP portfolio was valued at $19.8 billion as of June 30, 2012, according to a process administered by Bank of New York Mellon, acting as valuation agent.479 That was $1.4 billion lower than the portfolio value at the end of the previous quar- ter. The PPIP portfolio consists of eligible securities and cash assets to be used to

Debt: Investment in a business that is Pro Rata: Refers to dividing something Limited Partnership: Partnership in which required to be paid back to the investor, among a group of participants according there is at least one partner whose usually with interest. to the proportionate share that each liability is limited to the amount invested participant holds as a part of the whole. (limited partner) and at least one partner whose liability extends beyond monetary investment (general partner). 134 special inspector general I troubled asset relief program

purchase securities. The securities eligible for purchase by PPIFs (“eligible Non-Agency Residential Mortgage- assets”) are non-agency residential mortgage-backed securities (“non-agency Backed Securities (“non-agency RMBS”) and commercial mortgage-backed securities (“CMBS”) that meet the RMBS”): Financial instrument backed following criteria:480 by a group of residential real estate mortgages (i.e., home mortgages for • issued before January 1, 2009 (legacy) residences with up to four dwelling • rated when issued AAA or equivalent by two or more credit rating agencies units) not guaranteed or owned by designated as nationally recognized statistical rating organizations (“NRSROs”) a Government-sponsored enterprise • secured directly by actual mortgages, leases, or other assets, not other securities (“GSE”) (Fannie Mae or Freddie Mac), (other than certain swap positions, as determined by Treasury) or a Government agency. • located primarily in the United States (the loans and other assets that secure the non-agency RMBS and CMBS) • purchased from financial institutions that are eligible for TARP participation

PPIP Process The following steps describe the process by which funds participate in PPIP:481

1. Fund managers applied to Treasury to participate in the program. 2. Pre-qualified fund managers raised the necessary private capital for the PPIFs. 3. Treasury matched the capital raised, dollar-for-dollar, up to a preset maximum. Treasury also received warrants so that it could benefit further if the PPIFs turn a profit. 4. Fund managers may borrow additional funds from Treasury up to 100% of the total equity investment (including the amount invested by Treasury). 5. Each fund manager purchases and manages the legacy securities and provides monthly reports to its investors, including Treasury.

Obligated funds are not given immediately to PPIP managers. Instead, PPIP managers send a notice to Treasury and the private investors requesting a “draw down” of portions of obligated contributions in order to purchase specific invest- ments or to pay certain expenses and debts of the partnerships.482

PPIF Purchasing Power During the capital-raising period, the eight PPIP fund managers raised $7.4 billion of private-sector equity capital, which Treasury matched with a dollar-for-dollar obligation, for a total of $14.7 billion in equity capital. Treasury also obligated $14.7 billion of debt financing, resulting in $29.4 billion of PPIF purchasing power. The fund-raising stage for PPIFs was completed in December 2009. After the capital-raising stage, Treasury obligated $22.4 billion in a combination of matching equity funds and debt financing for PPIP; that was reduced to $21.9 billion after PPIP manager Invesco terminated its investment period in September 2011.483 As of June 30, 2012, there is $28.9 billion in PPIF purchasing power from private and TARP capital. Table 2.35 shows equity and debt committed by Treasury for current PPIFs under the program. quarterly report to congress I July 25, 2012 135

TABLE 2.35 Public-private investment program PURCHASING POWER, AS OF 6/30/2012 ($ Billions) Private- Total Sector Equity Treasury Treasury Purchasing Manager Capital Equity Debt Power Active Funds AG GECC PPIF Master Fund, L.P. $1.2 $1.2 $2.5 $5.0 AllianceBernstein Legacy 1.2 1.2 2.3 4.6 Securities Master Fund, L.P. BlackRock PPIF, L.P. 0.7 0.7 1.4 2.8 Marathon Legacy Securities Public- Private Investment Partnership, 0.5 0.5 0.9 1.9 L.P. Oaktree PPIP Fund, L.P. 1.2 1.2 2.3 4.6 RLJ Western Asset Public/Private 0.6 0.6 1.2 2.5 Master Fund, L.P. Wellington Management Legacy 1.1 1.1 2.3 4.6 Securities PPIF Master Fund, LP Totals for Active Funds $6.5 $6.5 $13.0 $26.0 Inactive Fundsa Invesco Legacy Securities Master $0.9 $0.9 $1.2 $2.9 Fund, L.P.b Totals for All Funds $7.4 $7.4 $14.2 $28.9C

Notes: Numbers may not total due to rounding. a Purchasing power figures show what was available to funds when they were actively investing. b Invesco did not draw down all committed equity and debt available before terminating its investment period. Treasury has reduced its debt obligation to the fund, but will not reduce its equity obligation until the fund is formally liquidated. c Treasury initially funded $356 million to TCW, which TCW repaid in full in early 2010. As this PPIF has liquidated, the amount is not included in the total purchasing power.

Source: Treasury, response to SIGTARP data call, 7/5/2012.

Each current PPIP manager has up to three years (the “PPIF investment period”) from closing its first private-sector equity contribution to draw upon the TARP funds obligated for the PPIF and buy legacy securities on behalf of private and Government investors.484 During this period, the program will strive to main- tain “predominantly a long-term buy and hold strategy.”485 The last of the three-year investment periods expires in December 2012. At the end of the PPIF investment period, fund managers have five years ending in 2017 to manage and sell off the fund’s investment portfolio and return proceeds to taxpayers and investors. This period may be extended up to two years.486 136 special inspector general I troubled asset relief program

Amounts Drawn Down The eight PPIP managers (including Invesco) had drawn down approximately $24.2 billion to buy legacy securities and cash assets through June 30, 2012, spending $6.1 billion in private-sector equity capital and $18.1 billion in TARP equity and debt funding.487 That included a combined $873 million drawn down by two fund managers, Oaktree PPIP Fund, L.P. (“Oaktree”) and Wellington Management Legacy Securities PPIF Master Fund, LP (“Wellington”), in the quarter ended June 30, 2012.488 Treasury also disbursed $356.3 million to TCW, which TCW fully repaid in early 2010 when it withdrew from the program.489 Five PPIP managers have drawn down at least 90% of their available PPIP capital to purchase legacy securities as of June 30, 2012.490 Among the active funds, Oaktree, the only fund limited solely to purchasing CMBS, had drawn down the smallest amount, 48%, of its available capital. Table 2.36 shows how much each PPIF has drawn down from the private and Government money available to it to buy real-estate backed securities.

Table 2.36 PPIP CAPITAL DRAWN DOWN, AS OF 6/30/2012 ($ BILLIONS) Purchasing Private- Treasury Treasury Power Sector Equity Equity Drawn Debt Drawn Total Drawn Purchasing Manager Available Drawn Down Down Down Down Power Used Active Funds AG GECC PPIF Master Fund, L.P. $5.0 $1.1 $1.1 $2.2 $4.5 90% AllianceBernstein Legacy 4.6 1.1 1.1 2.1 4.3 92% Securities Master Fund, L.P. BlackRock PPIF, L.P. 2.8 0.5 0.5 1.1 2.1 76% Marathon Legacy Securities Public-Private Investment 1.9 0.5 0.5 0.9 1.9 100% Partnership, L.P. Oaktree PPIP Fund, L.P. 4.6 0.6 0.6 1.1 2.2 48% RLJ Western Asset Public/ 2.5 0.6 0.6 1.2 2.5 100% Private Master Fund, L.P. Wellington Management Legacy 4.6 1.1 1.1 2.2 4.5 97% Securities PPIF Master Fund, LP Totals for Active Funds $26.0 $5.5 $5.5 $10.9 $21.9 84% Inactive Funds Invesco Legacy Securities $2.9 $0.6 $0.6 $1.2 $2.3 81% Master Fund, L.P.a Totals for All Fundsb $28.9 $6.1 $6.1 $12.0 $24.2 84%

Notes: Numbers may not total due to rounding. a Invesco did not fully draw down all committed equity and debt available to it. Treasury has reduced its debt obligation to the fund, but will not reduce its equity obligation until the fund is formally liquidated. b Treasury initially funded $356 million to TCW, which TCW repaid in full in early 2010. As this PPIF has liquidated, the amount is not included in the total purchasing power.

Source: Treasury, response to SIGTARP data call, 7/5/2012. quarterly report to congress I July 25, 2012 137

Amounts Paid to Treasury PPIP managers make monthly debt interest payments to Treasury. In addition, through June 30, 2012, five of the seven active PPIP managers have repaid $1.6 billion in TARP debt. Invesco finished repaying its $1.2 billion in debt earlier this year and another $200 million in debt was repaid by TCW when it liquidated its fund in 2010, for a total of $3 billion in debt repayments to Treasury to date.491 Most of the active PPIFs have also begun repaying Treasury’s equity invest- ments. They repaid $687 million through June 30, 2012, in addition to repayments by Invesco and TCW. All seven active PPIFs also paid a total of $1.3 billion to the Government through June 30, 2012, in equity distributions, which Treasury defined as profits from sales of PPIF securities.492 Table 2.37 shows each fund’s payments to Treasury through June 30, 2012.

Table 2.37

PPIP MANAGERS’ PAYMENTS TO TREASURY, AS OF 6/30/2012 ($ MILLIONS) Debt Debt Equity Equity Equity Principal Interest Capital Distribution Warrant Manager Payments Payments Paymentsa Payments Paymentsb Active Funds AG GECC PPIF Master Fund, L.P. $523 $57 $262 $420 $— AllianceBernstein Legacy Securities 805 56 342 517 — Master Fund, L.P. BlackRock PPIF, L.P. — 30 — 3 — Marathon Legacy Securities Public- — 22 — 44 — Private Investment Partnership, L.P. Oaktree PPIP Fund, L.P. 158 9 79 92 — RLJ Western Asset Public/Private 14 35 5 114 — Master Fund, L.P. Wellington Management Legacy 125 48 — 110 — Securities PPIF Master Fund, LP Totals for Active Funds $1,624 $257 $687 $1,301 $— Inactive Funds UST/TCW Senior Mortgage Securities $200 $0.3 $156 $176 $0.5 Fund, L.P. Invesco Legacy Securities Master 1,162 18 581 718 3 Fund, L.P. Totals for All Funds $2,986 $276 $1,424 $2,195 $4

Notes: Numbers may not total due to rounding. Excludes management fees and expenses. a In April 2012, Treasury reclassified about $1 billion in combined payments from five PPIFs as equity capital payments instead of equity distributions. b Treasury received equity warrants from the PPIFs, which give Treasury the right to receive a percentage of any profits that would otherwise be distributed to the private partners in excess of their contributed capital.

Source: Treasury, response to SIGTARP data call, 7/5/2012. 138 special inspector general I troubled asset relief program

PPIP Manager Invesco Sells Portfolio Invesco was the first of the eight remaining PPIP funds to sell its portfolio. It announced on April 3, 2012, that it had sold all of its PPIP-eligible securities at a profit and returned “substantially all of its proceeds” to investors, including Treasury.493 Invesco said the fund, which began in October 2009, earned an internal rate of return of about 18%.494 Over the life of the fund, which invested solely in RMBS, according to Treasury, it received approximately $18 million in interest, $3 million in equity warrant proceeds, and $135 million in cumulative realized gains, net of fees and expenses, on Treasury’s equity investment of $581 million.495 Treasury also loaned $1.2 billion to the Invesco fund, which was repaid with interest.496 While Invesco’s PPIF no longer holds any RMBS, Treasury said Invesco had kept about $2.3 million in temporary investments to pay final audit and other expenses of the fund until it is formally liquidated in the next few months.497 The Invesco fund invested $2.3 billion of the $3.4 billion in total private and Government purchasing power available to it.

Fund Performance The program’s three-year investment period draws to a close in the final months of 2012 for the remaining PPIP funds. Four funds — AG GECC, AllianceBernstein, BlackRock, and Wellington — face October deadlines to make any additional investments in eligible securities. The investment period terminates in November for RLJ Western and Marathon, and in December for Oaktree. Each fund has reported rates of return for its portfolio of investments during the past two and one-half years, based on a methodology requested by Treasury. The lifetime net internal rates of return range from 7.4% for Wellington to 21.2% for Oaktree. Each PPIF’s performance — its gross and net returns since inception — as reported by PPIP managers, is listed in Table 2.38. The data in Table 2.38 constitutes a snapshot of the funds’ performance during the quarter ended June 30, 2012, and may not predict the funds’ performance over the long term. According to some PPIP managers, it would be premature to draw any long-term conclusions because, among other reasons, some managers have not fully executed their investment strategies or fully drawn down Treasury’s capital or debt obligations. quarterly report to congress I July 25, 2012 139

TABLE 2.38 PPIF investment status, AS OF 6/30/2012 Internal Rate of 1-Month 3-Month Cumulative Return Since Return Return Since Inception Inception Manager (percent) (percent)a (percent) (percent)b Investment Period Open

AG GECC PPIF Master Gross 4.60 2.57 78.91 19.64 Fund, L.P. Net 4.59 2.48 75.64 19.16 AllianceBernstein Legacy Gross 3.51 2.45 51.29 17.00 Securities Master Fund, L.P. Net 3.54 2.21 45.57 15.52 Gross 2.01 1.88 58.91 17.22 BlackRock PPIF, L.P. Net 1.97 1.64 53.96 15.88

Marathon Legacy Gross 2.12 2.23 52.89 15.15 Securities Public-Private Investment Partnership, L.P. Net 2.06 1.95 46.37 13.72 Gross 6.12 3.99 55.32 22.65 Oaktree PPIP Fund, Inc. Net 6.09 3.71 46.33 21.17 RLJ Western Asset Gross 2.15 1.06 58.03 18.78 Public/Private Master Fund, L.P. Net 2.11 0.78 53.25 17.45 Wellington Management Gross 2.07 1.75 30.98 8.75 Legacy Securities PPIF Master Fund, LP Net 2.01 1.75 26.37 7.35 Investment Period Closed UST/TCW Senior Mortgage Securities Net N/A N/A N/A N/A Fund, L.P.c Invesco Legacy Securities Master Fund, Net N/A N/A 33.50 18.24 L.P.

Notes: The performance indicators are listed as reported by the PPIP managers without further analysis by SIGTARP. The net returns include the deduction of management fees and partnership expenses attributable to Treasury. a Time-weighted, geometrically linked returns. b Dollar-weighted rate of return. c According to Treasury, rates of return are not available for TCW because it operated for only three months before withdrawing from the program.

Sources: PPIF Monthly Performance Reports submitted by each PPIP manager, June 2012, received 7/16/2012 and 7/17/2012; Treasury response to SIGTARP data call, 7/18/2012. 140 special inspector general I troubled asset relief program

Figure 2.3 Securities Purchased by PPIFs AGGREGATE COMPOSITION OF PPIF According to their agreements with Treasury, PPIP managers may trade in both PURCHASES, AS OF 6/30/2012 RMBS and CMBS, except for Oaktree, which may purchase only CMBS.498 Figure Percentage of $19.8 Billion 2.3 shows the collective value of securities purchased by all PPIFs as of June 30, 2012, broken down by RMBS and CMBS.

CMBS PPIF investments can be classified by underlying asset type. All non-agency RMBS investments are considered residential. The underlying assets are mortgages 28% for residences with up to four dwelling units. For CMBS, the assets are com-

72% RMBS mercial real estate mortgages: office, retail, multi-family, hotel, industrial (such as warehouses), mobile home parks, mixed-use (combination of commercial and/ or residential uses), and self-storage. Figure 2.4 breaks down CMBS investment distribution by sector. As of June 30, 2012, the aggregate CMBS portfolio had large

Notes: Numbers may be affected by rounding. Calculated concentrations in office (31%) and retail (28%) loans. based on monthly data supplied by the PPIF managers. Non-agency RMBS and CMBS can be classified by the degree of estimated Source: PPIF Monthly Performance Reports, June 2012. default risk (sometimes referred to as “quality”). Investors are most concerned about whether borrowers will default and the underlying collateral will be sold at a Figure 2.4 loss. Estimated risk, or quality, attempts to measure the likelihood of that outcome. AGGREGATE CMBS PURCHASES BY There are no universal standards for ranking mortgage quality, and the designations SECTOR, AS OF 6/30/2012 vary depending on context. In general, the highest-quality rankings are granted to Percentage of $5.5 Billion mortgages that have the strictest requirements regarding borrower credit, complete-

Others ness of documentation, and underwriting standards. Treasury characterizes these investment-quality levels of risk for the types of mortgage loans that support non- 8% 499 Lodging/ 31% agency RMBS as follows: Hotel 12% • Prime — mortgage loan made to a borrower with good credit that generally Industrial 6% meets the lender’s strictest underwriting criteria. Non-agency prime loans 15% Multi-family 28% generally exceed the dollar amount eligible for purchase by GSEs (jumbo loans)

Retail but may include lower-balance loans as well. • Alt-A — mortgage loan made to a borrower with good credit but with limited

Notes: Numbers may be affected by rounding. Calculated documentation or other characteristics that do not meet the standards for prime based on monthly data supplied by the PPIF managers. loans. An Alt-A loan may have a borrower with a lower credit rating, a higher Source: PPIF Monthly Performance Reports, June 2012. loan-to-value ratio, or limited or no documentation, compared with a prime loan. • Subprime — mortgage loan made to a borrower with a poor credit rating. • Option Adjustable Rate Mortgage (“Option ARM”) — mortgage loan that gives the borrower a set of choices about how much interest and principal to pay each month. This may result in negative amortization (an increasing loan principal balance over time). • Other (RMBS) — RMBS that do not meet the definitions for prime, Alt-A, subprime, or option ARM but meet the definition of “eligible assets” above. quarterly report to congress I July 25, 2012 141

Treasury characterizes CMBS according to the degree of “credit enhancement” supporting them:500

• Super Senior — most senior originally rated AAA bonds in a CMBS securitization with the highest level of credit enhancement. Credit enhancement refers to the percentage of the underlying mortgage pool by balance that must be written down before the bond suffers any losses. Super senior bonds often compose approximately 70% of a securitization and, therefore, have approximately 30% credit enhancement at issuance. • AM (Mezzanine) — mezzanine-level originally rated AAA bond. Creditors receive interest and principal payments after super senior creditors but before junior creditors.501 AM bonds often compose approximately 10% of a CMBS securitization. • AJ (Junior) — the most junior bond in a CMBS securitization that attained a AAA rating at issuance. • Other (CMBS) — CMBS that do not meet the definitions for super senior, AM, or AJ but meet the definition of “eligible assets” above.

Figure 2.5 and Figure 2.6 show the distribution of non-agency RMBS and CMBS investments held in PPIP by respective risk levels, as reported by PPIP managers.

Figure 2.5 Figure 2.6 AGGREGATE RMBS PURCHASES BY AGGREGATE CMBS PURCHASES BY QUALITY, AS OF 6/30/2012 QUALITY, AS OF 6/30/2012 Percentage of $14.3 Billion Percentage of $5.5 Billion

Other - RMBS a 0% Other - CMBS 1% Super Senior Option ARM 10% 7% Prime Subprime 12% 29%

AJ (Junior) 33% 59% AM (Mezzanine)

Alt-A 50%

Notes: Numbers may be affected by rounding. Calculated Notes: Numbers may be affected by rounding. Calculated based on monthly data supplied by the PPIF managers. based on monthly data supplied by the PPIF managers. a The actual percentage for “Other RMBS” is 0.32%.

Source: PPIF Monthly Performance Reports, June 2012. Source: PPIF Monthly Performance Reports, June 2012. 142 special inspector general I troubled asset relief program

Non-agency RMBS and CMBS can be classified geographically, according to the states where the underlying mortgages are held. Figure 2.7 and Figure 2.8 show the states with the greatest representation in the underlying non-agency RMBS and CMBS investments in PPIFs, as reported by PPIP managers.

Figure 2.7 Figure 2.8 AGGREGATE GEOGRAPHICAL AGGREGATE GEOGRAPHICAL DISTRIBUTION — PERCENT OF DISTRIBUTION — PERCENT OF TOTAL RMBS, AS OF 6/30/2012 TOTAL CMBS, AS OF 6/30/2012

40% 42% 15% 15%

30 10 12%

20 8% 7% 5 10 9% 3% 6% 0 0 CA FL NY VA CA NY TX FL

Notes: Only states with the largest representation shown. Notes: Only states with largest representation shown. Calculated Calculated based on monthly data supplied by PPIF managers. based on monthly data supplied by the PPIF managers.

Source: PPIF Monthly Performance Reports, June 2012. Source: PPIF Monthly Performance Reports, June 2012.

Non-agency RMBS and CMBS can also be classified by the delinquency of the underlying mortgages. Figure 2.9 and Figure 2.10 show the distribution of non-agency RMBS and CMBS investments held in PPIP by delinquency levels, as reported by PPIP managers.

Figure 2.9 Figure 2.10 AGGREGATE AVERAGE RMBS AGGREGATE AVERAGE CMBS DELINQUENCIES BY MARKET VALUE, DELINQUENCIES BY MARKET VALUE, AS OF 6/30/2012 AS OF 6/30/2012 Percentage of $14.3 Billion Percentage of $5.5 Billion

1% 30−59 Days 60+ Days 11% 60+ Days 27%

30−59 3% 70% Current Days 88% Current

Notes: Numbers may be affected by rounding. Calculated Notes: Numbers may be affected by rounding. Calculated based on monthly data supplied by the PPIF managers. based on monthly data supplied by the PPIF managers.

Source: PPIF Monthly Performance Reports, June 2012. Source: PPIF Monthly Performance Reports, June 2012. quarterly report to congress I July 25, 2012 143

Unlocking Credit for Small Businesses (“UCSB”)/Small Business Administration (“SBA”) Loan Support Initiative 7(a) Loan Program: SBA loan program On March 16, 2009, Treasury announced the Unlocking Credit for Small guaranteeing a percentage of loans for Businesses (“UCSB”) program, which according to Treasury was designed to small businesses that cannot otherwise encourage banks to increase lending to small businesses. Through UCSB, Treasury obtain conventional loans at reasonable purchased $368.1 million in securities backed by pools of loans from the Small terms. Business Administration’s (“SBA”) 7(a) Loan Program.502 Treasury signed contracts with two pool assemblers, Coastal Securities, Inc. Pool Assemblers: Firms authorized (“Coastal Securities”), and Shay Financial Services, Inc. (“Shay Financial”), on to create and market pools of SBA- March 2, 2010, and August 27, 2010, respectively.503 Under the governing agree- guaranteed loans. ment, EARNEST Partners, on behalf of Treasury, purchased SBA pool certificates from Coastal Securities and Shay Financial without confirming to the counterpar- SBA Pool Certificates: Ownership ties that Treasury was the buyer.504 From March 19, 2010, to September 28, 2010, interest in a bond backed by SBA- Treasury purchased 31 floating-rate 7(a) securities from Coastal Securities and guaranteed loans. Shay Financial for a total of approximately $368.1 million.505 In a series of sales from June 2011 through January 2012, Treasury sold all its SBA 7(a) securities, for total proceeds of $334.9 million, ending the program.506 For more information on SBA 7(a) Loan Program mechanics and TARP According to Treasury, over the life of the program Treasury also had received support for the program, see SIGTARP’s $29 million and $13.3 million in amortizing principal and interest payments, April 2010 Quarterly Report, pages respectively.507 105-106.

For a full listing of the SBA 7(a) securities Treasury purchased through UCSB, including investment amounts, sales proceeds, and other proceeds received by Treasury, see SIGTARP’s April 2012 Quarterly Report, page 134. 144 special inspector general I troubled asset relief program

Automotive Industry Support Programs During the financial crisis, Treasury, through TARP, launched three automotive industry support programs: the Automotive Industry Financing Program (“AIFP”), the Auto Supplier Support Program (“ASSP”), and the Auto Warranty Commitment Program (“AWCP”). According to Treasury, these programs were established “to prevent a significant disruption of the American automotive industry that poses a systemic risk to financial market stability and will have a negative effect on the economy of the United States.”508 As of June 30, 2012, General Motors Company (“New GM” or “GM”) and GMAC Inc. (“GMAC”), now Ally Financial Inc. (“Ally Financial”), remain in TARP. AIFP has not expended any TARP funds for the automotive industry since December 30, 2009.509 ASSP, designed to “ensure that automotive suppliers receive compensation for their services and products,” was terminated in April 2010 after all $413.1 million in loans made through it were fully repaid.510 AWCP, a $640.7 million program, was designed to assure car buyers that the warranties on any vehicles purchased during the bankruptcies of General Motors Corp. (“Old GM”) and Chrysler LLC (“Old Chrysler”) would be guaranteed by the Government. It was terminated in July 2009 after all loans under the program were fully repaid upon the companies’ emergence from bankruptcy.511 Treasury obligated approximately $84.8 billion through these three programs to Old GM and GM, Ally Financial, the Chrysler entities (Chrysler Holding LLC [now called CGI Holding LLC], Chrysler LLC [collectively, with CGI Holding LLC, “Old Chrysler”], Chrysler Group LLC [“New Chrysler”]), and Chrysler Financial Services Americas LLC (“Chrysler Financial”).512 Treasury originally obli- gated $5 billion under ASSP but adjusted this amount to $413.1 million to reflect actual borrowings, thereby reducing at that time the total obligation for all automo- tive industry support programs to approximately $81.8 billion. Treasury spent $79.7 billion in TARP funds on the auto bailout because $2.1 billion in loan commit- ments to New Chrysler were never drawn down.513 As of June 30, 2012, Treasury had received approximately $35.2 billion in principal repayments, proceeds from preferred stock redemptions, and stock sale proceeds in addition to $4.8 billion in dividends and interest.514 Taxpayers are owed $44.5 billion in TARP auto funds. This includes the $2.9 billion loss on Chrysler. The amount and types of Treasury’s outstanding AIFP investments have changed over time as a result of principal repayments, preferred stock redemptions by the issuer, Treasury’s sale of common stock, old loan conversions (into equity), and post-bankruptcy restructurings. Treasury now holds 32% of the common equity in New GM.515 Treasury also holds an administrative claim in Old GM’s bankruptcy with an outstanding principal amount of approximately $849.2 million based on loans made to Old GM. However, according to Treasury, it does not expect to recover any significant additional proceeds from this claim.516 Additionally, Treasury holds $5.9 billion in mandatorily convertible preferred shares (“MCP”) and approximately 74% of the common equity in Ally Financial.517 On July 21, 2011, Treasury sold to Fiat North America LLC (“Fiat”) Treasury’s remaining equity ownership interest in New quarterly report to congress I July 25, 2012 145

Chrysler and Treasury’s rights to receive proceeds under an agreement with the United Auto Workers (“UAW”) retiree trust pertaining to the trust’s shares in New Chrysler. Treasury retains the right to recover certain proceeds from Old Chrysler’s bankruptcy but, according to Treasury, it is unlikely to fully recover this claim. Treasury’s investments in these three programs and the companies’ payments of principal are summarized in Table 2.39 and, for Chrysler and GM, categorized by the timing of the investment in relation to the companies’ progressions through bankruptcy.

Table 2.39 TARP Automotive programs expenditures and payments, AS OF 6/30/2012 ($ BILLIONS) Chrysler Ally Financial Inc. Chryslera GMb Financial (formerly GMAC)d Total Pre-Bankruptcy AIFP $4.0 $19.4 $1.5 $17.2 $42.1 ASSPc 0.1 0.3 0.4 AWCP 0.3 0.4 0.6 Subtotal $4.4 $20.1 $1.5 $17.2 $43.1 In-Bankruptcy (DIP Financing) AIFP $1.9 $30.1 $32.0 Subtotal $1.9 $30.1 $32.0 Post-Bankruptcy (Working Capital) AIFP $4.6 $4.6 Subtotal $4.6 $4.6 Subtotals by Program: AIFP $78.7 ASSP 0.4 AWCP 0.6 Total Expenditures $10.9 $50.2 $1.5 $17.2 $79.7 Principal Repaid to ($8.0) ($23.2) ($1.5) ($2.5)e ($35.2) Treasury Net Expenditures $2.9 $27.0 $0.0 $14.7 $44.5 Total Loss on $2.9 $2.9 Investment

Notes: Numbers may not total due to rounding. a Total repayments including Treasury’s sale to Fiat of its equity ownership interest in New Chrysler and Treasury’s rights to receive proceeds under an agreement with the United Auto Workers (“UAW”) retiree trust pertaining to the trust’s shares in New Chrysler for $560 million on July 21, 2011. b Including GM’s debt payments of $50 million on March 31, 2011, $45 million on April 5, 2011, approximately $15.9 million on May 3, 2011, approximately $0.1 million on December 16, 2011, approximately $18.9 million on December 23, 2011, and approximately $6.7 million on January 11, 2012. c The final commitment and repayment amounts reflect the total funds expended under the ASSP loans. Treasury initially obligated $5 billion under ASSP. Treasury adjusted its obligation to $0.4 billion. d Total expenditures include $884 million loan to Old GM, which Old GM invested in GMAC in January 2009. e On March 2, 2011, Treasury entered into an underwriting offering of its Ally Financial TRUPS, which resulted in approximately $2.5 billion in principal repayment to Treasury.

Source: Treasury, Transactions Report, 6/27/2012. 146 special inspector general I troubled asset relief program

Automotive Industry Financing Program Treasury provided $79.7 billion through AIFP to support automakers and their financing arms in order to “avoid a disorderly bankruptcy of one or more auto[motive] companies.”518 As of June 30, 2012, Treasury had received approxi- mately $4.8 billion in dividends and interest from participating companies.519 Of AIFP-related loan principal repayments and share sale proceeds, Treasury has received approximately $22.5 billion related to its GM investment, $7.6 billion related to its Chrysler investment, $2.5 billion related to its Ally Financial/GMAC investment, and $1.5 billion related to its Chrysler Financial investment.520 As discussed below, additional payments of $640.7 million and $413.1 million, respec- tively, were received under AWCP and ASSP.521 Taxpayers are still owed $27 billion for the TARP investment in GM and $14.7 billion for the TARP investment in Ally Financial.522 Taxpayers suffered a $2.9 billion loss on the TARP investment in Chrysler. Chrysler Financial fully repaid the TARP investment.

GM GM is still in TARP and taxpayers are owed $27 billion for the investment in GM. In return for its investment, as of June 30, 2012, Treasury holds 32% of GM’s common stock. Through June 30, 2012, Treasury had provided approximately $49.5 billion to GM through AIFP. Of that amount, $19.4 billion was provided before bankruptcy and $30.1 billion was provided as financing during bankruptcy. During bankruptcy proceedings, Treasury’s loans were converted into common or preferred stock in New GM or debt assumed by New GM. As a result of Old GM’s bankruptcy, Treasury’s investment in Old GM was converted to a 60.8% common equity stake in New GM, $2.1 billion in preferred stock in New GM, and a $7.1 billion loan to New GM ($6.7 billion through AIFP and $360.6 million through AWCP). As part of a credit agreement with Treasury, $16.4 billion in TARP funds were placed in an escrow account that GM could access only with Treasury’s permission.523 In addition, Treasury has a claim in Old GM’s bankruptcy but does not expect to recover any significant additional proceeds from this claim.524

Debt Repayments As of June 30, 2012, the GM entities had made approximately $756.7 million in dividend and interest payments to Treasury under AIFP.525 New GM repaid the $6.7 billion loan provided through AIFP with interest, using a portion of the escrow account that had been funded with TARP funds. What remained in escrow was released to New GM with the final debt payment by New GM.526

Sale of GM Common Stock and GM’s Repurchase of Preferred Shares From Treasury In November and December 2010, New GM successfully completed an initial public offering (“IPO”) in which New GM’s shareholders sold 549.7 million shares of common stock and 100 million shares of Series B mandatorily convertible preferred shares (“MCP”) for total gross proceeds of $23.1 billion.527 As part of the quarterly report to congress I July 25, 2012 147

IPO, Treasury sold 412.3 million common shares for $13.5 billion in net proceeds (after taking into account underwriting fees associated with the IPO), reducing its number of common shares to 500.1 million and its ownership in New GM from 60.8% to 33.3%.528 On December 15, 2010, GM repurchased Treasury’s Series A preferred stock (83.9 million shares) for total proceeds of $2.1 billion and a capital gain to Treasury of approximately $41.9 million.529 On January 13, 2011, Treasury’s ownership in GM was diluted from 33.3% to 32% as a result of GM contributing 61 million of its common shares to fund GM’s hourly and salaried pension plans.530 In order to recoup its total investment in GM, Treasury will need to recover an additional $27 billion in proceeds. This translates to an average of $53.98 per share on its remaining common shares in New GM, not taking into account dividend 531 and interest payments received from the GM entities. The break-even price For more on the results of GM’s — $53.98 per share — is calculated by dividing the $27 billion (the amount that November 2010 IPO, see SIGTARP’s remains outstanding to Treasury) by the 500.1 million remaining common shares January 2011 Quarterly Report, owned by Treasury. If the $756.7 million in dividends and interest received by page 163. Treasury is included in this computation, then Treasury will need to recover $26.2 billion in proceeds, which translates into a break-even price of $52.39 per share, not taking into account other fees or costs associated with selling the shares.

Chrysler Chrysler is no longer in TARP and taxpayers suffered a $2.9 billion loss on the TARP investment in Chrysler. Through October 3, 2010, Treasury made approximately $12.5 billion available to Chrysler directly through AIFP in three stages to three corporate entities: $4 billion before bankruptcy to CGI Holding LLC — the parent company of Old Chrysler (the bankrupt entity) — and Chrysler Financial; $1.9 billion in financing to Old Chrysler during bankruptcy; and $6.6 billion to New Chrysler.532 In consideration for its assistance to Chrysler, Treasury received 9.9% of the common equity in New Chrysler. On April 30, 2010, following the bankruptcy court’s approval of the plan of liquidation for Old Chrysler, the $1.9 billion loan was extinguished without repay- ment. In return, Treasury retained the right to recover proceeds from the sale of assets that were collateral for the loan from the liquidation of Old Chrysler assets.533 According to Treasury, it is unlikely to fully recover its initial investment of approximately $1.9 billion related to the loan.534 As of June 30, 2012, Treasury had recovered approximately $57.4 million from asset sales by Old Chrysler.535 Of the $4 billion lent to Old Chrysler’s parent company, CGI Holding LLC, before bankruptcy, $500 million of the debt was assumed by New Chrysler while the remaining $3.5 billion was held by CGI Holding LLC.536 Under the terms of this loan agreement, as amended on July 23, 2009, Treasury was entitled to the greater of approximately $1.4 billion or 40% of any proceeds that Chrysler Financial paid to its parent company, CGI Holding LLC, after certain other distributions were made.537 On May 14, 2010, Treasury accepted $1.9 billion in full satisfaction of its $3.5 billion loan to CGI Holding LLC.538 On May 24, 2011, New Chrysler used the proceeds from a series of refinanc- ing transactions and an equity call option exercised by Fiat to repay the loans from 148 special inspector general I troubled asset relief program

Treasury and the Canadian government.539 The repaid loans were made up of $6.6 billion in post-bankruptcy financing (of which $2.1 billion was never drawn down), and the $500 million in debt assumed by New Chrysler.540 Treasury terminated New Chrysler’s ability to draw the remaining $2.1 billion TARP loan.541 Over time, Fiat increased its ownership of New Chrysler. On July 21, 2011, Treasury sold to Fiat for $500 million Treasury’s remaining equity ownership inter- est in New Chrysler. Treasury also sold to Fiat for $60 million Treasury’s rights to receive proceeds under an agreement with the United Auto Workers retiree trust pertaining to the trust’s shares in New Chrysler.542 Treasury also retains the right to recover proceeds from Old Chrysler’s bankruptcy, but, according to Treasury, it is unlikely to fully recover its $1.9 billion loan. As of July 21, 2011, the Chrysler entities made approximately $1.2 billion in interest payments to Treasury under AIFP.543

Automotive Financing Companies Ally Financial, formerly known as GMAC Ally Financial is still in TARP and taxpayers are owed $14.7 billion for the TARP investment in Ally Financial. In return for its investment, as of June 30, 2012, Treasury holds approximately 74% of Ally Financial’s common stock and $5.9 billion worth of mandatorily convertible preferred shares (“MCP”). On December 29, 2008, Treasury purchased $5 billion in senior preferred equity from GMAC and received an additional $250 million in preferred shares through warrants that Treasury exercised immediately at a cost of $2,500.544 In January 2009, Treasury loaned Old GM $884 million, which it invested in GMAC.545 In May 2009, Treasury exchanged this $884 million debt for a 35.4% common equity ownership in GMAC.546 On May 21, 2009, Treasury made an additional investment in GMAC when it purchased $7.5 billion of MCP and received warrants that Treasury immediately exercised for an additional $375 million in MCP at an additional cost of approxi- mately $75,000.547 On December 30, 2009, Treasury invested another $3.8 billion in GMAC, and Treasury received $2.5 billion in trust preferred securities (“TRUPS”) and $1.3 billion in MCP. Treasury also received warrants, which were immediately exercised, to purchase an additional $127 million in TRUPS and $62.5 million in MCP at an additional cost of approximately $1,270 and $12,500, respectively.548 Additionally, Treasury converted $3 billion of its MCP into GMAC common stock, increasing its common equity ownership from 35.4% to 56.3%.549 On May 10, 2010, GMAC changed its name to Ally Financial Inc.550 On December 30, 2010, Treasury announced the conversion of $5.5 billion of its MCP in Ally Financial to common equity, increasing Treasury’s ownership stake in Ally Financial’s common equity from 56.3% to 73.8%.551 As a result, Treasury will no longer receive the quarterly dividend payments that Ally Financial was required to pay on the $5.5 billion of MCP. On March 7, 2011, Treasury sold its $2.7 billion in TRUPS in Ally Financial in a public offering, resulting in $2.7 billion in total proceeds to Treasury.552 quarterly report to congress I July 25, 2012 149

As a result of its conversion of MCP to common stock in Ally Financial, and Figure 2.11 for as long as Treasury maintains common equity ownership at or above 70.8%, OWNERSHIP IN ALLY FINANCIAL/GMAC Treasury has the right to appoint two additional directors, in addition to the four Treasury has already appointed to Ally Financial’s board, increasing the size of the board to 11 members.553 As of June 30, 2012, Treasury had not exercised its right GM Trust 554 Third-Party to fill its remaining two director positions. The conversion of $5.5 billion of Investors 10% Treasury’s MCP diluted the shares of other existing shareholders in Ally Financial. 8% Following the conversion, the private equity firm Cerberus Capital Management, Cerberus 9% United States 74% Department L.P. (“Cerberus”) held 8.7%, third-party investors collectively held 7.6%, an inde- of the pendently managed trust owned by New GM held 5.9%, and New GM directly held Treasury a 4% stake in Ally Financial’s common equity.555 New GM’s interests have been consolidated in the trust. Figure 2.11 shows the breakdown of common equity ownership in Ally Financial as of June 30, 2012. Notes: Numbers may be affected by rounding. Note: Numbers may not total due to rounding. Source: Ally Financial, Inc.: “Ownership Structure,” http://media. Proposed Ally Financial IPO Soally.com/index.php?s=51,urce: : Ally Financial, Inc.: accessed “Ownership 7/9/2012. Structure,” media.ally.com/index.php?s=51, accessed 4/21/2012. On March 31, 2011, Ally Financial filed a Form S-1 Registration statement for an IPO with the Securities and Exchange Commission (“SEC”).556 The document includes a prospectus relating to the issuance of Ally Financial common stock.557 The prospectus also outlines certain aspects of Ally Financial’s business operations and risks facing the company.558 Ally Financial stated that the proposed IPO would consist of “common stock to be sold by the U.S. Department of the Treasury.”559 Ally Financial has disclosed additional details about its proposed IPO in several amended Form S-1 Registration statements filed over time with the SEC, the most recent on April 12, 2012.560 Concurrent with the proposed IPO, Treasury plans to convert $2.9 billion of its existing $5.9 billion of MCP into common stock.561 Treasury will exchange the remaining $3 billion of its MCP into so-called tangible equity units, a type of preferred stock, and will offer a portion of these tangible equity units alongside the proposed common equity offering.562 Treasury agreed to be named as a seller but retained the right to decide whether to sell any of its 73.8% ownership of Ally Financial’s common stock and in what amounts.563 As of June 30, 2012, taxpayers are owed $14.7 billion for the TARP investment in Ally Financial. In return for the TARP investment Treasury holds 73.8% of Ally Financial’s common stock and $5.9 billion in MCP.564 Treasury also exercised war- rants at a cost of $90,015 to purchase securities with a par value of approximately $688 million: $250 million in preferred shares (which were later converted to MCP) and $438 million in additional MCP.565 As of June 30, 2012, Ally Financial had made approximately $2.9 billion in dividend and interest payments to Treasury.566

Ally Financial Subsidiary Files for Chapter 11 Bankruptcy Relief On May 14, 2012, Ally Financial announced that its mortgage subsidiary, Residential Capital, LLC, and certain of its subsidiaries (“ResCap”) filed for bankruptcy court relief under Chapter 11 of the U.S. Bankruptcy Code, and that it was exploring strategic alternatives for its international operations, which include 150 special inspector general I troubled asset relief program

auto finance, insurance, and banking and deposit operations in Canada, Mexico, Europe, the U.K., and South America.567 Ally Financial also announced that as a result of the Chapter 11 filing, ResCap will be deconsolidated from Ally Financial’s financial statements and Ally Financial’s equity interest in ResCap will be written down to zero.568

Chrysler Financial Chrysler Financial is no longer in TARP, having fully repaid the TARP investment. In January 2009, Treasury loaned Chrysler Financial $1.5 billion under AIFP to support Chrysler Financial’s retail lending. On July 14, 2009, Chrysler Financial fully repaid the loan in addition to approximately $7.4 million in interest payments.569 In connection with the $3.5 billion pre-bankruptcy loan remaining with CGI Holding LLC, the parent company of Old Chrysler (the bankrupt entity) and Chrysler Financial, Treasury was entitled to the greater of approximately $1.4 billion or 40% of any proceeds that Chrysler Financial paid to its parent company, CGI Holding LLC, after certain other distributions were made.570 On May 14, 2010, Treasury accepted $1.9 billion in full satisfaction of its $3.5 billion loan to CGI Holding LLC, thereby relinquishing any interest in or claim on Chrysler Financial.571 Seven months later, on December 21, 2010, TD Bank Group announced it had agreed to purchase Chrysler Financial from Cerberus, the owner of CGI Holding LLC, for approximately $6.3 billion.572 TD Bank Group completed its acquisition of Chrysler Financial on April 1, 2011, and has rebranded Chrysler Financial under the TD Auto Finance brand.573

Auto Supplier Support Program (“ASSP”) On March 19, 2009, Treasury announced a commitment of $5 billion to ASSP to “help stabilize the automotive supply base and restore credit flows in a critical sector of the American economy.”574 Because of concerns about the auto manufacturers’ ability to pay their invoices, suppliers had not been able to borrow from banks by using their receivables as collateral. ASSP enabled automotive parts suppliers to access Government-backed protection for money owed to them for the products they shipped to manufacturers. Under the program, Treasury made loans for GM ($290 million) and Chrysler ($123.1 million) that were fully repaid in April 2010.575

Auto Warranty Commitment Program (“AWCP”) AWCP was designed to bolster consumer confidence by guaranteeing Chrysler and GM vehicle warranties during the companies’ restructuring in bankruptcy.576 Treasury obligated $640.7 million to this program — $360.6 million for GM and $280.1 million for Chrysler.577 On July 10, 2009, the companies fully repaid Treasury upon their exit from bankruptcy.578 AIG Remains in TARP Section 3 as the Largest TARP Investment 152 special inspector general I troubled asset relief program quarterly report to congress I July 25, 2012 153

Introductioni Treasury’s largest TARP investment is American International Group, Inc., (“AIG”) with Treasury holding 61% of AIG’s common stock as of June 30, 2012. Once the world’s largest insurance company, AIG became a central figure in the fixed-income securities market beginning in the 1990s by underwriting the risk on a number of structured products, including volatile residential mortgage-backed securities (“RMBS”). In 2008, AIG suffered a severe liquidity crisis and credit downgrades due to exposures on risky derivatives related to mortgage-backed securities in its subsidiary, AIG Financial Products Corporation (“AIGFP”). The Government, first through the Federal Reserve Bank of New York (“FRBNY”), and later through TARP’s Systemically Significant Failing Institutions (“SSFI”) program, bailed out AIG at a price tag of $161 billion.ii Taxpayers are still owed more than half of the original TARP investment — a significant $36 billion of the $67.8 billion TARP investment. According to Treasury’s TARP books and records, taxpayers have realized losses on the TARP investment from an accounting standpoint of $5.5 billion on Treasury’s sale of AIG stock. However, given the January 2011 restructuring of the FRBNY and Treasury investment, according to Treasury, the Government overall has made a gain thus far on the stock sales. According to Treasury, this leaves $30.4 billion in TARP funds outstanding.579 In return for that investment, Treasury holds 1.06 billion shares of AIG common stock (61% of AIG’s common stock). Post-bailout, there have been several changes to AIG’s corporate governance, sales of AIG’s subsidiaries and assets, and a reduction in AIG’s exposure to risky derivatives. As controlling shareholder, Treasury has consented to or been consulted on many of these changes. Largely as a result of assets sales, by the end of 2011, assets had fallen from $1 trillion in 2007 to $552.4 billion.580 Revenue decreased from $81.5 billion in 2007 to $64.3 billion in 2011.581 These are large numbers by any measure. AIG remains one of the world’s largest insurance companies, and is the third largest in the United States by assets.582 Although AIG has sold several foreign life insurance subsidiaries, it still has 219 subsidiaries (compared with 245 in 2007) and continues to operate in more than 130 countries.583 AIGFP continues to exist, but with far less exposure, due to efforts by FRBNY to remove exposure and efforts by AIG to further reduce exposure. AIG has operated in a changing regulatory environment. How it will be regulat- ed in the future will not be known until Federal regulators designate which non- bank financial companies are systemically important financial institutions (“SIFI”) as called for in the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”).584 There is no stated time when this designation will be made. For more than two years, AIG has had no consolidated banking regulator of its non-insurance financial business. AIG continues to operate its non-insurance financial business today, albeit with far less exposure than in 2008, in part due to Government action. Before it was abolished, the Office of Thrift Supervision i This discussion is based on publicly available information. It is not an audit or evaluation under the Inspector General Act of 1978 as amended. ii ssFI had only one participant, AIG. 154 special inspector general I troubled asset relief program

(“OTS”) was AIG’s consolidated regulator based on AIG’s ownership of a small thrift. OTS officials admitted failures in their regulation of AIG. If AIG is designat- ed a SIFI or recognized as a savings and loan holding company, the Federal Reserve will become AIG’s primary regulator and heightened regulatory requirements will apply. Regulatory oversight of AIG will be an enormous undertaking, presenting challenges in examination, enforcement, and supervision, particularly as it relates to risk, given AIG’s history. Effective, comprehensive, and rigorous regulation of AIG is vital to ensure that history does not repeat itself.

Rise and Fall of AIG Prior to TARP In the years before the Government bailout, AIG had a solid reputation, reliable earnings, and was generally perceived to be one of the stronger companies in the United States.585 Core insurance operations encompassed general insurance, including property and casualty, commercial, industrial, and life insurance, including annuities and retirement services. Insurance operations (including general insurance, life insurance, and retirement services) accounted for nearly 90% of AIG’s revenue, which is still the case today. Approximately half of the company’s revenue during this period came from outside the United States, largely from Asia. For decades, the company’s AAA credit rating helped bolster its insurance operations and allowed AIG to use its low cost of funds as leverage to boost non-insurance lines, including aircraft leasing and consumer finance. AIG’s credit rating also increased its attractiveness as a counterparty in capi- tal markets, helping the company expand its product base. Over the years, AIG expanded from insurance into other financial businesses. One of these was AIGFP, a subsidiary created in 1987 to conduct sophisticated financial market trades, many involving complex derivatives. Derivatives are financial instruments that can be used to hedge risks or to bet on market price trends, and are typically derived from underlying assets such as stocks, bonds, loans, currencies, or commodities. By the 1990s, AIGFP was a vital part of the fixed-income securities market as it related to RMBS and commercial mortgage-backed securities (“CMBS”). RMBS are finan- cial instruments backed by a pool of residential mortgage loans; CMBS are backed by a pool of commercial mortgage loans. The loans are packaged into bundles of loans sharing similar characteristics, and then sold to investors. This process, called securitization, removes the loans from the balance sheets of banks and mortgage lenders and gives them cash to issue new loans. The RMBS and CMBS were often further pooled into bundles known as collateralized debt obligations (“CDOs”). In 1998, AIGFP began to sell insurance-like contracts called credit default swaps (“CDS”) that provided protection to investors against losses from RMBS and CMBS that had been bundled into CDOs. The firm purchasing the CDS (the “counterparty” to AIG), would pay AIG regular insurance-like premiums and in return AIG would pay the counterparty if the CDO should default. Due to AIG’s AAA rating, AIG was able to enter into these insurance-like contracts without quarterly report to congress I July 25, 2012 155

posting any collateral, a benefit not available to lower-rated firms. Included in these CDS contracts was a provision that, should AIG’s credit rating be downgraded, AIG would be required to post collateral to ensure payment on these contracts. In addi- tion, if the value of the securities that AIG was insuring fell, AIG was contractually obligated to produce quickly the collateral to its counterparty to make up for the difference in the drop in value of the security. That collateral could be either cash or AAA-rated securities. AIGFP sold CDS to firms that bought or sold mortgages or CDOs and to unrelated investors. AIG had grown into a global giant with a top-tier AAA credit rating largely under the direction of one man, Hank Greenberg, who was chief executive officer from 1968 to 2005.586 Beginning in 2004, however, AIG became embroiled in a se- ries of fraud investigations conducted by the Securities and Exchange Commission (“SEC”), the Department of Justice, the New York State Insurance Department, and the New York State Attorney General’s Office. Amid those investigations, AIG’s board forced Greenberg to step down on March 14, 2005. In early May 2005, AIG restated five years of its financial results, cutting $3.9 billion off reported profit over that period and reducing its book value by $2.7 billion.587 Credit rating agencies began questioning AIG’s creditworthiness, and in March and June of 2005, Standard & Poor’s and Moody’s Investors Service downgraded AIG’s AAA rating.588 An S&P executive testified to Congress that the downgrade was due to “the company’s involvement in a number of questionable financial transactions.”589 Starting in the third quarter of 2007 and continuing through 2008, AIG’s financial condition deteriorated, causing a decline in market confidence that, in turn, brought downgrades of AIG’s credit rating and nearly caused the company’s collapse. The trigger and primary cause was AIGFP. While AIGFP’s operating income grew from $131 million in 1994 to $949 million in 2006, closely tracking the boom in the CDS market and the overall derivatives market, the risk involved in this business turned out to be dramatically disproportionate to the income produced.590 As of June 2008, AIG provided more than $400 billion of credit protection, primarily to banks, through AIGFP CDS.591 AIG was exposed to the underlying securities, which were composed largely of subprime mortgages in CDOs that were initially rated AAA. When the U.S. residential mortgage market deteriorated, the securities underly- ing AIGFP’s CDS contracts turned toxic as home prices tumbled and defaults sky- rocketed. The value of the underlying securities plummeted, and the credit ratings of those securities were downgraded. In the fourth quarter of 2007, counterparties began making significant collateral calls to AIG, which only continued. With its credit no longer rated AAA, AIG posted collateral in cash. According to AIG’s 2008 Form 10-K, “From July 1, 2008, to August 31, 2008, the continuing decline in value of the super senior CDO securities protected by AIGFP’s super senior CDS portfolio, together with rating downgrades of such CDO securities, resulted in AIGFP posting additional collateral in an aggregate net amount of $5.9 billion. By the beginning of September 2008, these collateral postings and securities lending requirements were placing increasing stress on AIG parent’s liquidity.”592 156 special inspector general I troubled asset relief program

AIG was also taking risks with the assets of its life insurance subsidiaries through its securities-lending program. AIG made short-term loans of securities it owned and used the fees it earned on those loans to invest in RMBS. The value of these and other AIG real estate-related investments also declined sharply, and con- tributed to further downgrades of AIG’s credit ratings in May 2008. The problems in AIGFP exacerbated the problems in securities lending, and vice versa, as collat- eral demands from both sets of counterparties left the company struggling to find cash. In September 2008, AIG’s credit ratings were downgraded again, triggering additional collateral calls and cash requirements in excess of $20 billion.593 AIG, facing an acute liquidity crisis, was on the brink of collapse, unable to access credit in the private markets and bleeding cash. The Congressional Oversight Panel (“COP”) found that AIG was brought down by the company’s “insatiable appetite for risk and blindness to its own liabilities.”594 According to the Financial Crisis Inquiry Commission (“FCIC”), “AIG failed and was rescued by the Government primarily because its enormous sales of credit default swaps were made without putting up initial collateral, setting aside capital reserves, or hedging its exposure — a profound failure in corporate governance, particularly its risk management practices.”595 AIG sought and received Government support through a revolving credit facility from FRBNY and later TARP funding from Treasury. Officials involved in the res- cue maintained that if AIG went under, it would have taken down other financial institutions and caused havoc around the world.596 Then-Treasury Secretary Henry M. Paulson wrote in his memoir, “An AIG collapse would be much more devas- tating than the Lehman failure because of its size and the damage it would do to millions of individuals whose retirement accounts it insured.”597

Changes at AIG After the Government Bailout Since the Government bailout, AIG has undergone some key changes.iii Some were a direct result of the bailout, including a change in AIG’s capital structure such that the Government took an ownership interest in AIG that was eventually converted to common stock. AIG’s CEO, chairman of the board, and other management and directors have changed, leaving only a few from pre-bailout times. FRBNY created its Maiden Lane II and III investment vehicles to remove a large part of AIG’s liquidity strain caused by its securities-lending portfolio and AIGFP’s exposure to RMBS under its CDS contracts. AIG has sold a number of subsidiaries, primarily foreign life insurance subsidiaries, using proceeds to pay down what was owed to the Government.

iii This discussion does not attempt to chronicle all of the changes at AIG while it has been in TARP. quarterly report to congress I July 25, 2012 157

Changes to Balance Sheet As a Result of the Bailout The bailout and subsequent restructuring significantly altered AIG’s capital structure. Prior to the bailout, AIG’s balance sheet consisted of $95.8 billion in equity and $952.5 billion in total liabilities.598 For the year ended December 31, 2011, AIG’s balance sheet consisted of approximately $105 billion in equity and $441.4 billion in total liabilities.599 In the bailout, the Government injected capital into AIG and became AIG’s largest shareholder.

Changes to AIG’s Corporate Governance After the Government Bailout There have been substantial changes to AIG’s corporate governance while the Government has been AIG’s largest shareholder. Changes in management after the Government bailout included a new CEO, Edward M. Liddy, a former Allstate Corporation CEO, who was appointed in September 2008 after discussions with Treasury. Less than a year after he became CEO, Liddy resigned. Liddy was succeeded in August 2009 by Robert H. Benmosche, former CEO of MetLife, Inc. As of June 30, 2012, out of AIG’s ten executives listed in its Form 10-K, only four were executives with the company prior to TARP. They are William Dooley, executive vice president of investments and financial services, who has been with AIG since 1992; David Herzog, chief financial officer, who was hired in 2005; Brian Schreiber, treasurer, who has been an AIG executive since 2002; and Jay Wintrob, executive vice president of domestic life and retirement services, who has been with AIG since 1999.600 There have been significant changes to AIG’s board while the company has been in TARP. Although Greenberg had long been gone from AIG by the time of the bailout, several board members appointed during Greenberg’s tenure re- mained.601 During the nearly four decades that Greenberg ran AIG, the company’s board of directors played a minor role in governing the company, according to cor- porate governance expert Jennifer S. Taub, an associate law professor at Vermont Law School.602 In the boardroom, there were as many as nine AIG executives seated on the company’s 20-member board of directors in 2002.603 In 2008, the year of the bailout, five AIG directors resigned. Two more followed in May 2009, while two others did not seek re-election.604 Chairman Harvey Golub resigned in July 2010 and was replaced by AIG director Steve Miller, a former chairman of auto parts manufacturer Delphi Corp.605 AIG’s annual proxy mailing to shareholders ahead of its 2009 annual meeting included a new set of corporate governance guidelines adopted by the board. The guidelines trimmed the board size to between 8 and 12 directors and described that a lead independent director would annually review the CEO’s performance.606 As of June 30, 2012, AIG’s 12-member board includes only two people who have been directors since before TARP.607 George L. Miles, Jr., chairman of Chester Engineers, Inc., joined the AIG board in 2005 and Suzanne Nora Johnson, for- mer vice chairman of Goldman Sachs Group, became a director in July 2008. Other current board members include fund managers in charge of Oak Street Management Co. and Marblegate Asset Management; the former head of KPMG LLP’s banking and finance practice; and the ex-CEO of Sears, Roebuck and Co. 158 special inspector general I troubled asset relief program

Two other board directors have significant aircraft industry experience: one is the CEO of aircraft maker Hawker Beechcraft, Inc., and the other once headed Northwest Airlines Corp.608 In April 2010, after AIG had missed five TARP dividend payments, Treasury exercised its right to appoint two directors to the AIG board.609 Treasury named Ronald Rittenmeyer, head of a private equity firm, and Donald Layton, a veteran of JPMorgan Chase.610 Layton resigned from the AIG board in May 2012 to become CEO of Freddie Mac.611 On July 11, 2012, a retired AIG director, Morris W. Offit, was re-elected to the board.612

No Changes to AIG’s Outside Independent Auditor While in TARP AIG has not changed its outside auditor while it has been in TARP. PricewaterhouseCoopers has been AIG’s auditor for decades and continues to serve in that role.

FRBNY Took Significant Mortgage-Backed Securities Off AIG’s Books AIG held nearly $141 billion worth of RMBS, CMBS, derivatives, and asset- backed securities investments on its books at the end of 2007.613 The holdings were slashed to $34.6 billion at the end of 2010, in part due to the actions taken by FRBNY.614 The 2008 liquidity pressures on AIG were concentrated in two areas, securities lending and CDS, insurance-like protection on CDOs (generally bundles of RMBS). As part of the Federal bailout, most of the securities involved in those areas were unloaded into two newly created special purpose vehicles: Maiden Lane II (which held the RMBS associated with AIG’s securities-lending program) and Maiden Lane III (which held the underlying CDO securities associated with the CDS). Maiden Lane is the street behind the FRBNY building in the heart of Manhattan’s financial district. FRBNY made a $19.5 billion loan to Maiden Lane II which was used to purchase subprime RMBS in AIG’s securities-lending portfolio that FRBNY put into Maiden Lane II. FRBNY had sole control over Maiden Lane II and sales of the RMBS in it.615 Last year, AIG offered to buy the entire portfolio for $15.7 billion. The FRBNY declined and instead held a series of auctions for the assets.616 Investment banks that won the auctions turned around and re-sold the securities to clients, including AIG. The FRBNY also created Maiden Lane III as a vehicle to buy from AIG’s counterparties the CDOs that AIGFP had insured through CDS. The purchase of the underlying CDOs terminated AIGFP’s obligations under the CDS con- tracts. SIGTARP previously reported in its audit, “Factors Affecting Efforts to Limit Payments to AIG Counterparties,” issued in November 2009, that “FRBNY decided to pay the counterparties the full market value of the CDOs, which, when combined with the already posted collateral, meant that the counterparties were effectively paid full face (or par) value of the credit default swaps, an amount far above their market value at the time.”617 The face value amount of the securities was $62.1 billion. AIG’s counterparties retained $35 billion in collateral posted by quarterly report to congress I July 25, 2012 159

AIG and were paid an additional $26.8 billion.618 The FRBNY began auctioning Figure 3.1 securities from Maiden Lane III in April 2012. AIG’S MAJOR RECENT FOREIGN Maiden Lane III did not remove all of AIGFP’s exposure on CDS contracts. For ASSET SALES example, FRBNY did not purchase synthetic CDOs, which are CDOs backed by Nan Shan: On August 18, 2011, AIG sold CDS rather than real estate loans. AIGFP still had about $302 billion in exposure its 97.6% interest in Nan Shan Life Insurance Company, Ltd., its Taiwanese life insurance unit, 619 to CDS on its books on December 31, 2008, after Maiden Lane III was created. to Taiwan-based Ruen Chen Investment Holding Co., Ltd. for $2.2 billion. Established in 1963, Nan Shan is the largest life insurer in Taiwan by total AIG Sales of Certain Foreign Life Insurance Subsidiaries and book value and the third largest by total premiums.

Other Assets Star and Edison: On February 1, 2011, AIG sold While in TARP, AIG has sold several of its foreign life insurance subsidiaries its Japan-based life insurance subsidiaries, AIG Star Life Insurance Co., Ltd., and AIG Edison Life including Nan Shan, AIG Star Life Insurance Co., ALICO, and AIA. These Insurance Company, to Prudential Financial, Inc., transactions were with the consent of or in consultation with Treasury as AIG’s for a total of $4.8 billion, made up of $4.2 billion in cash and $0.6 billion in the assumption of third- controlling shareholder. Some of the transactions resulted in proceeds that went party debt. Star and Edison offer life, medical, and to pay down amounts owed to the Government as part of a plan to recapitalize the annuity products to individuals and groups. Government’s interest in AIG. At the end of 2011, about 14% of AIG’s consolidated ALICO: On November 1, 2010, AIG sold ALICO, assets were located outside the United States and Canada, down from 37% in a foreign life insurance company with operations on four continents, to MetLife for approximately 620 2008. Figure 3.1 shows recent major foreign divestitures of $1 billion or more. $16.2 billion ($7.2 billion in cash and the remain- On the one hand, these transactions may be key steps in AIG’s restructuring der in securities of MetLife). that have allowed AIG to meet working capital needs and to pay down the AIA: On October 29, 2010, AIG sold, in an initial public offering, 8.08 billion shares (or 67%) of Government. As Benmosche stated in March 2010, “Clearly, we will be a smaller Pan-Asian life insurer AIA for approximately $20.5 and more focused company than in the past. The only way we can repay taxpayers billion. On March 8, 2012, AIG sold 1.72 billion 621 shares of AIA to institutional investors for approxi- is to divest parts of the organization, and we are.” mately $6 billion. However, AIG’s sales of ALICO and AIA, key pieces of AIG’s foreign life AIGFP Energy and Infrastructure Portfolio: On insurance operations, meant losing what Benmosche described as some of “the August 11, 2009, AIG sold its remaining energy company’s crown jewels.”622 In 2010, AIG sold ALICO, one of the world’s largest and infrastructure investment assets, including three Spanish solar power plants along with sev- and most diversified international life insurance companies, to MetLife, Inc. The eral U.S. assets, realizing aggregate net proceeds sale included the company’s vast distribution network throughout four continents, in excess of $1.9 billion. This disposition effort began during the fall of 2008. including agents, brokers and financial institutions; 12,500 employees across AIG Otemachi Building in Tokyo: On May 28, more than 50 countries; and 20 million customers worldwide. The significance of 2009, AIG sold its prime real estate holding in ALICO’s loss to AIG is best shown by the numbers. In 2008, ALICO generated Tokyo, the AIG Otemachi Building and property, for 623 approximately $1.2 billion in cash to Nippon Life revenue of $32.3 billion, or approximately one-third of AIG’s revenue that year. Insurance Company. The sale of AIA Group, Limited (“AIA”) entailed AIG parting ways with a leading Sources: AIG, Press Release, “AIG Reduces United States Pan-Asian life insurance organization that traces its roots in the Asia-Pacific region Treasury Investment in AIG Subsidiary by Approximately $2 Billion,” 8/18/2011, www.aigcorporate.com/newsroom/ back more than 90 years. The sale included all of the AIA companies operating index.html, accessed 6/28/2012; AIG, Press Release, “AIG Enters Into Agreement to Sell Nan Shan to Taiwan-Based in 15 geographic markets across the Asia-Pacific region, including the company’s Consortium Led by the Roentex Group,” 1/12/2011, www.aigcorporate.com/newsroom/index.html, accessed international network of more than 320,000 agents and approximately 23,500 6/29/2012; AIG, Press Release, “AIG Completes Sale employees.624 AIA accounted for $9.3 billion of insurance premiums in 2010, about of Star and Edison Companies,” 2/1/2011, www. aigcorporate.com/newsroom/index.html, accessed 12% of AIG’s revenue that year.625 6/28/2012; AIG, Press Release, “AIG Raises Nearly $37 Billion in Two Transactions to Repay Government,” In addition to these major transactions, AIG has sold its own Manhattan 11/1/2010, www.aigcorporate.com/newsroom/index. html, accessed 6/28/2012; AIG, Press Release, “AIG headquarters building; a commodity index; a U.S. rail services leasing unit; its Announces Pricing of Sale of Ordinary Shares of AIA Group Limited,” 3/5/2012, www.aigcorporate.com/newsroom/ U.S. personal auto insurance business; a German marine insurer; consumer index.html, accessed 6/28/2012; AIG, Press Release, “AIG finance businesses in Mexico, Argentina, and Thailand; life insurance operations Financial Products Corp. Completes Disposition of Energy and Infrastructure Investment Portfolio,” 8/11/2009, in Canada, Japan, the Philippines, and Taiwan; and 80% of its consumer credit www.aigcorporate.com/newsroom/index.html, accessed 6/28/2012; AIG, Press Release, “AIG Completes Sale of provider, American General Finance. Prime Tokyo Real Estate Asset to Nippon Life Insurance Company,” 5/28/2009, www.aigcorporate.com/ newsroom/index.html, accessed 6/28/2012. 160 special inspector general I troubled asset relief program

AIG’s Current Businesses For the year ending December 31, 2011, AIG reported the results of its businesses through four segments: Chartis, which writes policies for foreign property/casualty, commercial/industrial, and consumer insurance; SunAmerica Financial Group, which focuses on U.S. life insurance, retirement services, and annuities; Aircraft Leasing; and “Other Operations,” which includes the remaining derivatives portfolio from AIGFP, other corporate investment operations, and AIG’s insurance for residential mortgage lenders.626 Insurance continues to account for almost 90% of the company’s revenue, as was generally the case historically. Aircraft leasing accounts for 7% and other operations for 6%.627 In TARP, AIG has sold certain subsidiaries and other assets and added several operations, although they are only a fraction of the size of those that it shed. Most notably, through transactions in 2010 and 2011, AIG increased its ownership stake in Japanese insurer Fuji Fire & Marine Insurance Company, Limited, from 41.7% to 100%.628 Fuji is now part of Chartis, and largely because of that acquisition, consumer insurance accounted for 38% of Chartis’s business in 2011, up from 30% in 2009.629 The company has also acquired financial assets, including mortgage securities. Table 3.1. provides a snapshot of key AIG financial information from 2007 to 2011.

TABLE 3.1

AIG FINANCIAL HIGHLIGHTS ($ BILLIONS EXCEPT FOR EARNINGS PER SHARE AND RETURN ON AVERAGE EQUITY) 2007 2008 2009 2010 2011 Assets $1,048.4 $860.4 $847.6 $675.6 $552.4 Liabilities 952.5 807.7 748.6 568.4 441.4 Revenue 81.5 (6.8) 75.4 77.5 64.3 Net income 7.5 (100.4) (12.3) 12.3 21.3 Earnings per 47.73 (756.85) (90.48) 14.98 11.01 share Return on 7.2% -130.7% -18.2% 11.8% 24% average equity

Notes: Earnings per share is fully diluted, after extraordinary items. Return on average equity is net income as a percent of average equity.

Source: SNL Financial; all data reflect company restatements of results as of April 20, 2012.

Chartis and SunAmerica Chartis is AIG’s largest subsidiary. Chartis generated $40.7 billion in 2011 revenue primarily through the sale of property and casualty insurance policies to companies around the world for natural disasters and industrial accidents.iv Chartis has had four consecutive years of underwriting losses, which in part reflect the severity of

iv It also wrote policies to protect companies and wealthy individuals from specialized risks such as computer hackers, executive kidnappings, yachting mishaps, crisis management, and shareholder lawsuits. quarterly report to congress I July 25, 2012 161

recent disasters.630 The U.S. property/casualty industry saw underwriting net losses more than triple to $36.5 billion in 2011 from the previous year after a string of costly catastrophes.631 Chartis had $3.2 billion in underwriting losses in 2011 from catastrophes including Japan’s worst-ever earthquake, damages in the U.S. from Hurricane Irene and tornadoes, and deadly flooding in Thailand.632 In its smaller consumer business, Chartis is using direct marketing to expand sales of health, accident, and auto insurance in Brazil, Mexico, United Arab Emirates, Turkey, Vietnam, Indonesia, India, and China. Revenue from con- sumer premiums rose to $3.6 billion in the 2012 first quarter, accounting for 41% of Chartis’s sales. Part of the increase was due to Chartis’s 2010 acquisition of Japanese insurer Fuji, which sells mainly to Asian consumers. Meanwhile, com- mercial premiums declined to $5.2 billion in the first quarter of 2012, down about $500 million from a year ago.633 AIG subsidiary SunAmerica sells bread-and-butter life and health insurance policies and retirement annuities to U.S. clients. SunAmerica also offers prod- ucts such as brokerage services, financial planning, and retail mutual funds. SunAmerica’s revenue of $15.3 billion in 2011 accounted for 24% of AIG’s total sales.634

Investments by Chartis and SunAmerica Like other insurers, Chartis and SunAmerica invest insurance premium payments from customers to generate income for paying claims and benefits. Life insurers such as SunAmerica have a relatively predictable business and can invest in fixed maturity securities that match up with estimated payouts to customers. SunAmerica also invests in private equity funds, hedge funds, and affordable housing partnerships. Property insurers contend with unpredictable natural disasters such as earthquakes and hurricanes. While according to AIG, Chartis invests in relatively safe fixed-income securities such as municipal bonds, it also needs strong investment income to offset insurance policy underwriting losses. In recent years, it has lost money on underwriting, but attempted to make it up on profits from investments.635 Average investments at Chartis and SunAmerica have steadily increased from 2009 to 2011. In 2011, Chartis and SunAmerica together held average investments of $286.3 billion, up 12% from 2010 holdings.636 However, pre-tax returns on those investments have fluctuated. Their combined portfolio produced $14.2 billion in net investment income in 2011, a decline of 6% from the previous year.637

Aircraft Leasing AIG’s International Lease Finance Corporation (“ILFC”) leases commercial jet aircraft to foreign and domestic airlines. Revenue in the business has been steadily decreasing since 2009 — it fell 4% from 2009 to 2010, and then another 6% from 2010 to 2011.638 The business’s loss deepened from $729 million in 2010 to $1 billion in 2011, which included write-downs in the value of older aircraft.639 162 special inspector general I troubled asset relief program

Mortgage-Backed Securities According to AIG, to earn the higher returns needed to pay claims and benefits to insurance customers, AIG has returned to investing in mortgage-backed securities, although at a much smaller level than prior to TARP.640 From December 31, 2010, to March 31, 2012, AIG had more than doubled its CMBS and non-agency RMBS holdings to $28.4 billion.641 That did not include AIG’s April 2012 purchase of $600 million worth of CDOs that had been in the Maiden Lane III portfolio.642

AIGFP and Other Securities Lending and CDS AIG continues to maintain a portfolio of CDS and continues to engage in securities lending, albeit much smaller than prior to TARP. AIGFP continues to exist and was folded into the company’s Global Capital Markets business along with a separate unit, AIG Markets Inc., which writes derivatives on behalf of other AIG subsidiaries.643 AIGFP has sharply reduced its CDS portfolio to one-tenth its former size, from about $2 trillion in net notional value in 2008 to about $168 billion in net notional value at the end of its 2012 first quarter.644 Net notional value is the total risk expo- sure for a transaction, or the maximum amount of money that would be transferred from the seller of protection to the buyer in the event of a credit default.645 This reduction in exposure is due in part to FRBNY’s actions with Maiden Lane III. The size of AIGFP’s trading book is greatly diminished, but it may come as a surprise to some that any of AIGFP still exists at all. Former AIG CEO Edward M. Liddy told Congress in 2009 he was weighing a number of options to quickly shut down AIGFP and “break apart these trading books.”646 His successor and current CEO, Robert H. Benmosche, has been winding down some of AIGFP’s trading books over time.647 Benmosche hired Peter Hancock, the founder of JPMorgan’s global derivatives group and now the head of AIG’s Chartis unit, to manage what AIG has described as the “de-risking” of AIGFP.648 AIG’s 2008 Form 10-K stated that the orderly wind-down of AIGFP would take a substantial period of time. An AIG presentation about its first quarter 2012 results noted that AIGFP may be around for at least seven more years until its final contracts expire.649 The company says it manages the AIGFP portfolio “for maximum profit contribution and limited risk.”650 According to AIG, active trading wound down in mid-2011, and AIGFP now enters into new derivative transactions only to hedge its portfolio, which according to AIG means to protect that portfolio by making an offsetting investment in a related security.651 Its non-AIGFP divisions also use derivatives to hedge against risk. According to AIG, “Although the remain- ing AIGFP derivatives portfolio may experience periodic fair value volatility, the portfolio consists predominantly of transactions AIG believes are of low complex- ity, low risk, supportive of AIG’s risk management objectives, or not economically appropriate to unwind based on a cost versus benefit analysis.”652 Table 3.2 shows how AIGFP’s portfolio of investments has changed since 2008. quarterly report to congress I July 25, 2012 163

TABLE 3.2

AIGFP’s Portfolio 2008-2012 ($ BILLIONS) 12/31/2008 12/31/2009 12/31/2010 12/31/2011 3/31/2012 Market ~$1,450 Not reported Not reported $131 $126 derivatives Stable value ~40 Not reported Not reported 20 19 wraps Corporate ~52 22 12 12 12 debt CDS Regulatory ~245 150 38 7 6 capital CDS Multi-sector ~13 8 7 6 5 CDS Total ~$1,800 $940 $352.8 $176 $168

Notes: Net notional value in billions of dollars.

Sources: AIG, conference call presentations, May 4, 2012, February 24, 2012, and February 25, 2011, www.aigcorporate. com/investors/financial_reports.html, accessed 7/21/2012; AIG 10-K for 2010, 2/24/2011, www.sec.gov/Archives/edgar/ data/5272/000104746911001283/0001047469-11-001283-index.htm, accessed 6/28/2012.

AIGFP’s remaining portfolio includes these components:

• The largest group of securities is $126 billion in what the company describes as “market derivatives” that are fully hedged. Managed by AIG’s Global Capital Markets Group, about three-fourths of these instruments are intended to protect AIG affiliate companies’ own assets, while the others are “legacy” third- party client trades left from before the bailout.653 • Next in size is $19 billion in AIGFP securities meant to smooth out interest rate volatility in stable value funds, which are similar to money market funds but offer higher returns. AIGFP’s instruments, known as stable value wraps, help fixed-income investments in stable value funds maintain book value even if market value drops.654 On May 4, 2012, AIG said it expected to move the stable value wraps to one of its insurance entities this year.655 • Another component of the AIGFP portfolio is $12 billion in CDS contracts written for bundles of corporate debt.656 • A dwindling number of CDS contracts that AIGFP tailored specifically for European banks also remain. Banks bought these regulatory capital swaps as protection from potential losses on mortgages and corporate loans so they could hold less capital and still comply with regulatory requirements.657 • AIGFP’s portfolio includes $5 billion in synthetic CDOs not placed into Maiden Lane III.658 AIG said this set of securities “managed to retain significant future upside” for additional profits.

According to AIG’s 2011 Form 10-K, “The senior management of AIGFP reports the results of its operations to and reviews future strategies with AIG’s senior management.”659 The Form 10-K provided details about some components 164 special inspector general I troubled asset relief program

of the AIGFP portfolio such as a breakdown of credit ratings, origination years of RMBS, and risk sensitivity of remaining swaps. AIG began edging back into securities lending in 2011, when Chartis began lending municipal bonds and requiring counterparties to put up 102% collateral.660 SunAmerica began securities lending in early 2012.661 As of March 31, 2012, AIG had securities valued at $8.9 billion pledged in securities-lending programs.662 That compares with about $76 billion at the end of 2007 prior to the TARP injection.663

AIG’s Changing Regulatory Environment In the years leading up to its near collapse, AIG’s massive size, interconnectedness, geographic reach, and product breadth of operations were not matched by a coherent U.S. regulatory structure to oversee its business. A combination of state, international, and Federal authorities regulate AIG and its subsidiaries. There is currently no Federal banking regulator with responsibility for overseeing AIG’s non- insurance financial businesses. AIG’s domestic, life, and property/casualty insurance subsidiaries are regulated by the state insurance regulators or foreign regulators where these companies are domiciled or operate.v The state insurance regulators examine the parent company only to the extent that it relates to the insurance subsidiaries.vi Foreign insurance regulators, operating under their own countries’ laws, have jurisdiction over AIG’s overseas insurance subsidiaries. From 1999 to March 2010, OTS was the supervisor of AIG’s non-insurance financial business because AIG was permitted to be considered a savings and loan holding company due to its ownership of a small Wilmington, Delaware, thrift, AIG Federal Savings Bank, which accounted for a tiny piece of its operations. This was significant because the European Union required foreign companies doing busi- ness in Europe to have the equivalent of a “consolidated supervisor” in their home country. Starting in 2004, OTS had worked to successfully persuade the European Union that it was capable of performing this role.664 AIG was subject to OTS regulation, examination, supervision, and reporting requirements. OTS also had enforcement authority over AIG and its subsidiaries and could restrict or prohibit activities that were a serious risk to the financial safety, soundness, or stability of AIG Federal Savings Bank. The Office of the Comptroller of the Currency is now responsible for regulating AIG Federal Savings Bank, but not the rest of the com- pany. Since 2010, AIG has been in discussions with European regulators concern- ing consolidated regulation.665

v The primary state insurance regulators include New York, Pennsylvania, and Texas. vi Though examinations of the AIG parent were limited to how it related to the subsidiaries, the regulators typically obtained additional information about the parent through informal channels, such as regular communications with parent company management and review of public filings. (Congressional Oversight Panel, “June Oversight Report: The AIG Rescue, Its Impact on Markets, and the Government’s Exit Strategy,” 6/10/2010, p. 23, http://cybercemetery.unt.edu/archive/cop/20110401232818/http://cop.senate.gov/reports/ library/report-061010-cop.cfm, accessed 6/28/2012.) quarterly report to congress I July 25, 2012 165

The Federal Reserve has not regulated AIG either before or after the bailout. Its involvement with the company was instead through the Federal Reserve’s responsi- bility to maintain financial system stability and contain systemic risk that may arise in financial markets. The significant interconnectedness and complexity of AIG’s businesses, and the lack of effective regulatory oversight of AIG’s financial business, were factors in AIG’s near collapse and subsequent bailout. Despite what turned out to be AIG’s key role as a financial institution, its only U.S. Federal banking regulator was OTS. AIGFP fell outside the scope of the state insurance regulators, even though its CDS had a function similar to insurance, and AIGFP’s CDS trades fell outside OTS’s regulatory authority. This regulatory structure meant there was no compre- hensive examination and regulation of CDS activity within AIGFP. Certain other financial operations inside AIG — including capital markets, consumer finance, and aircraft leasing — were regulated on a piecemeal basis or escaped regulation entirely. As the FCIC and COP concluded in separate reports to Congress, OTS failed in its role as AIG’s consolidated supervisor; it neither understood its responsibility nor had the tools to oversee the entire company’s complex financial services, including AIGFP. As AIG’s holding company regulator, OTS was charged with over- seeing the parent and had the power and the duty to spot and require the company to curtail its risk, but according to COP, it “failed to do so.”666 At a March 2009 congressional hearing, then-Acting OTS Director Scott Polakoff acknowledged that his agency failed to recognize the extent of the liquidity risk in AIGFP’s CDS port- folio. In addition, John Reich, a former OTS director, told the FCIC that as late as September 2008, he had “no clue — no idea — what [AIG’s] CDS liability was.”667 He further told the FCIC, “At the simplest level, . . . an organization like OTS can- not supervise AIG, GE, Merrill Lynch, and entities that have worldwide offices. . . it’s like a gnat on an elephant — there’s no way.”668 The Dodd-Frank Act may subject AIG to substantial additional Federal regu- lation. The law abolished OTS and moved supervision of savings and loan insti- tutions to the OCC and supervision of their holding companies to the Federal Reserve. The Federal Reserve could take over regulating AIG if it recognizes AIG as a savings and loan holding company under the Home Owners’ Loan Act. However, AIG anticipates that it will not be a savings and loan holding company until Treasury holds less than 50% ownership interest.669 The Dodd-Frank Act also set up a new framework for supervising nonbank financial companies designated as systemically important financial institutions because of the role they play in the financial system. SIFIs face more stringent capital and liquidity requirements and annual stress tests, among other things. They also will be required to follow height- ened corporate governance requirements and to prepare “living wills” — plans on how they could be unwound if they fail. Nonbank SIFI designations have not yet been made and there is no stated time frame to do so. On April 3, 2012, the Financial Stability Oversight Council (“FSOC”), a collection of regulators responsible for rule-making in this area, issued a final rule effective May 11, 2012, with the criteria and process it will 166 special inspector general I troubled asset relief program

use to decide which large U.S. nonbank financial firms are designated as SIFIs. A nonbank financial institution may be designated a SIFI if it is predominantly engaged in financial activities. FSOC currently is analyzing the potential systemic importance of individual companies. However, before any SIFI determination can be made, the Federal Reserve Board must define what it means for a company to be “predominantly engaged in financial activities.” If FSOC designates AIG as a nonbank SIFI, AIG would be subject to Federal Reserve examination, enforcement, and supervision. AIG’s senior managers expect AIG to be named a SIFI, and they say that AIG has begun preparing for this desig- nation. “People say, ‘Are you worried about being a SIFI? Are you worried about the Federal Reserve?’ No. I welcome it,” Benmosche said at an insurance conference earlier this year.670 Peter Hancock, the head of AIG’s Chartis insurance unit, told a conference last December, “We’ve done more to de-lever our balance sheet and be- come Fed-ready, because we expect to be regulated by the Fed, than I think almost any other large insurance company.”671 While the Dodd-Frank Act’s nonbank SIFI designation process was intended to give regulators better oversight of nonbank financial players that have crucial roles in the nation’s financial system and subject those designated entities to prudential standards promulgated by the Federal Reserve, the designation of a company as a SIFI is only the first step in a host of challenges Federal regulators face in imple- menting financial reform. If AIG is designated as a SIFI or recognized as a savings and loan holding company, the Federal Reserve, as its primary supervisor, will face enormous examination, enforcement, supervision, and logistical challenges in its responsibility to provide comprehensive and effective oversight. This is particularly true as it relates to risk, given AIG’s history. Although AIG has made changes while in TARP, it remains one of the world’s largest companies, with hundreds of subsidiaries in more than 130 countries. Comprehensive and effective oversight of AIG would require the Federal Reserve to have extensive expertise with and knowledge of a wide array of nonbanking businesses and their risks, including AIG’s insurance operations, aircraft leasing business, its mortgage guaranty, securities lending, and other derivatives trading business. One vital concern for AIG (and any future regulator of AIG) is determining the proper level of risk to make a profit while minimizing the chance of failure. Although this is a continuing challenge for all companies, given its history, risk is of particular concern for AIG. In its 2011 annual report, AIG said, “Risk manage- ment is a key element of AIG’s approach to corporate governance.”672 This state- ment is not much different from statements made before the company crashed. In its 2007 annual report, the company said, “AIG believes that strong risk manage- ment practices and a sound internal control environment are fundamental to its continued success and profitable growth.”673 And until shortly before the company imploded, AIG executives denied there was much, if any, risk from its derivatives portfolio. Even during an August 2007 investor presentation in which AIG revealed that AIGFP had $79 billion in exposure to super-senior multi-sector CDOs (largely U.S. subprime mortgages), and that the AIG securities lending portfolio included quarterly report to congress I July 25, 2012 167

$28.7 billion in sub-prime RMBS, accompanying slides emphasized that risk was “extremely remote.”674 On a telephone call with analysts that day, Joseph Cassano, then the head of AIGFP, said, “It is hard for us, without being flippant, to even see a scenario within any kind of realm or reason that would see us losing $1 in any of those transactions.”675 Within a year, the bottom dropped out. The decisions regulators make today about AIG will be crucial to protect- ing taxpayers in the future. Proper and effective supervision of AIG is just one of the many challenges regulators will likely face in the months and years to come. Effective, comprehensive, and rigorous regulation of AIG is vital to ensure that his- tory does not repeat itself and that taxpayers are protected. 168 special inspector general I troubled asset relief program TARP Operations and Section 4 Administration 170 special inspector general I troubled asset relief program quarterly report to congress I July 25, 2012 171

Under the Emergency Economic Stabilization Act of 2008 (“EESA”), Congress authorized the Secretary of the Treasury (“Treasury Secretary”) to create the operational and administrative mechanisms to carry out the Troubled Asset Relief Program (“TARP”). EESA established the Office of Financial Stability (“OFS”) within the U.S. Department of the Treasury (“Treasury”). OFS is responsible for administering TARP.676 Treasury has authority to establish program vehicles, issue regulations, directly hire or appoint employees, enter into contracts, and designate financial institutions as financial agents of the Government.677 In addition to using permanent and interim staff, OFS relies on contractors and financial agents for legal services, investment consulting, accounting, and other key services.

TARP Administrative and Program Expenditures As of June 30, 2012, Treasury has obligated $314.2 million for TARP administrative costs and $797.3 million in programmatic expenditures for a total of $1.1 billion. According to Treasury, as of June 30, 2012, it had spent $265.5 million on TARP administrative costs and $697.0 million on programmatic expenditures, for a total of $962.5 million.678 Treasury reported that it employs 74 career civil servants, 97 term appointees, and 22 reimbursable detailees, for a total of 193 full-time employees.679 Table 4.1 provides a summary of the expenditures and obligations for TARP administrative costs through June 30, 2012. These costs are categorized as “personnel services” and “non-personnel services.” 172 special inspector general I troubled asset relief program

TABLE 4.1 TARP ADMINISTRATIVE EXPENDITURES AND OBLIGATIONS Obligations for Period Expenditures for Period Budget Object Class Title Ending 6/30/2012 Ending 6/30/2012 Personnel Services Personnel Compensation & Benefits $94,533,456 $94,364,796 Total Personnel Services $94,533,456 $94,364,796

Non-Personnel Services Travel & Transportation of Persons $1,908,580 $1,854,247 Transportation of Things 11,960 11,960 Rents, Communications, Utilities & Misc. Charges 764,636 689,873 Printing & Reproduction 402 402 Other Services 215,389,359 166,974,667 Supplies & Materials 1,364,438 1,356,533 Equipment 253,286 243,907 Land & Structures — — Dividends and Interest 634 634 Total Non-Personnel Services $219,693,295 $171,132,223

Grand Total $314,226,751 $265,497,019

Notes: Numbers affected by rounding. The cost associated with “Other Services” under TARP Administrative Expenditures and Obligations are composed of administrative services including financial, administrative, IT, and legal (non-programmatic) support.

Source: Treasury, response to SIGTARP data call, 7/9/2012.

Current Contractors and Financial Agents As of June 30, 2012, Treasury had retained 139 private vendors: 18 financial agents and 121 contractors, to help administer TARP.680 Table 4.2 provides a summary of the programmatic expenditures, which include costs to hire financial agents and contractors, and obligations through June 30, 2012, excluding costs and obligations related to personnel services and travel and transportation. Although Treasury has informed SIGTARP that it “does not track” the number of individuals who provide services under its agreements, the number likely dwarfs the 193 that Treasury has identified as working for OFS.681 For example, on October 14, 2010, the Congressional Oversight Panel (“COP”) reported that “Fannie Mae alone currently has 600 employees working to fulfill its TARP commitments.”682 quarterly report to congress I July 25, 2012 173

TABLE 4.2 OFS SERVICE CONTRACTS Type of Obligated Expended Date Vendor Purpose Transaction Value Value

Legal services for the implementation of 10/10/2008 Simpson Thacher & Bartlett MNP LLP Contract $931,090 $931,090 TARP

10/11/2008 Ennis Knupp & Associates Inc.1 Investment and Advisory Services Contract 2,635,827 2,635,827

The Bank of New York Mellon 10/14/2008 Custodian Financial Agent 48,098,612 45,712,347 Corporation 10/16/2008 PricewaterhouseCoopers Internal control services Contract 34,921,161 32,352,065 Interagency 10/17/2008 Turner Consulting Group, Inc.2 For process mapping consultant services 9,000 — Agreement 10/18/2008 Ernst & Young LLP Accounting Services Contract 14,550,519 13,640,626 Legal services for the Capital 10/29/2008 Hughes Hubbard & Reed LLP Contract 3,060,921 2,835,357 Purchase Program Legal services for the Capital 10/29/2008 Squire, Sanders & Dempsey LLP Contract 2,687,999 2,687,999 Purchase Program 10/31/2008 Lindholm & Associates, Inc. Human resources services Contract 614,963 614,963 Legal services related to auto industry 11/7/2008 Sonnenschein Nath & Rosenthal LLP4 Contract 2,702,441 2,702,441 loans Interagency 11/9/2008 Internal Revenue Service Detailees 97,239 97,239 Agreement Interagency 11/17/2008 Internal Revenue Service CSC Systems & Solutions LLC2 8,095 8,095 Agreement Department of the Treasury — Interagency 11/25/2008 Administrative Support 16,512,820 16,131,121 Departmental Offices Agreement Alcohol and Tobacco Tax and IAA — TTB Development, Mgmt & Interagency 12/3/2008 67,489 67,489 Trade Bureau Operation of SharePoint Agreement Interagency 12/5/2008 Washington Post3 Subscription 395 — Agreement Legal services for the purchase of 12/10/2008 Sonnenschein Nath & Rosenthal LLP4 Contract 102,769 102,769 assets-backed securities 12/10/2008 Thacher Proffitt & Wood4 Admin action to correct system issue Contract — — Interagency 12/15/2008 Office of Thrift Supervision Detailees 225,547 164,823 Agreement Department of Housing and Interagency 12/16/2008 Detailees — — Urban Development Agreement Interagency 12/22/2008 Office of Thrift Supervision Detailees 103,871 — Agreement 12/24/2008 Cushman and Wakefield of VA Inc. Painting Services for TARP Offices Contract 8,750 8,750 Interagency 1/6/2009 Securities and Exchange Commission Detailees 30,416 30,416 Agreement 1/7/2009 Colonial Parking Inc. Lease of parking spaces Contract 338,050 224,033 1/27/2009 Cadwalader Wickersham & Taft LLP Bankruptcy Legal Services Contract 409,955 409,955 Continued on next page 174 special inspector general I troubled asset relief program

OFS SERVICE CONTRACTS (Continued) Type of Obligated Expended Date Vendor Purpose Transaction Value Value 1/27/2009 Whitaker Brothers Bus Machines Inc. Paper Shredder Contract $3,213 $3,213 Interagency 1/30/2009 Comptroller of the Currency Detailees 501,118 501,118 Agreement IAA — GAO required by P.L. 110-343 to Interagency 2/2/2009 US Government Accountability Office conduct certain activities related to 7,459,049 7,459,049 Agreement TARP IAA Interagency 2/3/2009 Internal Revenue Service Detailees 242,499 242,499 Agreement Temporary Services for Document 2/9/2009 Pat Taylor & Associates, Inc. Production, FOIA assistance, and Contract 692,108 692,108 Program Support Initiate Interim Legal Services in support of 2/12/2009 Locke Lord Bissell & Liddell LLP Contract 272,243 272,243 Treasury Investments under EESA 2/18/2009 Fannie Mae Homeownership Preservation Program Financial Agent 318,054,368 283,824,329 2/18/2009 Freddie Mac Homeownership Preservation Program Financial Agent 209,158,529 181,217,492 Interagency 2/20/2009 Financial Clerk U.S. Senate Congressional Oversight Panel 3,394,348 3,394,348 Agreement Interagency 2/20/2009 Office of Thrift Supervision Detailees 203,390 189,533 Agreement 2/20/2009 Simpson Thacher & Bartlett MNP LLP Capital Assistance Program (I) Contract 1,530,023 1,530,023 Capital Assistance Program (II) 2/20/2009 Venable LLP Contract 1,394,724 1,394,724 Legal Services Interagency 2/26/2009 Securities and Exchange Commission Detailees 18,531 18,531 Agreement Interagency 2/27/2009 Pension Benefit Guaranty Corporation Rothschild, Inc. 7,750,000 7,750,000 Agreement Management Consulting relating to the 3/6/2009 The Boston Consulting Group Contract 991,169 991,169 Auto industry 3/16/2009 Earnest Partners Small Business Assistance Program Financial Agent 2,947,780 2,947,780 SBA Initiative Legal Services — Contract 3/30/2009 Bingham McCutchen LLP5 Novated from TOFS-09-D-0005 with Contract 273,006 143,893 McKee Nelson 3/30/2009 Cadwalader Wickersham & Taft LLP Auto Investment Legal Services Contract 17,392,786 17,392,786 3/30/2009 Haynes and Boone, LLP Auto Investment Legal Services Contract 345,746 345,746 SBA Initiative Legal Services — Contract 3/30/2009 McKee Nelson5 Novated to TOFS-10-D-0001 with Bingham Contract 149,349 126,631 McCutchen LLP 3/30/2009 Sonnenschein Nath & Rosenthal LLP4 Auto Investment Legal Services Contract 1,834,193 1,834,193 3/31/2009 FI Consulting Inc. Credit Reform Modeling and Analysis Contract 4,124,750 3,041,748 Interagency 4/3/2009 American Furniture Rentals Inc.3 Furniture Rental 1801 35,187 25,808 Agreement Management Consulting relating to the 4/3/2009 The Boston Consulting Group Contract 4,100,195 4,099,923 Auto industry Interagency 4/17/2009 Bureau of Engraving and Printing Detailees 45,822 45,822 Agreement 4/17/2009 Herman Miller, Inc. Aeron Chairs Contract 53,799 53,799 4/21/2009 AllianceBernstein LP Asset Management Services Financial Agent 43,372,479 39,575,340 4/21/2009 FSI Group, LLC Asset Management Services Financial Agent 23,633,383 22,052,953 Continued on next page quarterly report to congress I July 25, 2012 175

OFS SERVICE CONTRACTS (Continued) Type of Obligated Expended Date Vendor Purpose Transaction Value Value 4/21/2009 Piedmont Investment Advisors, LLC Asset Management Services Financial Agent $11,561,031 $10,588,154 Interagency 4/30/2009 Department of State Detailees — — Agreement Interagency 5/5/2009 Federal Reserve Board Detailees 48,422 48,422 Agreement Department of the Treasury — Interagency 5/13/2009 “Making Home Affordable” Logo search 325 325 U.S. Mint Agreement Executive Search and recruiting Services 5/14/2009 Knowledgebank Inc.2 Contract 124,340 124,340 — Chief Homeownership Officer Freedom of Information Act (FOIA) Analysts 5/15/2009 Phacil, Inc. to support the Disclosure Services, Privacy Contract 90,301 90,301 and Treasury Records Interagency 5/20/2009 Securities and Exchange Commission Detailees 430,000 430,000 Agreement Interagency 5/22/2009 Department of Justice — ATF Detailees 243,778 243,778 Agreement Legal services for work under Treasury’s 5/26/2009 Anderson, McCoy & Orta Public Private Investment Funds (PPIF) Contract 2,286,996 2,286,996 program Legal services for work under Treasury’s 5/26/2009 Simpson Thacher & Bartlett MNP LLP Public Private Investment Funds (PPIF) Contract 7,849,026 3,526,454 program Interagency 6/9/2009 Financial Management Services Gartner, Inc. 89,436 89,436 Agreement Interagency 6/29/2009 Department of the Interior Federal Consulting Group (Foresee) 49,000 49,000 Agreement Executive search services for the OFS 7/17/2009 Korn/Ferry International Contract 74,023 74,023 Chief Investment Officer position 7/30/2009 Cadwalader Wickersham & Taft LLP Restructuring Legal Services Contract 1,278,696 1,278,696 7/30/2009 Debevoise & Plimpton LLP Restructuring Legal Services Contract 1,650 1,650 Fox, Hefter, Swibel, Levin & 7/30/2009 Restructuring Legal Services Contract 26,493 26,493 Carol, LLP Interagency 8/10/2009 Department of Justice — ATF Detailees 63,109 63,109 Agreement National Aeronautics and Space Interagency 8/10/2009 Detailees 140,889 140,889 Administration (NASA) Agreement 8/18/2009 Mercer (US) Inc. Executive Compensation Data Subscription Contract 3,000 3,000 Interagency 8/25/2009 Department of Justice — ATF Detailees 63,248 63,248 Agreement 9/2/2009 Knowledge Mosaic Inc. SEC filings subscription service Contract 5,000 5,000 9/10/2009 Equilar, Inc. Executive Compensation Data Subscription Contract 59,990 59,990 9/11/2009 PricewaterhouseCoopers PPIP compliance Contract 3,065,705 2,976,502 Interagency 9/18/2009 Treasury Franchise Fund BPD 436,054 436,054 Agreement Interagency 9/30/2009 Immixtechnology Inc.3 EnCase eDiscovery ProSuite 210,184 — Agreement Interagency 9/30/2009 Immixtechnology Inc.3 Guidance Inc. 108,000 — Agreement Continued on next page 176 special inspector general I troubled asset relief program

OFS SERVICE CONTRACTS (Continued) Type of Obligated Expended Date Vendor Purpose Transaction Value Value 9/30/2009 NNA INC. Newspaper delivery Contract $8,479 $8,220 SNL Unlimited, a web-based 9/30/2009 SNL Financial LC Contract 460,000 460,000 financial analytics service Department of the Treasury — Interagency 11/9/2009 Administrative Support 23,682,061 18,056,064 Departmental Offices Agreement Interagency 12/16/2009 Internal Revenue Service Detailees — — Agreement 12/22/2009 Avondale Investments LLC Asset Management Services Financial Agent 772,657 772,657 12/22/2009 Bell Rock Capital, LLC Asset Management Services Financial Agent 2,175,615 1,868,409

12/22/2009 Howe Barnes Hoefer & Arnett, Inc. Asset Management Services Financial Agent 3,284,195 2,947,231

Document Production services and 12/22/2009 Hughes Hubbard & Reed LLP Contract 1,456,803 855,396 Litigation Support 12/22/2009 KBW Asset Management, Inc. Asset Management Services Financial Agent 4,937,433 4,937,433 12/22/2009 Lombardia Capital Partners, LLC Asset Management Services Financial Agent 3,242,419 2,810,840 Paradigm Asset Management 12/22/2009 Asset Management Services Financial Agent 3,298,978 2,968,731 Co., LLC IAA — GAO required by P.L.110-343 to Interagency 1/14/2010 US Government Accountability Office 7,304,722 7,304,722 conduct certain activities related to TARP Agreement Association of Government 1/15/2010 CEAR Program Application Contract 5,000 5,000 Accountants Interagency 2/16/2010 Internal Revenue Service Detailees 52,742 52,742 Agreement FNMA IR2 assessment — OFS task order 2/16/2010 The MITRE Corporation Contract 730,192 730,192 on Treasury MITRE Contract Interagency 2/18/2010 Treasury Franchise Fund BPD 1,221,140 1,221,140 Agreement 3/8/2010 Qualx Corporation FOIA Support Services Contract 549,518 549,518 Department of the Treasury — Interagency 3/12/2010 Administrative Support 671,731 671,731 Departmental Offices Agreement Interagency 3/22/2010 Gartner, Inc. Financial Management Services 73,750 73,750 Agreement Interagency 3/26/2010 Federal Maritime Commission Detailees 158,600 158,600 Agreement 3/29/2010 Morgan Stanley Disposition Agent Services Financial Agent 16,685,290 16,685,290 Interagency 4/2/2010 Financial Clerk U.S. Senate Congressional Oversight Panel 4,797,556 4,797,556 Agreement 4/8/2010 Squire, Sanders & Dempsey LLP Housing Legal Services Contract 1,229,350 918,224 4/12/2010 Hewitt EnnisKnupp, Inc.1 Investment Consulting Services Contract 4,499,750 2,661,486 Data and Document Management 4/22/2010 Digital Management Inc. Contract — — Consulting Services Data and Document Management 4/22/2010 MicroLink, LLC Contract 11,442,511 8,425,393 Consulting Services Data and Document Management 4/23/2010 RDA Corporation Contract 6,626,280 4,309,463 Consulting Services Interagency 5/4/2010 Internal Revenue Service Training — Bulux CON 120 1,320 1,320 Agreement Continued on next page quarterly report to congress I July 25, 2012 177

OFS SERVICE CONTRACTS (Continued) Type of Obligated Expended Date Vendor Purpose Transaction Value Value 5/17/2010 Lazard Fréres & Co. LLC Transaction Structuring Services Financial Agent $15,032,527 $11,518,280 Accurint subscription service for 6/24/2010 Reed Elsevier Inc (dba LexisNexis) Contract 8,208 8,208 one year — 4 users Financial Institution Management & 6/30/2010 The George Washington University Contract 5,000 5,000 Modeling — Training course (J.Talley) 7/21/2010 Navigant Consulting Program Compliance Support Services Contract 1,766,984 313,234 7/21/2010 Regis and Associates PC Program Compliance Support Services Contract 1,161,816 296,521 7/22/2010 Ernst & Young LLP Program Compliance Support Services Contract 3,323,286 2,042,110 7/22/2010 PricewaterhouseCoopers Program Compliance Support Services Contract — — 7/22/2010 Schiff Hardin LLP Housing Legal Services Contract 97,526 97,526 7/27/2010 West Publishing Corporation Subscription Service for 4 users Contract 6,722 6,664 8/6/2010 Alston & Bird LLP Omnibus procurement for legal services Contract 1,339,366 213,527 8/6/2010 Cadwalader Wickersham & Taft LLP Omnibus procurement for legal services Contract 5,949,077 2,789,647 Fox, Hefter, Swibel, Levin & 8/6/2010 Omnibus procurement for legal services Contract 199,200 152,947 Carol, LLP 8/6/2010 Haynes and Boone, LLP Omnibus procurement for legal services Contract — — 8/6/2010 Hughes Hubbard & Reed LLP Omnibus procurement for legal services Contract 1,877,048 796,190 8/6/2010 Love & Long LLP Omnibus procurement for legal services Contract — — 8/6/2010 Orrick Herrington Sutcliffe LLP Omnibus procurement for legal services Contract — — Paul, Weiss, Rifkind, Wharton & 8/6/2010 Omnibus procurement for legal services Contract 6,475,491 2,911,462 Garrison LLP 8/6/2010 Perkins Coie LLP Omnibus procurement for legal services Contract — — 8/6/2010 Seyfarth Shaw LLP Omnibus procurement for legal services Contract — — Shulman, Rogers, Gandal, Pordy & 8/6/2010 Omnibus procurement for legal services Contract 313,725 202,303 Ecker, PA 8/6/2010 Sullivan Cove Reign Enterprises JV Omnibus procurement for legal services Contract — — 8/6/2010 Venable LLP Omnibus procurement for legal services Contract 498,100 960 8/12/2010 Knowledge Mosaic Inc. SEC filings subscription service Contract 5,000 5,000 Department of Housing and Interagency 8/30/2010 Detailees 29,915 29,915 Urban Development Agreement One-year subscription (3 users) to the CQ Today Breaking News & Schedules, CQ 9/1/2010 CQ-Roll Call Inc. Contract 7,500 7,500 Congressional & Financial Transcripts, CQ Custom Email Alerts 9/17/2010 Bingham McCutchen LLP5 SBA 7(a) Security Purchase Program Contract 19,975 11,177 Program Operations Support Services to include project management, scanning 9/27/2010 Davis Audrey Robinette Contract 2,328,450 1,852,662 and document management and correspondence GSA Task Order for procurement books — FAR, T&M, Government 9/30/2010 CCH Incorporated Contract 2,430 2,430 Contracts Reference, World Class Contracting Interagency 10/1/2010 Financial Clerk U.S. Senate Congressional Oversight Panel 5,200,000 2,777,752 Agreement 10/8/2010 Management Concepts Inc. Training Course — CON 217 Contract 1,025 1,025 Continued on next page 178 special inspector general I troubled asset relief program

OFS SERVICE CONTRACTS (Continued) Type of Obligated Expended Date Vendor Purpose Transaction Value Value 10/8/2010 Management Concepts Inc. Training Course — CON 216 Contract $1,025 $1,025 10/8/2010 Management Concepts Inc. Training Course — CON 218 Contract 2,214 2,214 10/8/2010 Management Concepts Inc. Training Course — 11107705 Contract 995 995 10/8/2010 Management Concepts Inc. Training Course — Analytic Boot Contract 1,500 1,500 10/8/2010 Management Concepts Inc. Training Course — CON 218 Contract 2,214 2,214 10/8/2010 Management Concepts Inc. Training Course — CON 217 Contract 1,025 1,025 10/8/2010 Management Concepts Inc. Training Course — CON 218 Contract 2,214 2,214 Hispanic Association of Colleges & 10/14/2010 Detailees Contract 12,975 12,975 Universities IAA — GAO required by P.L. 110-343 to Interagency 10/26/2010 US Government Accountability Office 5,600,000 3,738,195 conduct certain activities related to TARP Agreement FNMA IR2 assessment — OFS task order 11/8/2010 The MITRE Corporation on Treasury MITRE Contract for cost and Contract 2,288,166 1,501,419 data validation services related to HAMP FA 11/18/2010 Greenhill & Co., Inc. Structuring and Disposition Services Financial Agent 6,139,167 6,139,167 Acquisition Support Services — PSD TARP 12/2/2010 Addx Corporation Contract 1,311,314 1,148,690 (action is an order against BPA) 12/29/2010 Reed Elsevier Inc. (dba LexisNexis) Accurint subscription services one user Contract 1,026 684 Interagency 1/5/2011 Canon U.S.A. Inc. Administrative Support 12,937 12,013 Agreement 1/18/2011 Perella Weinberg Partners & Co. Structuring and Disposition Services Financial Agent 5,542,473 5,542,473 Interagency 1/24/2011 Treasury Franchise Fund BPD 1,092,962 1,090,860 Agreement Association of Government 1/26/2011 CEAR Program Application Contract 5,000 5,000 Accountants Mentor Program Training 2/24/2011 ESI International Inc. Contract 20,758 20,758 (call against IRS BPA) Department of the Treasury — Interagency 2/28/2011 Administrative Support 17,805,529 13,299,171 Departmental Offices Agreement 3/3/2011 Equilar, Inc. Executive Compensation Data Subscription Contract 59,995 59,995 3/10/2011 Mercer (US) Inc. Executive Compensation Data Subscription Contract 7,425 3,600 3/22/2011 Harrison Scott Publications, Inc. Subscription Service Contract 5,894 5,894 Interagency 3/28/2011 Fox News Network LLC6 Litigation Settlement 121,000 121,000 Agreement Federal Reserve Bank of New York Interagency 4/20/2011 Oversight Services 1,300,000 875,415 (FRBNY) HR Agreement 4/26/2011 PricewaterhouseCoopers LLP Financial Services Omnibus Contract 2,509,632 1,442,695 4/27/2011 ASR Analytics, LLC Financial Services Omnibus Contract — — 4/27/2011 Ernst & Young, LLP Financial Services Omnibus Contract 1,414,262 283,378 4/27/2011 FI Consulting, Inc. Financial Services Omnibus Contract 1,703,711 1,105,778 4/27/2011 Lani Eko & Company CPAs LLC Financial Services Omnibus Contract 50,000 — 4/27/2011 MorganFranklin, Corporation Financial Services Omnibus Contract 50,000 — 4/27/2011 Oculus Group, Inc. Financial Services Omnibus Contract 2,284,646 608,490 4/28/2011 Booz Allen Hamilton, Inc. Financial Services Omnibus Contract 50,000 — 4/28/2011 KPMG, LLP Financial Services Omnibus Contract 50,000 — Continued on next page quarterly report to congress I July 25, 2012 179

OFS SERVICE CONTRACTS (Continued) Type of Obligated Expended Date Vendor Purpose Transaction Value Value Office of Personnel Management Interagency 4/28/2011 (OPM) — Western Management Leadership Training $21,300 $— Agreement Development Center Accurint subscriptions by LexisNexis for 5/31/2011 Reed Elsevier Inc (dba LexisNexis) Contract 10,260 6,840 5 users Five (5) user subscriptions to CLEAR by 5/31/2011 West Publishing Corporation Contract 7,515 7,515 West Government Solutions One year subscription to the CQ Today Breaking News & Schedules, CQ 6/9/2011 CQ-Roll Call Inc. Contract 7,750 7,750 Congressional & Financial Transcripts, CQ Custom Email Alerts Anti-Fraud Protection and Monitoring 6/17/2011 Winvale Group LLC Contract 504,232 242,507 Subscription Services Interagency 7/28/2011 Internal Revenue Service-Procurement Detailee 84,234 84,234 Agreement Interagency 9/9/2011 Financial Management Service FMS – NAFEO 22,755 — Agreement MHA Felony Certification Background 9/12/2011 ADC LTD NM Contract 447,799 227,950 Checks (BPA) 9/15/2011 ABMI – All Business Machines, Inc 4 Level 4 Security Shredders and Supplies Contract 4,392 4,392

National Business Center, Federal Interagency 9/29/2011 Department of Interior 25,000 25,000 Consulting Group Agreement

Renewing TD010-F-249 SEC filings 9/29/2011 Knowledge Mosaic Inc. Contract 4,200 4,200 Subscription Service Interagency 10/4/2011 Internal Revenue Service IRS 168,578 63,216 Agreement 10/20/2011 ABMI – All Business Machines, Inc. 4 Level 4 Security Shredders and Supplies Contract 4,827 4,827 11/18/2011 Qualx Corporation FOIA Support Services Contract 68,006 68,006 11/29/2011 Houlihan Lokey, Inc. Transaction Structuring Services Financial Agent 4,500,000 2,661,290 Pre-Program and Discovery Process Team 12/20/2011 Allison Group LLC Contract 19,980 19,065 Building Department of the Treasury — Interagency 12/30/2011 Department of Treasury — DO 15,098,746 4,698,183 Departmental Offices Agreement Interagency 12/30/2011 Treasury Franchise Fund ARC 901,433 674,451 Agreement Interagency 1/4/2012 Government Accountability Office Government Accountability Office 3,510,818 1,853,391 Agreement Office of Personnel Management Office of Personnel Management (OPM) — Interagency 1/5/2012 (OPM) — Western Management 31,088 — Western Management Development Center Agreement Development Center 2/2/2012 Moody’s Analytics Inc. ABS/MBS Data Subscription Services Contract 1,804,000 1,043,333 2/7/2012 Greenhill & Co., LLC Structuring and Disposition Services FAA Listing 1,050,000 706,034 2/14/2012 Association of Govt Accountants CEAR Program Application Contract 5,000 5,000 2/27/2012 Diversified Search LLC CPP Board Placement Services Contract 50,000 135,175 3/6/2012 Integrated Federal Solutions, Inc. TARP Acquisition Support (BPA) Contract 99,750 87,282 Continued on next page 180 special inspector general I troubled asset relief program

OFS SERVICE CONTRACTS (Continued) Type of Obligated Expended Date Vendor Purpose Transaction Value Value National Business Center, Federal Interagency 3/14/2012 Department of Interior $26,000 $26,000 Consulting Group Agreement 3/15/2012 Integrated Federal Solutions, Inc. TARP Acquisition Support (BPA) Contract 668,548 96,817 Department of the Treasury — Interagency 3/30/2012 Departmental Offices 1,136,980 — Departmental Offices WCF Agreement 3/30/2012 E-Launch Multimedia, Inc. Subscription Service Contract 13,100 — Maintenance Agreement for Canon 5/2/2012 Cartridge Technology, Inc. Contract 7,846 654 ImageRunner 5/10/2012 Equilar Inc. Executive Compensation Data Subscription Contract 44,995 44,995 Interagency 6/12/2012 Department of Justice Department of Justice 1,737,884 — Agreement 6/15/2012 Qualx Corporation FOIA Support Services Contract 50,000 — Subscription for Anti Fraud Unit to Perform 6/30/2012 West Publishing Corporation Contract 8,660 — Background Research Department of the Treasury — Interagency Administrative Support 660,601 660,601 Departmental Offices Agreement Judicial Watch7 Litigation related Other Listing 1,500 1,500 Judicial Watch7 Litigation related Other Listing 2,146 2,146 Total $1,035,016,005 $886,035,122

Notes: Numbers may not total due to rounding. At year-end, OFS validated the matrix against source documents resulting in modification of award date. At year-end, a matrix entry that included several Interagency Agreements bundled together was split up to show the individual IAAs. For IDIQ contracts, $0 is obligated if no task orders have been awarded. Table 4.2 includes all vendor contracts administered under Federal Acquisition Regulations, inter-agency agreements and financial agency agreements entered into support of OFS since the beginning of the program. The table does not include salary, benefits, travel, and other non-contract related expenses. 1 EnnisKnupp Contract TOFS-10-D-0004, was novated to Hewitt EnnisKnupp (TOFS-10-D-0004). 2 Awarded by other agencies on behalf of OFS and are not administered by PSD. 3 Awarded by other branches within the PSD pursuant to a common Treasury service level and subject to a reimbursable agreement with OFS. 4 Thacher Proffitt & Wood, Contract TOS09-014B, was novated to Sonnenschein Nath & Rosenthal (TOS09-014C). 5 McKee Nelson Contract, TOFS-09-D-0005, was novated to Bingham McCutchen. 6 Fox News Network LLC is a payment in response to a litigation claim. No contract or agreement was issued to Fox News Network LLC. 7 Judicial Watch is a payment in response to a litigation claim. No contract or agreement was issued to Judicial Watch.

Source: Treasury, response to SIGTARP data call, 7/11/2012. Section 5 SIGTARP Recommendations 182 special inspector general I troubled asset relief program quarterly report to congress I July 25, 2012 183

One of the critical responsibilities of the Office of the Special Inspector General for the Troubled Asset Relief Program (“SIGTARP”) is to provide recommendations to the U.S. Department of the Treasury (“Treasury”) and other Federal agencies related to the Troubled Asset Relief Program (“TARP”) to facilitate transparency and effective oversight and to prevent fraud, waste, and abuse. SIGTARP has made 105 recommendations in its quarterly reports to Congress and in many of its audit reports. This section discusses developments with respect to SIGTARP’s prior recommendations, including recommendations made since SIGTARP’s Quarterly Report to Congress dated April 25, 2012 (the “April 2012 Quarterly Report”), and, in the table at the end of this section, summarizes SIGTARP’s recommendations from past quarters and notes the extent of implementation.

Recommendations from SIGTARP’s Audit of the Hardest Hit Fund In its audit report “Factors Affecting Implementation of the Hardest Hit Fund Program,” released April 12, 2012, SIGTARP reviewed Treasury’s administration of the Housing Finance Agency Innovation Fund for the Hardest Hit Housing Markets (“HHF”). Under HHF, TARP dollars are meant to fund “innovative measures” developed by 19 state housing finance agencies (“HFAs”). SIGTARP found that after two years, HHF has experienced significant delay in providing help to homeowners due to several factors, including a lack of comprehensive planning by Treasury and a delay and limitation in participation in the program by large servicers, and the GSEs Fannie Mae and Freddie Mac. In its audit, SIGTARP reported that as of December 31, 2011, the latest data then available, HHF had spent only $217.4 million to provide assistance to 30,640 homeowners — approximately 3% of the TARP funds allocated to HHF and approximately 7% of the minimum number of homeowners the state HFAs estimate helping over the life of the program. The report included five recommendations to Treasury.

Treasury should set meaningful and measurable performance goals for the Hardest Hit Fund program including, at a minimum, the number of homeowners Treasury estimates will be helped by the program, and measure the program’s progress against those goals. Treasury has not set measurable goals and metrics that would allow Treasury, the public, and Congress to measure the progress and success of HHF. Treasury set a single goal for HHF: help prevent foreclosures and help preserve homeownership. Treasury deferred to individual states to set goals but did not require those states to set measurable goals. Most states’ goals are high-level expectations with no measur- able target, such as Florida’s “preserving homeownership” and “protecting home values.” Rather than acknowledge that after more than two years, HHF is not reaching enough homeowners and make changes suggested by SIGTARP that are designed 184 special inspector general I troubled asset relief program

to measure progress and ultimately reach those homeowners, Treasury is not adopting SIGTARP’s recommendation. Rather than set meaningful goals for HHF and measure progress against those goals, Treasury chooses instead to rely on its requirement that each state estimate the number of households to be assisted. This number has limited usefulness. First, states have been reporting this number for more than two years and Treasury has not used this number effectively to change the program to help a significant number of homeowners. Second, states can, and have, changed estimates, creating a shifting baseline that makes it difficult to mea- sure performance against expectations. The states’ estimated number of homeown- ers to be assisted by the Hardest Hit Fund has steadily decreased over the last year. Treasury has not adopted this estimate or even reported it. It is not too late for Treasury to set measurable goals, including at a minimum, adopting the HFAs’ collective estimate or developing its own goal of how many homeowners Treasury expects HHF to help. Treasury must set meaningful goals and metrics to identify program successes and set-backs, and change the program as needed. Treasury has stated that establishing static numeric targets is not suited to the dynamic nature of HHF. Taxpayers that fund this program have an absolute right to know what the Government’s expectations and goals are for using $7.6 billion in TARP funds. By refusing to set any goals for the programs, Treasury is subject to criticism that it is attempting to avoid accountability.

Treasury should instruct state housing finance agencies in the Hardest Hit Fund to set meaningful and measurable overarching and interim performance goals with appropriate metrics to measure progress for their individual state programs. Treasury is not adopting this recommendation. Most states’ goals are high-level expectations with no measurable targets. Although states estimate the number of households to be assisted, these estimates are of limited value for performance measurement because the states can, and have, changed that number. The states’ collective estimate of the number of households to be assisted is a moving target, and has been steadily decreasing. If the estimate of the number of households to be assisted changes, consistent performance measurement over the life of the program is not possible, progress is no longer measured based on a goal established at the outset, and opportunities for accountability to the public are diminished.

Treasury should set milestones at which the state housing finance agencies in the Hardest Hit Fund must review the progress of individual state programs and make program adjustments from this review. Treasury has not agreed to implement this recommendation, although it would be easy to do so. For example, Treasury could at a minimum adopt the HFAs’ esti- mates of homeowners to be assisted through 2017, and then set interim goals, such as the number of homeowners that each state HFA should reach each year. States continue to need Treasury’s help and support to increase the number of home- owners helped, and Treasury should do everything it can to ensure the program’s quarterly report to congress I July 25, 2012 185

success. Without regular periodic milestones and program adjustments, opportuni- ties to reach struggling homeowners may be lost.

Treasury should publish on its website and in the Housing Scorecard on a quarterly basis the total number of homeowners assisted, funds drawn down by states, and dollars expended for assistance to homeowners, assistance committed to homeowners, and cash on hand, aggregated by all state Hardest Hit Fund programs. Treasury has rejected this basic recommendation for greater transparency. While the 19 HFAs have provided a significant amount of transparency on their HHF programs on each of their websites, Treasury itself can do more to improve transparency. Tracking performance of all HHF programs would require a tax- payer to gather information from 19 websites. Treasury aggregates the number of homeowners assisted and dollars expended, but SIGTARP, not Treasury, publishes this information. Treasury should publish this information, along with other useful information on HHF’s performance, on its website and in the monthly Housing Scorecard that reports on the Administration’s efforts in housing programs. A Treasury official told SIGTARP during its audit that it is appropriate to leave report- ing of the data to the states, stating, “This is not our program. These are their pro- grams.” However, HHF is a TARP program, the source of the funds is TARP, and Treasury is the steward over TARP. Congress and the public are rightfully entitled to increased transparency and accountability of how TARP funds are used.

Treasury should develop an action plan for the Hardest Hit Fund that includes steps to increase the numbers of homeowners assisted and to gain industry support for Treasury-approved HHF programs. Treasury should set interim metrics for how many homeowners it intends to assist in a Treasury- defined time period in each particular program (such as principal reduction, second lien reduction, or reinstatement). If Treasury cannot achieve the desired level of homeowners assisted in any one program area in the defined time period, Treasury should put the funds to better use toward programs that are reaching homeowners. Treasury is rejecting this recommendation. Treasury must change the status quo and fulfill its role as steward over TARP programs and make determinations of which programs are successful and which programs are not working. In par- ticular, Treasury needs to develop an action plan that includes steps that Treasury intends to take to increase dramatically the numbers of homeowners assisted in all the HHF programs, including the two known areas Treasury supports but that are lacking broad industry support — principal reduction and second-lien reduction. If Treasury is unable to help struggling homeowners with one type of assistance, for example principal reduction, then it must take leadership to put the funds to better use. This may include putting the funds toward programs that are more successful at reaching homeowners. Treasury has an obligation to ensure that HHF funds are reaching homeowners, and it is unacceptable to delegate all of this responsibility to the states. 186 special inspector general I troubled asset relief program

Recommendations from SIGTARP’s Audit of the Net Present Value Test’s Impact on the Home Affordable Modification Program In its audit report “The Net Present Value Test’s Impact on the Home Affordable Modification Program,” released June 18, 2012, SIGTARP assessed the issues surrounding the Net Present Value (“NPV”) test that have posed challenges to HAMP’s success. SIGTARP’s report identified concerns with the NPV test that may stand as barriers to homeowners getting much-needed help from HAMP. The report included four recommendations to Treasury.

Treasury should stop allowing servicers to add a risk premium to Freddie Mac’s discount rate in HAMP’s net present value test. SIGTARP found in its sample that the discretion that Treasury gave to servicers to override the baseline discount rate in the NPV test by adding a risk premium (of up to 2.5%) reduces the number of otherwise qualified homeowners Treasury helps through HAMP. Treasury responded that it would discuss this recommendation with SIGTARP, but that use of a risk premium is traditional in expected cash flow modeling. HAMP is not a traditional program and the risk premium is not tradi- tionally used by servicers in HAMP. Only four servicers add a risk premium, includ- ing Bank of America, N.A., and Wells Fargo Bank, N.A. More than 100 servicers do not add a risk premium. There is a simple fix for Treasury to remove this obstacle to homeowners getting into HAMP — tell servicers that risk premiums are no longer allowed.

Treasury should ensure that servicers use accurate information when evaluating net present value test results for homeowners applying to HAMP and should ensure that servicers maintain documentation of all net present value test inputs. To the extent that a servicer does not follow Treasury’s guidelines on input accuracy and documentation maintenance, Treasury should permanently withhold incentives from that servicer. Any model will be only as good as its inputs. SIGTARP found in its sample that servicers made errors using NPV inputs and did not properly maintain records of all NPV inputs during the period of our review. Within SIGTARP’s judgmental sample of 149 HAMP applications, SIGTARP found that the servicers could provide both accurate inputs and documentation for only two HAMP applications. SIGTARP found that servicers failed to comply with HAMP guidelines on maintaining records on NPV inputs, which is crucial for compliance and to protect homeown- ers’ rights to challenge servicer error. Treasury responded that it would discuss this recommendation with SIGTARP.

Treasury should require servicers to improve their communication with homeowners regarding denial of a HAMP modification so that homeowners can move forward with other foreclosure alternatives in a timely and fully quarterly report to congress I July 25, 2012 187

informed manner. To the extent that a servicer does not follow Treasury’s guidelines on these communications, Treasury should permanently withhold incentives from that servicer. In its sample, SIGTARP found that servicers had poor communication with homeowners on the denial of a HAMP modification due to the NPV test. HAMP guidelines require that servicers communicate a denial to the homeowner within 10 days of the decision. Servicers’ failure to communicate denial in a timely man- ner can have serious consequences because a delay may prevent homeowners from finding other foreclosure alternatives sooner. In addition, HAMP guidelines require that the servicer list certain NPV inputs and provide vital information on foreclo- sure alternatives in the denial letter. Treasury said it would discuss this recommen- dation with SIGTARP, and that it made improvements in this area according to a sample that Treasury compliance agent Freddie Mac recently conducted on four large servicers.

Treasury should ensure that more detail is captured by the Making Home Affordable Compliance Committee meeting minutes regarding the substance of discussions related to compliance efforts on servicers in HAMP. Treasury should make sure that minutes clearly outline the specific problems encountered by servicers, remedial options discussed, and any requisite actions taken to remedy the situation. SIGTARP found a lack of detail in Treasury’s meeting minutes related to Treasury’s oversight of servicers and servicer remediation efforts. Because Treasury failed to document its oversight, SIGTARP was unable to verify Treasury’s role in the oversight of servicers or its compliance agent Freddie Mac. Treasury said it would discuss this recommendation with SIGTARP.

Update on Recommendation Regarding Hardest Hit Fund Information Security As part of its ongoing efforts to reduce TARP’s vulnerabilities to fraud, waste, and abuse, SIGTARP notified Treasury, in a letter dated November 23, 2011, of an area of potential vulnerability related to the handling of sensitive borrower information by the state HFAs that participate in HHF, and made recommendations on how to reduce that vulnerability. SIGTARP recommended:

Treasury should protect borrower personally identifiable information (“PII”) and other sensitive borrower information compiled for the Hardest Hit Fund (“HHF”) by: (1) requiring that within 90 days, all Housing Finance Agencies (and their contractors) (“HFAs”) participating in HHF develop and implement effective policies and procedures to ensure protection against unauthorized access, use, and disposition of PII and other sensitive borrower 188 special inspector general I troubled asset relief program

information; (2) Treasury reviewing each HFA’s policies and procedures to determine if they are effective, and taking such action as is required to ensure effectiveness; (3) requiring that all parties granted access to borrower information should be made aware of restrictions on copying and disclosing this information; (4) requiring annual certification by HFAs to Treasury that that they are in compliance with all applicable laws, policies and procedures pertaining to borrower information; and (5) requiring that HFAs promptly notify Treasury and SIGTARP within 24 hours, when a breach of security has occurred involving borrower information. Treasury told SIGTARP that it obtained all 19 HFAs’ policies and procedures regarding the protection of PII, is in the process of discussing these policies with the HFAs, and sent a survey to each of the HFAs. Treasury told SIGTARP that the three current certifications per year, as required by the contract between Treasury and the HFAs, cover all federal and state laws regarding PII, and extend to a contractor’s handling of PII. Treasury told SIGTARP that it informed all partici- pating HFAs by email that it considers PII breaches to be included in contractual notification requirements. However, Treasury did not require notification within 24 hours or notification to SIGTARP. It is important that the reporting of any breach of homeowner PII occur as expeditiously as possible to SIGTARP and Treasury to protect against or lessen the damage that could be done with this information. SIGTARP will continue to monitor Treasury’s efforts to implement SIGTARP’s recommendation. quarterly report to congress I July 25, 2012 189 Continued on next page C omments has made Although Treasury substantial efforts to comply with in many of its this recommendation have been exceptions, there agreements, with servicers including in its agreements in MH A. The F ederal Reserve adopted this mechanisms that address recommendation. was implemented This recommendation to CMB S, and the F ederal with respect LF to R MB S. Reserve did not expand TA TBD / N A X N ot I mplemented I n Process X Partially I mplemented X X X X X X X I mplemented , Treasury should , Treasury , that the party on which ble tion s Ta Recommendation consider requiring, before committing TARP funds to the committing TARP before consider requiring, and/ that certain minimum underwriting standards program, mechanisms be put in place with or other fraud prevention to the A B S and/or assets underlying respect used for collateral. Treasury should include language in the automobile industry Treasury oversight transaction term sheet acknowledging SIGTARP’s access to relevant giving SIGTARP and expressly role documents and personnel. agreements should include language in new TARP Treasury SIGTARP to facilitate compliance and oversight. Specifically, participant should (1) that each program recommends acknowledge explicitly the jurisdiction and authority of to oversee and other oversight bodies, as relevant, SIGTARP compliance of the conditions contained in agreement to with respect in question, (2) establish internal controls periodically to the C ompliance that condition, (3) report department of the O ffice of F inancial Stability (“ OF S- the implementation of those controls C ompliance”) regarding a and its compliance with the condition, (4) provide senior official to an appropriate signed certification from is accurate. OF S- C ompliance that such report as well those governing agreements, All existing TARP website new transactions, should be posted on the Treasury as soon possible. on the to report recipients all TARP should require Treasury funds. actual use of TARP valuation quickly determines its going-forward Treasury methodology. begins to develop an overall investment strategy Treasury its portfolio of stocks and decide whether it intends address warrants of common stock. to exercise LF of TA In formulating the structure LF participants should include an with TA Agreements subject to the oversight acknowledgment that: (1) they are to any (2) with respect of OF S- C ompliance and SIGTARP, LF condition imposed as part of TA to establish internal the condition is imposed required periodically to each condition, report with respect controls respect a certification with on such compliance, and provide to such compliance. agreeing consideration before should give careful Treasury LF to include MB S without a full review to the expansion of TA certainconsidering without and involved be may that risks of minimum fraud protections. ARP Recommend a * * * * * * * * * S I G T 1 2 3 4 5 6 7 8 9 closed and will take no further action. considers the recommendation Note: * Indicates that Treasury 190 special inspector general I troubled asset relief program Continued on next page C omments was implemented This recommendation to CMB S, and the F ederal with respect LF to R MB S. Reserve did not expand TA has formalized its valuation Treasury publishes its strategy and regularly estimates. O n D ecember 1, 2010, the F ederal Reserve publicly disclosed the identities had and that there LF borrowers of all TA of collateral. SIGTARP been no surrender if a will continue to monitor disclosures takes place. collateral surrender The F ederal Reserve announced that LF loans, ineligible for TA R MB S were moot. this recommendation rendering was implemented This recommendation to CMB S, and the F ederal with respect LF to R MB S. Reserve did not expand TA The F ederal Reserve adopted this mechanisms that address to CMB S, with respect recommendation LF to R MB S. and did not expand TA X X TBD / N A X N ot I mplemented I n Process Partially I mplemented X X X X X X X I mplemented ( C on ti nued) , including minimum . ble tion s Ta , Treasury should dispense with rating agency , Treasury significantly higher haircuts should require , Treasury Recommendation LF to legacy should oppose any expansion of TA Treasury program to MB S without significant modifications to the a full assessment of risks associated with such an ensure expansion. should formalize its valuation strategy and begin Treasury investments to the public. values of the TARP providing to and the F ederal Reserve should provide Treasury the identity of borrowers for public disclosure, SIGTARP, LF collateral in TA who surrender LF In TA a security-by-security screening determinations and require to participate should refuse for each legacy R MB S. Treasury is not designed so that R MB S, whether new if the program as collateral if the loans backing will be rejected or legacy, particular R MB S do not meet certain baseline underwriting to be in categories that have been proven criteria or are riddled with fraud, including certain undocumented subprime mortgages. residential LF In TA for legacy R MB S, for all MB S, with particularly high haircuts or other equally effective mitigation efforts. additional anti-fraud and credit should require Treasury specific to all MB S, before provisions, protection LF participating in an expanded TA with compliance protocol should design a robust Treasury LF transaction participants complete access rights to all TA oversight bodies. and other relevant for itself, SIGTARP, should not allow L egacy Securities PPI F s to invest Treasury included are LF unless significant mitigating measures in TA these dangers. to address or any LF modeling and decisions, whether on haircuts All TA or fraud loss mechanisms, should account for other credit including broadly, potential losses to Government interests funds, and not just potential losses to the F ederal TARP Reserve. the confusion and uncertainty on should address Treasury executive compensation by immediately issuing the required regulations. underwriting standards and other fraud prevention and other fraud prevention underwriting standards measures. ARP Recommend a * * * * * * * * * S I G T 10 11 12 13 14 15 16 17 18 19 closed and will take no further action. considers the recommendation Note: * Indicates that Treasury quarterly report to congress I July 25, 2012 191 our Continued on next page C omments OF S- C ompliance to Treasury, According its staffing level and has has increased contracted with four private firms to additional assistance to OF S- provide C ompliance. with no closed the program Treasury investments having been made, rendering moot. this recommendation has adopted some significant Treasury related to this rules conflict-of-interest but has failed to recommendation, impose other significant safeguards. with PPI F agreements Treasury’s managers include investor-screening such as “Know Y procedures Treasury C ustomer” requirements. that it will have access to has agreed any information in a fund manager’s to beneficial owners. possession relating did not impose an Treasury H owever, that managers requirement affirmative obtain and maintain beneficial owner information. has decided to adopt this Treasury recommendation. important SIGTARP will monitor Treasury’s SIGTARP implementation of the recommendation. X TBD / N A N ot I mplemented X I n Process X X X Partially I mplemented X I mplemented ( C on ti nued) ustomer” requirements at least our C ustomer” requirements ble tion s Ta Recommendation as rigorous as that of a commercial bank or retail brokerage brokerage bank or retail as that of a commercial as rigorous money laundering and the participation operation to prevent to abusing the system, and (2) be required of actors prone with the identities of all beneficial Treasury to provide in the fund so that Treasury owners of the private interests that investors in the diligence to ensure can do appropriate legitimate. funds are Treasury should significantly increase the staffing levels of should significantly increase Treasury the timely development and OF S- C ompliance and ensure implementation of an integrated risk management and compliance program. C AP participants to (1) establish an should require Treasury funds, (2) to monitor their actual use of TARP internal control funds, on their actual use of TARP periodic reporting provide (3) certify to OF S- C ompliance, under the penalty of criminal is accurate, that the same criteria sanction, that the report reports certified should be and regular of internal controls applied to all conditions imposed on C AP participants, and (4) acknowledge explicitly the jurisdiction and authority of to and other oversight bodies, as appropriate, SIGTARP oversee conditions contained in the agreement. rules upon should impose strict conflict-of-interest Treasury that specifically address all programs PPI F managers across whether and to what extent the managers can (1) invest PPI F funds in legacy assets that they hold or manage on behalf of themselves or their clients (2) conduct PPI F transactions with entities in which they have invested on behalf of themselves or others. that all PPI F fund managers (1) should require Treasury including procedures, have stringent investor-screening “Know Y comprehensive most PPIP managers to provide should require Treasury nation clauses to PPI F equity stakeholders, favored and to a fiduciary duty, acknowledge that they owe Treasury ethics policy and compliance apparatus. adopt a robust servicers in MH A to submit third- should require Treasury residing in the party verified evidence that the applicant is funding a mortgage modification. before subject property ARP Recommend a * * * * * S I G T 20 21 22 23 24 25 closed and will take no further action. considers the recommendation Note: * Indicates that Treasury 192 special inspector general I troubled asset relief program Continued on next page C omments SIGTARP’s rejected Treasury for a closing-like recommendation since this H owever, procedure. was issued, Treasury recommendation has taken several actions to prevent fraud on the part of either MH A servicers or applicants. has said it will adopt this Treasury will monitor SIGTARP recommendation. implementation of the Treasury’s recommendation. SIGTARP’s has rejected Treasury and does not require recommendation on the modification income reported to income application to be compared on the original loan application. reported Rather than deferring payment of the incentive until after the homeowner has verifiably made a minimum number of payments on its permanent modification, will pay the incentive after Treasury that the homeowner servicer represents payments during the trial has made three period. TBD / N A X X N ot I mplemented X I n Process X Partially I mplemented X X I mplemented ( C on ti nued) ble tion s Ta Recommendation A, Treasury should require a closing-like procedure a closing-like procedure should require In MH A, Treasury be conducted that would include (1) a closing warning sheet that would warn the applicant of consequences and thumbprint of each of fraud; (2) the notarized signature participant; (3) mandatory collection, copying, and retention of copies identification documents all participants in the transaction; (4) verbal and written warnings regarding made fully hidden fees and payments so that applicants are entitled of them; (5) the benefits to which they are aware a corrupt servicer from (to prevent under the program the Government and not passing collecting payments from the full amount of subsidies to homeowners); and (6) for the modification. the fact that no fee should be charged should be adopted in MH A Additional anti-fraud protections to verify the identity of participants in the transaction the potential for servicers to steal from and to address Government subsidies without applying individuals receiving them for the benefit of homeowner. the servicer to compare should require In MH A, Treasury on a mortgagethe income reported modification application on the original loan applications. with the income reported that verifiable, third-party should require In MH A, Treasury income information be obtained to confirm an applicant’s made. any modification payments are before should defer payment of the $1,000 In MH A, Treasury incentive to the servicer until after homeowner has verifiably made a minimum number of payments under the mortgage modification program. educate homeowners should proactively In MH A, Treasury warn them about of the program, about the nature rescue fraudsters, and publicize that no fee is modification necessary to participate in the program. ARP Recommend a * * * * * S I G T 26 27 28 29 30 31 closed and will take no further action. considers the recommendation Note: * Indicates that Treasury quarterly report to congress I July 25, 2012 193 Continued on next page C omments administrator, program While Treasury’s F annie M ae, has developed a H A P that maintains the system of record servicers’ and investors’ names personally participating borrowers’ identifiable information, such as names the database is not and addresses, constructed to maintain other information that may assist in detecting insiders who fraud. committing large-scale are to adopt this has refused Treasury designed significant anti-fraud measure This conflicts of interest. to prevent a material deficiency in the represents program. has committed to publish Treasury on a quarterly basis certain high-level purchases information about aggregated by the PPI F s, but not within seven days of has not Treasury the close of quarter. full transparency committed to providing invested public dollars are to show where of every periodic disclosure by requiring trade in the PPI F s. than two years, Treasury After more now states that it has developed risk it and performance metrics. H owever, will use is still not clear how Treasury these metrics to evaluate the PPIP action as managers and take appropriate by SIGTARP. recommended to adopt this has refused Treasury solely on relying recommendation, right to end the investment Treasury’s period after 12 months. That timeframe to failure Treasury’s expired. has already potentially adopt this recommendation puts significant Government funds at risk. TBD / N A X X X N ot I mplemented I n Process X X Partially I mplemented X I mplemented ( C on ti nued) ble tion s Ta Recommendation A, Treasury should require its agents to keep track of should require In MH A, Treasury the names and identifying information for each participant in each mortgage modification transaction and to maintain a database of such information. the imposition of strict information should require Treasury barriers or “walls” between the PPI F managers making investment decisions on behalf of the PPI F and those employees of the fund management company who manage non-PPI F funds. should periodically disclose PPI F trading activity Treasury within PPI F managers to disclose SIGTARP, and require all trading activity, seven days of the close quarter, may disclose holdings, and valuations so that SIGTARP in its protections, such information, subject to reasonable quarterly reports. metrics and an should define appropriate Treasury evaluation system should be put in place to monitor the they effectiveness of the PPI F managers, both to ensure and to measure fulfilling the terms of their agreements are performance. a “cause” to remove The conditions that give Treasury PPI F manager should be expanded to include a manager’s performance benchmark, or if below a certain standard concludes that the manager has materially violated Treasury compliance or ethical rules. PPI F managers to disclose should require Treasury not only as partL ist process, of the Watch Treasury, information about holdings in eligible assets but also liabilities. to related assets or exposures holdings in related ARP Recommend a * * * * * S I G T 32 33 34 35 36 37 closed and will take no further action. considers the recommendation Note: * Indicates that Treasury 194 special inspector general I troubled asset relief program Continued on next page C omments that it can have has agreed Treasury access to any information in a fund to possession relating manager’s is Treasury beneficial owners. H owever, requirement not making an affirmative that managers obtain and maintain will Treasury beneficial owner information. to give not adopt the recommendation itself unilateral ability to deny access stating that such a an investor, or remove right would deter participation. and the F ederal Reserve have Treasury discussed concerns about potential overrating or rating shopping with the to rating agencies, and have agreed continue to develop and enhance risk where management tools and processes, appropriate. stated that it does not Treasury anticipate taking a substantial percentage ownership position in any other financial institution pursuant to EE SA. to work closely with has agreed Treasury involved other F ederal agencies that are in TARP. X TBD / N A X N ot I mplemented I n Process X Partially I mplemented X X X X I mplemented ( C on ti nued) ble tion s Ta Recommendation Treasury should require PPI F managers to obtain and should require Treasury maintain information about the beneficial ownership of all should have the and Treasury the private equity interests, participation of private equity unilateral ability to prohibit investors. assertions and F R BNY should (1) examine M oody’s Treasury using lower standards rating agencies are that some credit LF security the necessary AAA rating to give a potential TA that acceptance of and (2) develop mechanisms to ensure LF is not unduly influenced by the improper collateral in TA agencies. incentives to overrate that exist among the credit explicitly document the vote of each should more Treasury to Investment C ommittee member for all decisions related funds. the investment of TARP systems to existing control should improve Treasury of external phone calls and nature document the occurrence and in-person meetings about actual potential recipients of funding under the C PP and other similar TARP-assistance to which they may be part of the decision making. programs the Special should direct of the Treasury The Secretary M aster to work with F R BNY officials in understanding AIG challenges before and retention compensation programs compensation decisions that may affect developing future by AIG for F ederal both institutions’ ability to get repaid assistance provided. should establish policies to guide any similar Treasury decisions to take a substantial ownership position in future review an advance require financial institutions that would of the obligations aware can be reasonably so that Treasury and challenges facing such institutions. should establish policies to guide decision making Treasury to defer another in determining whether it is appropriate decisions where programming agency when making TARP than one F ederal agency is involved. more ARP Recommend a * * * * * * S I G T 38 39 40 41 42 43 44 closed and will take no further action. considers the recommendation Note: * Indicates that Treasury quarterly report to congress I July 25, 2012 195 Continued on next page C omments highlighting repeated D espite SIGTARP’s and of this essential transparency has Treasury effectiveness measure, to disclose clear and relevant refused goals and estimates for the program. its has increased Although Treasury of servicer performance,reporting it has not identified goals for each metric and performance against those measured goals. to has adopted some programs Treasury assist underwater mortgages to address concerns of negative equity but has not other factors contained in this addressed recommendation. TBD / N A X X N ot I mplemented I n Process X X Partially I mplemented X X X X I mplemented ( C on ti nued) ble tion s Ta Recommendation Treasury should rectify the confusion that its own should rectify Treasury disclosing statements have caused for H A M P by prominently its goals and estimates (updated over time, as necessary) will help through of how many homeowners the program report monthly on its progress permanent modifications and meeting that goal. toward should develop other performance metrics Treasury over time against them to measure and publicly report F or example, the implementation and success of H A M P. against those could set goals and publicly report Treasury times, modifications as a goals for servicer processing loans in default, modifications of a servicer’s proportion rates of how generally, of foreclosures as a proportion prior to permanent fall out of the program many borrowers re-default rates. modification, and should undertake a sustained public service Treasury additional campaign as soon possible, both to reach and to arm the program who could benefit from borrowers the public with complete, accurate information — this will fraud and and prevent help to avoid confusion and delay, abuse. its position that allows servicers should reconsider Treasury to substitute alternative forms of income verification based on subjective determinations by the servicer. that to ensure structure H A M P’s should re-examine Treasury stemming it is adequately minimizing the risk of re-default non-mortgage rate debt, second liens, partialfrom interest from many after the five-year modifications end, and resets being underwater. borrowers putting before screening should institute careful Treasury CDC I into an institution with additional capital through TARP matching funds that the insufficient capital to ensure of not flowing into an institution that is on the verge are failure. to audit and procedure should develop a robust Treasury verify the bona fides of any purported capital raise in CDC I to verify the source, and to establish adequate controls amount and closing of all claimed private investments. CDC I terms to clarify that Treasury should revise Treasury CDC I inspection and copy rights continue until the entire consistent with investment is terminated. Additionally, made in connection with other TARP recommendations expressly to provide the terms should be revised programs, equal records shall have access to the CDF I’s that SIGTARP to that of Treasury. ARP Recommend a S I G T 45 46 47 48 49 50 51 52 closed and will take no further action. considers the recommendation Note: * Indicates that Treasury 196 special inspector general I troubled asset relief program Continued on next page C omments has indicated that it Treasury implemented this recommendation. Although the detail of minutes has is still not identifying Treasury improved, how each member of the committee casts his or her vote. to document the has agreed Treasury dates, participants, and subject line of to document the calls. It has refused substance of such conversations. has adopted procedures Treasury this designed to address including a policy to recommendation, discuss only warrant valuation inputs and a bid, methodologies prior to receiving generally to limit discussion valuation from approval ranges after receiving C ommittee, and to note the Warrant of any added information the provision in the C ommittee minutes. H owever, believes that its existing internal Treasury adequate sufficient to ensure are controls consistency in the negotiation process. continues largely Although Treasury stating that on self-reporting, to rely it only plans to conduct testing where they have particular concerns as to a compliance procedures recipient’s TARP it has conducted or testing results, independent testing of compliance obligations during some compliance reviews. states that it has developed Treasury that guidance to guidance and provided the exceptional assistance participants as of in TARP remaining that were has not June 30, 2011. Treasury other factors contained in this addressed citing its belief that recommendation, materiality should be subject to a fact review. and circumstances TBD / N A X X N ot I mplemented I n Process X X X Partially I mplemented X I mplemented ( C on ti nued) ble tion s Ta Recommendation Treasury should consider more frequent surveys of a CDC I frequent should consider more Treasury funds than annually as currently use of TARP participant’s effectivelycontemplated. Quarterly surveys would more emphasize the purpose of CDC I. by detail is captured that more should ensure Treasury C ommittee meeting minutes. At a minimum, the Warrant the minutes should include members’ qualitative accepted or bids were the reasons considerations regarding within fair market value ranges. rejected should document in detail the substance of Treasury concerning warrant all communications with recipients repurchases. should develop and follow guidelines internal Treasury negotiations concerning how warrant repurchase controls of and nature will be pursued, including the degree institutions with repurchasing information to be shared valuation of the warrants. concerning Treasury’s take steps to verify TARP should promptly Treasury participants’ conformance to their obligations, not only by ensuring that they have adequate compliance procedures but also by independently testing participants’ compliance. should develop guidelines that apply consistently Treasury participants for when a violation is sufficiently TARP across that or in the alternative require material to merit reporting, all violations be reported. ARP Recommend a * * * S I G T 53 54 55 56 57 58 closed and will take no further action. considers the recommendation Note: * Indicates that Treasury quarterly report to congress I July 25, 2012 197 Continued on next page C omments anticipated costs, has provided Treasury but not expected participation. plans to maintain the voluntary Treasury an providing of the program, nature explanation that on its face seems will SIGTARP unpersuasive to SIGTARP. continue to monitor performance. to refused Treasury than a year, F or more even though adopt this recommendation, average U .S. terms of unemployment in July 2011, lengthening. H owever, were the Administration announced a policy has extended the change, and Treasury minimum term of the unemployment months to 12 three from program months, effective O ctober 1, 2011. to adopt this refused Treasury citing its belief that recommendation, C PP participants may be unfairly current disadvantaged in their S BLF applications if their existing C PP investments are not counted as part of their capital provides base, and that S BLF “already that C PP recipients substantial hurdles that don’t apply to other must overcome” applicants. X TBD / N A X X N ot I mplemented I n Process X Partially I mplemented X X X I mplemented ( C on ti nued) , because conditions for many of the . ble tion s Ta Recommendation relevant institutions have changed dramatically since they relevant and the bank regulators Treasury for C PP, approved were should conduct a new analysis of whether the applying institution is sufficiently healthy and viable to warrant participation in S BLF P-related program and subprogram, Treasury Treasury and subprogram, program F or each H A M P-related should publish the anticipated costs and expected is participation in each and that, after program performance monthly as to the program’s launched, it report against these expectations. of its the voluntary nature should re-evaluate Treasury of whether it and, irrespective program principal reduction consider changes to better or mandatory, is discretionary extent to the greatest maximize its effectiveness, ensure of similarly situated possible the consistent treatment issues. potential conflict of interest and address borrowers, across should adopt a uniform appraisal process Treasury short-sale and principal all H A M P and P-related procedures. consistent with FH A’s programs reduction the length of minimum term should reconsider Treasury unemployment forbearance program. of H A M P’s information should launch a broad-based Treasury campaign, including public service announcements in target markets that focus on warnings about potential fraud, and include conspicuous fraud warnings whenever it makes public announcements about the H A M P program. broad considers whether to accept an existing C PP When Treasury participant into S BLF conducts the new analysis of an institution’s When Treasury should shares the existing C PP preferred health and viability, capital base. not be counted as part of the institution’s ARP Recommend a * * S I G T 59 60 61 62 63 64 65 closed and will take no further action. considers the recommendation Note: * Indicates that Treasury 198 special inspector general I troubled asset relief program Continued on next page C omments to adopt this refused Treasury suggesting that recommendation, its adoption would subvert the will and that SIGTARP’s of C ongress “may not be helpful” recommendation because “it is unclear that using this statutorily mandated baseline will lead to anomalies.” that OF S has told SIGTARP Treasury new guidance using the FD I C ’s created O utside C ounsel D eskbook and other resources. that OF S has told SIGTARP Treasury distributed its new guidance to all under contract to law firms currently further stated that OF S OF S. Treasury Procurement will work with Treasury’s Services D ivision to begin modifying base contracts for OF S legal services to as well. include those standards that OF S has held told SIGTARP Treasury training on its newly adopted guidance how legal fee bills should prescribing with OF S CO TRs and other be prepared of legal fee staff involved in the review bills, and that the OF S CO TRs will begin with invoices in accordance reviewing its new guidance for periods starting 2011. OF S also stated that with M arch portions of its it incorporated relevant training on the new legal fee bill review into written procedures. standards TBD / N A X N ot I mplemented X I n Process Partially I mplemented X X X X I mplemented ( C on ti nued) ble tion s Ta Recommendation Treasury should take steps to prevent institutions that are institutions that are should take steps to prevent Treasury securing windfall C PP from into the S BLF from refinancing in lending. increase without any relevant dividend reductions as part of its due diligence concerning any Treasury, or sale of its C PP recapitalization, restructuring, proposed the to SIGTARP should provide party, investment to a third identity of the C PP institution and details proposed transaction. into S BLF and seeks When a C PP participant refinances to should provide additional taxpayer funds, Treasury the identity of institution and details SIGTARP additional S BLF investment. proposed OF S should adopt the legal fee bill submission standards Outside Counsel Deskbook , or contained in the FD I C ’s for how law establish similarly detailed requirements legal fee bills and describe specific firms should prepare work performed in the bills, and which costs fees are allowable and unallowable. OF S should include in its open legal service contracts and for law firms on the preparation detailed requirements the submission of legal fee bills, or separately provide instructions to law firms and modify its open contracts, making application of the instructions mandatory. standards OF S should adopt the legal fee bill review Outside Counsel contained in the FD I C ’s and procedures Deskbook , or establish similarly specific instructions and legal fee guidance for OF S CO TRs to use when reviewing bills, and incorporate those instructions guidance into OF S written policies. ARP Recommend a * * * * * S I G T 66 67 68 69 70 71 closed and will take no further action. considers the recommendation Note: * Indicates that Treasury quarterly report to congress I July 25, 2012 199 Continued on next page C omments that Treasury told SIGTARP Treasury is trying to determine what procurement with other is appropriate action, if any, legal service contracts. made important changes to Treasury its servicer assessments by including metrics for the ratings, including several qualitative quantitative metrics. H owever, internal metrics to assess the servicer’s ratings categories in the three controls and guidelines or criteria for remain, rating the effectiveness of internal SIGTARP still necessary. are controls will continue to monitor Treasury’s implementation of this recommendation. MH A C ompliance M inutes of recent C ommittee meetings contain brief explanations of servicer assessment these rating decisions. H owever, minutes do not explain the C ommittee’s deliberations in detail, do not indicate how members voted beyond a tally of the votes, and do not discuss follow- up actions or escalation. SIGTARP will continue to monitor Treasury’s implementation of the recommendation. to adopt this has refused Treasury saying it already recommendation, a loan servicer to communicate requires an average in writing with a borrower most written of 10 times. H owever, apply to a H A M P requirements fails response application and Treasury’s homeowners who receive to address servicers on miscommunication from important milestones or changes. that it already told SIGTARP Treasury established benchmarks in this area, including that trial periods should last to four months, and escalated three in 30 days. If cases should be resolved the benchmarks for acceptable these are performance, many servicers have has yet missed the mark. Also, Treasury to establish a benchmark for conversion trial modifications to rates from permanent modifications. TBD / N A X X N ot I mplemented X I n Process X X Partially I mplemented I mplemented ( C on ti nued) A agreement, or any other A agreement, ble tion s Ta Recommendation S should review previously paid legal fee bills to previously OF S should review and seek or unallowable charges, identify unreasonable as appropriate. for those charges, reimbursement should establish detailed guidance and internal Treasury governing how the MH A Servicer C ompliance controls Assessment will be conducted and how each compliance will be weighted. area by detail is captured that more should ensure Treasury the MH A C ompliance ommittee meeting minutes. At a proposed minimum, the minutes should include MH A- C ’s the committee members’ qualitative rating for each servicer, each servicer’s and quantitative considerations regarding the final ratings, the votes of each committee member, in justification for any difference rating for each servicer, rating, and any follow- proposed that rating with MH A- C ’s O ffice of General up including escalation to Treasury’s and the outcomes of that C ounsel or the Assistant Secretary escalation. that MH A servicer communications should require Treasury to changes in the status or with homeowners relating modification application, trial or terms of a homeowner’s permanent modification, H A F should establish benchmarks and goals for Treasury performance for all MH A servicers, acceptable program including the length of time it takes for trial modifications to be converted into permanent modifications, the conversion rate for trial modifications into permanent modifications, escalated homeowner the length of time it takes to resolve modification of required complaints, and the percentage missing. that are status reports significant change affecting the homeowner’s participation in significant change affecting the homeowner’s be in writing. the MH A program, ARP Recommend a * * * * * S I G T 72 73 74 75 76 closed and will take no further action. considers the recommendation Note: * Indicates that Treasury 200 special inspector general I troubled asset relief program Continued on next page C omments this important has rejected Treasury stating that it “believes recommendation, enacted have been that the remedies and that appropriate appropriate, exists.” transparency this important has rejected Treasury stating that it “believes recommendation, enacted have been that the remedies and that appropriate appropriate exists.” transparency nor disagreed neither agreed Treasury with the recommendation. nor disagreed neither agreed Treasury with the recommendation. nor disagreed neither agreed Treasury with the recommendation. nor disagreed neither agreed Treasury with the recommendation. nor disagreed neither agreed Treasury with the recommendation. TBD / N A X X X X X X X N ot I mplemented I n Process Partially I mplemented I mplemented ( C on ti nued) ble tion s Ta Recommendation Treasury should publicly assess the top 10 MH A servicers’ Treasury performance against acceptable performanceprogram of: the length of time it takes benchmarks in the areas for trial modifications to be converted into permanent modifications, the conversion rate for trial modifications into permanent modifications, the length of time it takes escalated homeowner complaints, and the to resolve reports that are modification status of required percentage missing. that all servicers participating in MH A must ensure Treasury enforcing by vigorously requirements comply with program including the terms of servicer participation agreements, remedies such as withholding, permanently using all financial and clawing back incentives for servicers who reducing, should be fail to perform at an acceptable level. Treasury actions taken and make public all remedial transparent against any servicer. should specifically determine the allowability of Treasury $7,980,215 in questioned, unsupported legal fees and expenses paid to the following law firms: Simpson Thacher & B artlett LL P ($5,791,724); C adwalader Wickersham & B issell & L iddell LL P LL P ($1,983,685); L ocke ord Taft ($146,867); and B ingham M c C utchen LL P (novated from $57,939). M cKee N elson LL P, contracting officer should disallow and seek The Treasury Simpson Thacher & B artlett LL P for $96,482 from recovery in questioned, ineligible fees and expenses paid that were those are not allowed under the OF S contract. Specifically, $68,936 for labor hours billed at rates in excess of the allowable maximums set in contract T OF S-09-0001, task costs not allowed 1, and $22,546 in other direct order 1. under contract T OF S-09-007, task order paid legal fee all previously review should promptly Treasury all law firms with which it has a closed or open bills from or unallowable charges contract to identify unreasonable as appropriate. for those charges, and seek reimbursement solicitation for legal in any future should require Treasury services multiple rate categories within the various partner, counsel, and associate labor categories. The additional labor rate categories should be based on the number of years the attorneys have practiced law. specified labor categories and should pre-approve Treasury allowed to they are rates of all contracted legal staff before time to OF S projects. work on and charge ARP Recommend a * S I G T 77 78 79 80 81 82 83 closed and will take no further action. considers the recommendation Note: * Indicates that Treasury quarterly report to congress I July 25, 2012 201 Continued on next page C omments to this responded Treasury by saying that it recommendation continues its efforts to wind down C PP and restructuring, repayments, through sales, all of which it was doing prior to intends Treasury this recommendation. securities. to auction off a pool of TARP the criteria has not addressed Treasury for these divestment strategies. this recommendation rejected Treasury why. without ever addressing See discussion in this section O S M began memorializing in its records justifications for exceptions. SIGTARP will continue to monitor whether those substantiate each exception records and whether the requests requested demonstrate or fail to “good cause.” TBD / N A X N ot I mplemented X X X I n Process Partially I mplemented X I mplemented As to Treasury that As to Treasury ( C on ti nued) As”) participating in HHF develop ble tion s Ta A’s policies and procedures to determine policies and procedures A’s As promptly notify Treasury and SIGTARP and SIGTARP notify Treasury As promptly Recommendation ederal banking regulators, in consultation with F ederal banking regulators, Treasury, that exit path to ensure should develop a clear TARP the TARP as many community banks possible repay to deal with the banks that cannot. investment and prepare should develop criteria pertaining to restructurings, Treasury investments (including any exchanges, and sales of its TARP of unpaid investment, the treatment discount of the TARP payments, and warrants). dividend and interest TARP the should assess whether it renegotiate Treasury contracts for those Program terms of its C apital Purchase prior community banks that will not be able to exit TARP the to help preserve in order to the dividend rate increase value of taxpayers’ investments. personally identifiable borrower should protect Treasury information information (“PII”) and other sensitive borrower H it F und (“ HHF ”) by: (1) requiring compiled for the H ardest that within 90 days, all H ousing F inance Agencies (and their contractors) (“ HF that the O ffice of the Special M aster consistently ensure To grants exceptions to the $500,000 cash salary cap, O ffice of the Special M aster should substantiate each demonstrate and whether the requests exception requested or fail to demonstrate “good cause.” The O ffice of the Special M aster should better document its use of market data in calculations. At a minimum, the document O ffice of the Special M aster should prospectively used as comparisons which companies and employees are of the market, and in its analysis of the 50th percentile and data so that the it should also maintain records between its determinations and benchmarks are relationship clearly understood. within 24 hours, when a breach of security has occurred of security has occurred within 24 hours, when a breach information. involving borrower and implement effective policies and procedures to ensure to ensure and implement effective policies and procedures against unauthorized access, use, and disposition protection information; (2) Treasury of PII and other sensitive borrower each HF reviewing to effective, and taking such action as is required if they are that all parties effectiveness; granted (3) requiring ensure information should be made aware access to borrower on copying and disclosing this information; of restrictions annual certification by HF (4) requiring in compliance with all applicable laws, policies they are information; and (5) pertaining to borrower and procedures that HF requiring ARP Recommend a * * * * S I G T 84 85 86 87 88 closed and will take no further action. considers the recommendation Note: * Indicates that Treasury 202 special inspector general I troubled asset relief program Continued on next page C omments O S M defended the adequacy of its O S M stated it policies and procedures. focus on how it can further will carefully develop and articulate its policies, and guidelines. procedures, to this responded Treasury that by requiring recommendation certify that they intend to rent borrowers for at least five years and the property effortsthat they will make reasonable This does not go far enough. to rent. Requiring only a self-certification, without compliance and enforcement a strong that the intent is to ensure regime is actually carried out and the property vulnerable to leaves the program rented, funds will pay investors risks that TARP for modifications mortgages on not rented, vacation homes that are as opposed to prevent, and may delay, H A M P redefault and increase foreclosures rates. to this responded Treasury that by requiring recommendation certify that they intend to rent borrowers for at least five years and the property effortsthat they will make reasonable This does not go far enough. to rent. Requiring only a self-certification, without compliance and enforcement a strong that the intent is to ensure regime is actually carried out and the property vulnerable to leaves the program rented, funds will pay investors risks that TARP for modifications mortgages on not rented, vacation homes that are as opposed to prevent, and may delay, H A M P redefault and increase foreclosures rates. TBD / N A X X X N ot I mplemented I n Process Partially I mplemented I mplemented ( C on ti nued) ble tion s Ta Recommendation aster should develop more The O ffice of the Special M aster should develop more or guidelines to help ensure policies, procedures, robust and its decisions are that its pay determination process transparency will improve evenhanded. These measures and help the O ffice of the Special M aster consistently apply allocation,” the Interim F inal Rule principles of “appropriate “performance-based compensation,” and “comparable and payments. structures to allow for effective compliance and enforcement In order that the borrower should require in H A M P Tier 2, Treasury and is occupied has been rented that the property prove applies for a loan by a tenant at the time borrower requiring only a certification modification, as opposed to As part of the property. intends to rent that the borrower the Request for M ortgage Assistance (“R M A”) application the servicer should provide for H A M P Tier 2, the borrower verified evidence of with a signed lease and third-party occupancy in the form of documents showing that a renter such as a utility bill, driver’s address, lives at the property insurance. In the case of of renter’s license, or proof should under one mortgage,Treasury multiple-unit properties the servicer with evidence provide that the borrower require that at least one unit is occupied by a tenant as part of the R M A. continue to allow for effective compliance and To in H A M P Tier 2 after the trial modification has enforcement that, prior to conversion should require started, Treasury of a trial modification to permanent modification, the certify under penalty of perjury that none the borrower stated in the R M A have changed. occupancy circumstances ARP Recommend a S I G T 89 90 91 closed and will take no further action. considers the recommendation Note: * Indicates that Treasury quarterly report to congress I July 25, 2012 203 Continued on next page C omments to this responded Treasury that by requiring recommendation certify that they intend to rent borrowers for at least five years and the property effortsthat they will make reasonable to basis on a year-round the property rent actions if it becomes vacant. Treasury’s the did not go far enough to protect to With no compliance regime program. is in place, the determine that a renter vulnerable to TARP remains program funds being paid to modify mortgages that do not fit within the intended expansion of the program. has not implemented this Treasury It is important that recommendation. educate as many homeowners Treasury as possible with accurate information about H A M P in an effort to prevent mortgage modification fraud. has not implemented this Treasury has not held Treasury recommendation. a summit of all key stakeholders to efficient and roll-out make the program date of roll-out effective. O n the program of the top 10 June 1, 2012, only three servicers had fully implemented largest H A M P Tier 2. TBD / N A X X X N ot I mplemented I n Process Partially I mplemented I mplemented ( C on ti nued) ble tion s Ta Recommendation To prevent a property that has received a H A M P Tier 2 that has received a property prevent To remaining vacant for an extended period modification from or a tenant vacates, of time after a lease expires immediately notify that borrowers should require (a) Treasury vacant for more has remained their servicer if the property months. than three monthly servicers to provide should require (b) Treasury that have remained of any properties to Treasury reports months. than three vacant for more incentives should bar payment of TARP-funded (c) Treasury to any participant that for a loan modification on property months, until than three vacant for more has been reported by a tenant has been re-occupied such time as the property verification of third-party has provided and the borrower occupancy. against the possibility that extension to protect In order in mortgage and expansion of H A M P will lead to an increase modification fraud, the that servicers provide should require (a) Treasury C onsumer F raud F orce Joint Task CF P B /Treasury SIGTARP/ as partAlert of their monthly to all H A M P-eligible borrowers mortgage statement until the expiration of application period for H A M P Tier 1 and 2. should undertake a sustained public service (b) Treasury additional campaign as soon possible both to reach who could potentially be helped by H A M P Tier 2 borrowers and to arm the public with complete, accurate information and to to avoid confusion and delay, about the program fraud and abuse. prevent in the volume of H A M P Given the expected increase applications due to the implementation of H A M P Tier 2, should convene a summit of key stakeholders to Treasury implementation and servicer ramp-up discuss program is roll-out so that the program performance requirements efficient and effective. ARP Recommend a S I G T 92 93 94 closed and will take no further action. considers the recommendation Note: * Indicates that Treasury 204 special inspector general I troubled asset relief program Continued on next page C omments said that it will include metrics Treasury will continue to SIGTARP in the future. implementation of this monitor Treasury’s recommendation. this has rejected Treasury to refusal Treasury’s recommendation. meaningful and measurable goals provide leaves it vulnerable to accusations that is trying to avoid accountability. See discussion in this section See discussion in this section See discussion in this section See discussion in this section TBD / N A X X X X X N ot I mplemented X I n Process Partially I mplemented I mplemented ( C on ti nued) ble tion s Ta Recommendation To ensure servicer compliance with H A M P Tier 2 guidelines ensure To and assess servicer performance, should include additional criteria in its servicer (a) Treasury compliance with the compliance assessments that measure of H A M P Tier 2. guidelines and requirements program should develop and publish separate metrics (b) Treasury and to H A M P Tier 2 in the compliance results related sections of the quarterly M aking H ome results program 10 MH A (“ MH A”) servicer assessments of the Top Affordable servicers. and success allow for assessment of the progress To should set meaningful and of H A M P Tier 2, Treasury measurable goals, including at a minimum the number of estimates will be helped by H A M P Tier Treasury borrowers disclose should unambiguously and prominently 2. Treasury in meeting monthly on its progress its goals and report these goals. should set meaningful and measurable Treasury H it F und program performance goals for the H ardest including, at a minimum, the number of homeowners and estimates will be helped by the program, Treasury against those goals. progress the program’s measure should instruct state housing finance agencies Treasury H it F und to set meaningful and measurable in the H ardest and interim performance goals with appropriate overarching for their individual state progress metrics to measure programs. should set milestones at which the state housing Treasury the H it F und must review finance agencies in the H ardest and make program of individual state programs progress this review. adjustments from should publish on its website and in the H ousing Treasury on a quarterly basis the total number of Scorecard homeowners assisted, funds drawn down by states, and dollars expended for assistance to homeowners, committed to homeowners, and cash on hand, aggregated H it F und programs. by all state H ardest ARP Recommend a S I G T 95 96 97 98 99 100 closed and will take no further action. considers the recommendation Note: * Indicates that Treasury quarterly report to congress I July 25, 2012 205 C omments See discussion in this section See discussion in this section See discussion in this section See discussion in this section See discussion in this section TBD / N A X X X X N ot I mplemented X I n Process Partially I mplemented I mplemented ( C on ti nued) ble tion s Ta Recommendation ardest should develop an action plan for the H ardest Treasury the numbers of H it F und that includes steps to increase homeowners assisted and to gain industry support for should set Treasury HHF programs. Treasury-approved interim metrics for how many homeowners it intends to time period in each particular assist in a Treasury-defined second lien reduction, (such as principal reduction, program cannot achieve the desired If Treasury or reinstatement). in area level of homeowners assisted in any one program should put the funds to Treasury the defined time period, homeowners. reaching that are programs better use toward should stop allowing servicers to add a risk Treasury net H A M P’s discount rate in M ac’s to F reddie premium value test. present that servicers use accurate should ensure Treasury value test results information when evaluating net present that for homeowners applying to H A M P and should ensure value servicers maintain documentation of all net present the extent that a servicer does not follow test inputs. To guidelines on input accuracy and documentation Treasury’s should permanently withhold maintenance, Treasury that servicer. incentives from their servicers to improve should require Treasury denial of a communication with homeowners regarding H A M P modification so that homeowners can move forward alternatives in a timely and fully with other foreclosure the extent that a servicer does not To informed manner. guidelines on these communications, follow Treasury’s that should permanently withhold incentives from Treasury servicer. by the detail is captured that more should ensure Treasury C ompliance ommittee meeting M aking H ome Affordable to the substance of discussions related minutes regarding should Treasury compliance efforts on servicers in H A M P. that minutes clearly outline the specific problems make sure options discussed, and by servicers, remedial encountered the situation. actions taken to remedy any requisite ARP Recommend a S I G T 101 102 103 104 105 closed and will take no further action. considers the recommendation Note: * Indicates that Treasury Endnotes

206 special inspector general I troubled asset relief program

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37. Treasury, “Factsheet on Capital Purchase Program,” 3/17/2009, www.treasury.gov/initiatives/financial-stability/programs/investment-programs/ cpp/Pages/capitalpurchaseprogram.aspx, accessed 6/28/2012. 38. Treasury, “Factsheet on Capital Purchase Program,” 3/17/2009, www.treasury.gov/initiatives/financial-stability/programs/investment-programs/ cpp/Pages/capitalpurchaseprogram.aspx, accessed 6/28/2012. 39. Treasury, Transactions Report, 6/27/2012, www.treasury.gov/initiatives/financial-stability/briefing-room/reports/tarp-transactions/ DocumentsTARPTransactions/07-02-12%20Transactions%20Report%20as%20of%2006-27-12_INVESTMENT.pdf, accessed 7/6/2012. 40. Treasury, response to SIGTARP data call, 7/5/2012. 41. 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659. AIG, 10-K, 2/23/2012, p. 175, www.sec.gov/Archives/edgar/data/5272/000104746912001369/a2207458z10-k.htm, accessed 6/28/2012. 660. AIG, 10-Q, 5/3/2012, p. 46, www.sec.gov/Archives/edgar/data/5272/000104746911009000/a2206083z10-q.htm, accessed 6/22/2012. 661. AIG, 10-K, 2/23/2012, p. 128, www.sec.gov/Archives/edgar/data/5272/000104746912001369/a2207458z10-k.htm, accessed 6/28/2012. 662. AIG, 10-Q, 5/3/2012, p. 37, www.sec.gov/Archives/edgar/data/5272/000104746912005310/a2209238z10-q.htm, accessed 6/28/2012. 663. AIG, 10-K, 2/28/2008, p. 101, www.sec.gov/Archives/edgar/data/5272/000095012308002280/0000950123-08-002280-index.htm, accessed 6/28/2012. 664. Financial Crisis Inquiry Commission, “The Financial Crisis Inquiry Report,” 1/27/2011, p. 350, http://fcic.law.stanford.edu/report, accessed 6/28/2012. 665. AIG, 10-K, 2/24/2011, p. 20, www.sec.gov/Archives/edgar/data/5272/000104746911001283/0001047469-11-001283-index.htm, accessed 6/28/2012. 666. Congressional Oversight Panel, “June Oversight Report: The AIG Rescue, Its Impact on Markets, and the Government’s Exit Strategy,” 6/10/2010, pp. 21-22, http://cybercemetery.unt.edu/archive/cop/20110401232818/http://cop.senate.gov/reports/library/report-061010-cop.cfm, accessed 6/28/2012. 667. Financial Crisis Inquiry Commission, “The Financial Crisis Inquiry Report,” 1/27/2011, p. 350, http://fcic.law.stanford.edu/report, accessed 6/28/2012. 668. Financial Crisis Inquiry Commission, “The Financial Crisis Inquiry Report,” 1/27/2011, p. 351, http://fcic.law.stanford.edu/report, accessed 6/28/2012. 669. AIG, 10-K, 2/23/2012, pp. 21-22, www.sec.gov/Archives/edgar/data/5272/000104746912001369/a2207458z10-k.htm, accessed 6/28/2012. 670. PropertyCasualty360, “Benmosche: Chartis Retaining Customers, Did Not Underprice Business,” 2/27/2012, www.propertycasualty360. com/2012/02/24/benmosche-chartis-retaining-customers-did-not-unde, accessed 6/12/2012. 671. Bloomberg, “AIG Is ‘Fed-Ready’ Ahead of Expected Oversight, Hancock Says,” 12/7/2011, www.bloomberg.com/news/print/2011-12-07/aig-is- fed-ready-ahead-of-expected-oversight-hancock-says-1-.html, accessed 6/12/2012. 672. AIG, 10-K, 2/23/2012, p. 158, www.sec.gov/Archives/edgar/data/5272/000104746912001369/a2207458z10-k.htm, accessed 6/28/2012. 673. AIG, 10-K, 2/28/2008, p. 112, www.sec.gov/Archives/edgar/data/5272/000095012308002280/0000950123-08-002280-index.htm, accessed 6/28/2012. 674. AIG, “Residential Mortgage Presentation,” 8/9/2007, http://media.corporate-ir.net/media_files/irol/76/76115/REVISED_AIG_and_the_ Residential_Mortgage_Market_FINAL_08-09-07.pdf, accessed 7/18/2012. 675. Financial Crisis Inquiry Commission, “The Financial Crisis Inquiry Report,” 1/27/2011, p. 268, http://fcic.law.stanford.edu/report, accessed 6/28/2012. 676. Emergency Economic Stabilization Act of 2008, P.L. 110-343, 10/3/2008. 677. Emergency Economic Stabilization Act of 2008, P.L. 110-343, 10/3/2008. 678. Treasury, response to SIGTARP data call, 7/9/2012. 679. Treasury, response to SIGTARP data call, 7/5/2012. 680. Treasury, response to SIGTARP data call, 7/5/2012. 681. Treasury, response to SIGTARP data call, 7/5/2012. 682. Congressional Oversight Panel, “Examining Treasury’s Use of Financial Crisis Contracting Authority,” 10/14/2010, http://cybercemetery.unt.edu/ archive/cop/20110402010440/http://cop.senate.gov/documents/cop-101410-report.pdf, accessed 7/9/2012. 228 Appendix a I glossary I July 25, 2012

Glossary This appendix provides a glossary of terms that are used in the context of this report.

7(a) Loan Program: SBA loan program guaranteeing Credit Default Swap (“CDS”): A contract where the seller a percentage of loans for small businesses that cannot receives payments from the buyer in return for agreeing to otherwise obtain conventional loans at reasonable terms. pay the buyer when a particular credit event occurs, such as when the credit rating on a bond is downgraded or a Accredited Investors: Individuals or institutions that loan goes into default. The buyer does not need to own the by law are considered financially sophisticated enough asset covered by the contract, meaning the swap can serve so that they can invest in ventures that are exempt from essentially as a bet against the underlying bond or loan. investor protection laws. Under U.S. securities laws, these include many financial companies, pension plans, wealthy Cumulative Preferred Stock: Stock requiring a defined individuals, and top executives or directors of the issuing dividend payment. If the company does not pay the dividend companies. on schedule, it still owes the missed dividend to the stock’s owner. Asset-Backed Securities (“ABS”): Bonds backed by a portfolio of consumer or corporate loans, e.g., credit card, CUSIP number (“CUSIP”): Unique identifying number auto, or small-business loans. Financial companies typically assigned to all registered securities in the United States issue ABS backed by existing loans in order to fund new loans and Canada; the name originated with the Committee on for their customers. Uniform Securities Identification Procedures. Auction Agent: Firm (such as an investment bank) that buys Custodian Bank: Bank holding the collateral and managing a series of securities from an institution for resale. accounts for FRBNY; for TALF the custodian is Bank of New York Mellon. Collateral: Asset pledged by a borrower to a lender until a loan is repaid. Generally, if the borrower defaults on the loan, Debt: Investment in a business that is required to be paid the lender gains ownership of the pledged asset and may sell back to the investor, usually with interest. it to satisfy the debt. In TALF, the ABS or CMBS purchased Deed-in-Lieu of Foreclosure: Instead of going through with the TALF loan is the collateral that is posted with foreclosure, the borrower voluntarily surrenders the deed to FRBNY. the home to the home lender, as satisfaction of the unpaid Collateralized Debt Obligation (“CDO”): A security that mortgage balance. entitles the purchaser to some part of the cash flows from a Deficiency Judgment: Court order authorizing a lender to portfolio of assets such as mortgage-backed securities, bonds, collect all or part of an unpaid and outstanding debt resulting loans, or other CDOs. from the borrower’s default on the mortgage note securing a Commercial Mortgage-Backed Securities (“CMBS”): debt. A deficiency judgment is rendered after the foreclosed Bonds backed by one or more mortgages on commercial real or repossessed property is sold when the proceeds are estate (e.g., office buildings, rental apartments, hotels). insufficient to repay the full mortgage debt. Common Stock: Equity ownership entitling an individual to Deobligations: An agency’s cancellation or downward share in corporate earnings and voting rights. adjustment of previously incurred obligations. Community Development Financial Institutions Due Diligence: Appropriate level of attention or care a (“CDFIs”): Financial institutions eligible for Treasury reasonable person should take before entering into an funding to serve urban and rural low-income communities agreement or a transaction with another party. In finance, it through the CDFI Fund. CDFIs were created in 1994 often refers to the process of conducting an audit or review of by the Riegle Community Development and Regulatory the institution before initiating a transaction. Improvement Act. These entities must be certified by Dutch Auction: A type of auction in which multiple bidders Treasury; certification confirms that they target at least 60% bid for different quantities of the asset; the price the seller of their lending and other economic development activities to accepts is set at the lowest bid of the group of high bidders areas underserved by traditional financial institutions. whose collective bids fulfill the amount of shares offered. As glossary I Appendix A I July 25, 2012 229

an example, three investors place bids to own a portion of Illiquid Assets: Assets that cannot be quickly converted to 100 shares offered by the issuer: cash. • Bidder A wants 50 shares at $4/share. Investors: Owners of mortgage loans or bonds backed by mortgage loans who receive interest and principal payments • Bidder B wants 50 shares at $3/share. from monthly mortgage payments. Servicers manage the cash • Bidder C wants 50 shares at $2/share. flow from borrowers’ monthly payments and distribute them to investors according to Pooling and Servicing Agreements The seller selects Bidders A and B as the two highest bidders, (“PSAs”). and their collective bids consume the 100 shares offered. The winning price is $3, which is what both bidders pay per share. Legacy Securities: Real estate-related securities originally Bidder C’s bid is not filled. Treasury uses a modified version issued before 2009 that remained on the balance sheets of a Dutch Auction in the dispensation of its warrants. of financial institutions because of pricing difficulties that resulted from market disruption. Equity: Investment that represents an ownership interest in a business. Limited Partnership: Partnership in which there is at least one partner whose liability is limited to the amount invested Equity Capital Facility: Commitment to invest equity (limited partner) and at least one partner whose liability capital in a firm under certain future conditions. An equity extends beyond monetary investment (general partner). facility when drawn down is an investment that increases the provider’s ownership stake in the company. The investor Loan Servicers: Companies that perform administrative may be able to recover the amount invested by selling its tasks on monthly mortgage payments until the loan is ownership stake to other investors at a later date. repaid. These tasks include billing, tracking, and collecting monthly payments; maintaining records of payments and Excess Spread: Funds left over after required payments and balances; allocating and distributing payment collections to other contractual obligations have been met. In TALF it is investors in accordance with each mortgage loan’s governing the difference between the periodic amount of interest paid documentation; following up on delinquencies; and initiating out by the collateral and the amount of interest charged by foreclosures. FRBNY on the nonrecourse loan provided to the borrower to purchase the collateral. Loan-to-Value (“LTV”) Ratio: Lending risk assessment ratio that mortgage lenders examine before approving a mortgage; Exercise Price: Preset price at which a warrant holder calculated by dividing the outstanding amount of the loan may purchase each share. For warrants in publicly traded by the value of the collateral backing the loan. Loans with institutions issued through CPP, this was based on the high LTV ratios are generally seen as higher risk because the average stock price during the 20 days before the date that borrower has less of an equity stake in the property. Treasury granted preliminary CPP participation approval. Mandatorily Convertible Preferred Stock (“MCP”): A type Government-Sponsored Enterprises (GSEs): Private of preferred share (ownership in a company that generally corporations created and chartered by the Government to entitles the owner of the shares to collect dividend payments) reduce borrowing costs and provide liquidity in the market, that can be converted to common stock under certain the liabilities of which are not officially considered direct parameters at the discretion of the company and must be taxpayer obligations. On September 7, 2008, the two largest converted to common stock by a certain time. GSEs, the Federal National Mortgage Association (“Fannie Mae”) and the Federal Home Loan Mortgage Corporation Nationally Recognized Statistical Rating Organization (“Freddie Mac”), were placed into Federal conservatorship. (“NRSRO”): Credit rating agency registered with the They are currently being financially supported by the SEC. Credit rating agencies provide their opinion of the Government. creditworthiness of companies and the financial obligations issued by companies. The ratings distinguish between Haircut: Difference between the value of the collateral and investment grade and non-investment grade equity and debt the value of the loan (the loan value is less than the collateral obligations. value). 230 Appendix a I glossary I July 25, 2012

Net Present Value (“NPV”) Test: Compares the money down funds up to a guaranteed maximum amount. The generated by modifying the terms of the mortgage with the amount of available credit decreases and increases as funds amount an investor can reasonably expect to recover in a are borrowed and then repaid. foreclosure sale. Risk-Weighted Assets: Risk-based measure of total assets Non-Agency Residential Mortgage-Backed Securities held by a financial institution. Assets are assigned broad (“non-agency RMBS”): Financial instrument backed by risk categories. The amount in each risk category is then a group of residential real estate mortgages (i.e., home multiplied by a risk factor associated with that category. The mortgages for residences with up to four dwelling units) not sum of the resulting weighted values from each of the risk guaranteed or owned by a Government-sponsored enterprise categories is the bank’s total risk-weighted assets. (“GSE”) (Fannie Mae or Freddie Mac) or a Government SBA Pool Certificates: Ownership interest in a bond backed Agency. by SBA-guaranteed loans. Non-Cumulative Preferred Stock: Preferred stock with Senior Preferred Stock: Shares that give the stockholder a defined dividend, without the obligation to pay missed priority dividend and liquidation claims over junior preferred dividends. and common stockholders. Non-Recourse Loan: Secured loan in which the borrower is Senior Subordinated Debentures: Debt instrument ranking relieved of the obligation to repay the loan upon surrendering below senior debt but above equity with regard to investors’ the collateral. claims on company assets or earnings. Obligations: Definite commitments that create a legal Servicing Advances: If borrowers’ payments are not made liability for the Government to pay funds. promptly and in full, servicers are contractually obligated to Pool Assemblers: Firms authorized to create and market advance the required monthly payment amount in full to the pools of SBA-guaranteed loans. investor. Once a borrower becomes current or the property is sold or acquired through foreclosure, the servicer is repaid all Preferred Stock: Equity ownership that usually pays a fixed advanced funds. dividend before distributions for common stock owners but only after payments due to debt holders. It typically confers Short Sale: Sale of a home for less than the unpaid mortgage no voting rights. Preferred stock also has priority over balance. A borrower sells the home and the lender accepts common stock in the distribution of assets when a bankrupt the proceeds as full or partial satisfaction of the unpaid company is liquidated. mortgage balance, thus avoiding the foreclosure process. Pro Rata: Refers to dividing something among a group of Skin in the Game: Equity stake in an investment; down participants according to the proportionate share that each payment; the amount an investor can lose. participant holds as a part of the whole. Special Purpose Vehicle (“SPV”): A legal entity, often off- Qualifying Financial Institutions (“QFIs”): Private and balance-sheet, that holds transferred assets presumptively public U.S.-controlled banks, savings associations, bank beyond the reach of the entities providing the assets, and that holding companies, certain savings and loan holding is legally isolated from its sponsor or parent company. companies, and mutual organizations. Subchapter S Corporations (“S corporations”): Corporate Qualified Institutional Buyers (“QIB”): Institutions that form that passes corporate income, losses, deductions, and under U.S. securities law are permitted to buy securities that credit through to shareholders for Federal tax purposes. are exempt from registration under investor protection laws Shareholders of S corporations report the flow-through of and to resell those securities to other QIBs. Generally, these income and losses on their personal tax returns and are taxed institutions own and invest at least $100 million in securities, at their individual income tax rates. or are registered broker-dealers that own or invest at least $10 Subordinated Debentures: Form of debt security that ranks million in securities. below other loans or securities with regard to claims on assets Revolving Credit Facility: Line of credit for which borrowers or earnings. pay a commitment fee, allowing them to repeatedly draw glossary I Appendix A I July 25, 2012 231

Systemically Significant Institutions: Term referring to any Sources: Board of Governors of the Federal Reserve System, “Bank Holding Companies,” no date, www. financial institution whose failure would impose significant fedpartnership.gov/bank-life-cycle/manage-transition/bank-holding-companies.cfm, accessed losses on creditors and counterparties, call into question the 7/5/2012. Federal Reserve Board, Federal Reserve Banks Operating Circular No. 8: Collateral, www.frbservices. financial strength of similar institutions, disrupt financial org/files/regulations/pdf/operating_circular_8.pdf, accessed 7/11/2012. markets, raise borrowing costs for households and businesses, FCIC, glossary, no date, www.fcic.gov/resource/glossary, accessed 7/5/2012. and reduce household wealth. FDIC, “Credit Card Securitization Manual,” no date, www.fdic.gov/regulations/examinations/credit_ card_securitization/glossary.html, accessed 7/5/2012. TALF Agent: Financial institution that is party to the TALF FDIC, “FDIC Law, Regulations, Related Acts,” no date, www.fdic.gov/regulations/laws/ rules/2000-4600.html, accessed 7/5/2012. Master Loan and Security Agreement and that occasionally FRBNY, “TALF FAQ’s,” 7/21/2010, www.newyorkfed.org/markets/talf_faq.html, accessed 7/5/2012. acts as an agent for the borrower. TALF agents include SIGTARP, “Factors Affecting Implementation of the Home Affordable Modification Program,” primary and nonprimary broker-dealers. 3/25/2010, www.sigtarp.gov/Audit%20Reports/Factors_Affecting_Implementation_of_the_Home_ Affordable_Modification_Program.pdf, accessed 7/11/2012. Trial Modification: Under HAMP, a period of at least three GAO, “Principles of Federal Appropriations Law, Third Edition, Volume II,” 1/2004, www.gao.gov/ special.pubs/d06382sp.pdf, p. 7-3, accessed 7/5/2012. months in which a borrower is given a chance to establish GAO, “Troubled Asset Relief Program Treasury Needs to Strengthen Its Decision-Making Process that he or she can make lower monthly mortgage payments on the Term Asset-Backed Securities Loan Facility,” 2/2010, www.gao.gov/new.items/d1025. pdf, accessed 7/5/2012.GAO, “Troubled Asset Relief Program: Third Quarter 2010 Update of and qualify for a permanent modification. Government Assistance Provided to AIG and Description of Recent Execution of Recapitalization Plan,” 1/20/2011, www.gao.gov/new.items/d1146.pdf, accessed 7/5/2012. Trust Preferred Securities (“TRUPS”): Securities that have IRS, “Glossary of Offshore Terms,” no date, www.irs.gov/businesses/small/article/0,,id=106572,00. both equity and debt characteristics created by establishing a html, accessed 7/5/2012. Making Home Affordable base NPV model documentation v4.0, updated 10/1/2010. www. trust and issuing debt to it. hmpadmin.com/portal/programs/docs/hamp_servicer/npvmodeldocumentationv4.pdf, pp. 23-24, accessed 7/5/2012. Undercapitalized: Condition in which a financial institution SBA, “Notice of Changes to SBA Secondary Market Program,” 9/21/2004, archive.sba.gov/idc/ does not meet its regulator’s requirements for sufficient groups/public/documents/sba_program_office/bank_notice_of_changes.htm, accessed 7/5/2012. SEC, “NRSRO,” no date, www.sec.gov/answers/nrsro.htm, accessed 7/5/2012. capital to operate under a defined level of adverse conditions. Treasury, “Decoder,” www.treasury.gov/initiatives/financial-stability/Pages/Glossary.aspx, accessed 7/5/2012. Underwater Mortgage: Mortgage loan on which a Treasury, “Fact Sheet: Unlocking Credit for Small Businesses,” 3/16/2009, http://www.treasury.gov/ homeowner owes more than the home is worth, typically as a press-center/press-releases/Pages/tg58.aspx, accessed 7/5/2012. result of a decline in the home’s value. Underwater mortgages Treasury, “Special Master Feinberg Testimony before the House Committee on Oversight and Government Reform,” 10/28/2009, www.treasury.gov/press-center/press-releases/Pages/tg334. are also referred to as having negative equity. aspx, accessed 7/5/2012. Treasury, “Supplemental Directive 10-14: Making Home Affordable Program - Principal Reduction Alternative Update,” 10/15/2010, www.hmpadmin.com/portal/programs/docs/hamp_servicer/ sd1014.pdf, accessed 7/5/2012. Treasury, “TARP Standards for Compensation and Corporate Governance,” 6/10/2009, www. treasury.gov/press-center/press-releases/Pages/tg165.aspx, accessed 7/5/2012. U.S. Census Bureau, “Residential Finance Survey, Glossary Of RFS Terms And Definitions,” no date, www.census.gov/hhes/www/rfs/glossary.html#l, accessed 7/5/2012. U.S. Department of Housing and Urban Development, “Glossary,” no date, www.hud.gov/offices/hsg/ sfh/buying/glossary.cfm, accessed 7/5/2012. 232 Appendix B I Acronyms and abbreviations I July 25, 2012

Acronyms and Abbreviations

2MP Second Lien Modification Program Coastal Coastal Securities, Inc. Securities ABS asset-backed securities Colonial Colonial Bank AGP Asset Guarantee Program COP Congressional Oversight Panel AHR American Home Recovery CPP Capital Purchase Program American International Assurance Co., Ltd.; AIA AIA Group Limited CUSIP numbers; from Committee on Uniform CUSIPs Securities Identification Procedures AIA SPV AIA Aurora LLC Dodd-Frank Wall Street Reform and Consumer AIFP Automotive Industry Financing Program Dodd-Frank Act Protection Act AIG American International Group, Inc. DTI debt-to-income ratio AIGFP AIG Financial Products Corporation Edison AIG Edison Life Insurance Company AIG Trust AIG Credit Facility Trust EESA Emergency Economic Stabilization Act of 2008 ALICO American Life Insurance Company Eligible assets securities eligible for purchase by PPIFs ALICO SPV ALICO Holdings LLC Fannie Mae Federal National Mortgage Association Ally Financial Ally Financial Inc. Farmers Capital Bank Corporation, Farmers Capital Ameris Ameris Bancorp, Moultrie, Georgia Frankfort, Kentucky ASSP Auto Supplier Support Program FBI Federal Bureau of Investigation AWCP Auto Warranty Commitment Program FCIC Financial Crisis Inquiry Commission Bank of FDIC Federal Deposit Insurance Corporation Bank of America Corporation America Federal Deposit Insurance Corporation Office of FDIC OIG BOC Bank of the Commonwealth Inspector General Bridgeview Bridgeview Bancorp, Inc., Bridgeview, Illinois Federal Federal Reserve System Reserve CAP Capital Assistance Program FHA Federal Housing Administration CBO Congressional Budget Office FHA2LP Treasury/FHA Second-Lien Program CDCI Community Development Capital Initiative FHFA Federal Housing Finance Agency CDFI Community Development Financial Institution Federal Housing Finance Agency Office of the CDOs collateralized debt obligations FHFA OIG Inspector General CDS Credit Default Swap Fiat Fiat North America LLC Centrue Centrue Financial Corporation, St. Louis, Missouri Fidelity Fidelity Southern Corporation, Atlanta, Georgia CEO chief executive officer Southern Cerberus Cerberus Capital Management, L.P. First Capital First Capital Bancorp, Inc., Glen Allen, Virginia Bancorp CFPB Consumer Financial Protection Bureau Firstbank Firstbank Corporation, Alma, Michigan Chrysler Chrysler Holding LLC First Citizens Chrysler First Citizens Banc Corp, Sandusky, Ohio Chrysler Financial Services Americas LLC Banc Financial FirstCity FirstCity Bank CIC CIC Bancshares, Inc. First Citigroup Citigroup, Inc. Community First Community Bank of Hammond, Louisiana CLTV Combined Loan-to-Value Bank CMBS commercial mortgage-backed securities First Defiance First Defiance Financial Corp., Defiance,O hio Acronyms and abbreviations I Appendix B I July 25, 2012 233

First Security Millennium Millennium Bancorp, Inc., Edwards, Colorado First Security Group, Inc. Group Nan Shan Nan Shan Life Insurance Company Ltd. First Trust First Trust Corporation, New Orleans, Louisiana New Chrysler Chrysler Group LLC FLC Flahive Law Corporation New Point New Point Financial Services, Inc. FNB United FNB United Corp., Asheboro, North Carolina Non-Agency Non-Agency Residential Mortgage-Backed Securities Fort Lee Fort Lee Federal Savings Bank, Fort Lee, New Jersey RMBS FRB Federal Reserve Board of Governors NPV net present value FRBNY Federal Reserve Bank of New York NRSRO nationally recognized statistical rating organization Federal Reserve Board Office of the Oaktree Oaktree PPIP Fund, L.P. FRB OIG Inspector General OCC Office of theC omptroller of the Currency Freddie Mac Federal Home Loan Mortgage Corporation Ocala Ocala Funding FSOC Financial Stability Oversight Council Old Chrysler Chrysler Group LLC GAO Government Accountability Office Old GM General Motors Corp. Genesis Genesis Staffing, Inc. OFS Office of FinancialS tability Ginnie Mae Government National Mortgage Association OMB Office ofM anagement and Budget GM General Motors Company Option ARM Option Adjustable Rate Mortgage GMAC GMAC Inc. Orion Bank Orion Bank Greater Kinston Greater Kinston Credit Union, Kinston, North Carolina OTS Office ofT hrift Supervision GSE Government-sponsored enterprise Oxford Oxford Collection Agency, Inc. HAFA Home Affordable Foreclosure Alternatives program Peoples Peoples Bancorp of North Carolina, Inc., Newton, HAMP Home Affordable Modification Program Bancorp of NC North Carolina HFA Housing Finance Agency PII personally identifiable information HHF Hardest Hit Fund PPIF Public-Private Investment Fund HPDP Home Price Decline Protection program PPIP Public-Private Investment Program HUD Department of Housing and Urban Development PRA Principal Reduction Alternative program Department of Housing and Urban Development Premier HUD OIG Premier Bancorp, Inc., Wilmette, Illinois Office of the Inspector General Bancorp ILFC International Lease Finance Corporation PremierWest PremierWest Bancorp, Medford, Oregon Intervest Intervest Bancshares Corporation PSA Pooling and Servicing Agreement Invesco Invesco Legacy Securities Master Fund, L.P. QFI qualifying financial institution IPO initial public offering Pulaski Pulaski Financial Corp, Creve Coeur, Missouri Internal Revenue Service Criminal QIB Qualified Institutional Buyers IRS-CI Investigation Division Department of Agriculture’s Office of RD Jobs Act Jobs Act of 2010 Rural Development JPMorgan JPMorgan Chase & Co. Rural Development Home Affordable RD-HAMP Modification Program Legacy Home Legacy Home Loans and Real Estate Loans ResCap Residential Capital, LLC Litton Litton Loan Servicing, LP RMBS residential mortgage-backed securities LNB LNB Bancorp, Inc., Lorain, Ohio Rogers Rogers Bancshares, Inc. Bancshares LT V loan-to-value ratio S corporations IRS subchapter S corporations M&T M&T Bank Corporation SBA Small Business Administration MainSource MainSource Financial Group SBLF Small Business Lending Fund MBS mortgage-backed securities SCB Bank SCB Bank, Shelbyville, Indiana MCP mandatorily convertible preferred shares SEC Securities and Exchange Commission MetroCorp MetroCorp Bancshares, Inc., Houston, Texas Secret Service Secret Service MHA Making Home Affordable program 234 Appendix B I Acronyms and abbreviations I July 25, 2012

Servicers loan servicers TPP trial period plan Shay Financial Shay Financial Services, Inc. Treasury Department of the Treasury SIFI Systemically Important Financial Institutions Treasury/FMA HAMP Loan Modification Option for HAMP FHA-insured Mortgages Special Inspector General for the Troubled Asset SIGTARP Act Relief Program Act of 2009 Treasury Secretary of the Treasury Secretary SNL SNL Financial, LLC TRUPS trust preferred securities Southern First Bancshares, Inc., Greenville, South Southern First Carolina TSG The Shmuckler Group, LLC SPA Servicer Participation Agreement UAW United Auto Workers SPV special purpose vehicle UCB United Commercial Bank SSFI Systemically Significant Failing Institutions program UCBH UCBH Holdings, Inc. Star AIG Star Life Insurance Co., Ltd. UCSB Unlocking Credit for Small Businesses TALF Term Asset-Backed Securities Loan Facility United Bancorp United Bancorp, Inc., Tecumseh, Michigan TARP Troubled Asset Relief Program UP Home Affordable Unemployment Program Task Force joint task force USPIS U.S. Postal Inspection Service Taylor Capital Taylor Capital Group, Rosemont, Illinois VA Department of Veterans Affairs TBW Taylor, Bean and Whitaker Mortgage Corporation Valley National Valley National Bancorp, Wayne, New Jersey TCW The TCW Group, Inc. Wellington Management Legacy Securities PPIF Wellington Master Fund, LP Tennessee Tennessee Commerce Bancorp, Inc. Commerce Wells Fargo Wells Fargo & Company TIP Targeted Investment Program WSFS WSFS Financial Corporation Tivest Tivest Development and Construction LLC Reporting Requirements I Appendix C I July 25, 2012 235

Reporting Requirements This appendix provides Treasury’s responses to data call questions regarding the reporting requirements of the Special Inspector General for the Troubled Asset Relief Program outlined in EESA Section 121, as well as a cross-reference to related data presented in this report and prior reports. Italic style indicates narrative taken verbatim from source documents.

EESA EESA Reporting SIGTARP # Section Requirement Treasury Response to SIGTARP Data Call Report Section 1 Section A description of Treasury’s authority to make new financial commitments under TARP ended on Section 2: 121(c)(A) the categories of October 3, 2010 “TARP Overview” troubled assets purchased or Below are program descriptions from Treasury’s www.treasury.gov/initiatives/financial- Appendix D: otherwise procured stability/Pages/default.aspx website, as of 6/30/2012: “Transaction by the Treasury Detail” Secretary.

CPP: Treasury created the Capital Purchase Program (CPP) in October 2008 to stabilize the financial system by providing capital to viable financial institutions of all sizes throughout the nation. With a strengthened capital base, financial institutions have an increased capacity to lend to U.S. businesses and consumers and to support the U.S. economy.

AIG: In September of 2008, panic in the financial system was deep and widespread Amidst these events, on Friday, September 12, American International Group (AIG) of- ficials informed the Federal Reserve and Treasury that the company was facing potentially fatal liquidity problems. At the time, AIG was the largest provider of conventional insurance in the world, with approximately 75 million individual and corporate customers in over 130 countries.a

AGP: Under the Asset Guarantee Program (AGP), Treasury acted to support the value of certain assets held by qualifying financial institutions, by agreeing to absorb unexpectedly large losses on certain assets. The program was designed for financial institutions whose failure could harm the financial system and was used in conjunction with other forms of exceptional assistance.

TIP: Under the Targeted Investment Program (TIP), Treasury provided exceptional assistance on a case-by-case basis in order to stabilize institutions that were considered systemically significant to prevent broader disruption of financial markets. Treasury provided this assistance by purchasing preferred stock, and also received warrants to purchase common stock, in the institutions.

TALF: This joint initiative with the Federal Reserve builds off, broadens and expands the resources available to support the consumer and business credit markets by providing the financing to private investors to help unfreeze and lower interest rates for auto, student loan, small business, credit card and other consumer and business credit. The U.S. Treasury originally committed $20 billion to provide credit protection for $200 billion of lending from the Federal Reserve. This commitment was later reduced to $4.3 billion after the program closed to new lending on June 30, 2010, with $43 billion in loans outstanding.

PPIP: On March 23, 2009, the U.S. Department of the Treasury (“Treasury”), announced the Legacy Securities Public-Private Investment Program (“PPIP”) as a key component of President Obama’s Financial Stability Plan. The Financial Stability Plan outlines a broad framework to bring capital into the financial system and address the problem of legacy real estate assets.

CDCI: As part of the Administration’s ongoing commitment to improving access to credit for small businesses, Treasury announced on February 3 final terms for the Community Development Capital Initiative (CDCI). This TARP program invested lower-cost capital in Community Development Financial Institutions (CDFIs) that lend to small businesses in the country’s hardest-hit communities.

Continued on next page 236 Appendix C I Reporting Requirements I July 25, 2012

EESA EESA Reporting SIGTARP # Section Requirement Treasury Response to SIGTARP Data Call Report Section SBLF: Enacted into law as part of the Small Business Jobs Act of 2010 (the Jobs Act), the Small Business Lending Fund (SBLF) is a $30 billion fund that encourages lending to small businesses by providing capital to qualified community banks with assets of less than $10 billion. Through the Small Business Lending Fund, Main Street banks and small businesses can work together to help create jobs and promote economic growth in local communities across the nation.

UCSB: The Treasury Department will begin making direct purchases of securities backed by SBA loans to get the credit market moving again, and it will stand ready to purchase new securities to ensure that community banks and credit unions feel confident in extending new loans to local businesses.

AIFP: The objective of the Automotive Industry Financing Program (AIFP) is to prevent a significant disruption of the American automotive industry, which would pose a systemic risk to financial market stability and have a negative effect on the economy of the United States.

ASSP: [ASSP was created to] provide up to $5 billion in financing, giving suppliers the confidence they need to continue shipping parts, pay their employees and continue their operations.b

AWCP: The Treasury Department announced an innovative new program to give consumers who are considering new car purchases the confidence that even while Chrysler and GM were restructuring in bankruptcy, their warrantees will be honored. This program is part of the Administration’s broader program to stabilize the auto industry and stand behind a restructuring effort that will result in stronger, more competitive and viable American car companies.b

HAMP (a program under MHA): The Home Affordable Modification Program has a simple goal: reduce the amount homeowners owe per month to sustainable levels to stabilize communities. This program will bring together lenders, investors, servicers, borrowers and the Government, so that all stakeholders share in the cost of ensuring that responsible homeowners can afford their monthly mortgage payments -- helping to reach up to 3 to 4 million at-risk borrowers in all segments of the mortgage market, reducing foreclosures, and helping to avoid further downward pressures on overall home prices.

2 Section A listing of the Treasury’s authority to make new financial commitments under TARP ended on Appendix D: 121(c)(B) troubled assets October 3, 2010. “Transaction purchased in each Detail” such category Information on all transactions as well as additional information about these programs described under and related purchases is available in the transaction reports and monthly 105(a) reports Section 121(c)(A) posted at www.treasury.gov/initiatives/financial-stability/briefing-room/reports/Pages/ Home.aspx. Information regarding all transactions through the end of June 2012 is available at the aforementioned link in a transaction report dated 6/27/2012.

3 Section An explanation Treasury’s authority to make new financial commitments under TARP ended on Section 2: “TARP 121(c)(C) of the reasons October 3, 2010. Overview” the Treasury Secretary deemed Appendix C: it necessary to “Reporting purchase each such Requirements” troubled asset. of prior SIGTARP Quarterly Reports to Congress

4 Section A listing of each See #2. See #2. 121(c)(D) financial institution from which such troubled assets were purchased

Continued on next page Reporting Requirements I Appendix C I July 25, 2012 237

EESA EESA Reporting SIGTARP # Section Requirement Treasury Response to SIGTARP Data Call Report Section 5 Section A listing of There have been no new PPIP fund managers hired between March 31, 2012, and Section 2: 121(c)(E) and detailed June 30, 2012. “Public-Private biographical Investment information on each On February 7, 2012, the Treasury executed a new Financial Agency Agreement with Program” person or entity Greenhill & Co. LLC (Greenhill) to provide certain services relating to the management hired to manage and disposition of American International Group, Inc. (AIG) investments acquired Appendix C: such troubled pursuant to the Emergency Economic Stability Act of 2008 (EESA). Greenhill is a global “Reporting assets. financial services firm providing investment banking, advice on mergers, acquisitions, Requirements” restructurings, financings and capital raisings to corporations, partnerships, institutions of prior SIGTARP and governments. Quarterly Reports to Congress

6 Section A current estimate The transaction reports capture detailed information about troubled asset purchases, Table C.1; 121(c)(F) of the total amount price paid, and the amount of troubled assets currently on Treasury’s books. The latest Section 2: “TARP of troubled assets transaction reports are available on Treasury’s website at www.treasury.gov/initiatives/ Overview” purchased pursuant financial-stability/briefing-room/reports/Pages/Home.aspx. Information regarding all to any program transactions through the end of June 2012 is available at the aforementioned link in a Appendix D: established under transaction report dated 6/27/2012. “Transaction Section 101, the Detail” amount of troubled Treasury published its most recent valuation of TARP investments as of June 30, 2012, assets on the on 7/10/2012, in its July 2012 105(a) report that is available at the following link: www. books of Treasury, treasury.gov/initiatives/financial-stability/briefing-room/reports/105/Pages/default.aspx the amount of troubled assets Information on the repayments of Treasury’s investments under the CPP and proceeds sold, and the profit from the sale of warrants are available within Treasury’s press releases, transactions and loss incurred reports and Section 105(a) Monthly Congressional Reports at the following links: on each sale or www.treasury.gov/initiatives/financial-stability/briefing-room/Pages/press-releases.aspx disposition of each www.treasury.gov/initiatives/financial-stability/briefing-room/reports/Pages/Home.aspx such troubled assets.

7 Section A listing of the Treasury’s authority to make new financial commitments under TARP ended on October 3, Section 2: 121(c)(G) insurance contracts 2010. As such, Treasury cannot issue any new insurance contracts after this date. “TARP Overview” issued under Section 102. Section 2: “Targeted Investment Program and Asset Guarantee Program”

8 Section A detailed statement Treasury’s authority to make new financial commitments under TARP ended on Table C.1; 121(f) of all purchases, October 3, 2010. Section 2: obligations, “TARP Overview” expenditures, and Treasury provides information about TARP obligations, expenditures and revenues in revenues associated separate transaction reports available on Treasury’s public website at www.treasury.gov/ Section 3: with any program initiatives/financial-stability/briefing-room/reports/Pages/Home.aspx. Information regarding “TARP Operations established by the all transactions through the end of June 2012 is available at the aforementioned link in a and Administration” Secretary of the transaction report dated 6/27/2012. Treasury under Appendix D: Sections 101 and Information on obligations and expenditures is also available in the Daily TARP Update “Transaction Detail” 102. reports available on Treasury’s public website at: www.treasury.gov/initiatives/financial- stability/briefing-room/reports/tarp-daily-summary-report/pages/default.aspx, accessed 7/5/2012.

Notes: a Otherwise known as Systemically Significant Failing Institution (“SSFI”). b Description is of 3/31/2011.

Sources: Treasury, response to SIGTARP data call, 7/5/2012; Program Descriptions: Treasury, “Programs,” www.treasury.gov/initiatives/financial-stability/programs/Pages/default.aspx accessed 7/5/2012; ASSP: “Treasury Announces Auto Suppliers Support Program,” 3/19/2009, www.treasury.gov/press-center/press-releases/Pages/tg64.aspx, accessed 7/5/2012; AWCP: “Obama Administration’s New Warrantee Commitment Program,” no date, www.whitehouse.gov/assets/documents/Warrantee_Commitment_Program.pdf, accessed 7/5/2012; TALF: Federal Reserve, “Term Asset-Backed Securities Loan Facility (TALF) Frequently Asked Questions,” no date, www.federalreserve.gov/newsevents/press/monetary/monetary20090303a2.pdf, accessed 7/5/2012; SBLF: Small Business Lending Act, P.L. 111-240, 9/27/2010; MHA “Making Home Affordable Updated Detailed Description Update,” 3/26/2010, www.treasury.gov/initiatives/financial-stability/programs/housing- programs/mha/Pages/default.aspx, accessed 7/5/2012. 238 Appendix C I Reporting Requirements I July 25, 2012

Table C.1

TOTAL AMOUNT OF TROUBLED ASSETS PURCHASED AND HELD ON TREASURY’S BOOKs ($ BILLIONS)

Obligations After Dodd-Frank Current Obligations On Treasury’s (As of 10/3/2010) (As of 6/30/2012) Expended Booksa

Housing Support Programs $45.6 $45.6 $4.5 $—

Capital Purchase Program (“CPP”) 204.9 204.9 204.9 13.8

Community Development Capital Initiative (“CDCI”) 0.6 0.6 0.2 0.6

Systemically Significant Failing Institutions (“SSFI”) 69.8 67.8c 67.8 36.0

Targeted Investment Program (“TIP”) 40.0 40.0 40.0 0.0

Asset Guarantee Program (“AGP”) 5.0 5.0 0.0 0.0

Term Asset-Backed Securities Loan Facility (“TALF”) 4.3 1.4 0.1 0.1

Public-Private Investment Program (“PPIP”) 22.4 21.9 18.5 14.1

Unlocking Credit for Small Businesses (“UCSB”) 0.4 0.4 0.4 0.0

Automotive Industry Support Programs (“AIFP”)b 81.8 79.7d 79.7 44.5

Total $474.8 $467.2 $416.1 $109.1

Notes: Numbers may not total due to rounding. a “On Treasury’s Books” calculated as the amount of TARP funds remaining outstanding, including realized losses and write-offs. b Includes amounts for AIFP, ASSP, and AWCP. c Treasury deobligated $2 billion in equity facility for AIG that was never drawn down. d Includes $80.7 billion for Automotive Industry Financing Program, $0.6 billion for Auto Warranty Commitment Program, and $0.4 billion for Auto Supplier Support Program.

Sources: Repayments data: Treasury, Transactions Report, 6/27/2012; Treasury, Daily TARP Update, 7/2/2012. Transaction detail I Appendix D I July 25, 2012 239 Treasury Treasury $941,667 $370,903 $360,694 $998,057 $784,605 $469,599 $538,360 $388,742 $409,753 $529,576 $343,021 $162,682 $920,142 $122,725 $150,577 $421,921 $279,991 $451,111 $1,106,667 $1,715,769 $2,776,667 $1,326,398 $1,516,737 $2,439,028 $3,354,167 $1,128,156 $1,229,949 $9,302,107 $1,028,415 $2,686,411 $4,207,399 $7,888,889 $1,039,677 $1,061,947 $1,146,635 $1,460,782 Dividends/ $68,104,167 $10,730,000 $74,367,308 $12,082,539 $835,416,667 $458,333,333 Interest Paid to Interest Continued on next page 698,554 Current Current 299,706 730,994 475,204 Warrants Warrants 7,399,103 Outstanding $9.41 $6.21 $2.82 $6.80 $2.80 $0.90 $8.20 $0.27 $6.85 $0.45 $0.70 $2.99 $8.18 $0.23 Stock $13.19 $22.60 $30.08 $13.00 $34.34 $58.21 $12.60 $37.01 Price as of 6/29/2012 N/ A $90,000 $326,576 $500,000 $636,000 $825,000 $410,000 $125,000 $220,000 $900,000 $184,000 $125,000 $300,000 $370,000 Proceeds $3,435,006 $1,400,000 $3,750,000 $1,055,000 $2,400,000 $2,650,000 $1,703,984 $340,000,000 $183,547,824 $122,365,216 Final Disposition 15 A A A P P R R R R R R R R R R R R R R R R R R Note 11/18/2011 Final Disposition Date 11/30/2011 9/30/2009 3/9/2011 11/24/2009 11/18/2009 7/21/2011 11/2/2011 7/14/2011 8/18/2011 9/29/2010 10/26/2011 9/1/2011 N/ A 6/17/2009 9/22/2011 9/15/2011 1/26/2011 11/2/2011 9/15/2011 11/18/2011 7/29/2009 3/3/2010 3/3/2010 $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— Remaining $4,076,000 $262,500,000 Capital Amount 6 $4,076,000 $4,400,000 $6,000,000 $3,674,000 $2,492,000 $1,800,000 $6,000,000 $7,400,000 $12,000,000 $30,000,000 $75,000,000 $10,000,000 $12,720,000 $47,665,332 $21,000,000 $21,100,000 $13,669,000 $48,000,000 $17,000,000 $26,918,000 $28,000,000 $262,500,000 $262,500,000 $111,000,000 Amount (Loss) $3,388,890,000 $15,000,000,000 $10,000,000,000 Capital Repayment 10/27/2010 9/14/2011 4/6/2011 8/5/2009 12/29/2010 4/18/2012 11/4/2009 Capital Repayment Date 11/18/2009 7/21/2011 6/13/2012 8/11/2011 7/14/2011 8/18/2011 9/29/2010 9/27/2011 9/1/2011 9/1/2011 5/13/2009 9/22/2011 9/15/2011 6/17/2009 1/26/2011 11/2/2011 9/15/2011 12/9/2009 12/9/2009 3/31/2009 $3,500,000 $8,152,000 $4,400,000 $6,000,000 $6,514,000 $4,781,000 $2,986,000 $3,652,000 $3,674,000 $2,492,000 $1,800,000 $6,000,000 $5,000,000 $2,000,000 $7,400,000 $8,600,000 $1,004,000 $3,000,000 $2,672,000 $12,000,000 $30,000,000 $16,369,000 $75,000,000 $10,000,000 $12,720,000 $12,000,000 $70,000,000 $52,000,000 $21,000,000 $21,100,000 $13,669,000 $48,000,000 $17,000,000 $12,639,000 $26,918,000 $50,000,000 $28,000,000 $13,179,000 $525,000,000 $111,000,000 $110,000,000 $3,388,890,000 $15,000,000,000 $10,000,000,000 Investment Amount Preferred Stock w/ Warrants Stock w/ Warrants Preferred Preferred Stock w/ Warrants Stock w/ Warrants Preferred Stock w/ Warrants Preferred Preferred Stock w/ Warrants Stock w/ Warrants Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred Investment Description Warrants Stock w/ E xercised Preferred Stock Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Debentures Subordinated Warrants w/ E xercised Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred w/ E xercised Debentures Subordinated Warrants Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred Warrants Stock w/ E xercised Preferred Stock w/ Warrants Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Preferred Stock w/ Warrants Stock w/ Warrants Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred 2 2 2 8 2,49 8 2,49 1b 1a,1b a i l 49 2 2 2 50 A 2,10 2,49 2,10a,49 2,10,49 2,30 2 2 2,49 2 2,50 2 85 2 2,49 2 ancorp, Cranbury, NJ 1st Constitution B ancorp, Cranbury, 1st E nterprise B ank, L os A ngeles, C ancshares, Inc., B luffton, SC A tlantic B ancshares, 1st United B ancorp, Inc., oca Raton, F L A larion Financial Services, Inc., Ocala, F L A mFirst Financial Services, Inc., McCook, N E WI B ay, A ssociated B anc-Corp, Green RI B ancorp Rhode Island, Inc., Providence, B ancPlus Corporation, Ridgeland, MS NV L as Vegas, B ank of George, B ancorp, Inc., B ankers’ ank of the West CO Denver, 1st E nterprise B ank, L os A ngeles, C 1st FS Corporation, Hendersonville, NC Corporation, South B end, IN 1st Source AB &T Financial Corporation, Gastonia, NC C A B ancorp, A rcadia, A merican Premier A meriServ Financial, Inc, Johnstown, P A nnapolis B ancorp, Inc., nnapolis, MD B ancIndependent, Inc., Sheffield, AL I L B ancorp Financial, Inc., Oak rook, Inc., Festus, MO B ancStar, B ank Financial Services, Inc., E den Prairie, MN B ank of A merica Corporation, Charlotte, NC B ank of the Ozarks, Inc., L ittle Rock, A R Institution A dbanc, Inc, Ogallala, N E Inc., Juneau, A K A laska Pacific B ancshares, Inc., Dalton, G A A lliance B ancshares, A lliance Financial Corporation, Syracuse, NY A lliance Financial Services Inc., Saint Paul, MN A llied First B ancorp, Inc., Oswego, I L A lpine B anks of Colorado, Glenwood Springs, CO IN A M B Financial Corp., Munster, Collinsville, OK A meri B ank Holding Company, NY New York, Company, A merican E xpress B end, KS Inc., Great A merican State B ancshares, A meris B ancorp, Moultrie, G A nchor B anCorp Wisconsin Inc., Madison, WI A venue Financial Holdings, Inc., Nashville, TN Inc., Mobile, AL Financial Group, B ancTrust B ank of A merica Corporation, Charlotte, NC Charlotte, NC B ank of Commerce, Holdings, Redding, C A B ank of Commerce B ank of Marin ancorp, Novato, C A Corporation, Mocksville, NC B ank of the Carolinas 12/23/2008 2/13/2009 12/29/2009 3/13/2009 1/23/2009 8/21/2009 11/21/2008 12/19/2008 2/20/2009 3/13/2009 1/30/2009 12/11/2009 11/14/2008 1/23/2009 1/23/2009 5/29/2009 12/19/2008 1/30/2009 3/13/2009 7/10/2009 4/3/2009 8/14/2009 1/9/2009 12/12/2008 CPP TRANSACTION DETAIL, AS OF 6/30/2012 CPP TRANSACTION DETAIL, Purchase Date 1/30/2009 2/6/2009 6/26/2009 12/19/2008 6/26/2009 4/24/2009 3/27/2009 1/30/2009 3/6/2009 1/9/2009 1/9/2009 11/21/2008 1/30/2009 2/27/2009 12/19/2008 10/28/2008 1/16/2009 11/14/2008 12/5/2008 4/17/2009 T r a ns ction De t D.1 Table 240 Appendix D I Transaction Detail I July 25, 2012 $87,124 Treasury Treasury $107,411 $877,778 $137,063 $177,428 $173,508 $963,317 $342,023 $825,326 $529,105 $211,458 $440,542 $636,921 $909,542 $468,624 $810,417 $402,720 $2,217,469 $1,036,514 $1,283,777 $2,613,582 $1,295,586 $9,739,583 $1,129,500 $1,728,861 $1,760,350 $5,383,667 $2,506,855 $1,516,271 $2,393,156 Dividends/ $92,703,517 $12,060,000 $20,873,747 $11,022,222 Interest Paid to Interest Continued on next page 243,998 Current Current 337,480 183,465 111,083 543,337 Warrants Warrants Outstanding $8.80 $9.18 $3.30 $7.02 $0.02 $3.55 $7.86 $2.11 $8.93 $1.30 Stock $30.85 $36.00 $22.00 $16.15 $21.91 $10.89 $13.50 $13.00 Price as of 6/29/2012 N/ A $30,000 $40,000 $50,000 $82,000 $775,000 $250,000 $500,000 $550,000 $300,000 $240,000 Proceeds $1,040,000 $1,395,000 $6,202,523 $67,010,402 Final Disposition 15 A R R R R R R R R R R R R R Note Final Disposition Date 7/22/2009 7/28/2010 6/24/2009 9/8/2011 7/28/2011 9/1/2011 7/14/2011 4/20/2011 9/15/2011 11/2/2011 6/27/2012 7/28/2011 N/ A 8/4/2011 2/1/2011 $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $300,000 Remaining $3,000,000 $1,500,000 $8,864,000 $9,000,000 $4,500,000 $2,750,000 $104,000,000 Capital Amount 6 $795,000 $300,000 $985,000 $607,000 $8,864,000 $1,500,000 $1,500,000 $1,200,000 $6,000,000 $1,500,000 $1,635,000 $1,744,000 $2,250,000 $4,797,000 $18,751,000 $40,000,000 $15,500,000 $55,000,000 $67,000,000 $10,000,000 $15,000,000 $11,000,000 $10,800,000 $50,000,000 $108,071,915 $104,000,000 Amount (Loss) $3,133,640,000 Capital Repayment 6/17/2009 3/16/2011 2/24/2010 5/27/2009 Capital Repayment Date 9/8/2011 7/28/2011 6/27/2012 6/27/2012 10/19/2011 3/7/2012 6/6/2012 6/27/2012 9/1/2011 7/14/2011 2/23/2011 9/15/2011 5/23/2012 11/2/2011 3/28/2012 1/26/2011 7/6/2011 7/28/2011 7/28/2011 6/27/2012 8/4/2011 1/13/2010 6/16/2010 $795,000 $985,000 $607,000 $1,000,000 $1,706,000 $6,000,000 $1,635,000 $1,744,000 $6,400,000 $5,000,000 $5,000,000 $7,500,000 $4,797,000 $5,586,000 $9,000,000 $6,000,000 $2,400,000 $18,751,000 $40,000,000 $15,500,000 $55,000,000 $67,000,000 $10,000,000 $12,000,000 $20,093,000 $10,000,000 $23,864,000 $11,000,000 $15,000,000 $10,800,000 $21,750,000 $31,260,000 $38,000,000 $124,000,000 $154,000,000 $3,133,640,000 Investment Amount (C ontinu e d ) Preferred Stock w/ Warrants Stock w/ Warrants Preferred Preferred Stock w/ Warrants Stock w/ Warrants Preferred Stock w/ Warrants Preferred Preferred Stock w/ Warrants Stock w/ Warrants Preferred Investment Description Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Stock w/ Warrants Preferred Warrants Stock w/ E xercised Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Stock Preferred Debentures Subordinated Warrants w/ E xercised Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred w/ E xercised Debentures Subordinated Warrants Stock Preferred Stock Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Preferred Stock w/ Warrants Stock w/ Warrants Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred xercised Warrants Warrants Stock w/ E xercised Preferred w/ E xercised Debentures Subordinated Warrants 2 2,49 66 2,49 8,10 2 2,49 2,71 2 2,49 2 2 8 66 8 74 2 2 2,49 2,49 2 2 2 3a,72 3,10a,72 2,49 2,10a,49 2 B ankFirst Capital Corporation, Macon, MS BB CN B ancorp, Inc. (Center Financial Corporation), L os A ngeles, C ankGreenville, Greenville, SC Greenville, B ankGreenville, BB &T Corp., Winston-Salem, NC B oscobel ancorp, Inc, oscobel, WI I L B ridgeview ancorp, Inc., ridgeview, Inc., Clayton, MO B usiness ancshares, ar Harbor, M E B ar Harbor, B ar Harbor ankshares, BB CN B ancorp, Inc. (Nara B ancorp, Inc.), L os A ngeles, C AL Inc., Theodore, B C Holding Company, B each usiness ank, Manhattan each, C A Hills B ancorp, Inc., Pittsfield, M A B erkshire Inc., B ern, KS B ern ancshares, Inc, B irmingham loomfield ancshares, B irmingham, MI ND B lackridge Financial, Inc., Fargo, Inc., Shelbyville, IN B lue River ancshares, Inc., New Canaan, CT B NC Financial Group, B utler Point, Inc., Catlin, I L ancshares, Inc, B irmingham loomfield ancshares, B irmingham, MI B ridge Capital Holdings, San Jose, C A Institution anner Corporation, Walla Walla, W A Walla, B anner Corporation, Walla N E B anner County an Corporation, Harrisburg, MD B CS ancorp, Inc., altimore, F L Inc., Coconut Grove, B iscayne ancshares, B lackhawk ancorp, Inc., eloit, WI Inc., Independence, MO B lue Ridge ancshares, B an Corp, Overland Park, KS B lue Valley B N Financial Services Corporation, New York, NY B NC ancorp, Thomasville, ND Inc., B ismarck, B NCCORP, B OH Holdings, Inc., Houston, TX B oston Private Financial Holdings, Inc., B oston, M A Financial Corporation, B roadway L os A ngeles, C Inc., Kaukauna, WI B ankshares, B rogan roadway Financial Corporation, B roadway L os A ngeles, C KS Inc., Kansas City, B ancshares, B rotherhood 1/23/2009 12/12/2008 2/13/2009 11/14/2008 5/15/2009 12/19/2008 4/24/2009 1/16/2009 11/21/2008 4/3/2009 1/30/2009 12/19/2008 2/13/2009 4/24/2009 5/22/2009 3/6/2009 2/27/2009 3/13/2009 12/18/2009 12/23/2008 CPP TRANSACTION DETAIL, AS OF 6/30/2012 CPP TRANSACTION DETAIL, Purchase Date 11/21/2008 2/6/2009 12/23/2008 6/19/2009 3/13/2009 3/6/2009 12/5/2008 4/17/2009 12/5/2008 1/16/2009 3/6/2009 11/21/2008 12/4/2009 5/15/2009 11/14/2008 7/17/2009 Transaction detail I Appendix D I July 25, 2012 241 Treasury Treasury $172,938 $612,118 $555,900 $337,219 $187,178 $396,164 $517,281 $304,973 $739,989 $983,480 $505,000 $922,656 $685,071 $674,671 $516,989 $636,071 $372,781 $769,177 $501,822 $571,690 $271,580 $892,500 $450,656 $2,902,778 $1,341,667 $2,411,625 $1,084,486 $3,984,063 $3,973,104 $2,297,625 $1,531,581 $1,428,900 $4,217,049 $1,196,303 $1,361,111 $3,880,097 $1,012,791 $2,437,761 $2,362,500 $1,029,334 Dividends/ $44,433,333 $105,174,638 Interest Paid to Interest Continued on next page 67,314 86,957 79,288 Current Current 167,504 749,619 357,675 205,379 523,076 261,538 508,320 263,542 Warrants Warrants 1,846,374 Outstanding $7.15 $1.56 $0.28 $2.28 $5.82 $3.00 $5.35 $2.65 $0.70 $6.90 $0.57 Stock $40.16 $16.51 $11.25 $31.72 $54.66 $17.75 $14.12 $19.30 Price as of 6/29/2012 N/ A N/ A N/ A N/ A N/ A $245,000 $750,000 $319,659 $200,000 $165,000 $235,000 $313,000 $150,000 $113,000 $212,000 $290,000 $182,000 $375,000 $238,000 $185,017 Proceeds $2,525,000 $146,500,065 Final Disposition 15 A R R R R R R R R R R R R R R R R Note Final Disposition Date 12/1/2010 N/ A N/ A N/ A N/ A 12/7/2011 4/15/2009 10/19/2011 N/ A 9/15/2011 12/8/2010 12/30/2010 9/8/2011 7/21/2011 7/21/2011 10/28/2009 7/6/2011 7/14/2011 7/28/2011 12/3/2009 7/14/2011 9/28/2011 $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— Remaining $10,000,000 $99,116,719 Capital Amount 6 $4,640,000 $4,000,000 $3,300,000 $4,700,000 $6,251,000 $3,000,000 $3,500,000 $5,800,000 $6,056,000 $7,500,000 $4,767,000 $7,000,000 $10,000,000 $10,000,000 $11,300,000 $38,000,000 $41,279,000 $18,980,000 $16,250,000 $10,000,000 $15,000,000 $10,000,000 $27,875,000 $35,883,281 $36,039,222 Amount (Loss) $3,555,199,000 Capital Repayment 4/11/2012 7/27/2011 11/24/2010 Capital Repayment Date 3/4/2011 1/28/2011 8/27/2010 6/30/2011 9/15/2011 3/31/2009 8/25/2011 7/14/2011 9/15/2011 12/8/2010 12/30/2010 6/17/2009 9/8/2011 7/21/2011 7/21/2011 9/30/2009 7/6/2011 6/17/2011 7/14/2011 7/28/2011 3/29/2012 7/14/2011 8/18/2011 $4,000,000 $7,225,000 $4,640,000 $4,000,000 $3,300,000 $1,037,000 $4,656,000 $4,700,000 $5,100,000 $4,000,000 $6,251,000 $9,201,000 $3,000,000 $3,500,000 $2,644,000 $1,753,000 $3,564,000 $2,250,000 $5,800,000 $6,056,000 $7,500,000 $4,767,000 $4,114,000 $7,000,000 $20,000,000 $11,560,000 $11,300,000 $32,668,000 $44,000,000 $41,279,000 $18,980,000 $38,970,000 $24,300,000 $10,000,000 $15,000,000 $10,000,000 $22,500,000 $22,000,000 $10,000,000 $16,000,000 $27,875,000 $11,385,000 $258,000,000 $135,000,000 $3,555,199,000 Investment Amount (C ontinu e d ) Preferred Stock w/ Warrants Stock w/ Warrants Preferred Preferred Stock w/ Warrants Stock w/ Warrants Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred Investment Description Stock Preferred Stock w/ Warrants Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Stock w/ Warrants Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Debentures Subordinated Warrants w/ E xercised Stock Preferred Stock w/ Warrants Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Stock Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Stock w/ Warrants Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Stock w/ Warrants Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Common Stock w/ Warrants Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Debentures Subordinated Warrants w/ E xercised Preferred Stock w/ Warrants Stock w/ Warrants Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred xercised Warrants Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred 2 2 2 50 2 A 33 A 2,10,49 2,49 2 2,49 47 A 37,46 2,10a,49 2,49 2,10a,49 2 8,50 A 35 2 2 2 2 3,30 2,49 50 2 49 2 2 2,10a 2,63 2 8 Cache Valley B anking Company , L ogan, UT Cache Valley C&F Financial Corporation, West Point, V C&F Financial Corporation, West Catskill Hudson B ancorp, Inc, Rock Hill, NY OH Center B ank, Milford, Central B ancorp, Inc., Somerville, M A Central Pacific Financial Corp., Honolulu, HI Cadence Financial Corporation, Starkville, MS L afayette, C A California B ank of Commerce, B ancorp, Inc., Milwaukee, WI Capital Commerce Capital Pacific B ancorp, Portland, OR B ank, L incolnton, NC Trust Carolina W A Cascade Financial Corporation, E verett, Cathay General B ancorp, L os A ngeles, C Cecil B ancorp, Inc., E lkton, MD WV Centra Financial Holdings, Inc., Morgantown, Central B ancorp, Inc., Garland, TX Inc., Houston, TX Central B ancshares, Central Federal Corporation, Fairlawn, OH Central Jersey B ancorp, Oakhurst, NJ Centrue Financial Corporation, St. L ouis, MO ancorp, Fresno, C A Community B ancorp, Fresno, Central Valley Institution California Oaks State B ank, Thousand Oaks, C A Calvert Financial Corporation, A shland, MO C A B ancorp, Rancho Santa Margarita, CalWest Capital B ancorp, Inc., Rockville, MD Capital B ank Corporation, Raleigh, NC Capital One Financial Corporation, Mc L ean, V MO B ancorp II, Inc., Washington, Cardinal NC B ank Holdings, Inc., Greensboro, Carolina MD B ancorp, altimore, Carrollton NY Carver B ancorp, Inc, New York, Catskill Hudson B ancorp, Inc, Rock Hill, NY C B Holding Corp., A ledo, I L C BB B ancorp, Cartersville, G A C B S anc-Corp., Russellville, AL CedarStone B ank, L ebanon, TN Center B ancorp, Inc., Union, NJ Centerstate B anks of Florida Inc., Davenport, F L TX Central Community Corporation, Temple, NH B edford, Centrix B ank & Trust, Century Financial Services Corporation, Santa Fe, NM anking Company, L ogan, UT B anking Company, Cache Valley C BB B ancorp, Cartersville, G A Inc., Powhatan, V B ankshares, Central Virginia P Centric Financial Corporation, Harrisburg, 12/23/2008 1/9/2009 2/27/2009 5/1/2009 2/27/2009 1/9/2009 1/9/2009 2/27/2009 4/10/2009 12/23/2008 2/6/2009 11/21/2008 12/5/2008 12/23/2008 1/16/2009 12/5/2008 1/30/2009 12/5/2008 12/23/2008 1/9/2009 1/30/2009 CPP TRANSACTION DETAIL, AS OF 6/30/2012 CPP TRANSACTION DETAIL, Purchase Date 1/23/2009 1/23/2009 1/23/2009 12/23/2008 12/12/2008 11/14/2008 10/23/2009 1/9/2009 2/13/2009 1/16/2009 12/22/2009 5/29/2009 12/29/2009 3/27/2009 2/6/2009 1/9/2009 11/21/2008 2/20/2009 2/6/2009 6/19/2009 12/18/2009 2/20/2009 1/30/2009 12/18/2009 242 Appendix D I Transaction Detail I July 25, 2012 $65,143 $36,111 $86,973 $76,189 Treasury Treasury $223,571 $628,033 $535,813 $248,883 $180,259 $424,646 $281,859 $307,925 $967,361 $316,479 $445,348 $139,020 $573,012 $697,084 $569,865 $1,982,529 $2,847,222 $2,151,875 $6,621,772 $2,233,412 $4,923,341 $1,356,907 $1,235,449 $8,763,410 $1,229,278 $3,990,000 $5,101,405 $2,975,700 $2,152,822 $2,628,111 $2,161,377 $1,908,453 $1,065,021 $2,049,100 Dividends/ $13,875,000 $43,687,500 $23,916,667 $150,937,500 $932,291,667 Interest Paid to Interest Continued on next page 87,209 205,579 Current Current 780,000 254,218 500,000 351,194 Warrants Warrants 1,757,813 Outstanding $1.80 $6.78 $9.50 $0.01 $4.00 $8.45 $4.25 $6.26 $4.73 $9.61 $6.10 $3.68 $2.20 Stock $17.13 $13.84 $18.79 $12.58 $35.64 $48.58 $30.71 $27.41 $19.05 Price as of 6/29/2012 N/ A N/ A N/ A $29,000 $225,157 $526,604 $150,000 $143,677 $113,000 $400,000 Proceeds $3,301,647 $2,600,000 $1,100,870 $1,000,000 $18,500,000 $54,621,849 $181,102,043 Final Disposition 15 A A P R R R R R R R R R R R Note Final Disposition Date 9/1/2010 N/ A 11/9/2011 11/18/2011 9/28/2011 10/26/2011 9/29/2010 10/19/2011 8/18/2011 N/ A 7/28/2011 4/7/2010 9/22/2011 N/ A 5/6/2010 9/1/2010 1/25/2011 $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— Remaining $6,566,692 $200,000,000 Capital Amount 6 $— $574,000 $5,000,000 $7,462,000 $3,000,000 $2,212,308 $2,260,000 $1,747,000 $76,898,000 $20,500,000 $64,450,000 $16,500,000 $52,000,000 $19,468,000 $20,000,000 $26,440,000 $200,000,000 $200,000,000 Amount (Loss) $2,250,000,000 $25,000,000,000 Capital Repayment 3/3/2010 8/11/2010 10/7/2009 Capital Repayment Date 2/8/2010 9/22/2011 9/8/2011 8/18/2011 10/26/2011 9/29/2010 9/15/2011 8/18/2011 8/13/2010 7/28/2011 2/16/2011 12/30/2009 9/22/2011 3/17/2010 9/29/2010 8/4/2010 ** $574,000 $500,000 $5,000,000 $7,000,000 $7,462,000 $2,400,000 $6,300,000 $3,000,000 $8,779,000 $9,439,000 $3,000,000 $9,950,000 $2,260,000 $7,701,000 $2,550,000 $3,872,000 $1,747,000 $3,976,000 $6,970,000 $17,680,000 $28,000,000 $76,898,000 $19,817,000 $10,400,000 $24,990,000 $20,500,000 $16,015,000 $64,450,000 $16,500,000 $10,000,000 $20,400,000 $52,000,000 $19,468,000 $20,000,000 $12,725,000 $17,806,000 $12,643,000 $26,440,000 $300,000,000 $400,000,000 $2,330,000,000 $2,250,000,000 $25,000,000,000 Investment Amount (C ontinu e d ) Preferred Stock w/ Warrants Stock w/ Warrants Preferred Preferred Stock w/ Warrants Stock w/ Warrants Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred Investment Description Debentures Subordinated Warrants w/ E xercised Warrants Stock w/ E xercised Preferred Rights Contingent Value Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Stock Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Stock w/ Warrants Preferred Stock Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Debentures Subordinated Warrants w/ E xercised Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Stock Preferred Stock w/ Warrants Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Preferred Stock w/ Warrants Stock w/ Warrants Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred Preferred Stock w/ Warrants Stock w/ Warrants Preferred Common Stock w/ Warrants 2 2 2 50 2 A 2 2 2,49 8 2 2 A A 3,30 2,10 2,49 3,30 2 8 2 2,49 A 49 2

A 2 2 2,61 50

16 11,23 2,10 2 2,30 2,3 49 A ancshares, Inc., Danville, A R Chambers B ancshares, ank, West Sacramento, C A Community B usiness ank, West Citizens South B anking Corporation, Gastonia, NC Corporation, City National B ancshares Newark, NJ CO Inc., L amar, Colo E ast B ankshares, Columbine Capital Corp., B uena Vista, CO Corporation, Glen Community B ankers Trust A llen, V ankshares, Inc., Clover, SC Inc., Clover, Clover Community B ankshares, Chicago Shore Corporation , Chicago, I L Chicago Shore NY Inc., New York, Citigroup Citizens Republic B ancorp, Inc., Flint, MI CO Co B iz Financial Inc., Denver, P B ancorp, Inc., York, Codorus Valley Conshohocken, P Colonial A merican B ank, West Colony B ankcorp, Inc., Fitzgerald, G A W A Columbia B anking System, Inc., Tacoma, National B ank, Newport B each, C A Commerce Inc., L ouisville, KY Commonwealth B ancshares, Commonwealth B usiness ank, L os A ngeles, C Inc., Kingman, A Z Community B ancshares, Inc., Harrison, A R Community First B ancshares, Community First Inc., Columbia, TN Institution Inc., Glen E llyn, I L Community Financial Shares, CIT Group Inc., New York, NY Inc., New York, CIT Group Co., Chillicothe, MO Citizens B ancshares Corporation, A tlanta, G Citizens B ancshares Covington, LA Company, Citizens B ank & Trust Inc., B ancshares, Citizens Commerce Citizens Community B ank, South Hill, V KY Citizens First Corporation, B owling Green, City National Corporation, B everly Hills, C A Inc., Coastal B anking Company, Fernandina B each, F L Inc., CoastalSouth B ancshares, Hilton Head Island, SC Comerica Inc., Dallas, TX Community 1st B ank, Roseville, C A of Kansas, Inc., Goff, KS Community B ancshares of Mississippi, Inc., Community B ancshares B randon, MS Oakland, C A Community B ank of the ay, of Indiana, Inc., New Community B ank Shares IN A lbany, Community Financial Corporation, Staunton, V TN Inc., Union City, Community First B ancshares Versailles, KY Versailles, ancorp, Nevada City, C A Citizens B ancorp, Nevada City, Citizens & Northern Corporation, Wellsboro, P Citizens & Northern Corporation, Wellsboro, 5/29/2009 2/27/2009 12/12/2008 4/10/2009 2/13/2009 2/27/2009 12/19/2008 3/27/2009 7/31/2009 10/28/2008 12/12/2008 12/19/2008 1/9/2009 3/27/2009 1/9/2009 11/21/2008 1/9/2009 5/22/2009 1/23/2009 7/24/2009 4/3/2009 2/27/2009 CPP TRANSACTION DETAIL, AS OF 6/30/2012 CPP TRANSACTION DETAIL, Purchase Date 5/15/2009 12/31/2008 5/29/2009 3/6/2009 3/20/2009 2/6/2009 12/23/2008 12/19/2008 11/21/2008 12/5/2008 8/28/2009 11/14/2008 1/16/2009 3/6/2009 9/11/2009 1/16/2009 5/29/2009 12/19/2008 3/20/2009 12/23/2008 1/16/2009 Transaction detail I Appendix D I July 25, 2012 243 Treasury Treasury $186,676 $480,993 $448,253 $608,728 $113,228 $810,989 $546,741 $180,940 $407,478 $512,339 $832,488 $387,509 $994,792 $480,206 $748,600 $2,220,000 $2,989,008 $2,800,592 $1,475,278 $3,817,732 $5,959,722 $1,138,750 $3,259,100 $2,461,333 $4,230,091 $1,922,001 $4,739,583 $5,112,555 $2,631,197 $3,076,173 $4,778,889 $1,206,873 $7,395,044 $3,034,288 $1,349,880 $1,272,996 Dividends/ $31,676,420 $67,690,844 Interest Paid to Interest Continued on next page Current Current 373,832 144,984 324,074 521,158 Warrants Warrants Outstanding $3.72 $9.36 $5.70 $2.50 $2.70 $7.10 $4.52 Stock $23.46 $34.58 $13.50 $15.75 $10.96 $11.65 $19.95 $20.63 Price as of 6/29/2012 $51,113 $995,000 $458,000 $460,000 $145,000 $132,000 $637,071 $200,000 $438,000 Proceeds $1,200,000 $2,794,422 $1,307,000 $14,500,000 $172,000,000 Final Disposition 15 P P R R R R R R R R R R R R Note Final Disposition Date 1/26/2011 7/6/2011 9/27/2011 7/7/2010 9/21/2011 11/18/2011 11/18/2011 10/26/2011 12/28/2011 10/28/2009 9/8/2011 12/7/2011 8/25/2011 8/11/2011 $— $— $— $— $— $— $— $— $— $— $— $— $— $— Remaining $23,235,000 $32,500,000 Capital Amount 6 $9,000,000 $2,892,000 $2,639,000 $7,500,000 $4,000,000 $8,750,000 $23,235,000 $24,000,000 $32,500,000 $19,891,000 $11,750,000 $15,000,000 $34,000,000 $97,500,000 $306,546,000 Amount (Loss) $1,224,558,000 Capital Repayment 12/29/2010 7/14/2011 4/21/2010 Capital Repayment Date 7/6/2011 9/2/2009 9/27/2011 8/4/2011 12/23/2009 9/27/2011 8/11/2011 12/28/2011 8/26/2009 9/8/2011 8/18/2011 8/25/2011 8/11/2011 $638,000 $1,050,000 $2,600,000 $9,000,000 $4,400,000 $3,285,000 $7,525,000 $5,000,000 $3,100,000 $2,400,000 $2,892,000 $2,639,000 $9,000,000 $1,173,000 $1,508,000 $7,500,000 $4,000,000 $8,750,000 $2,993,000 $4,609,000 $3,535,000 $24,000,000 $17,949,000 $15,600,000 $35,000,000 $24,000,000 $24,900,000 $10,650,000 $19,891,000 $20,445,000 $11,750,000 $12,000,000 $38,235,000 $34,000,000 $43,000,000 $17,000,000 $306,546,000 $130,000,000 $146,053,000 $1,224,558,000 Investment Amount (C ontinu e d ) Preferred Stock w/ Warrants Stock w/ Warrants Preferred Stock w/ Warrants Preferred Preferred Stock w/ Warrants Stock w/ Warrants Preferred Preferred Stock w/ Warrants Stock w/ Warrants Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred Investment Description Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Stock w/ Warrants Preferred Debentures Subordinated Warrants w/ E xercised Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Stock w/ Warrants Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Debentures Subordinated Warrants w/ E xercised Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Stock Preferred Debentures Subordinated Warrants w/ E xercised Warrants Stock w/ E xercised Preferred Stock w/ Warrants Preferred Debentures Subordinated Warrants w/ E xercised Stock w/ Warrants Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Debentures Subordinated Warrants w/ E xercised Warrants Stock w/ E xercised Preferred Stock Preferred Warrants Stock w/ E xercised Preferred Preferred Stock w/ Warrants Stock w/ Warrants Preferred 2 2 2 2 49 49 8,49 8 A 2 65 2,60 2 8 A 2

49 2 2 2,10a A 50 2 2,10a 2,49 49 8 2 2,49 2 2 2 A 2,49 8,10 A 2 2,49 Community Holding Company of Florida, Inc., Miramar B each, F L ankshares, Inc., B ankshares, E astern Virginia V Tappahannock, NC E C B ancorp, Inc., ngelhard, Financial Corp., E mlenton, P E mclaire Deerfield Financial Corporation, Deerfield, WI DN B Financial Corporation, Downingtown, P Inc., Minneapolis, MN Duke Financial Group, B ancorp, Pasadena, C A E ast West Inc., E nterprise Financial Services Group, A llison Park, P Community Pride B ank Corporation, Ham L ake, MN Goleta, C A B ancshares, Community West Inc., Cayce, SC B ancshares, Congaree B laine, MN Holding Company, Crosstown G A CSR A B ank Corp., Wrens, ID D. L . E vans B ancorp, urley, MO Dickinson Financial Corporation II, Kansas City, Discover Financial Services , Riverwoods, I L E agle B ancorp, Inc., ethesda, MD E nterprise Financial Services Corp., St. L ouis, MO E xchange B ank, Santa Rosa, C A F & C B ancorp, Inc., Holden, MO Institution Community Investors B ancorp, Inc., ucyrus, OH Community Partners B ancorp, Middletown, NJ Financial Corporation, Community Trust Ruston, LA Corning Savings and L oan A ssociation, Corning, A R N E Inc., Milford, Country B ank Shares, Covenant Financial Corporation, Clarksdale, MS B ancorp, Inc., uffalo, WY Creek Crazy Woman Inc. Financial B ancshares, Crescent NC Financial Corporation), Cary, (Crescent Customers B ancorp, Inc. B ancorp, Inc.), Phoenixville, P ( B erkshire CV B Financial Corp, Ontario, C A MD Delmar B ancorp, Delmar, DeSoto County B ank, Horn L ake, MS DeSoto County B ank, Horn L ake, MS MO Diamond B ancorp, Inc., Washington, Inc., Houston, TX B ancshares E ncore Inc., Wichita, KS E quity B ancshares, TN Inc., Trezevant, F & M B ancshares, TN Inc., Trezevant, F & M B ancshares, NC F & M Financial Corporation, Salisbury, 2/6/2009 1/9/2009 1/16/2009 12/23/2008 5/15/2009 1/30/2009 6/19/2009 12/5/2008 6/12/2009 11/13/2009 12/19/2008 1/9/2009 1/23/2009 3/27/2009 2/27/2009 1/16/2009 3/13/2009 12/5/2008 12/19/2008 12/19/2008 5/22/2009 CPP TRANSACTION DETAIL, AS OF 6/30/2012 CPP TRANSACTION DETAIL, Purchase Date 12/23/2008 1/30/2009 1/9/2009 2/13/2009 1/30/2009 6/5/2009 2/20/2009 1/9/2009 6/12/2009 12/5/2008 12/4/2009 2/13/2009 12/29/2009 5/22/2009 12/5/2008 1/30/2009 1/30/2009 11/6/2009 2/6/2009 244 Appendix D I Transaction Detail I July 25, 2012 $— $90,174 $75,919 Treasury Treasury $300,643 $156,090 $979,300 $664,597 $633,322 $191,232 $538,231 $448,105 $620,001 $614,488 $154,592 $3,333,333 $4,192,649 $1,441,222 $3,211,806 $3,059,343 $4,808,414 $1,913,405 $5,166,600 $2,925,316 $1,397,234 $6,734,009 $8,207,389 $6,037,238 $1,759,344 $3,838,240 $1,579,466 $1,352,721 $1,198,750 $8,594,444 $1,236,732 $1,308,403 $1,204,167 Dividends/ $11,318,975 $32,999,386 $12,347,222 $355,946,667 Interest Paid to Interest Continued on next page Current Current 819,640 223,992 389,484 250,947 469,312 121,387 616,308 Warrants Warrants 2,462,439 Outstanding $6.88 $6.57 $8.64 $8.89 $2.34 $8.45 $4.82 Stock $13.40 $16.88 $23.50 $10.87 $10.41 $17.00 $10.77 $14.43 Price as of 6/29/2012 N/ A N/ A N/ A $40,000 $63,677 $30,600 $500,000 $599,042 $690,100 $465,000 $250,000 $112,000 $924,462 $167,000 $110,000 $225,000 Proceeds $2,079,963 $280,025,936 Final Disposition 15 P P P P R R R R R R R R R R R Note Final Disposition Date 11/18/2011 5/11/2011 7/21/2011 3/16/2011 11/18/2011 9/8/2011 8/24/2011 9/22/2011 7/21/2011 9/1/2011 7/21/2011 11/18/2011 9/24/2010 N/ A 9/22/2011 11/18/2011 N/ A N/ A $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— Remaining $3,675,000 $25,010,000 $35,000,000 Capital Amount 6 $700,000 $650,000 $9,931,327 $9,294,000 $5,000,000 $3,742,000 $3,675,000 $3,345,000 $2,200,000 $2,836,000 $4,500,000 $31,762,000 $25,010,000 $12,505,000 $21,594,229 $42,757,786 $15,000,000 $65,000,000 $10,000,000 $25,000,000 $20,689,633 $41,500,000 $17,000,000 $100,000,000 $100,000,000 Amount (Loss) $3,408,000,000 Capital Repayment 1/3/2012 3/30/2011 9/9/2009 2/2/2011 2/23/2011 Capital Repayment Date 6/13/2012 7/21/2011 6/27/2012 12/21/2011 9/1/2011 9/8/2011 7/14/2011 6/13/2012 6/27/2012 3/9/2011 9/22/2011 7/21/2011 9/1/2011 1/18/2012 7/21/2011 8/25/2011 9/24/2010 9/24/2010 9/22/2011 7/8/2009 8/13/2010 $442,000 $700,000 $8,752,000 $3,035,000 $9,294,000 $7,289,000 $3,942,000 $7,000,000 $6,657,000 $5,000,000 $3,742,000 $1,177,000 $3,422,000 $7,350,000 $3,345,000 $2,211,000 $2,032,000 $2,200,000 $2,836,000 $4,500,000 $31,762,000 $37,515,000 $17,243,000 $11,000,000 $30,000,000 $12,000,000 $21,042,000 $36,282,000 $48,200,000 $50,000,000 $65,000,000 $10,000,000 $25,000,000 $10,958,000 $23,184,000 $41,500,000 $17,000,000 $100,000,000 $424,174,000 $295,400,000 $100,000,000 $3,408,000,000 Investment Amount (C ontinu e d ) Preferred Stock w/ Warrants Stock w/ Warrants Preferred Preferred Stock w/ Warrants Stock w/ Warrants Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred Investment Description Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Stock w/ Warrants Preferred Debentures Subordinated Warrants w/ E xercised Warrants Stock w/ E xercised Preferred Debentures Subordinated Warrants w/ E xercised Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Debentures Subordinated Warrants w/ E xercised Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Stock w/ Warrants Preferred Warrants Stock w/ E xercised Preferred Debentures Subordinated Warrants w/ E xercised Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Debentures Subordinated Warrants w/ E xercised Stock w/ Warrants Preferred Common Stock w/ Warrants Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Stock w/ Warrants Preferred Warrants Stock w/ E xercised Preferred Stock Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred Warrants Stock w/ E xercised Preferred Stock Preferred Stock w/ Warrants Preferred Warrants Stock w/ E xercised Preferred Preferred Stock w/ Warrants Stock w/ Warrants Preferred Stock w/ Warrants Preferred Preferred Stock Preferred

2 87 3,30 8,10,49 2,50 2,49 A 2 2, 50 8 2 92 2,50 2 2,50 2 2,10a 90 A 94 2,10 8 8,10,38 2 50 A A 2,50 2, 30 2,10a,30

2 2 2 67 50 2 A A 28 8 2 2 50 ancshares, Inc., B ancshares, Farmers & Merchants Houston, TX F&M Financial Corporation, Clarksville, TN First Choice B ank, Cerritos, C A Financial Security Corporation, B asin, WY First B anks, Inc., Clayton, MO First Capital B ancorp, Inc., Glen A llen, V B . Corporation, Hermitage, P F.N. B . Corporation (Parkvale Financial F.N. P Corporation), Monroeville, Financial Corporation, Farmers & Merchants KS A rgonia, B end, KS Farmers E nterprises, Inc., Great Inc., Holton, KS Farmers State B ankshares, CO B oulder, F B HC Holding Company, IN FFW Corporation, Wabash, Fidelity Southern Corporation, A tlanta, G B ancorp, Cincinnati, OH Fifth Third NY Financial Institutions, Inc., Warsaw, NY First A merican International Corp., B rooklyn, NC First B ancorp, Troy, First B usey Corporation, Urbana, I L First Choice B ank, Cerritos, C A OH First Citizens B anc Corp, Sandusky, NH B ancorp, Inc., Colebrook, First Colebrook Institution ank , Windsor, V Farmers B ank , Windsor, Farmers Capital B ank Corporation, Frankfort, KY FC B ancorp, Inc., L ouisville, KY Fidelity B ancorp, Inc, aton Rouge, LA P Fidelity B ancorp, Inc., Pittsburgh, Fidelity Federal B ancorp, E vansville, IN Fidelity Financial Corporation, Wichita, KS MN Inc., Winger, Financial Services of Winger, Inc., Coon Rapids, MN First A dvantage B ancshares TN Inc., Cordova, First A lliance B ancshares, First A merican B ank Corporation, Village, I L E lk Grove Corporation, Paris, I L First B ancTrust First B ank of Charleston, Inc., WV I L Inc., Quincy, First B ankers Trustshares, First B usiness ank, N. A ., San Diego, C First B usiness ank, N. A ., San Diego, C Inc, Westlake First California Financial Group, Village, C A Inc., B luefield, V First Community B ancshares FC Holdings, Inc., Houston, TX First B anCorp, San Juan, PR 3/6/2009 2/13/2009 12/22/2009 2/13/2009 12/31/2008 4/3/2009 1/9/2009 12/23/2008 3/20/2009 6/19/2009 3/20/2009 12/29/2009 12/19/2008 12/19/2008 12/31/2008 12/23/2008 3/13/2009 1/16/2009 3/6/2009 2/13/2009 1/23/2009 3/20/2009 CPP TRANSACTION DETAIL, AS OF 6/30/2012 CPP TRANSACTION DETAIL, Purchase Date 1/23/2009 1/9/2009 12/19/2008 5/29/2009 12/12/2008 11/13/2009 12/19/2008 7/31/2009 5/22/2009 6/26/2009 7/24/2009 2/20/2009 2/6/2009 1/16/2009 4/10/2009 12/11/2009 12/19/2008 11/21/2008 6/26/2009 1/9/2009 Transaction detail I Appendix D I July 25, 2012 245 $45,087 Treasury Treasury $570,625 $237,983 $818,468 $604,950 $744,982 $639,738 $824,313 $694,280 $437,343 $757,454 $659,722 $676,865 $584,794 $330,944 $207,327 $4,677,778 $2,383,333 $4,753,618 $1,994,333 $7,009,095 $2,305,990 $2,178,580 $1,862,389 $1,976,792 $2,910,906 $6,546,862 $1,600,000 $2,330,477 $2,848,444 $2,403,117 $2,042,406 $1,402,500 $1,099,102 $1,327,473 $1,361,039 Dividends/ $91,227,406 $28,628,333 $10,815,494 $12,167,111 $11,225,272 Interest Paid to Interest Continued on next page Current Current 513,113 195,915 550,595 241,696 215,983 823,627 114,080 Warrants Warrants 3,670,822 Outstanding $8.10 $5.18 $7.65 $0.62 $8.65 $6.00 $8.00 $2.25 $3.55 $3.00 $0.03 Stock $15.98 $11.86 $15.45 $10.98 $17.12 $10.72 $12.46 Price as of 6/29/2012 N/ A N/ A N/ A $37,000 $600,000 $900,000 $892,000 $375,000 $545,000 $677,000 $375,000 $250,000 $113,000 $240,000 $367,500 $130,000 Proceeds $2,966,288 $2,700,000 $1,003,227 $1,030,000 $1,488,046 $79,700,000 Final Disposition 15 A P R R R R R R R R R R R R R R R R R Note N/ A 6/2/2010 Final Disposition Date 6/24/2009 1/5/2011 3/9/2011 12/21/2011 N/ A 9/22/2011 5/27/2009 11/18/2011 8/4/2011 11/16/2011 6/16/2010 4/14/2010 9/15/2011 9/17/2010 2/15/2012 9/22/2011 4/7/2010 9/15/2011 9/15/2011 N/ A $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— Remaining $36,875,000 Capital Amount 6 $731,000 $6,000,000 $7,754,267 $7,500,000 $5,000,000 $3,756,000 $4,797,000 $2,600,000 $2,417,000 $80,000,000 $30,000,000 $19,300,000 $46,400,000 $35,084,144 $55,926,478 $20,699,000 $12,000,000 $69,600,000 $17,836,000 $17,390,000 $13,125,000 $10,900,000 $13,533,000 $10,000,000 $184,011,000 $866,540,000 $193,000,000 Amount (Loss) Capital Repayment 5/3/2011 2/24/2010 9/29/2010 5/27/2009 12/15/2010 12/22/2010 9/22/2011 11/23/2011 Capital Repayment Date 5/31/2011 6/13/2012 3/28/2012 9/22/2011 5/27/2009 9/22/2011 8/4/2011 9/15/2011 9/28/2011 6/16/2010 4/14/2010 9/15/2011 9/17/2010 2/15/2012 9/22/2011 4/7/2010 9/15/2011 9/15/2011 9/15/2011 $731,000 $7,500,000 $5,000,000 $3,756,000 $8,700,000 $7,570,000 $3,223,000 $6,398,000 $4,797,000 $4,579,000 $4,596,000 $2,600,000 $2,417,000 $7,400,000 $5,500,000 $16,500,000 $80,000,000 $30,000,000 $72,927,000 $19,300,000 $20,000,000 $46,400,000 $33,000,000 $14,800,000 $10,685,000 $22,000,000 $37,000,000 $65,000,000 $20,699,000 $12,000,000 $69,600,000 $13,900,000 $17,836,000 $17,390,000 $15,349,000 $50,000,000 $10,900,000 $13,533,000 $11,350,000 $10,000,000 $184,011,000 $866,540,000 $193,000,000 Investment Amount (C ontinu e d ) Preferred Stock w/ Warrants Stock w/ Warrants Preferred Preferred Stock w/ Warrants Stock w/ Warrants Preferred Preferred Stock w/ Warrants Stock w/ Warrants Preferred Preferred Stock w/ Warrants Stock w/ Warrants Preferred Preferred Stock w/ Warrants Stock w/ Warrants Preferred Stock w/ Warrants Preferred Preferred Stock w/ Warrants Stock w/ Warrants Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred Trust Preferred Securities Preferred Trust Investment Description Warrants Stock w/ E xercised Preferred Stock w/ Warrants Preferred Warrants Stock w/ E xercised Preferred Stock w/ Warrants Preferred w/ E xercised Debentures Subordinated Warrants Warrants Stock w/ E xercised Preferred Debentures Subordinated Warrants w/ E xercised Stock w/ Warrants Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Stock Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Stock w/ Warrants Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Stock w/ Warrants Preferred Warrants Stock w/ E xercised Preferred Stock Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Stock Preferred Stock w/ Warrants Preferred Debentures Subordinated Warrants w/ E xercised Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Preferred Stock w/ Warrants Stock w/ Warrants Preferred Stock w/ Warrants Preferred 2 2 2,49 49 8,30 2 2,10 8,10,49 2 2 2,49 89 75 2,3 2 2 2 2 2,10a 8 2 27,49,50

A A A 30 2,49 2,50 2,10a,49 A A 2 2,49 39 2

42 awrence, KS Inc., L awrence, First Financial B ancshares, First Financial B ancorp, Cincinnati, OH ancshares, Inc, First Community B ancshares, Overland Park, KS First Manitowoc B ancorp, Inc., Manitowoc, WI First Northern Community B ancorp, Dixon, C A OH First Place Financial Corp., Warren, First Priority Financial Corp., Malvern, P First Independence Corporation, Detroit, MI First Independence Corporation, Detroit, V First National Corporation, Strasburg, L ockport, NY First Niagara Financial Group, B ancorp, Inc., Chula Vista, C A First PacTrust First Community Financial Partners, Inc., Joliet, I L First Defiance Financial Corp., Defiance, OH Inc., Hanover Park, I L First E agle B ancshares, First Financial Service Corporation, E lizabethtown, KY Inc., L ebanon, TN B ancshares, First Freedom First Horizon National Corporation, Memphis, TN Inc., Neenah, WI First Menasha B ancshares, First Midwest B ancorp, Inc., Itasca, I L First N B C ank Holding Company, New Orleans, LA B ank, E xton, P First Resource Inc., Chattanooga, TN First Security Group, First Southern B ancorp, Inc., oca Raton, F L First Southwest B ancorporation, Inc., A lamosa, CO B HC, Inc., Fort Worth, TX First Texas Institution First Sound B ank, Seattle, W A First Community B ank Corporation of A merica, Pinellas Park, F L First Community Corporation, L exington, SC of Nebraska, Inc., Gering, N E First E xpress of A rkansas, Inc., First Federal B ancshares Harrison, A R First Financial Holdings Inc., Charleston, SC Inc., B ancshares, First Gothenburg N E Gothenburg, Inc., Hammond, LA First Guaranty B ancshares, B ank, Doraville, G A First Intercontinental First L itchfield Financial Corporation, itchfield, CT First M&F Corporation, Kosciusko, MS Corporation, Muncie, IN First Merchants First Priority Financial Corp., Malvern, P SC Inc., Florence, First Reliance B ancshares, B ank, E xton, P First Resource First South B ancorp, Inc., L exington, TN First State B ank of Mobeetie, TX 6/12/2009 12/23/2008 5/15/2009 1/16/2009 3/13/2009 3/13/2009 2/20/2009 8/28/2009 3/13/2009 11/21/2008 11/21/2008 12/11/2009 12/5/2008 9/11/2009 1/9/2009 12/22/2009 11/14/2008 2/13/2009 12/5/2008 3/20/2009 1/30/2009 1/9/2009 1/30/2009 3/6/2009 3/6/2009 CPP TRANSACTION DETAIL, AS OF 6/30/2012 CPP TRANSACTION DETAIL, Purchase Date 12/23/2008 12/23/2008 11/21/2008 2/6/2009 3/6/2009 12/5/2008 2/27/2009 8/28/2009 3/13/2009 12/12/2008 2/27/2009 2/20/2009 12/18/2009 3/6/2009 12/11/2009 7/17/2009 2/27/2009 246 Appendix D I Transaction Detail I July 25, 2012 $— $— $49,037 $66,021 $87,185 $53,860 $45,190 Treasury Treasury $417,770 $413,928 $273,889 $221,722 $827,998 $759,993 $321,660 $258,192 $960,795 $961,471 $864,059 $145,750 $517,145 $540,896 $420,740 $975,831 $759,575 $5,942,858 $1,788,194 $3,004,167 $1,667,700 $7,838,056 $1,046,896 $2,312,500 $5,431,250 $1,180,793 $1,339,751 $2,589,305 $2,452,500 $8,475,080 $1,856,917 $2,969,910 Dividends/ $37,220,872 $29,335,625 Interest Paid to Interest Continued on next page 22,071 Current Current 326,323 578,947 183,158 Warrants Warrants 6,451,379 Outstanding $0.84 $9.99 $4.31 $9.80 $0.02 $4.50 $4.50 Stock $16.51 $13.63 $16.15 $27.58 $12.99 $12.80 Price as of 6/29/2012 N/ A N/ A $33,000 $900,000 $600,000 $245,000 $245,000 $475,000 $155,000 $162,000 $150,000 $300,000 $435,000 $200,000 $450,000 Proceeds $5,025,000 $6,436,364 $10,800,000 Final Disposition 15 R R R R R R R R R R R R R R R R Note N/ A Final Disposition Date 5/27/2009 12/30/2009 9/8/2010 9/15/2011 9/21/2011 7/14/2010 4/22/2009 9/29/2010 9/22/2011 9/15/2011 6/16/2010 10/6/2010 4/13/2012 2/16/2011 9/8/2011 9/8/2011 N/ A $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— Remaining $2,240,000 $1,400,000 Capital Amount 6 $651,000 $2,240,000 $1,400,000 $4,900,000 $6,000,000 $9,495,000 $3,100,000 $1,000,000 $1,600,000 $6,000,000 $8,700,000 $4,000,000 $9,000,000 $6,319,000 $68,700,000 $70,000,000 $30,587,530 $12,000,000 $58,000,000 $125,000,000 $376,500,000 Amount (Loss) Capital Repayment 9/7/2011 4/22/2009 10/28/2009 7/14/2010 Capital Repayment Date 6/27/2012 9/15/2011 6/16/2010 10/6/2010 8/18/2011 7/14/2010 4/22/2009 9/29/2010 9/22/2011 9/15/2011 12/16/2009 11/24/2009 4/13/2012 2/16/2011 9/8/2011 9/8/2011 9/8/2011 $651,000 $825,000 $4,900,000 $6,000,000 $8,559,000 $9,495,000 $1,300,000 $3,100,000 $5,800,000 $3,240,000 $5,097,000 $3,000,000 $1,968,000 $3,000,000 $6,000,000 $8,700,000 $4,500,000 $4,967,000 $1,607,000 $2,568,000 $4,000,000 $2,443,320 $3,076,000 $9,000,000 $6,319,000 $2,400,000 $9,993,000 $8,400,000 $72,278,000 $70,000,000 $17,969,000 $11,881,000 $33,000,000 $20,471,000 $12,000,000 $51,500,000 $15,000,000 $35,000,000 $58,000,000 $30,000,000 $266,657,000 $125,000,000 $376,500,000 Investment Amount (C ontinu e d ) Preferred Stock w/ Warrants Stock w/ Warrants Preferred Preferred Stock w/ Warrants Stock w/ Warrants Preferred Preferred Stock w/ Warrants Stock w/ Warrants Preferred Stock w/ Warrants Preferred Preferred Stock w/ Warrants Stock w/ Warrants Preferred Investment Description Debentures Subordinated Warrants w/ E xercised Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Stock Preferred Stock w/ Warrants Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Common Stock w/ Warrants Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Stock w/ Warrants Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Debentures Subordinated Warrants w/ E xercised Debentures Subordinated Warrants w/ E xercised Warrants Stock w/ E xercised Preferred Debentures Subordinated Warrants w/ E xercised Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Debentures Subordinated Warrants w/ E xercised Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Stock Preferred Stock w/ Warrants Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Preferred Stock w/ Warrants Stock w/ Warrants Preferred Subordinated Debentures Debentures Subordinated Warrants w/ E xercised 2 2 8 2,49 2,82 2 2 2,50 2,10a,49 2 2,50 8 A 2,10,30

50 8 2,80 2 2,10a 59 2,50 2 2 8 8 2 2,49 55 8 2,10 2 2 2 2 58 97 2 2 2 First Trust Corporation, New Orleans, LA First Trust Investments, Inc., Clive, I A Circle Green ank Group, Inc., Tampa, F L Inc., Tampa, Florida B ank Group, ancorp, Inc., Troy, MI Flagstar B ancorp, Inc., Troy, FN B ancorp, South San Francisco, C A NC FN B United Corp., A sheboro, Inc., Ringgold, G A Gateway B ancshares, TN Inc., Greeneville, B ankshares, Green First U LB Corp., Oakland, C A AL Inc., Vernon, B ancshares, First Vernon OH FirstMerit Corporation, A kron, F L Inc., Tampa, Florida B usiness ancGroup, Flushing Financial Corporation, L ake Success, NY I L Inc., Rockford, Financial Group, Foresight Fort L ee Federal Savings B ank, Fort L ee, NJ MO Franklin B ancorp, Inc., Washington, C A First B ank, Fresno, Fresno P Fulton Financial Corporation, L ancaster, SC GrandSouth B ancorporation, Greenville, MN B axter, River Holding Company, Great SC Incorporated, Greer, B ancshares Greer Firstbank Corporation, A lma, MI Institution First United Corporation, Oakland, MD CO Financial, Inc., Denver, First Western CO Financial, Inc., Denver, First Western Fortune Financial Corporation, A rnold, MO FP B ancorp, Inc., Port St. L ucie, F FP B Financial Corp., Hammond, LA L I Inc., Freeport, B ancshares, Freeport C A B ancorporation, Fremont, Fremont Inc., A ustin, TX B ancshares, Frontier Inc., A tlanta, G B ancshares, Commerce Georgia Primary B ank, A tlanta, G Georgia Germantown Capital Corporation, Inc., Germantown, TN Gold Canyon B ank, Canyon, A Z Goldwater B ank, N. A ., Scottsdale, Z OK Grand Capital Corporation, Tulsa, MS Grand Financial Corporation, Hattiesburg, CO Inc., Granby, Grand Mountain B ancshares, SC GrandSouth B ancorporation, Greenville, MO City, Inc., Green City B ancshares, Green Inc., Ozark, MO B ancshares, Gregg Great Southern B ancorp, Springfield, MO Great 6/5/2009 2/27/2009 7/24/2009 1/30/2009 2/27/2009 2/13/2009 5/8/2009 12/23/2008 1/23/2009 6/12/2009 1/9/2009 2/20/2009 12/19/2008 5/15/2009 5/22/2009 5/22/2009 1/23/2009 12/23/2008 12/11/2009 7/17/2009 1/30/2009 1/30/2009 CPP TRANSACTION DETAIL, AS OF 6/30/2012 CPP TRANSACTION DETAIL, Purchase Date 1/30/2009 2/6/2009 12/11/2009 4/3/2009 12/5/2008 1/23/2009 5/8/2009 6/26/2009 4/24/2009 2/6/2009 5/1/2009 3/6/2009 6/26/2009 1/30/2009 4/24/2009 9/25/2009 5/29/2009 1/9/2009 2/27/2009 2/13/2009 12/5/2008 Transaction detail I Appendix D I July 25, 2012 247 $41,524 Treasury Treasury $666,667 $947,284 $969,040 $913,299 $757,380 $876,542 $819,166 $282,744 $547,251 $617,712 $267,050 $573,342 $337,113 $837,793 $277,131 $837,500 $427,216 $391,980 $453,067 $124,306 $1,450,000 $3,435,502 $2,503,333 $1,090,702 $6,761,267 $5,141,755 $6,180,556 $3,106,771 $2,817,361 $2,510,844 $2,462,778 $1,456,279 $3,151,000 $1,043,675 $1,158,113 $1,009,349 $1,321,339 Dividends/ $11,188,087 $129,861,111 $147,185,809 Interest Paid to Interest Continued on next page 91,714 53,034 Current Current 611,650 462,963 276,090 459,459 833,333 253,666 Warrants Warrants Outstanding $5.57 $0.25 $6.50 $9.23 $7.91 $1.09 $4.25 $5.75 $3.00 $4.95 $7.20 $6.55 $6.40 $3.76 $0.02 Stock $50.45 $19.00 $14.65 $24.00 $12.20 $30.58 $26.30 $17.63 $10.50 $13.25 Price as of 6/29/2012 N/ A N/ A N/ A N/ A $21,000 $92,000 $650,000 $450,000 $303,000 $346,000 $375,000 $350,000 $155,000 $200,000 $299,000 $314,000 Proceeds $1,200,000 $1,800,000 $1,300,000 $1,750,551 $49,100,000 $706,264,560 Final Disposition 15 A P R R R R R R R R R R R R R R R R Note 5/20/2009 Final Disposition Date 6/30/2009 8/17/2011 7/27/2011 N/ A 12/29/2010 9/28/2011 8/11/2011 11/18/2011 9/15/2011 8/18/2011 4/13/2011 9/22/2011 N/ A 4/21/2010 9/22/2011 N/ A N/ A 9/22/2011 9/22/2011 9/21/2010 1/19/2011 $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— Remaining $7,497,000 $18,255,000 $18,750,000 $12,000,000 Capital Amount 6 $425,000 $7,497,000 $2,606,000 $6,250,000 $6,920,000 $5,000,000 $7,500,000 $7,000,000 $3,091,000 $2,359,000 $4,000,000 $5,983,000 $4,205,000 $6,000,000 $6,272,000 $4,000,000 $90,000,000 $25,000,000 $24,000,000 $40,000,000 $18,750,000 $12,000,000 $50,000,000 $14,000,000 $81,698,000 Amount (Loss) $3,400,000,000 $1,398,071,000 Capital Repayment 6/3/2009 12/22/2010 3/7/2012 8/11/2011 8/25/2011 5/9/2012 7/6/2011 Capital Repayment Date 7/30/2010 12/29/2010 9/15/2011 3/16/2011 11/10/2010 9/15/2011 6/13/2012 8/18/2011 4/13/2011 3/31/2010 9/22/2011 9/22/2011 4/21/2010 9/22/2011 12/22/2010 9/10/2010 3/31/2009 9/3/2010 9/22/2011 9/22/2011 $425,000 $6,920,000 $7,500,000 $7,500,000 $7,000,000 $6,800,000 $7,000,000 $3,091,000 $2,359,000 $6,700,000 $4,000,000 $3,250,000 $1,900,000 $5,983,000 $5,000,000 $4,000,000 $1,552,000 $5,976,000 $4,205,000 $2,295,000 $6,000,000 $6,000,000 $6,900,000 $6,272,000 $4,000,000 $25,000,000 $21,000,000 $24,000,000 $12,895,000 $40,000,000 $30,255,000 $50,000,000 $18,400,000 $14,000,000 $80,347,000 $81,698,000 $10,103,000 $10,000,000 $25,000,000 $17,000,000 $26,000,000 $90,000,000 $3,400,000,000 $1,398,071,000 Investment Amount (C ontinu e d ) Preferred Stock w/ Warrants Stock w/ Warrants Preferred Preferred Stock w/ Warrants Stock w/ Warrants Preferred Preferred Stock w/ Warrants Stock w/ Warrants Preferred Preferred Stock w/ Warrants Stock w/ Warrants Preferred Stock w/ Warrants Preferred Preferred Stock w/ Warrants Stock w/ Warrants Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred Investment Description Warrants Stock w/ E xercised Preferred Debentures Subordinated Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Common Stock w/ Warrants Stock Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Stock w/ Warrants Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Stock Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Stock w/ Warrants Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Debentures Subordinated Warrants Stock w/ E xercised Preferred Stock Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Preferred Stock w/ Warrants Stock w/ Warrants Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred 2 2,3 31 2 A 2,3a,30 2 50 3,8,30 2 2 2,50 2,10 2,50 2,49 2,49 2,10a,49 2,10a 2 2,10,50 A 50 10,21 2 A 3,8,30 2 2,10 2 2 2,10 2 A 2,13 ,49 2,10a,13,49 ancorp, Inc., Woodsville, NH Guaranty B ancorp, Inc., Woodsville, I B T ancorp, Inc., Irving, TX HF Financial Corp., Sioux Falls, SD Highlands B ancorp, Inc. (Highlands State ank), NJ Vernon, Heritage Oaks B ancorp, Paso Robles, C A ancshares, Inc., Franklin, IN Heartland B ancshares, Heritage Financial Corporation, Olympia, W A HCS B Financial Corporation, L oris, SC Inc., Norfolk, V Heritage B ankshares, Corp., San Jose, C A Heritage Commerce Hometown B ancorp of A labama, Inc., Oneonta, AL MD B ancorp, Inc., E llicott City, Howard GulfSouth Private B ank, Destin, F L MD Corporation, B altimore, Harbor B ankshares Inc., Haviland, KS Haviland B ancshares, Summit, MO Inc., L ee’s Hawthorne B ancshares, Inc., Highlands Independent B ancshares, Sebring, F L A R Inc., Conway, Home B ancshares, HopFed B ancorp, Hopkinsville, KY IN Horizon B ancorp, Michigan City, Hyperion B ank, Philadelphia, P Idaho B ancorp, oise, ID Illinois State B ancorp, Inc., Chicago, I L Institution Guaranty Capital Corporation, B elzoni, MS Inc., Springfield, MO Guaranty Federal B ancshares, Inc., Stuart, F L B ancshares, Gulfstream Hoschton, G A Hamilton State B ancshares, Inc., Norfolk, V Hampton Roads B ankshares, Inc., Financial Services Group, Hartford CT Hartford, Heartland Financial US A , Inc., Dubuque, I Highlands B ancorp, Inc. (Highlands State ank), NJ Vernon, Hilltop Community B ancorp, Inc., Summit, NJ MN HMN Financial, Inc., Rochester, Inc., Corbin, KY Hometown B ancshares, Corporation, B ankshares HomeTown Roanoke, V HPK Financial Corporation, Chicago, I L HPK Financial Corporation, Chicago, I L Columbus, OH Huntington B ancshares, I A B ancorp, Inc., Iselin, NJ I B C ancorp, Inc., Chicago, L Iberiabank Corporation, L afayette, LA DC I B W Financial Corporation , Washington, IC B Financial, Ontario, C A Illinois State B ancorp, Inc., Chicago, I L 2/20/2009 3/27/2009 11/21/2008 5/8/2009 3/20/2009 9/11/2009 11/21/2008 3/6/2009 9/25/2009 11/21/2008 2/20/2009 2/27/2009 9/25/2009 7/17/2009 3/13/2009 12/19/2008 3/6/2009 1/16/2009 12/12/2008 12/19/2008 2/6/2009 1/16/2009 12/29/2009 CPP TRANSACTION DETAIL, AS OF 6/30/2012 CPP TRANSACTION DETAIL, Purchase Date 9/25/2009 1/30/2009 6/26/2009 2/20/2009 12/31/2008 6/26/2009 12/19/2008 12/22/2009 1/30/2009 12/23/2008 2/13/2009 9/18/2009 11/13/2009 5/1/2009 11/14/2008 9/18/2009 5/15/2009 12/5/2008 3/13/2009 3/6/2009 5/22/2009 248 Appendix D I Transaction Detail I July 25, 2012 $— $66,347 $80,900 Treasury Treasury $194,367 $165,139 $174,325 $595,867 $267,134 $393,763 $609,961 $355,079 $838,516 $461,009 $700,000 $674,763 $169,422 $538,188 $524,833 $1,118,056 $1,452,047 $6,460,833 $3,596,156 $1,661,468 $1,118,094 $2,430,000 $1,950,340 $1,222,500 $7,816,966 $3,000,452 $1,399,560 $4,438,492 $9,489,792 $1,682,083 $9,159,773 $3,681,875 Dividends/ $36,660,000 $46,180,555 $39,920,833 $297,222,222 $795,138,889 $100,531,250 Interest Paid to Interest Continued on next page 95,383 Current Current 691,882 346,154 653,226 561,343 407,542 379,310 571,906 188,707 Warrants Warrants 1,326,238 1,218,522 7,418,876 Outstanding $3.83 $7.74 $3.85 $2.47 $1.05 $4.00 $6.58 $5.99 Stock $19.52 $13.00 $10.52 $26.83 $21.87 $29.21 $35.73 $82.57 $69.50 $11.83 $22.05 $13.33 Price as of 6/29/2012 N/ A N/ A N/ A $63,364 $522,000 $877,557 $690,000 $100,000 $292,000 $560,000 $225,000 $602,557 Proceeds $2,800,000 $2,875,000 $1,095,000 $2,200,000 $70,000,000 $213,671,319 $936,063,469 Final Disposition 15 A A P P R R R R R R R R R R R R Note Final Disposition Date 11/18/2011 4/20/2011 2/29/2012 9/16/2010 10/14/2009 8/18/2011 7/21/2011 8/18/2011 N/ A 8/18/2011 5/27/2009 9/29/2010 N/ A 11/18/2011 11/24/2010 N/ A 12/16/2009 3/9/2012 12/10/2009 $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— Remaining $6,885,000 $19,000,000 $39,000,000 $10,340,000 $230,000,000 Capital Amount 6 $3,455,000 $6,885,000 $1,700,000 $3,455,000 $1,998,000 $2,453,000 $5,830,000 $5,645,000 $4,500,000 $56,044,000 $20,000,000 $19,000,000 $20,000,000 $10,449,000 $57,500,000 $21,900,000 $21,863,750 $11,735,000 $52,277,171 $78,158,000 $13,400,000 $15,000,000 $950,000,000 $370,000,000 $330,000,000 Amount (Loss) $2,500,000,000 $25,000,000,000 Capital Repayment 8/18/2011 3/30/2011 6/9/2010 3/16/2011 2/8/2012 6/8/2011 8/4/2010 6/30/2010 9/16/2009 Capital Repayment Date 8/18/2011 7/21/2011 8/18/2011 6/13/2012 8/20/2010 11/24/2009 3/28/2012 4/22/2009 6/17/2009 9/29/2010 9/29/2010 10/21/2009 11/24/2010 9/24/2010 11/18/2009 5/18/2011 5/13/2011 3/9/2012 $470,000 $1,700,000 $1,065,000 $1,312,000 $4,000,000 $4,000,000 $1,998,000 $2,453,000 $3,000,000 $5,830,000 $5,498,000 $6,500,000 $5,645,000 $3,072,000 $3,370,000 $4,500,000 $25,000,000 $56,044,000 $27,000,000 $59,000,000 $74,426,000 $83,586,000 $10,449,000 $57,500,000 $21,900,000 $17,280,000 $25,223,000 $11,735,000 $13,795,000 $57,000,000 $78,158,000 $21,500,000 $13,400,000 $15,000,000 $11,000,000 $216,000,000 $950,000,000 $151,500,000 $600,000,000 $330,000,000 $2,500,000,000 $25,000,000,000 Investment Amount (C ontinu e d ) Preferred Stock w/ Warrants Stock w/ Warrants Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred Preferred Stock w/ Warrants Stock w/ Warrants Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred Investment Description Warrants Stock w/ E xercised Preferred Mandatorily Convertible Preferred Stock w/ Warrants Warrants Stock w/ E xercised Preferred Stock w/ Warrants Preferred Debentures Subordinated Warrants w/ E xercised Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Stock Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Stock Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Stock Preferred Warrants Stock w/ E xercised Preferred Stock w/ Warrants Preferred Warrants Stock w/ E xercised Preferred Stock Preferred Stock w/ Warrants Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Stock w/ Warrants Preferred Preferred Stock w/ Warrants Stock w/ Warrants Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred 78 2 2 2,50 2,49 2,10 2,50 22 2 14,57 A 2, 73 2 3,53 A 2,30 2,10a,30 2 2 2 2,3,10,30 88 2 43 2 2,49 8 3,30 ast Greenwich, RI Independence B ank, E ast Greenwich, bensburg, P Mainline B ancorp, Inc., E bensburg, Investors Financial Corporation of Pettis County, Investors Financial Corporation of Pettis County, Inc., Sedalia, MO Kirksville B ancorp, Inc., Kirksville, MO ancshares Corporation, New York, NY Corporation, New York, Intervest B ancshares KeyCorp, Cleveland, OH IN L akeland Financial Corporation, Warsaw, Milwaukee, WI L ayton Park Financial Group, L N B ancorp Inc., orain, OH Independent B ank Corporation, Ionia, MI Indiana B ank Corp., Dana, IN Intermountain Community B ancorp, Sandpoint, ID TX Corporation, L aredo, International B ancshares Corp., Houlton, M E Katahdin B ankshares L akeland B ancorp, Inc., Oak Ridge, NJ Inc., Springfield, MO L iberty B ancshares, Inc., FortL iberty Worth, TX B ancshares, P L incoln National Corporation, Radnor, L one Star B ank, Houston, TX M&T B ank Corporation, uffalo, NY M&T B ank Corporation (Wilmington Trust Corporation), Wilmington, D E Madison Financial Corporation, Richmond, KY Manhattan B ancorp, E l Segundo, C A Institution Independent B ank Corp., Rockland, M A Indiana Community B ancorp, Columbus, IN Integra B ank Corporation, E vansville, IN NY Chase & Co., New York, JPMorgan KS B ancorp, Inc., Smithfield, NC MS L afayette B ancorp, Inc., Oxford, MS L afayette B ancorp, Inc., Oxford, L CN B Corp., ebanon, OH L egacy B ancorp, Inc., Milwaukee, WI A R Inc., Jonesboro, L iberty B ancshares, L iberty Financial Services, Inc., New Orleans, LA Inc., Hinesville, G A L iberty Shares, M A L S B Corporation, North A ndover, M&F B ancorp, Inc., Durham, NC B ancshares M&T B ank Corporation (Provident MD Corp.), B altimore, Mackinac Financial Corporation, Manistique, MI Magna B ank, Memphis, TN IN Inc., Greensburg, Financial Group, MainSource L eader B ancorp, Inc., A rlington, M 1/9/2009 12/29/2009 5/8/2009 3/20/2009 12/23/2008 11/14/2008 2/27/2009 12/18/2009 12/12/2008 12/12/2008 4/24/2009 12/19/2008 12/23/2008 1/30/2009 2/6/2009 2/13/2009 12/4/2009 7/10/2009 2/6/2009 11/14/2008 12/12/2008 3/13/2009 12/5/2008 CPP TRANSACTION DETAIL, AS OF 6/30/2012 CPP TRANSACTION DETAIL, Purchase Date 1/9/2009 12/12/2008 2/27/2009 10/28/2008 8/21/2009 2/20/2009 12/29/2009 1/9/2009 1/30/2009 1/23/2009 2/6/2009 2/20/2009 12/12/2008 6/26/2009 12/23/2008 4/24/2009 12/23/2008 1/16/2009 12/23/2008 Transaction detail I Appendix D I July 25, 2012 249 $28,294 Treasury Treasury $652,959 $508,989 $643,345 $235,713 $138,778 $197,653 $570,433 $475,815 $424,668 $256,560 $332,256 $636,219 $275,105 $824,289 $343,053 $759,584 $456,042 $190,517 $262,919 $743,167 $474,604 $986,944 $2,317,675 $1,933,333 $1,779,122 $5,109,510 $6,588,899 $3,166,021 $7,528,750 $2,627,778 $1,082,431 $1,299,481 $1,869,051 $1,381,348 $3,454,185 $1,702,778 $1,118,716 Dividends/ $32,095,000 $318,055,555 $226,522,917 Interest Paid to Interest Continued on next page 73,099 Current Current 616,438 771,429 260,962 Warrants Warrants 4,282,020 Outstanding $6.00 $3.01 $4.95 $1.21 $9.85 Stock $14.59 $21.50 $21.54 $18.45 $10.67 $10.95 $107.00 Price as of 6/29/2012 N/ A N/ A $35,000 $55,000 $94,000 $237,000 $590,000 $509,000 $650,000 $300,000 $175,000 $176,000 $206,557 $260,000 $476,000 $301,001 Proceeds $3,250,000 $1,000,000 $1,518,072 $950,000,000 Final Disposition 15 P P R R R R R R R R R R R R R R R R Note Final Disposition Date 8/12/2009 7/27/2011 7/5/2011 7/21/2011 12/23/2009 11/18/2011 11/10/2009 7/20/2011 5/2/2012 8/18/2011 7/21/2011 8/4/2011 9/8/2011 9/7/2011 11/18/2011 N/ A N/ A 2/10/2010 9/15/2011 8/11/2011 $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— Remaining $5,116,000 $10,500,000 Capital Amount 6 $700,000 $6,000,000 $9,698,000 $3,500,000 $3,510,000 $1,881,000 $5,116,000 $5,500,000 $9,516,000 $4,734,000 $1,100,000 $16,000,000 $11,800,000 $10,500,000 $10,500,000 $43,490,360 $10,189,000 $20,000,000 $13,000,000 $22,000,000 $14,700,000 $196,000,000 Amount (Loss) $1,715,000,000 $10,000,000,000 Capital Repayment 6/17/2009 7/6/2011 Capital Repayment Date 7/5/2011 7/21/2011 4/4/2012 6/6/2012 6/27/2012 12/23/2009 8/25/2011 11/10/2009 7/20/2011 3/14/2012 8/18/2011 7/21/2011 8/4/2011 9/8/2011 9/7/2011 12/23/2009 12/28/2011 8/20/2010 12/23/2009 9/15/2011 8/11/2011 4/25/2012 $700,000 $2,639,000 $3,000,000 $2,060,000 $1,700,000 $6,000,000 $9,698,000 $3,500,000 $3,510,000 $1,881,000 $6,200,000 $6,335,000 $7,700,000 $7,186,000 $2,040,000 $2,348,000 $5,222,000 $7,260,000 $5,116,000 $5,500,000 $1,834,000 $6,785,000 $9,516,000 $4,734,000 $6,216,000 $3,300,000 $16,000,000 $20,300,000 $35,500,000 $11,800,000 $21,000,000 $45,000,000 $74,706,000 $10,189,000 $20,000,000 $89,388,000 $10,000,000 $13,000,000 $10,000,000 $22,000,000 $14,700,000 $196,000,000 $1,715,000,000 $10,000,000,000 Investment Amount (C ontinu e d ) Preferred Stock w/ Warrants Stock w/ Warrants Preferred Preferred Stock w/ Warrants Stock w/ Warrants Preferred Preferred Stock w/ Warrants Stock w/ Warrants Preferred Investment Description Debentures Subordinated Warrants w/ E xercised Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Debentures Subordinated Warrants w/ E xercised Warrants Stock w/ E xercised Preferred Stock w/ Warrants Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Stock Preferred Warrants Stock w/ E xercised Preferred Stock w/ Warrants Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Stock Preferred Warrants Stock w/ E xercised Preferred Stock w/ Warrants Preferred Warrants Stock w/ E xercised Preferred Mandatorily Convertible Preferred Stock w/ Warrants Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Stock Preferred Stock Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Preferred Stock w/ Warrants Stock w/ Warrants Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred 2 3 A 2 A 2 2 2,10a 8 2 14,20 2 2 2 44 2 2 2,50 8 2,41 95 2 2,50 2,84 3,30 A 49 2 2 2,49 2,49 2,10a,49 2,49 2,41 2 2 2,10a A A 2,49 2,62 ancshares, Inc., Manhattan, I L Manhattan B ancshares, ancshares, Inc., Merriam, KS Morrill B ancshares, Morgan Stanley, New York, NY New York, Stanley, Morgan ake City, UT Medallion B ank, Salt L ake City, WI Mid-Wisconsin Financial Services, Inc., Medford, TN Inc., Moscow, Moscow B ancshares, Marquette National Corporation, Chicago, I L Marquette Marshall & Ilsley Corporation, Milwaukee, WI MD Maryland Financial B ank, Towson, MN Inc., Shorewood, Mc L eod B ancshares, Capital Corp., B oston, M A Mercantile Inc. B ank Group, Metropolitan (NC B ancorp, Inc.), Chicago, I L MidSouth B ancorp, Inc., L afayette, LA A tlanta, G Company, Midtown B ank & Trust I A Inc., Iowa City, Financial Group, MidWestOne CO Millennium B ancorp, Inc., E dwards, Monument B ank, ethesda, MD Mercantile B ank Corporation, Grand Rapids, MI Mercantile Institution ank & Trust Company, Vero B each, F L Vero Company, Marine B ank & Trust Market B ancorporation, Inc., New Market, MN I L Inc., Mt. Vernon, B ancshares, Market Street M B Financial Inc., Chicago, I L UT Medallion B ank, Salt L ake City, B ank Corporation, and Manufacturers Merchants Joliet, I L Inc., Toone, and Planters B ancshares, Merchants TN Meridian B ank, Devon, P Meridian B ank, Devon, P City B ank, Doraville, G A Metro Inc., Houston, TX B ancshares, MetroCorp Inc., Chicago, I L B ank Group, Metropolitan Capital B ancorp, Inc., Chicago, I L Metropolitan Capital B ancorp, Inc., Chicago, I L Metropolitan P Mid Penn B ancorp, Inc., Millersburg, V Financial Corporation, Middleburg, Middleburg Park, I L Midwest B anc Holdings, Inc., Melrose Midwest Regional B ancorp, Inc., Festus, MO Mission Community B ancorp, San L uis Obispo, C A C A B ancorp, Sun Valley, Mission Valley NH Monadnock B ancorp, Inc., Peterborough, MI Community B ancorp, Inc., Coldwater, Monarch Financial Holdings, Inc., Chesapeake, V Monarch TN Corporation, L enoir City, Moneytree Inc., Cleveland, G A B ancshares, Mountain Valley Midland States B ancorp, Inc., E ffingham, I L 6/19/2009 1/16/2009 10/28/2008 12/22/2009 2/20/2009 1/23/2009 12/19/2008 11/14/2008 3/27/2009 11/20/2009 2/6/2009 6/26/2009 1/9/2009 2/27/2009 2/6/2009 4/3/2009 1/30/2009 5/15/2009 CPP TRANSACTION DETAIL, AS OF 6/30/2012 CPP TRANSACTION DETAIL, Purchase Date 3/6/2009 2/20/2009 5/15/2009 12/5/2008 2/27/2009 6/19/2009 3/6/2009 2/13/2009 12/11/2009 1/30/2009 1/16/2009 6/26/2009 4/10/2009 11/20/2009 12/19/2008 1/30/2009 12/5/2008 2/13/2009 1/9/2009 12/23/2008 12/19/2008 2/6/2009 12/19/2008 3/13/2009 9/25/2009 1/23/2009 250 Appendix D I Transaction Detail I July 25, 2012 $— $50,311 $93,823 $18,088 Treasury Treasury $387,223 $463,125 $723,874 $356,067 $176,190 $568,199 $349,782 $418,323 $575,430 $272,103 $316,463 $213,889 $536,095 $358,065 $1,494,583 $1,828,122 $2,680,733 $4,326,595 $1,304,167 $2,192,843 $1,430,625 $1,811,250 $1,641,964 $1,097,290 $2,307,492 $1,311,028 $8,968,705 $1,267,292 $1,513,889 $5,769,028 $3,782,991 $1,257,315 $4,035,543 $2,107,397 Dividends/ $16,958,333 $16,694,444 $46,623,333 $48,797,641 Interest Paid to Interest Continued on next page 67,958 15,120 Current Current 399,006 584,084 163,830 815,339 Warrants Warrants 2,567,255 Outstanding $3.49 $1.99 $8.48 $5.21 $9.55 $6.96 $1.96 $4.38 $0.82 $4.54 $5.25 $1.30 $8.00 Stock $30.55 $14.36 $10.50 $12.75 $11.35 $69.75 $46.02 $10.27 $12.01 $45.73 Price as of 6/29/2012 N/ A N/ A $67,000 $600,000 $430,797 $900,194 $737,100 $748,000 $500,000 $560,000 $580,000 $386,000 $100,000 $225,000 $305,000 Proceeds $1,000,000 $2,842,400 $1,200,000 $87,000,000 Final Disposition 15 R R R R R R R R R R R R R R R R R Note Final Disposition Date 1/11/2012 2/3/2010 4/13/2011 5/2/2012 9/28/2011 2/15/2012 9/1/2011 9/15/2011 9/28/2011 7/28/2011 10/19/2011 12/29/2010 3/28/2012 N/ A 9/2/2009 5/8/2009 10/5/2011 8/26/2009 N/ A $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— Remaining Capital Amount 6 $— $7,723,000 $2,000,000 $1,341,000 $1,230,000 $7,000,000 $6,100,000 $10,200,000 $38,263,000 $32,382,000 $10,000,000 $14,964,000 $10,000,000 $13,500,000 $11,600,000 $150,000,000 $100,000,000 $100,000,000 Amount (Loss) $1,576,000,000 Capital Repayment 12/14/2011 12/30/2009 3/16/2011 4/25/2012 Capital Repayment Date 8/25/2011 8/25/2011 9/1/2011 9/15/2011 8/11/2011 7/28/2011 10/19/2011 12/29/2010 3/28/2012 3/28/2012 6/17/2009 7/15/2009 3/31/2009 10/5/2011 2/11/2010 $6,500,000 $4,227,000 $7,723,000 $4,000,000 $2,000,000 $2,330,000 $1,341,000 $1,230,000 $1,992,000 $7,700,000 $2,080,000 $7,000,000 $2,816,000 $5,500,000 $3,216,000 $6,100,000 $4,120,000 $4,060,000 $10,200,000 $38,263,000 $16,288,000 $17,211,000 $73,000,000 $32,382,000 $24,664,000 $10,000,000 $10,000,000 $14,964,000 $10,000,000 $10,500,000 $13,500,000 $17,300,000 $12,063,000 $16,200,000 $11,600,000 $23,200,000 $52,372,000 $150,000,000 $100,000,000 $267,274,000 $100,000,000 $195,045,000 $1,576,000,000 Investment Amount (C ontinu e d ) Preferred Stock w/ Warrants Stock w/ Warrants Preferred Preferred Stock w/ Warrants Stock w/ Warrants Preferred Preferred Stock w/ Warrants Stock w/ Warrants Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred Preferred Stock w/ Warrants Stock w/ Warrants Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred Investment Description Warrants Stock w/ E xercised Preferred Stock w/ Warrants Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Debentures Subordinated Warrants w/ E xercised Warrants Stock w/ E xercised Preferred Debentures Subordinated Warrants w/ E xercised Stock w/ Warrants Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Stock Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Stock w/ Warrants Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Debentures Subordinated Warrants w/ E xercised Stock Preferred Warrants Stock w/ E xercised Preferred w/ E xercised Debentures Subordinated Warrants Common Stock w/ Warrants Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Preferred Stock w/ Warrants Stock w/ Warrants Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred 2 2 A 2 8 29 8,10 2 2 8 2,49 2 8 2 50 2,49 2 50 2 2 2,10a 2 2 2 2,56 2,3 2,50 2,19 2 49 MS Financial, Inc., Kingwood, TX Pacific International B ancorp, Seattle, W A Park B ancorporation, Inc., Madison, WI Northeast B ancorp, L ewiston, M E NJ Northern State B ank, Closter, Ojai Community B ank, Ojai, C A Naples B ancorp, Inc., Naples, F L Point, N E Inc., West Nationwide B ankshares, Corporation, Private B ank & Trust New York NY New York, Inc., FortNorth Dodge, I A Central B ancshares, Northwest B ancorporation, Inc., Spokane, W A NJ River, OceanFirst Financial Corp., Toms Pacific Coast National B ancorp, San Clemente, C A Parke B ancorp, Inc., Sewell, NJ MutualFirst Financial, Inc., Muncie, IN Inc., B oyertown, P National Penn B ancshares, Inc., Madison, MO N E MO B ancshares WI B ay, Inc., Green Nicolet B ankshares, Northern States Financial Corporation, I L Waukegan, Northway Financial, Inc., B erlin, NH B ancorp, Oakdale, C A Oak Valley I L Old Second B ancorp, Inc., A urora, Omega Capital Corp., L akewood, CO OneUnited B ank, oston, M A Pacific Capital B ancorp, Santa arbara, C A Park National Corporation, Newark, OH Institution ancshares, Inc., B ettendorf, I A National B ancshares, NC AL B ancorp, L os A ngeles, C Inc., Thrift B ancshares, New Hampshire Newport, NH NC New B ridge ancorp, Greensboro, NJ Northern State B ank, Closter, Corporation, Chicago, I L Northern Trust B ank, L akewood, W A Northwest Commercial Oak Ridge Financial Services, Inc., Ridge, NC Inc., B owie, MD Old L ine B ancshares, Old National B ancorp, E vansville, IN B ank, A tlanta, G One Georgia OneFinancial Corporation , L ittle Rock, A R B ancorp, Inc., Salem, OR Oregon OS B Financial Services, Inc., Orange, TX Pacific City Financial Corporation, L os A ngeles, C Pacific Coast B ankers’ ancshares, San Francisco, C A Pacific Commerce B ank, L os A ngeles, C Pacific Commerce 3/27/2009 12/12/2008 3/6/2009 12/12/2008 5/15/2009 1/30/2009 3/27/2009 12/11/2009 1/9/2009 1/9/2009 2/13/2009 1/16/2009 1/16/2009 1/30/2009 12/23/2008 12/12/2008 6/19/2009 12/23/2008 2/20/2009 1/30/2009 12/5/2008 1/16/2009 4/17/2009 12/19/2008 11/21/2008 12/23/2008 CPP TRANSACTION DETAIL, AS OF 6/30/2012 CPP TRANSACTION DETAIL, Purchase Date 2/27/2009 12/19/2008 1/16/2009 12/12/2008 12/18/2009 11/14/2008 2/13/2009 1/30/2009 12/5/2008 12/12/2008 5/8/2009 6/5/2009 4/24/2009 5/1/2009 12/19/2008 12/23/2008 12/23/2008 Transaction detail I Appendix D I July 25, 2012 251 $77,852 $54,500 Treasury Treasury $630,157 $553,313 $377,867 $667,696 $635,844 $670,123 $159,163 $227,917 $207,948 $284,999 $534,286 $622,344 $132,253 $660,215 $467,413 $522,263 $498,860 $421,312 $543,091 $802,802 $4,725,833 $1,008,943 $2,425,250 $2,069,910 $2,704,136 $3,280,740 $1,287,689 $4,252,221 $2,143,811 $2,924,868 $1,046,500 $1,415,219 $2,271,405 $4,783,333 Dividends/ $16,163,194 $13,239,940 $40,127,885 $148,171,528 Interest Paid to Interest Continued on next page 81,670 Current Current 357,234 237,712 628,588 109,039 155,025 178,880 267,455 645,013 330,561 Warrants Warrants 2,093,284 Outstanding $9.75 $0.62 $9.00 $7.95 $3.12 $7.35 $1.45 $1.37 $7.75 $0.20 $0.16 $1.51 Stock $21.98 $15.51 $19.51 $16.61 $14.76 Price as of 6/29/2012 N/ A N/ A $71,000 $225,000 $900,000 $633,000 $188,000 $537,633 $110,000 $498,000 $175,000 $464,000 Proceeds $1,200,724 $4,382,000 Final Disposition 15 R R R R R R R R R R R R Note 8/11/2011 Final Disposition Date 2/15/2012 8/3/2011 4/24/2012 9/27/2011 10/19/2011 2/1/2012 4/4/2012 9/1/2011 8/25/2011 N/ A N/ A 9/15/2011 9/29/2010 $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— Remaining $3,440,000 $18,000,000 $14,341,000 $21,513,000 $71,250,000 Capital Amount 6 $250,000 $4,500,000 $7,172,000 $3,756,000 $6,771,000 $7,172,000 $9,960,000 $1,500,000 $3,000,000 $6,784,000 $4,000,000 $9,270,000 $18,000,000 $21,000,000 $71,250,000 $14,341,000 $18,000,000 $23,033,635 $12,660,000 $87,631,000 $23,750,000 Amount (Loss) Capital Repayment 12/28/2011 2/2/2011 6/20/2012 Capital Repayment Date 3/2/2011 1/11/2012 8/3/2011 6/27/2012 4/24/2012 9/27/2011 10/19/2011 9/1/2011 3/7/2012 1/6/2010 9/1/2011 8/25/2011 8/13/2010 12/28/2011 8/13/2010 9/15/2011 9/29/2010 8/11/2011 $6,000,000 $3,756,000 $6,000,000 $6,771,000 $3,727,000 $3,690,000 $9,960,000 $3,900,000 $1,500,000 $3,000,000 $6,800,000 $4,389,000 $2,500,000 $2,800,000 $6,784,000 $9,500,000 $6,349,000 $4,000,000 $4,960,000 $3,262,000 $4,000,000 $9,266,000 $9,270,000 $4,500,000 $39,000,000 $25,083,000 $26,038,000 $18,000,000 $25,054,000 $12,660,000 $12,325,000 $87,631,000 $10,800,000 $28,685,000 $95,000,000 $11,949,000 $22,252,000 $41,400,000 $35,000,000 $935,000,000 $243,815,000 Investment Amount (C ontinu e d ) Preferred Stock w/ Warrants Stock w/ Warrants Preferred Preferred Stock w/ Warrants Stock w/ Warrants Preferred Stock w/ Warrants Preferred Investment Description Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Stock w/ Warrants Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Stock w/ Warrants Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Stock Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred w/ E xercised Debentures Subordinated Warrants Securities w/ Warrants Preferred Trust Warrants Stock w/ E xercised Preferred Debentures Subordinated Warrants Stock w/ E xercised Preferred Debentures Subordinated Warrants w/ E xercised Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Stock Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Preferred Stock w/ Warrants Stock w/ Warrants Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred Preferred Stock w/ Warrants Stock w/ Warrants Preferred 2 2 2 2,10a 2 2,10,50 2 2,83 2 2,49 A 49 2 2 2,49 2,51 2,30 2 8 2,10,49 3,8,30 8,10 2,10 2,49 3,30 2,62 2 12 ynden, W A 2 2,13 93 Pascack B ancorp, Inc.(Pascack Community ank), NJ Westwood, ancorp of North Carolina, Inc., Peoples B ancorp of North Carolina, Newton, NC Penn L ibertyP Financial Corp., Wayne, Peoples B ancorp Inc., Marietta, OH of TN, Inc, Madisonville, TN Peoples B ancshares Plains Capital Corporation, Dallas, TX ancshares, Inc, Patterson, LA Patterson B ancshares, Peninsula B ank Holding Co., Palo A lto, C Peoples B ancorp, L SC Peoples B ancorporation, Inc., E asley, PFS B ancorporation, Inc., Pigeon Falls, WI Plato Holdings Inc., Saint Paul, MN Financial Corp, Dubuque, I A Premier B ank, San Francisco, C A Presidio Princeton National B ancorp, Inc., Princeton, I L Private B ancorporation, Inc., Minneapolis, MN Institution Patapsco B ancorp, Inc., Dundalk, MD Pathfinder B ancorp, Inc., Oswego, NY N E Pathway B ancorp, Cairo, Inc., Houston, TX Patriot B ancshares, Peapack-Gladstone Financial Corporation, Gladstone, NJ Inc., Colquitt, G A PeoplesSouth B ancshares, PG B Holdings, Inc., Chicago, I L W A County B ancorp, Tacoma, Pierce Inc., Pinnacle B ank Holding Company, F L Orange City, Pinnacle Financial Partners, Inc., Nashville, TN C A Plumas B ancorp, Quincy, Inc., San Juan, PR Popular, B ancorp, Inc., Wilmette, I L Premier F L Tallahassee, B ank Holding Company, Premier Financial B ancorp, Inc., Huntington, WV Premier Service B ank, Riverside, C A Premier OR B ancorp, Medford, PremierWest Private B ancorporation, Inc., Minneapolis, MN Private B ancorp, Inc., Chicago, I L B ank, Rocky Mount, NC Providence Inc., Community B ancshares, Provident Rock Hill, SC LA PS B Financial Corporation, Many, Puget Sound B ank, ellevue, W A Porter B ancorp Inc., L ouisville, KY Inc., Olathe, KS Prairie Star B ancshares, 2/6/2009 12/23/2008 4/17/2009 1/30/2009 3/20/2009 12/19/2008 4/17/2009 1/30/2009 2/13/2009 4/24/2009 9/11/2009 7/17/2009 5/22/2009 11/20/2009 1/23/2009 2/27/2009 CPP TRANSACTION DETAIL, AS OF 6/30/2012 CPP TRANSACTION DETAIL, Purchase Date 12/19/2008 9/11/2009 3/27/2009 12/19/2008 1/9/2009 3/6/2009 2/6/2009 1/23/2009 3/6/2009 12/12/2008 1/30/2009 12/5/2008 5/8/2009 3/20/2009 10/2/2009 2/20/2009 2/13/2009 12/29/2009 1/30/2009 10/2/2009 3/13/2009 2/27/2009 1/16/2009 11/21/2008 4/3/2009 252 Appendix D I Transaction Detail I July 25, 2012 $— Treasury Treasury $127,686 $608,163 $893,934 $520,626 $425,811 $784,282 $347,328 $266,142 $277,224 $195,637 $276,870 $738,021 $358,971 $158,928 $331,111 $517,145 $263,780 $381,942 $795,018 $996,698 $333,333 $209,588 $347,164 $560,656 $933,494 $4,949,567 $1,513,339 $7,593,868 $8,585,770 $1,153,111 $1,763,680 $5,418,481 $3,827,111 $3,728,275 $1,079,960 $1,115,639 $1,600,000 $1,414,005 $3,781,869 $1,816,667 Dividends/ $15,712,738 $16,386,111 $593,055,555 Interest Paid to Interest Continued on next page Current Current 778,421 517,012 137,966 556,976 172,970 Warrants Warrants 1,104,370 Outstanding $1.49 $8.50 $7.41 $7.00 $6.75 $0.70 $1.81 $0.66 $5.26 $0.34 $4.25 $9.65 $8.50 $3.12 $5.98 $4.30 $4.00 Stock $13.10 $18.00 $11.60 $15.64 $18.47 $24.65 $35.25 $60.97 Price as of 6/29/2012 N/ A $55,000 $90,000 $25,000 $85,000 $381,000 $522,000 $625,000 $275,000 $190,000 $150,000 $133,000 $205,000 $200,000 $290,000 $341,000 $400,000 Proceeds $1,100,000 $4,450,000 $1,400,000 $45,000,000 $11,150,940 Final Disposition 15 A R R R R R R R R R R R R R R R R R R R R Note Final Disposition Date 2/23/2011 6/24/2009 11/16/2011 1/27/2012 5/30/2012 9/29/2010 9/22/2011 7/21/2011 8/18/2011 7/21/2011 11/2/2011 N/ A 8/11/2011 6/24/2009 9/1/2011 7/14/2011 9/15/2011 11/16/2011 12/15/2010 3/10/2010 9/30/2010 5/2/2012 $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— Remaining $4,500,000 $41,547,000 Capital Amount 6 $7,414,000 $3,800,000 $2,995,000 $2,655,000 $8,816,000 $2,800,000 $4,000,000 $1,800,000 $5,803,000 $6,815,000 $1,700,000 $41,547,000 $41,547,000 $25,000,000 $28,460,338 $38,237,000 $12,700,000 $10,500,000 $40,404,700 $17,388,000 $18,000,000 $12,500,000 $64,779,000 $108,676,000 $120,000,000 $130,179,219 Amount (Loss) $3,500,000,000 Capital Repayment 12/15/2010 7/21/2010 4/15/2009 5/20/2009 Capital Repayment Date 6/27/2012 9/15/2011 1/27/2012 6/6/2012 3/28/2012 9/29/2010 9/29/2010 9/22/2011 7/21/2011 8/18/2011 7/21/2011 4/4/2012 12/7/2011 8/25/2011 10/21/2011 8/11/2011 5/20/2009 9/1/2011 7/14/2011 9/15/2011 12/15/2010 3/31/2009 9/30/2010 $7,414,000 $6,229,000 $8,900,000 $3,800,000 $2,995,000 $9,982,000 $2,655,000 $1,500,000 $5,983,000 $1,100,000 $1,549,000 $8,816,000 $2,900,000 $4,000,000 $4,000,000 $1,800,000 $2,152,000 $5,803,000 $6,815,000 $1,700,000 $8,653,000 $3,070,000 $83,094,000 $23,393,000 $25,000,000 $32,538,000 $38,237,000 $12,700,000 $40,000,000 $10,900,000 $15,000,000 $25,000,000 $30,407,000 $50,000,000 $17,388,000 $18,000,000 $12,500,000 $10,750,000 $12,900,000 $64,779,000 $108,676,000 $120,000,000 $347,000,000 $3,500,000,000 Investment Amount (C ontinu e d ) Preferred Stock w/ Warrants Stock w/ Warrants Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred Investment Description Stock w/ Warrants Preferred Stock w/ Warrants Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Debentures Subordinated Warrants w/ E xercised Debentures Subordinated Warrants w/ E xercised Warrants Stock w/ E xercised Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred Warrants Stock w/ E xercised Preferred Stock w/ Warrants Preferred Warrants Stock w/ E xercised Preferred Stock w/ Warrants Preferred Warrants Stock w/ E xercised Preferred Stock w/ Warrants Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Stock w/ Warrants Preferred Warrants Stock w/ E xercised Preferred Debentures Subordinated Warrants w/ E xercised Debentures Subordinated Warrants w/ E xercised Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Stock w/ Warrants Preferred Warrants Stock w/ E xercised Preferred Preferred Stock w/ Warrants Stock w/ Warrants Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred 2 2 2 2,49 2 8 2 2,10,30 2,49 2,49 2,49 8 26 2,49 2 2,10,69 2 2 2,49 96 30 2 2,49 8 64 2,25 2,10 49 2 2,49 2 49 A 2 8 A 77 Pulaski Financial Corp, Creve Coeur, MO Coeur, Pulaski Financial Corp, Creve sheboro, NC A sheboro, Company, Randolph B ank & Trust Inc., Hartsville, SC Regional B ankshares, B ank, N. A ., Santa Paula, C Santa Clara Valley B ank, Chula Vista, C A Seacoast Commerce Security Federal Corporation, A iken, SC Security State B ank Holding-Company, Jamestown, ND QCR Holdings, Inc., Moline, I L MO Inc., Frontenac, Reliance B ancshares, WI Ridgestone Financial Services, Inc., B rookfield, Inc., L ittle Rock, A R Riverside B ancshares, C A Saigon National B ank, Westminster, Salisbury B ancorp, Inc., L akeville, CT MD Sandy Spring B ancorp, Inc., Olney, Seacoast B anking Corporation of Florida, Stuart, F L Inc., Charleston, MO Security State B ancshares, Severn B ancorp, Inc., A nnapolis, MD Inc., E aston, MD B ancshares, Shore NJ Somerset Hills B ancorp, ernardsville, B ancorp, Sonoma, C A Sonoma Valley Inc., Fayetteville, G A Financial Group, SouthCrest Institution RC B Financial Corporation, Rome, G A C A Redwood Capital B ancorp, E ureka, Redwood Financial Inc., Falls, MN Regent B ancorp, Inc., Davie, F L Regent Capital Corporation, Nowata, OK W A Inc., Vancouver, Regents B ancshares, Regions Financial Corporation, B irmingham, AL Rising Sun B ancorp, Sun, MD WI B ancorporation, Inc., Wausau, River Valley Inc., L ittle Rock, A R Rogers B ancshares, of Pennsylvania, Inc., Royal B ancshares Narberth, P S&T B ancorp, Indiana, P C A Santa L ucia B ancorp, A tascadero, CT S B T ancorp, Inc., Simsbury, SC B T Financial Corporation, Columbia, Inc., of Pulaski County, Security B ancshares MO Waynesville, Security B usiness ancorp, San Diego, C A Security California B ancorp, Riverside, C A Security Capital Corporation, B atesville, MS Inc., Dallas, TX B ancshares, Signature NY B ank, New York, Signature NC City, Morehead Sound B anking Company, SC Inc., Greenville, South Financial Group, 1/16/2009 10/30/2009 2/13/2009 2/13/2009 12/23/2008 12/19/2008 5/1/2009 2/13/2009 2/13/2009 2/27/2009 5/15/2009 12/23/2008 3/13/2009 12/5/2008 12/19/2008 2/20/2009 11/21/2008 1/9/2009 1/16/2009 2/20/2009 7/17/2009 CPP TRANSACTION DETAIL, AS OF 6/30/2012 CPP TRANSACTION DETAIL, Purchase Date 6/19/2009 1/16/2009 1/9/2009 3/6/2009 2/27/2009 10/23/2009 11/14/2008 1/9/2009 6/12/2009 1/30/2009 2/20/2009 1/16/2009 12/19/2008 3/27/2009 1/16/2009 2/13/2009 1/9/2009 1/9/2009 6/26/2009 6/26/2009 12/12/2008 1/9/2009 12/5/2008 Transaction detail I Appendix D I July 25, 2012 253 Treasury Treasury $613,111 $705,472 $364,796 $518,658 $634,609 $214,972 $521,383 $253,122 $855,556 $4,923,333 $2,486,571 $4,271,875 $2,506,669 $1,728,673 $1,293,055 $1,755,554 $1,103,971 $2,693,234 $2,782,256 $1,254,764 $8,555,556 $2,261,750 $6,730,750 $5,508,472 $5,350,442 $2,083,520 $1,115,625 $1,599,381 $6,733,333 $4,983,333 $1,330,709 $4,156,250 Dividends/ $23,722,222 $12,109,028 $18,751,438 $63,611,111 $567,986,111 $164,806,753 Interest Paid to Interest Continued on next page 97,541 Current Current 302,623 399,970 114,326 703,753 Warrants Warrants 1,462,647 1,923,792 1,623,418 15,510,737 Outstanding $9.98 $1.98 $4.60 $2.68 $8.50 $1.75 $9.41 $5.75 $9.00 $0.04 $3.16 Stock $12.48 $24.23 $21.50 $10.28 $58.72 $16.39 $18.89 $44.64 Price as of 6/29/2012 N/ A $945,775 $911,000 $331,000 $107,398 $778,000 $682,000 $243,000 $250,000 $315,000 $100,000 $200,000 $292,000 $750,000 Proceeds $2,857,915 $2,500,000 $1,245,000 $2,100,000 $5,269,179 $6,820,000 $15,996,899 $14,069,763 $60,000,000 Final Disposition 15 A A A R R R R R R R R R R R R R R R R R R R Note Final Disposition Date 6/9/2010 5/18/2011 9/22/2011 9/22/2011 5/27/2009 9/22/2011 6/29/2011 1/18/2012 9/1/2011 10/26/2011 3/16/2011 9/15/2011 9/8/2011 8/25/2011 9/14/2011 12/29/2010 1/19/2011 8/31/2011 6/16/2010 9/8/2011 7/8/2009 9/29/2010 N/ A $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— Remaining $22,500,000 $37,500,000 $11,568,000 $100,000,000 Capital Amount 6 $7,500,000 $4,000,000 $4,862,000 $5,000,000 $9,550,000 $8,500,000 $2,000,000 $4,000,000 $9,720,000 125,198,000 $42,000,000 $22,500,000 $11,568,000 $89,310,000 $15,403,722 $18,215,000 $12,500,000 $37,500,000 $24,900,000 $11,019,000 $10,000,000 $13,644,000 $92,254,460 $15,000,000 $11,000,000 $100,000,000 $200,000,000 $235,000,000 Amount (Loss) $1,350,000,000 $3,500,000,000 $2,000,000,000 Capital Repayment 5/5/2009 4/27/2011 3/30/2011 12/28/2011 4/13/2011 3/30/2011 3/16/2011 4/8/2009 12/22/2010 Capital Repayment Date 6/27/2012 9/22/2011 8/12/2009 6/29/2011 1/18/2012 9/1/2011 9/1/2011 1/14/2011 9/15/2011 9/8/2011 8/25/2011 7/21/2011 8/4/2011 12/29/2010 4/21/2010 8/31/2011 12/23/2009 6/13/2012 9/8/2011 6/17/2009 9/29/2010 8/6/2010 $4,862,000 $5,000,000 $9,550,000 $2,760,000 $3,000,000 $8,500,000 $2,000,000 $4,000,000 $8,000,000 $9,720,000 $42,000,000 $30,000,000 $89,310,000 $17,299,000 $18,215,000 $30,000,000 $60,000,000 $50,000,000 $24,900,000 $11,019,000 $10,000,000 $15,568,000 $10,973,000 $15,000,000 $13,644,000 $70,000,000 $69,000,000 $15,000,000 $11,000,000 $42,750,000 $125,198,000 $967,870,000 $303,000,000 $300,000,000 $235,000,000 $104,823,000 $1,350,000,000 $3,500,000,000 $2,000,000,000 Investment Amount (C ontinu e d ) Preferred Stock w/ Warrants Stock w/ Warrants Preferred Preferred Stock w/ Warrants Stock w/ Warrants Preferred Stock w/ Warrants Preferred Preferred Stock w/ Warrants Stock w/ Warrants Preferred Stock w/ Warrants Preferred Preferred Stock w/ Warrants Stock w/ Warrants Preferred Preferred Stock w/ Warrants Stock w/ Warrants Preferred Investment Description Stock w/ Warrants Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Stock w/ Warrants Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Debentures Subordinated Warrants w/ E xercised Debentures Subordinated Warrants w/ E xercised Common Stock w/ Warrants Stock w/ Warrants Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Debentures Subordinated Warrants w/ E xercised Stock w/ Warrants Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Debentures Subordinated Warrants w/ E xercised Warrants Stock w/ E xercised Preferred Stock w/ Warrants Preferred Debentures Subordinated Warrants w/ E xercised Preferred Stock w/ Warrants Stock w/ Warrants Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred Trust Preferred Securities w/ Warrants Preferred Trust Preferred Stock w/ Warrants Stock w/ Warrants Preferred xercised Warrants Warrants Stock w/ E xercised Preferred Preferred Stock Preferred Stock w/ Warrants Preferred 2 49 98 8 2

A 24 8,10,50 8 2 2

2,30 8,49 2 A 2,49 3,30 17,54 A 2,49 49 86 2 2 8,10,50 2 2 2 49 2,50 Southern B ancorp, Inc., A rkadelphia, R ancshares, Inc., Houston, TX Sterling B ancshares, Sterling Financial Corporation, Spokane, W A Superior B ancorp Inc., irmingham, AL ancorp, New York, NY Sterling B ancorp, New York, B anks, Inc., A tlanta, G SunTrust Syringa B ancorp, oise, ID ristow, OK Spirit B ankCorp, Inc., ristow, StellarOne Corporation, Charlottesville, V SD Stockmens Financial Corporation, Rapid City, P Chester, Stonebridge Financial Corp., West B anks, Inc., A tlanta, G SunTrust Synovus Financial Corp., Columbus, G A SV Financial, Inc., Sterling, I L ancshares, Inc., Southern Heritage B ancshares, Cleveland, TN Inc., Sylacauga, AL SouthFirst B ancshares, Inc., Dallas, TX B ancshares, Sovereign Inc., St. L ouis, MO St. Johns B ancshares, ND Inc., Fargo, State B ankshares, MS State Capital Corporation, Greenwood, CO B ank Corporation, Denver, Steele Street Summit State B ank, Santa Rosa, C A Sun B ancorp, Inc., Vineland, NJ Financial Corporation , Horicon, WI Sword SC TC B Corporation, Greenwood, Institution Southern Illinois B ancorp, Inc., Carmi, I L Southern Missouri B ancorp, Inc., Poplar luff, MO OK Southwest B ancorp, Inc., Stillwater, Inc., Hickory Hills, I L B ancshares, Standard Financial Corporation, Stewardship Midland Park, NJ Suburban Illinois B ancorp, Inc., E lmhurst, I L Inc, L ititz, P Susquehanna B ancshares, Santa Clara, C A SV B Financial Group, Rosemont, I L Capital Group, Taylor iry, NC B ancorp, Mount A iry, Surrey Stearns Financial Services, Inc., St. Cloud, MN State Street Corporation, B oston, M A State Street ancshares, Inc., Greenville, SC Inc., Greenville, Southern First B ancshares, Southern Community Financial Corp., Winston-Salem, NC 1/16/2009 12/12/2008 12/5/2008 12/5/2008 12/23/2008 12/31/2008 1/16/2009 3/27/2009 12/19/2008 2/6/2009 1/23/2009 11/14/2008 12/19/2008 4/10/2009 5/15/2009 6/12/2009 3/13/2009 3/13/2009 1/16/2009 2/13/2009 9/25/2009 12/19/2008 1/9/2009 5/8/2009 8/28/2009 CPP TRANSACTION DETAIL, AS OF 6/30/2012 CPP TRANSACTION DETAIL, Purchase Date 1/23/2009 12/5/2008 12/5/2008 4/24/2009 1/30/2009 6/19/2009 12/12/2008 12/12/2008 11/21/2008 1/9/2009 6/26/2009 10/28/2008 2/27/2009 12/5/2008 254 Appendix D I Transaction Detail I July 25, 2012 $53,710 Treasury Treasury $690,832 $284,611 $146,242 $295,308 $169,834 $662,083 $411,806 $751,752 $882,900 $282,299 $215,183 $223,208 $346,491 $713,950 $501,325 $190,215 $977,440 $192,415 $1,195,973 $2,813,689 $3,734,375 $1,830,292 $1,284,722 $2,336,116 $7,925,719 $3,233,333 $1,218,750 $2,234,500 $3,940,694 $3,766,127 $1,219,575 $1,952,236 $6,107,966 $4,036,268 $1,387,480 $1,024,491 Dividends/ $95,416,667 $10,619,167 $421,066,667 $318,055,555 Interest Paid to Interest Continued on next page 54,705 Current Current 571,821 225,904 461,538 274,784 116,538 554,330 Warrants Warrants 3,098,341 Outstanding $9.43 $4.00 $8.40 $5.05 $0.25 Stock $21.95 $17.00 $10.83 $11.48 $40.39 $26.64 $19.28 $61.11 $14.00 $95.86 Price as of 6/29/2012 N/ A N/ A $27,000 $40,000 $51,000 $34,000 $750,000 $777,000 $100,000 $199,000 $792,783 $273,000 $106,000 $185,000 Proceeds $1,000,000 $4,753,985 $9,449,981 $6,559,066 $136,000,000 $320,277,984 $1,100,000,000 Final Disposition 15 A A A R R R R R R R R R R R R R R R R Note Final Disposition Date 9/8/2010 8/25/2011 8/5/2009 8/18/2011 9/22/2011 9/30/2010 9/22/2011 12/15/2009 8/3/2011 3/11/2010 5/19/2010 N/ A 4/19/2012 9/1/2011 9/22/2011 9/22/2011 4/4/2012 9/22/2011 N/ A 7/22/2009 4/29/2010 $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— Remaining $12,500,000 $17,000,000 Capital Amount 6 $541,000 $500,000 $2,000,000 $3,981,000 $1,742,850 $5,448,000 $9,090,000 $5,000,000 $5,450,000 $1,697,000 $1,505,000 $2,117,000 $3,700,000 $2,795,000 $45,220,000 $12,500,000 $20,000,000 $17,000,000 $15,000,000 $12,119,637 $76,458,000 $15,540,000 $75,000,000 $17,000,000 $361,172,000 Amount (Loss) $3,000,000,000 $7,579,200,000 $10,000,000,000 Capital Repayment 3/10/2010 6/17/2009 8/24/2011 Capital Repayment Date 8/25/2011 11/23/2011 8/18/2011 9/22/2011 9/30/2010 9/22/2011 9/22/2011 4/22/2009 8/3/2011 5/13/2009 5/19/2010 12/3/2010 12/22/2010 4/19/2012 8/25/2011 9/29/2010 6/17/2009 9/1/2011 9/22/2011 9/22/2011 4/4/2012 2/15/2011 9/22/2011 8/13/2010 2/10/2010 $301,000 $541,000 $2,000,000 $3,000,000 $3,981,000 $4,021,000 $5,448,000 $9,090,000 $5,000,000 $7,500,000 $5,450,000 $1,697,000 $1,505,000 $5,677,000 $3,800,000 $2,117,000 $4,000,000 $3,268,000 $3,700,000 $2,795,000 $2,765,000 $4,237,000 $14,448,000 $45,220,000 $25,000,000 $11,730,000 $30,000,000 $20,000,000 $20,749,000 $15,000,000 $12,000,000 $37,000,000 $76,458,000 $15,540,000 $35,539,000 $23,000,000 $75,000,000 $34,000,000 $16,641,000 $361,172,000 $3,000,000,000 $7,579,200,000 $10,000,000,000 Investment Amount (C ontinu e d ) Preferred Stock w/ Warrants Stock w/ Warrants Preferred Preferred Stock w/ Warrants Stock w/ Warrants Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred Investment Description Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Stock w/ Warrants Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Debentures Subordinated Warrants w/ E xercised Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Stock w/ Warrants Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Stock w/ Warrants Preferred Warrants Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Stock Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Stock Preferred Preferred Stock w/ Warrants Stock w/ Warrants Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred Preferred Stock w/ Warrants Stock w/ Warrants Preferred 70 2 2,49 2,49 2 2 2 A 30 2 2 49 2,3,30 2 2,13,49 2,49 8,10,49 A 2 2,36 2 2,52 2,34 2,13 2,49 2 2,49 2 2,10a 32 50 A 2 2 A 81 2,10a,49 A Holding Company, Texas Community B ank, Texas TC B Holding Company, TX The Woodlands, anking Company, Tifton, G A Tifton B anking Company, The B ank of Currituck, Moyock, NC The B araboo ancorporation, araboo, WI MS Inc., Hattiesburg, The First B ancshares, The L ittle B ank, Incorporated, Kinston, NC Inc, Mount Pleasant, SC Tidelands B ancshares, Capital Corporation , L os A lamos, NM Trinity Three Shores B ancorporation, Inc. (Seaside Shores Three Orlando, F L National B ank & Trust), TCN B Financial Corp., Dayton, OH Financial Holdings, Inc., Valley Tennessee Oak Ridge, TN National B ancorporation, Jacksonville, TX Texas The B ancorp, Inc., Wilmington, D E Mellon Corporation, The B ank of New York NY New York, Company, The Connecticut B ank and Trust CT Hartford, The First B ancorp, Inc., Damariscotta, M E The Private B ank of California, L os A ngeles, C Inc, Titonka, I A Titonka B ancshares, Oak B ancorp, Inc., A ustin, TX Treaty B ank of Memphis, TN Tri-State B ank, Kingsport, TN TriSummit Institution MO B ancorp, Inc., Frontenac, Triad TCF Financial Corporation, Wayzata, MN TCF Financial Corporation, Wayzata, B ancorp, Inc., Franklin, TN Commerce Tennessee Inc., Dallas, TX Capital B ancshares, Texas TX The A N B Corporation, Terrell, The B ank of Kentucky Financial Corporation, Hills, KY Crestview The E lmira Savings B ank, FS , lmira, NY KS State B ank, Harper, The Freeport NY Inc., New York, The Goldman Sachs Group, Inc., The PNC Financial Services Group P Pittsburgh, L ouisville, G A Company, The Queensborough E N B artley, The State B ank of artley, The Victory B ancorp, Inc. (The Victory B ank), L imerick, P The Victory B ancorp, Inc., L imerick, P TI B Financial Corp, Naples, F L Timberland B ancorp, Inc., Hoquiam, W A Inc., Hopkinsville, KY B ancshares, Todd B ank, Portsmouth, V Towne Financial Corporation, Waldorf, MD Tri-County P Capital Holdings, Inc., Pittsburgh, TriState B ank, Kingsport, TN TriSummit andrum Company, Columbia, MO The L andrum Company, 1/16/2009 4/17/2009 2/6/2009 1/16/2009 2/6/2009 12/23/2008 12/19/2008 3/27/2009 1/23/2009 12/23/2008 12/23/2008 1/9/2009 12/12/2008 10/28/2008 12/19/2008 1/9/2009 2/20/2009 4/3/2009 1/16/2009 4/3/2009 4/3/2009 CPP TRANSACTION DETAIL, AS OF 6/30/2012 CPP TRANSACTION DETAIL, Purchase Date 3/27/2009 11/14/2008 12/19/2008 1/16/2009 8/7/2009 2/13/2009 12/19/2008 2/6/2009 10/28/2008 12/31/2008 1/9/2009 9/4/2009 12/11/2009 2/27/2009 12/5/2008 12/23/2008 2/6/2009 12/12/2008 12/19/2008 2/27/2009 12/22/2009 5/22/2009 Transaction detail I Appendix D I July 25, 2012 255 $— Treasury Treasury $745,312 $680,292 $272,969 $872,639 $708,964 $432,678 $629,476 $124,775 $353,796 $725,020 $250,019 $5,361,111 $2,623,344 $1,023,611 $1,475,133 $2,695,972 $5,572,353 $1,234,912 $5,239,859 $3,527,704 $3,600,991 $3,556,217 $1,022,886 $1,849,972 $1,318,401 $2,781,430 $1,318,232 $1,544,026 $1,608,159 $4,256,944 $7,509,920 Dividends/ $11,287,500 $12,979,167 $31,018,750 $12,158,750 $13,475,555 $15,736,874 $195,220,417 Interest Paid to Interest Continued on next page Current Current 488,847 311,492 108,264 219,908 344,742 499,029 Warrants Warrants 2,696,203 7,847,732 Outstanding $9.01 $8.57 $6.00 $4.50 $3.95 $1.70 $1.25 $8.43 Stock $24.48 $16.89 $13.90 $32.16 $15.10 $10.60 $14.45 $16.94 $11.00 $13.16 $11.62 Price as of 6/29/2012 N/ A N/ A N/ A $65,000 $568,700 $600,000 $450,000 $450,000 $160,000 $283,000 $385,000 $150,000 Proceeds $1,625,000 $5,421,615 $5,500,000 $4,500,000 $10,000,000 $15,388,874 $139,000,000 Final Disposition 15 A A R R R R R R R R R R R R R R Note 12/30/2009 3/9/2010 3/2/2011 12/16/2009 Final Disposition Date 7/15/2009 9/1/2011 N/ A 12/23/2009 N/ A 5/18/2010 8/11/2011 9/22/2011 N/ A 9/15/2011 3/21/2012 9/22/2011 8/25/2011 9/15/2011 3/31/2010 $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— $— Remaining $9,000,000 $2,658,000 $225,000,000 $100,000,000 Capital Amount 6 $2,658,000 $3,000,000 $8,950,000 $3,194,000 $2,997,000 $3,000,000 $7,700,000 $1,300,000 $3,000,000 $26,380,000 $22,000,000 $75,000,000 $12,000,000 $35,595,000 $59,000,000 $16,750,221 $10,300,000 $11,926,000 $36,842,000 $215,000,000 $200,000,000 $125,000,000 $100,000,000 $110,000,000 $214,181,000 Amount (Loss) $6,599,000,000 Capital Repayment 12/9/2009 5/27/2009 1/12/2011 6/17/2009 6/3/2009 9/23/2009 12/23/2009 11/24/2009 Capital Repayment Date 9/1/2011 12/7/2011 11/18/2009 6/13/2012 9/3/2010 9/15/2011 7/30/2010 12/14/2011 4/4/2012 8/11/2011 9/22/2011 9/22/2011 12/15/2010 3/21/2012 9/22/2011 8/25/2011 9/15/2011 2/17/2010 $8,950,000 $3,194,000 $2,997,000 $2,179,000 $8,700,000 $5,658,000 $9,900,000 $2,861,000 $7,700,000 $5,500,000 $1,300,000 $3,000,000 $4,700,000 $1,500,000 $26,380,000 $20,649,000 $71,000,000 $22,000,000 $12,000,000 $50,236,000 $33,900,000 $59,000,000 $20,600,000 $10,300,000 $14,400,000 $11,926,000 $10,000,000 $36,842,000 $12,000,000 $16,019,000 $14,738,000 $25,000,000 $215,000,000 $200,000,000 $300,000,000 $180,000,000 $298,737,000 $110,000,000 $214,181,000 $6,599,000,000 Investment Amount (C ontinu e d ) Preferred Stock w/ Warrants Stock w/ Warrants Preferred Preferred Stock w/ Warrants Stock w/ Warrants Preferred Preferred Stock w/ Warrants Stock w/ Warrants Preferred Preferred Stock w/ Warrants Stock w/ Warrants Preferred Stock w/ Warrants Preferred Preferred Stock w/ Warrants Stock w/ Warrants Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred Investment Description Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Stock w/ Warrants Preferred Warrants Stock w/ E xercised Preferred Stock Preferred Warrants Stock w/ E xercised Preferred Stock Preferred Stock w/ Warrants Preferred Warrants Stock w/ E xercised Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred Debentures Subordinated Warrants w/ E xercised Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Debentures Subordinated Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Stock w/ Warrants Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Preferred Stock w/ Warrants Stock w/ Warrants Preferred Stock w/ Warrants Preferred Preferred Stock w/ Warrants Stock w/ Warrants Preferred Preferred Stock w/ Warrants Stock w/ Warrants Preferred 2,10 2,10 68 18 18 3,8,30 2,10 2,50 A A A 2,50 2,10a,49 2,49 8 2,40 A A 14 2 2 2 2 2,49 A 91 2 2 2 2 A 2,49 30 2,49 A Two Rivers Financial Group, B urlington, I A Rivers Financial Group, Two Trustmark Corporation, Jackson, MS Trustmark Washington Federal, Inc., Seattle, W A Washington anking Company, Oak Harbor, W A Oak Harbor, B anking Company, Washington U.S. Century B ank, Miami, F L Veritex Holdings, Inc. Veritex Company), Dallas, TX (Fidelity Resources U.S. B ancorp, Minneapolis, MN United A merican B ank, San Mateo, C NJ National B ancorp, Wayne, Valley UC B H Holdings, Inc., San Francisco, C A NM Union Financial Corporation, A lbuquerque, Corporation (Union Union First Market B ankshares V Corporation), B owling Green, B ankshares United B ancorporation of A labama, Inc., AL A tmore, United Community B anks, Inc., lairsville, G A United Financial B anking Companies, Inc., Vienna, V Unity B ancorp, Inc., Clinton, NJ Universal B ancorp, loomfield, IN C A Grove, B ank, Garden US Metro B ancorp, Visalia, C A Commerce Valley Community B ank, Pleasanton, C A Valley L td., 1st State B ank, Financial Group, Valley MI Saginaw, B ancorp, A rlington, V Commerce Virginia Company B ank, Newport News, V Virginia B oston, M A Company, B ank & Trust Wainwright Institution ancshares, Inc., Marysville, KS U B T ancshares, NC Oxford, Company, Union B ank & Trust NC Oxford, Company, Union B ank & Trust Corporation Union First Market B ankshares V (First Market B ank, FS ), owling Green, MI United B ancorp, Inc., Tecumseh, United B ank Corporation, arnesville, G A University Financial Corp, Inc., St. Paul, MN Uwharrie Capital Corp, A lbemarle, NC Financial Corporation, Roanoke, V Valley National B ancorp (State ancorp, Inc.) Valley Financial Corp, Village B ank and Trust Midlothian, V TX Richardson, Vision B ank - Texas, VIST Financial Corp., Wyomissing, P B . Financial Corporation, Spokane, W A W.T. Financial Services, Inc., Clinton, M A Wachusett Umpqua Holdings Corp., Portland, OR 5/29/2009 11/21/2008 11/14/2008 1/16/2009 8/7/2009 6/26/2009 11/14/2008 2/20/2009 11/14/2008 11/14/2008 12/29/2009 12/19/2008 12/23/2008 12/5/2008 1/16/2009 12/5/2008 5/22/2009 2/6/2009 1/30/2009 1/9/2009 12/18/2009 12/12/2008 6/12/2009 12/19/2008 CPP TRANSACTION DETAIL, AS OF 6/30/2012 CPP TRANSACTION DETAIL, Purchase Date 1/30/2009 5/1/2009 12/18/2009 2/6/2009 1/16/2009 5/22/2009 6/19/2009 12/23/2008 12/12/2008 12/5/2008 5/1/2009 4/24/2009 12/19/2008 1/30/2009 12/11/2009 11/14/2008 256 Appendix D I Transaction Detail I July 25, 2012 Treasury Treasury $855,616 $554,083 $370,600 $590,022 $768,450 $4,495,000 $2,755,981 $2,854,167 $1,510,318 $1,589,583 $8,405,558 $4,782,227 $1,811,199 Dividends/ $25,104,167 $10,282,176 $36,944,444 $19,950,000 $36,833,333 $240,625,000 Interest Paid to Interest $1,440,972,222 Continued on next page Current Current 246,698 175,105 273,534 385,990 Warrants Warrants 5,789,909 Outstanding $9.51 $5.47 $2.65 $9.36 Stock $47.19 $21.26 $33.44 $35.50 $21.66 $40.41 $19.42 $27.00 Price as of 6/29/2012 N/ A $700,000 $878,256 $950,000 $760,000 $332,000 $244,000 $415,000 Proceeds $6,900,000 $25,600,564 $20,388,842 $840,374,892 Final Disposition $7,677,500,194 15 A A A P P R R R R R R Note Final Disposition Date 11/18/2011 8/31/2011 12/23/2009 2/8/2011 5/20/2010 6/20/2012 N/ A 8/4/2011 6/2/2011 11/18/2011 6/3/2011 7/14/2011 Total Warrant Proceeds**** Warrant Total $— $— $— $— $— $— $— $— $— $— $— $— $— Remaining $41,863,000 $200,000,000 $300,000,000 $700,000,000 Capital Amount 6 41,863,000 $6,842,000 $6,633,000 $4,871,000 $41,863,000 $36,000,000 $75,000,000 $57,766,994 $47,435,299 140,000,000 $250,000,000 $100,000,000 $200,000,000 $100,000,000 $300,000,000 $700,000,000 Amount (Loss) $25,000,000,000 $10,889,606,012 ($2,794,703,500) Capital Repayment $191,259,517,808 Total Total Capital Amount ** Repayment 9/2/2009 11/18/2009 6/29/2011 9/9/2009 12/22/2010 12/23/2009 10/13/2010 12/29/2010 Capital Repayment Date 3/28/2012 3/28/2012 8/4/2011 8/4/2011 3/3/2010 9/27/2011 6/3/2011 7/14/2011 3/28/2012 Outstanding Total Losses*** Total $6,842,000 $6,633,000 $5,625,000 $7,290,000 $6,855,000 $4,567,000 $4,700,000 $2,720,000 $4,871,000 $83,726,000 $36,000,000 $75,000,000 $36,000,000 $13,312,000 $16,800,000 $62,158,000 $52,625,000 $250,000,000 $400,000,000 $140,000,000 $300,000,000 $1,400,000,000 Total Treasury CPP Investment Treasury Total $25,000,000,000 Investment Amount $204,943,827,320 (C ontinu e d ) Total Purchase Amount * Purchase Total Preferred Stock w/ Warrants Stock w/ Warrants Preferred Preferred Stock w/ Warrants Stock w/ Warrants Preferred Preferred Stock w/ Warrants Stock w/ Warrants Preferred Preferred Stock w/ Warrants Stock w/ Warrants Preferred Preferred Stock w/ Warrants Stock w/ Warrants Preferred Preferred Stock w/ Warrants Stock w/ Warrants Preferred Stock w/ Warrants Preferred Investment Description Stock Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Stock w/ Warrants Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Stock Preferred Warrants Stock w/ E xercised Preferred Warrants Stock w/ E xercised Preferred Stock w/ Warrants Preferred Stock w/ Warrants Preferred Warrants Stock w/ E xercised Preferred Stock w/ Warrants Preferred Warrants Stock w/ E xercised Preferred Preferred Stock w/ Warrants Stock w/ Warrants Preferred Stock w/ Warrants Preferred 2 2 49 45 2 2,10a 2,13,49 A 2 2,10 76 2,50 A 79 2,10a,49 2 A ankshares, Inc. (WashingtonFirst Inc. (WashingtonFirst B ankshares, WashingtonFirst B ank), Reston, V Westamerica B ancorporation, San Rafael, C A Westamerica NV A lliance B ancorporation, L as Vegas, Western ancorporation, Inc., West Des Moines, I A B ancorporation, Inc., West West B anco, Inc., Wheeling, WV Wes Worthington Financial Holdings, Inc., Huntsville, AL ake Forest, I L Wintrust Financial Corporation, L ake Forest, Wells Fargo & Company, San Francisco, C A & Company, Fargo Wells ankshares, Inc., Reston, V B ankshares, WashingtonFirst Whitney Holding Corporation, New Orleans, LA Financial Corporation, E lkin, NC Valley Yadkin Financial Corporation, E lkin, NC Valley Yadkin P B ank , York, Traditions York Institution ankshares, Inc., Waukesha, WI Inc., Waukesha, B ankshares, Waukesha CT Financial Corporation, Waterbury, Webster Inc., Community B ancshares, Western Palm Desert, C A Inc., Monmouth, I L Illinois B ancshares Western Inc., Monmouth, I L Illinois B ancshares Western Reserve B ancorp, Inc, Medina, OH Western B ancorp, Inc., L os A ngeles, C Wilshire WSFS Financial Corporation UT Zions B ancorporation, Salt L ake City, ancshares Company, Fayetteville, A R Company, White River B ancshares osses include (i) the investment amount for institutions that have completed bankruptcy proceedings (see Notes 16 and 19) and (ii) the investment amount less the amount of final proceeds for institutions where Treasury has completed a sale (see Notes 26, 32, 33, 34, 38, 39, 42, 46, 47, 59, 64, Treasury for institutions where (see Notes 16 and 19) (ii) the investment amount less of final proceeds L osses include (i) the investment amount for institutions that have completed bankruptcy proceedings (see Notes 14, 25, 51, 52, 53, 54, 55, 56, 57, 61, 63, 70, and 71). or bankruptcy proceedings 74, 75, 76, 77, 78, 79), but excludes investment amounts for institutions that have pending receivership Total repaid includes (i) the amount of $25 billion applied as repayment under the Capital Purchase Program from the total proceeds of $31.85 billion received pursuant to the sales of Citigroup, Inc. common stock as of December 6, 2010 (see Note 23 and “Capital Purchase Program - Citigroup - Citigroup Program Inc. common stock as of December 6, 2010 (see Note 23 and “Capital Purchase pursuant to the sales of Citigroup, of $31.85 billion received the total proceeds from Program under the Capital Purchase includes (i) the amount of $25 billion applied as repayment repaid Total by institutions that have completed exchanges for investments under the Community Development Capital Initiative (see Note 30 and “Community Initiative” on following pages). Common Stock Disposition” on following pages) and (ii) the amount of $355,724,000 repaid 10/30/2009 2/13/2009 11/21/2008 12/31/2008 12/5/2008 5/15/2009 12/19/2008 6/30/2012. inception through receipts from cumulative Report . A ll amounts and totals reflect 6/27/2012 Transactions Treasury’s taken verbatim from Data as of 6/30/2012. Numeric notes were Notes: Numbers may not total due to rounding. to in Notes 20, 22, 28 and 29. amount includes the capitalization of accrued dividends referred purchase * Total **  ***  (see Note 30a). included in nine institutions’ exchange into the CDCI program the total amount of warrants that were includes $7,566,000, which represents warrant proceeds **** Total 10/28/2008 1/30/2009 12/19/2008 1/16/2009 7/24/2009 4/24/2009 CPP TRANSACTION DETAIL, AS OF 6/30/2012 CPP TRANSACTION DETAIL, Purchase Date 6/26/2009 11/21/2008 12/23/2008 12/23/2008 12/29/2009 5/15/2009 12/12/2008 1/23/2009 11/14/2008 2/20/2009 Transaction detail I Appendix D I July 25, 2012 257 Continued on next page ynch by B ank of A merica was completed on was deferred pending merger. The purchase of Merrill L The purchase pending merger. ynch & Co., Inc. listed as the qualifying institution and a 10/28/2008 transaction date, footnoted to indicate that settlement was deferred This institution received an additional investment through the expansion of CPP for small banks. an additional investment through This institution received  Reports with Merrill L Transaction This transaction was included in previous 1/1/2009, and this transaction under the CPP was funded on 1/9/2009. warrants as part of its investment in certifiedrequire CDFIs when the size of investment is $50 million or less. does not Treasury community development financial institutions (CDFIs), promote To this institution due to its designation as a CDFI. from cancelled the warrants received Treasury Privately-held qualified financial institution; Treasury received a warrant to purchase additional shares of preferred stock (unless the institution is a CDFI), which it exercised immediately. stock (unless the institution is a CDFI), which it exercised preferred of additional shares received a warrant to purchase Treasury Privately-held qualified financial institution; Repayment pursuant to Title VII, Section 7001(g) of the A merican Recovery and Reinvestment ct 2009. Redemption pursuant to a qualified equity offering. This amount does not include accrued and unpaid dividends, which must be paid at the time of capital repayment. associated with the disposition of this investment do not include accrued and unpaid dividends. The proceeds immediately. (unless the institution is a CDFI), which it exercised debentures additional subordinated a warrant to purchase received Subchapter S corporation; Treasury reduced by half. underlying the warrant was shares Treasury’s the number of original investment, therefore, Treasury’s capital than In its qualified equity offering, this institution raised more merica Corporation that occurred on 10/28/2008 and 1/9/2009. The total net disposition proceeds from CPP warrants on 3/3/2010 was $305,913,040, consisting of $183,547,824 and from on 10/28/2008 and 1/9/2009. The total net disposition proceeds of the CPP investments in B ank A merica Corporation that occurred rata in respect stated pro amount are The warrant disposition proceeds the disposition of TIP warrants on 3/3/2010 appear a following page this report. from $122,365,216. Proceeds This institution participated in the expansion of CPP for small banks. investment in to exchange up $25 billion of Treasury’s with Citigroup into an agreement entered ( A GP) for a total of $49 billion. On 6/9/2009, Treasury (TIP), and A sset Guarantee Program Investment Program Targeted under the CPP, Inc. (Citigroup) separate investments in Citigroup made three Treasury for Series M Common Stock E quivalent (“Series M”) and a warrant to exchanged a total of $25 billion the CPP shares Private and Public E xchange Offerings. On 7/23/2009 and 7/30/2009, Treasury “dollar for dollar” in Citigroup’s Stock, Series H (CPP Shares) Fixed Rate Cumulative Perpetual Preferred approvals. of certain shareholder of common stock and the associated warrant terminated on receipt of Series M. On 9/11/2009, M automatically converted to 7,692,307,692 shares shares purchase Inc. paid a $13 million exchange fee in connection with this transaction. Inc. Popular, III, administrative trustee for Popular, securities issued by Popular Capital Trust Inc. for a like amount of non tax-deductible trust preferred stock issued by Popular, exchanged its series C preferred On 8/24/2009, Treasury original investment was made is shown in parentheses. exchanged its securities for a like amount of that comply with the CPP terms applicable to bank holding companies. The institution in which Treasury’s and Treasury This institution converted to a bank holding company structure in a registered a sale by Treasury after underwriting fees, from to Treasury, the proceeds “ A ” represents agreement, related securities purchase of warrants by the financial institution in a negotiated sale pursuant to terms repurchase a from proceeds represents For final disposition of warrants, “R” in a private auction principally involving qualified institutional buyers. Treasury a sale by placement expenses, from before Treasury, to the proceeds represents public offering of the warrants issued by financial institution, and “P” without value as the terms and conditions for distribution of by contingent value rights (CVRs). On 2/8/2010, the CVRs expired extinguished and replaced stock and warrant investment were preferred Inc. became effective and Treasury’s plan of CIT Group On 12/10/2009, the bankruptcy reorganization not met. to holders of CVRs were common shares II, administrative trustee for Superior B ancorp. Securities issued by Superior Capital Trust Preferred stock issued by Superior B ancorp, Inc. for a like amount of non tax-deductible Trust exchanged its series A preferred On 12/11/2009, Treasury in a single series but with blended exchanged for a like amount of securities the acquiror warrants issued by First Market on 2/6/2009 were stock and exercised the preferred Corporation (the acquiror), On 2/1/2010, following the acquisition of First Market B ank (First Market) by Union ankshares original investment. dividend rate equivalent to those of Treasury’s and the investment was extinguished. or investors, including Treasury, to any creditors with no recovery On 2/11/2010, Pacific Coast National B ancorp dismissed its bankruptcy proceedings accrued and unpaid Stock (MCP), which is equivalent to the initial investment amount of $84,784,000, plus $4,604,000 capitalized previously stock in Midwest B anc Holdings, Inc. (M HI) for $89,388,000 of mandatory convertible preferred exchanged its $84,784,000 of preferred On 3/8/2010, Treasury to its capital plan, the MCP may be converted to common stock. dividends. Subject to the fulfillment by M B HI of conditions related a Subchapter S corporation, that comply with the CPP terms applicable to privately held qualified financial institutions. stock, in connection with its conversion from in GulfSouth Private B ank for an equivalent amount of preferred debentures exchanged its $7,500,000 of subordinated On 3/30/2010, Treasury accrued Stock (MCP), which is equivalent to the initial investment amount of $72,000,000, plus $2,426,000 capitalized previously stock in Independent B ank Corporation (Independent) for $74,426,000 of mandatory convertible preferred exchanged its $72,000,000 of preferred On 4/16/2010, Treasury related to its capital plan, the MCP may be converted to common stock. and unpaid dividends. Subject to the fulfillment by Independent of conditions (see Program participation in the Capital Purchase in connection with Citigroup’s purchased stock that Treasury of the preferred for the exchange into common shares which provided and Citigroup between Treasury common stock pursuant to the June 2009 E xchange A greement Citigroup received Treasury time to during the period ending on 6/30/2010 (or completion of of the common stock from authority as its sales agent to sell su to Treasury. cash proceeds this disposition amount does not represent CDCI investment. Therefore stock exchanged for Treasury’s included in the total amount of preferred were the warrant preferreds exchange into the CDCI program, t the time of this institution’s A this institution is in bankruptcy proceedings. a s of the date this report,  pursuant to the terms of an exchanged for a like amount of securities the acquiror, company on 6/26/2009 were warrants issued by the acquired stock and exercised the preferred Holdings, Inc. (the acquiror), company) by Veritex Company (the acquired of the acquisition Fidelity Resources a s result Inc. for $81,892,000 of a new series B ank Group, stock in Metropolitan stock in NC B ancorp, Inc. and $71,526,000 of its preferred exchanged $6,880,000 of its preferred Treasury Inc. (the acquiror), B ank Group, company) by Metropolitan of the acquisition NC B ancorp, Inc. (the acquired a s result

1a 1b 2 3 3a 4 5 6 7 8 9 10 10a 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 30a 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 258 Appendix D I Transaction Detail I July 25, 2012 P, accessed 7/2/2012. ‑ L P, A RP data call, 7/9/2012; B loomberg, On 6/22/2011, Treasury completed the sale of 2,850,000 shares of common stock at $12.590625 per share (which represents the $12.75 public offering price less underwriting discounts) for net proceeds of $35,883,281.25 pursuant to an underwriting agreement executed on 6/17/2011. On of $35,883,281.25 pursuant to an underwriting agreement the $12.75 public offering price less underwriting discounts) for net proceeds (which represents of common stock at $12.590625 per share completed the sale of 2,850,000 shares On 6/22/2011, Treasury of $36,039,222.17, pursuant to an underwriting the $13.15 public offering price less underwriting discounts) for net proceeds represents (which of Central Pacific Financial Corp. common stock at $13.01 per share 2,770,117 shares remaining completed the sale of all Treasury’s 4/4/2012, Treasury executed on 3/29/2012. agreement into and Opus entered between Treasury price of $16,250,000.00, pursuant to the terms agreement purchase warrant to Opus A cquisition, Inc. (“Opus”) for an aggregate and the related stock held by Treasury completed the sale of all Cascade Financial Corporation preferred On 6/30/2011, Treasury on 6/28/2011. participation in the Small B usiness L ending Fund. in connection with the institution’s received Repayment pursuant to Title VII, Section 7001(g) of the A merican Recovery and Reinvestment ct 2009 using proceeds participation in the Small B usiness L ending Fund. in connection with the institution’s received proceeds amount obtained from Repayment pursuant to Title VII, Section 7001(g) of the A merican Recovery and Reinvestment ct 2009 — part of the repayment Department County B ancorp, was closed by the Washington of Financial Institutions, and Federal Deposit Insurance Corporation (FDIC) named Receiver. W A , the banking subsidiary of Pierce B ank, Tacoma, Commercial On 11/5/2010, Pierce Department of B anking & Finance, and the Federal Deposit Insurance Corporation (FDIC) was named Receiver. Tifton, G A , was closed by the Georgia On 11/12/2010, Tifton B anking Company, WisconsinOn 3/11/2011, L egacy B ank, Milwaukee, WI, the banking subsidiary of ancorp, Inc., was closed by State Department of Financial Institutions, and the Federal Deposit Insurance Corporation (FDIC) was named Receiver. On 4/15/2011, Superior B ank, irmingham, AL , the banking subsidiary of ancorp Inc., was closed by Office of Thrift Supervision, and the Federal Deposit Insurance Corporation (FDIC) was named Receiver. On 7/15/2011, First Peoples B ank, Port the Florida Office Saint L ucie, Florida, the banking subsidiary of FP B ancorp, Inc., was closed by of Financial Regulation, and the Federal Deposit Insurance Corporation (FDIC) was named Receiver. Department of B anking & Finance, and the Federal Deposit Insurance Corporation (FDIC) was named Receiver. B ank, A tlanta, G was closed by the State of Georgia On 7/15/2011, One Georgia receiver. which appointed the Federal Deposit Insurance Corporation (FDIC) as of the Currency, was closed by the OfficeOn 7/29/2011, Integra B ank, National A ssociation, E vansville, Indiana, the banking subsidiary of ank Corporation, of the Comptroller B United and FN between Treasury warrant, pursuant to the terms of agreement of FN B United common stock and an amended restated for 108,555,303 shares stock and warrants held by Treasury completed the exchange of all FN B United Corp. (“FN United”) preferred On 10/21/2011, Treasury into on 8/12/2011. entered A FH and N between Treasury price of $68,700,000.00, pursuant to the terms agreement purchase to North Warrant A merican Financial Holdings, Inc. (“N FH”) for an aggregate and the related stock held by Treasury Inc. preferred B ankshares, completed the sale of all Green On 9/7/2011, Treasury into on 9/6/2011. entered into on 9/16/2011. entered company and the acquiror the acquired among Treasury, unpaid dividends, pursuant to the terms of an agreement California, the banking subsidiary of Citizens B ancorp, was closed by California Department of Financial Institutions, which appointed the Federal Deposit Insurance Corporation (FDIC) as receiver. On 9/23/2011, Citizens B ank of Northern California, Nevada City, at a later date. participation in the Small B usiness L ending Fund, which occurred the institution’s Repayment pursuant to Title VII, Section 7001(g) of the A merican Recovery and Reinvestment ct 2009 in connection with Regulation - Division of B anking, which appointed the Federal Deposit Insurance Corporation (FDIC) as receiver. On 10/14/2011, Country B ank, A ledo, Illinois, the banking subsidiary of C Holding Corp., was closed by Illinois Department of Financial and Professional into on 10/20/2011. and CCI entered between Treasury price of $2,800,000.00, pursuant to the terms agreement purchase to CCI One A cquisition Corporation (“CCI”) fo plus accrued and previously exchanged for a like amount of securities the acquiror company on 6/12/2009 were warrants issued by the acquired stock and exercised the preferred company) by Customers B ancorp, Inc. (the acquiror), B ancorp, Inc. (the acquired of the acquisition B erkshire a s result exchanged for a like amount of securities CF B , pursuant to the terms of an agreement stock and warrant issued by CFC on 1/9/2009 were Inc. (CF B ), the preferred Financial B ancshares, into Crescent Financial Corporation (CFC) was merged Crescent transaction whereby of a reincorporation a s result among exchanged for a like amount of securities BB CN B ancorp, Inc., pursuant to the terms of an agreement stock and warrant issued by Center Financial Corporation were of the acquisition Center Financial Corporation by BB CN B ancorp, Inc. (formerly Nara Inc.), preferred a s result company the acquired among Treasury, pursuant to the terms of an agreement company on 12/5/2008 was exchanged for a like security of the acquiror, the warrant issued by acquired National B ancorp (the acquiror), company) by Valley of the acquisition State B ancorp, Inc. (the acquired a s result 46 47 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 70 71 72 73 74 75 76 77 78 79 80 81 82 83 84 85 86 87 88 89 90 91 92 93 94 95 96 97 98 , 7/11/2012; Treasury, response SIGT response Report Report, 7/11/2012; Treasury, , 6/27/2012; Dividends and Interest Transactions Treasury, Sources: Transaction detail I Appendix D I July 25, 2012 259 7 Proceeds $6,182,493,158 $4,322,726,825 $5,863,489,587 $4,967,921,811 $10,515,723,090 $31,852,354,471 1,500,000,000 1,108,971,857 1,500,000,000 1,165,928,228 2,417,407,607 Total Proceeds: Total Number of Shares Number of Shares 6 $4.12 $3.90 $3.91 $4.26 $4.35 Pricing Mechanism Date 4/26/2010 - 5/26/2010 5/26/2010 - 6/30/2010 7/23/2010 - 9/30/2010 10/19/2010 - 12/6/2010 12/6/2010 On 4/26/2010, Treasury gave Morgan Stanley & Co. Incorporated (Morgan Stanley) discretionary authority, as its sales agent, to sell subject certain authority, Stanley) discretionary Stanley & Co. Incorporated (Morgan gave Morgan On 4/26/2010, Treasury time to during the period ending on 6/30/2010 (or upon completion of sale). of common stock from parameters up to 1,500,000,000 shares on 5/26/2010. Completion of the sale under this authority occurred as its sales agent, to sell subject certain authority, Stanley) discretionary Stanley & Co. Incorporated (Morgan gave Morgan On 5/26/2010, Treasury time to during the period ending on 6/30/2010 (or upon completion of sale). of common stock from parameters up to 1,500,000,000 shares on 6/30/2010. Completion of the sale under this authority occurred  as its sales agent, to sell subject certain authority, Stanley) discretionary Stanley & Co. Incorporated (Morgan gave Morgan On 7/23/2010, Treasury time to during the period ending on 9/30/2010 (or upon completion of sale). of common stock from parameters up to 1,500,000,000 shares on 9/30/2010. Completion of the sale under this authority occured as its sales agent, to sell subject certain authority, Stanley) discretionary Stanley & Co. Incorporated (Morgan gave Morgan On 10/19/2010, Treasury time to during the period ending on 12/31/2010 (or upon completion of sale), of common stock from parameters up to 1,500,000,000 shares which plan was terminated on 12/6/2010. Closing of the offering is subject to the 2,417,407,607 shares. commenced an underwritten public offering of its remaining On 12/6/2010, Treasury fulfillment of certain closing conditions. over the course of Inc. common stock made by Treasury The price set forth is the weighted average price for all sales of Citigroup, period. corresponding to Treasury. proceeds the gross A mount represents

CPP - CITIGROUP, INC. COMMON STOCK DISPOSITION, AS OF 6/30/2012 CPP - CITIGROUP, Note 1 2 3 4 5 Report . 6/27/2012 Transactions notes taken verbatim from Data as of 6/30/2012. Numbered Notes: Numbers may not total due to rounding. 1  2  3 4  5  6  7  Report , 6/27/2012. Transactions Treasury, Source: Table D.2 Table 260 Appendix D I Transaction Detail I July 25, 2012 $455.78 $976.67 $227.89 $9,750.00 $4,760.83 $3,255.56 $9,966.67 $3,255.56 $73,349.67 $82,083.33 $16,342.89 $35,985.33 $32,833.33 $87,008.33 $14,650.00 $91,900.50 $49,549.56 $32,555.56 $15,959.44 $54,404.83 $10,714.44 $22,723.78 $281,005.18 $110,714.00 $166,370.28 $170,916.67 $106,131.11 $205,100.00 $446,507.39 $192,057.67 $407,479.22 $111,875.56 $171,888.89 $168,960.33 $264,111.33 $405,518.75 $976,666.67 $302,050.44 $166,215.80 $777,583.33 $150,164.44 $148,160.33 $421,258.14 $204,000.00 $2,634,200.22 $1,777,533.33 Paid to Treasury Dividend/Interest Dividend/Interest Continued on next page $ ­ — Remaining Disposition Details Investment Amount 5 Date 4/10/2012 Par Par Par Par Par Par Par Par Par Par Par Par Par Par Par Par Par Par Par Par Par Par Par Par Par Par Par Par Par Par Par Par Par Par Par Par Par Par Par Par Par Par Par Par Par Par Par Pricing Mechanism $ ­ — $7,000 $14,000 $30,000 $502,000 $300,000 $145,000 $450,000 $100,000 $300,000 $350,000 $100,000 $698,000 $2,234,000 $5,457,000 $2,500,000 $3,372,000 $3,297,000 $5,250,000 $3,260,000 $1,096,000 $1,000,000 $6,300,000 $5,781,000 $4,060,000 $2,650,000 $2,799,000 $5,146,000 $1,522,000 $8,044,000 $1,000,000 $7,875,000 $6,245,000 $1,657,000 $9,278,000 $4,520,000 $4,551,000 $8,086,000 $6,000,000 $3,154,000 $80,914,000 $18,980,000 $11,841,000 $54,600,000 $17,000,000 $30,000,000 $14,000,000 Investment Amount $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $4,379,000 $2,313,000 $3,881,000 $30,514,000 Additional Investment Purchase Details Purchase $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $7,462,000 $1,747,000 $5,146,000 $7,875,000 $6,245,000 $4,551,000 $4,205,000 $6,000,000 $50,400,000 $18,980,000 $54,600,000 $17,000,000 $30,000,000 $14,000,000 Amount from CPP Amount from Subordinated Debentures Subordinated Subordinated Debentures Subordinated Debentures Subordinated Investment Description Stock Preferred Debentures Subordinated Preferred Stock Preferred Preferred Stock Preferred Debentures Subordinated Subordinated Debentures Subordinated Debentures Subordinated Subordinated Debentures Subordinated Debentures Subordinated Debentures Subordinated Subordinated Debentures Subordinated Common Stock Stock Preferred Preferred Stock Preferred Preferred Stock Preferred Preferred Stock Preferred Preferred Stock Preferred Debentures Subordinated Subordinated Debentures Subordinated Stock Preferred Subordinated Debentures Subordinated Debentures Subordinated Stock Preferred Subordinated Debentures Subordinated Debentures Subordinated Debentures Subordinated Debentures Subordinated Debentures Subordinated Debentures Subordinated Subordinated Debentures Subordinated Stock Preferred Preferred Stock Preferred Subordinated Debentures Subordinated Subordinated Debentures Subordinated Subordinated Debentures Subordinated Subordinated Debentures Subordinated Subordinated Debentures Subordinated Debentures Subordinated Debentures Subordinated Stock Preferred Subordinated Debentures Subordinated Preferred Stock Preferred Debentures Subordinated Subordinated Debentures Subordinated A A A Seller lternatives Federal Credit Union, Ithaca, NY A lternatives Federal Credit rook, I L A merican B ancorp of Illinois, Inc., Oak rook, WY Union, L ander, A tlantic City Federal Credit Name of Institution ancshares, Inc., B ainbridge, G A B ainbridge ancshares, B ancorp of Okolona, Inc., MS B ancPlus Corporation, Ridgeland, MS B ank A siana, Palisades Park, NJ NY Union, B ronx, B ethex Federal Credit order Federal Credit Union, Del Rio, TX Federal Credit B order Union, Milwaukee, WI Credit B rewery rooklyn, NY Union, B rooklyn, Cooperative Federal Credit B rooklyn Union, B uffalo, NY B uffalo Cooperative Federal Credit Union, B iggs, C A B utte Federal Credit Carter Federal Credit Union, Springhill, LA Carter Federal Credit ancorp, Inc, New York, NY Carver B ancorp, Inc, New York, anc Corporation, Washington, DC CF B anc Corporation, Washington, ancshares Corporation, A tlanta, G Citizens B ancshares ancshares of Mississippi, Inc., B randon, MS Community B ancshares ay, Oakland, C A Community B ank of the ay, Community First Guam Federal Credit Union, Hagatna, GU Community First Guam Federal Credit rooklyn, NY First A merican International Corp., B rooklyn, Community Plus Federal Credit Union, Rantoul, I L Community Plus Federal Credit First Choice B ank, Cerritos, C A erkeley, C A Union, B erkeley, Cooperative Center Federal Credit NY Union, New York, Fidelis Federal Credit ancshares, Inc., Hanover Park, I L First E agle B ancshares, D.C. Federal Credit Union, Washington, DC Union, Washington, D.C. Federal Credit Union, L os A ngeles, C E piscopal Community Federal Credit Union, Fairfax,Fairfax V County Federal Credit Union, Oceanside, C A Faith B ased Federal Credit Union, Charlotte, NC First L egacy Community Credit First M&F Corporation, Kosciusko, MS aptist Tabernacle Federal Credit Union, B ridgeport, CT Federal Credit E ast nd B aptist Tabernacle ancshares, Inc., Vernon, AL Inc., Vernon, B ancshares, First Vernon Freedom First Federal Credit Union, Roanoke, V First Federal Credit Freedom Union, Missoula, MT Gateway Community Federal Credit Genesee Co-op Federal Credit Union, Rochester, NY Union, Rochester, Genesee Co-op Federal Credit Greater Kinston Credit Union, Kinston, NC Kinston Credit Greater Guaranty Capital Corporation, B elzoni, MS MS L afayette B ancorp, Inc., Oxford, Hill District Federal Credit Union, Pittsburgh, P Union, Pittsburgh, Hill District Federal Credit Union, Jackson, MS Hope Federal Credit I B C ancorp, Inc., Chicago, L W Financial Corporation, Washington, DC I B W Financial Corporation, Washington, mployers Group Federal Credit Union, Hilo, HI Federal Credit Independent E mployers Group Kilmichael B ancorp, Inc., Kilmichael, MS 9/24/2010 9/17/2010 9/24/2010 Purchase Date Purchase 9/24/2010 9/29/2010 9/29/2010 9/29/2010 9/29/2010 9/29/2010 9/24/2010 9/30/2010 9/24/2010 9/24/2010 9/29/2010 8/27/2010 9/17/2010 8/13/2010 9/17/2010 9/29/2010 9/29/2010 9/24/2010 8/13/2010 9/29/2010 9/24/2010 9/24/2010 9/29/2010 9/17/2010 9/29/2010 9/29/2010 9/24/2010 9/29/2010 9/29/2010 9/29/2010 9/29/2010 9/29/2010 9/29/2010 9/24/2010 9/17/2010 9/29/2010 7/30/2010 9/29/2010 9/29/2010 9/17/2010 9/10/2010 9/3/2010 9/29/2010 9/3/2010 CDCI PROGRAM TRANSACTION DETAIL, AS OF 6/30/2012 CDCI PROGRAM TRANSACTION DETAIL, Note 1, 2 1, 3 1 2a 1 1, 2 1 1 1 1 1 5 1 1 1, 2 1 Table D.3 Table Transaction detail I Appendix D I July 25, 2012 261 $— $328.33 $9,291.83 $5,023.50 $8,963.50 $1,009.22 $2,462.50 $9,603.89 $1,855.67 $14,282.50 $29,484.33 $10,580.56 $11,491.67 $35,518.11 $30,333.33 $82,083.33 $92,852.67 $86,142.00 $55,636.64 $35,811.11 $52,533.33 $98,135.56 $13,921.33 $24,395.17 $40,010.78 $62,875.83 $372,133.00 $407,465.28 $349,754.22 $316,895.78 $583,070.00 $716,222.22 $512,750.00 $557,448.78 $399,752.92 $350,200.00 $1,199,900.00 $1,228,303.96 Paid to Treasury Dividend/Interest Dividend/Interest Disposition Details $350,000 Remaining $569,723,000 Investment Amount Date Amount Par Par Par Par Par Par Par Par Par Par Par Par Par Par Par Par Par Par Par Par Par Par Par Par Par Par Par Par Par Par Par Par Par Par Par Par Par Par Par Pricing Total Capital Repayment Total Mechanism $ ­ — $31,000 $75,000 $10,000 $57,000 $435,000 $898,000 $283,000 $325,000 $350,000 $153,000 $273,000 $424,000 $295,000 $743,000 $1,091,000 $3,000,000 $6,784,000 $2,500,000 $2,828,000 $9,734,000 $2,646,000 $1,709,000 $1,100,000 $1,600,000 $7,922,000 $2,795,000 $1,229,000 $1,915,000 $11,334,000 $11,735,000 $10,336,000 $17,910,000 $22,000,000 $33,800,000 $15,750,000 $17,123,000 $10,300,000 $22,115,000 $570,073,000 Investment Amount $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — Amount $5,689,000 $4,836,000 $4,000,000 $22,800,000 $12,123,000 $10,189,000 Total Purchase Purchase Total Additional Investment Purchase Details Purchase $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — TOTAL TREASURY COMMUNITY DEVELOPMENT INITIATIVE (CDCI) INVESTMENT AMOUNT COMMUNITY DEVELOPMENT INITIATIVE TREASURY TOTAL $5,645,000 $5,500,000 $3,000,000 $6,784,000 $9,734,000 $5,000,000 $2,795,000 $11,735,000 $17,910,000 $18,000,000 $11,000,000 $15,750,000 $10,300,000 $11,926,000 Amount from CPP Amount from (CONTINU E D) Subordinated Debentures Subordinated Preferred Stock Preferred Debentures Subordinated Investment Description Stock Preferred Preferred Stock Preferred Debentures Subordinated Debentures Subordinated Preferred Stock Preferred Subordinated Debentures Subordinated Subordinated Debentures Subordinated Preferred Stock Preferred Subordinated Debentures Subordinated Subordinated Debentures Subordinated Debentures Subordinated Preferred Stock Preferred Debentures Subordinated Debentures Subordinated Subordinated Debentures Subordinated Stock Preferred Preferred Stock Preferred Debentures Subordinated Preferred Stock Preferred Subordinated Debentures Subordinated Subordinated Debentures Subordinated Preferred Stock Preferred Debentures Subordinated Preferred Stock Preferred Debentures Subordinated Debentures Subordinated Stock Preferred Subordinated Debentures Subordinated Debentures Subordinated Subordinated Debentures Subordinated Stock Preferred Debentures Subordinated Debentures Subordinated Subordinated Debentures Subordinated Subordinated Debentures Subordinated Subordinated Debentures Subordinated A Seller iberty, TX Union, L iberty, Federal Credit L iberty County Teachers L iberty Financial Services, Inc., New Orleans, LA ast Side People’s Federal Credit Union, New York, NY Union, New York, Federal Credit L ower E ast Side People’s Name of Institution M&F B ancorp, Inc., Durham, NC A C B ancorp, Sun Valley, Mission Valley Neighborhood Trust Federal Credit Union, New York, NY Union, New York, Federal Credit Neighborhood Trust Union, Chicago, I L North Side Community Federal Credit Northeast Community Federal Credit Union, San Francisco, C A Northeast Community Federal Credit Opportunities Credit Union, B urlington, VT Opportunities Credit PG B Holdings, Inc., Chicago, I L Phenix Pride Federal Credit Union, Phenix City, AL Union, Phenix City, Phenix Pride Federal Credit Premier B ancorp, Inc., Wilmette, I L Premier Prince Kuhio Federal Credit Union, Honolulu, HI Prince Kuhio Federal Credit Financial Corporation, Many, LA PS B Financial Corporation, Many, Pyramid Federal Credit Union, Tucson, A Z Union, Tucson, Pyramid Federal Credit Union, Santa Cruz, C A Santa Cruz Community Credit Security Capital Corporation, B atesville, MS Renaissance Community Development Credit Union, Somerset, NJ Renaissance Community Development Credit Security Federal Corporation, A iken, SC Shreveport Federal Credit Union, Shreveport, LA Union, Shreveport, Federal Credit Shreveport Southern B ancorp, Inc., A rkadelphia, R Southern Chautauqua Federal Credit Union, L akewood, NY Southern Chautauqua Federal Credit Southside Credit Union, San A ntonio, TX Southside Credit State Capital Corporation, Greenwood, MS State Capital Corporation, Greenwood, Tongass Federal Credit Union, Ketchikan, A K Federal Credit Tongass ancshares, Inc., Hattiesburg, MS Inc., Hattiesburg, The First B ancshares, B ank of Memphis, TN Tri-State The Magnolia State Corporation, B ay Springs, MS Thurston Union of L ow-Income People (TU IP) Cooperative Credit Union, Olympia, W A oyola Federal Credit Union, New Orleans, LA L oyola Federal Credit Tulane- NY Union, New York, Union Settlement Federal Credit tmore, AL United B ancorporation of A labama, Inc., tmore, University Financial Corp, Inc., St. Paul, MN aptist Church Federal Credit Union, FortIN Wayne, Federal Credit Union B aptist Church United Federal Credit Union, (Workers UNIT E H R Federal Credit NY Union), New York, UNO Federal Credit Union, New Orleans, LA UNO Federal Credit Vigo County Federal Credit Union, Terre Haute, IN Union, Terre Vigo County Federal Credit Virginia Community Capital, Inc., Christiansburg, V Community Capital, Inc., Christiansburg, Virginia 9/24/2010 9/24/2010 9/24/2010 Purchase Date Purchase 8/20/2010 8/20/2010 9/24/2010 9/29/2010 9/24/2010 9/24/2010 9/29/2010 8/13/2010 9/24/2010 8/13/2010 9/24/2010 9/29/2010 9/24/2010 9/24/2010 9/29/2010 9/29/2010 9/29/2010 9/29/2010 8/6/2010 9/29/2010 9/29/2010 9/29/2010 9/24/2010 9/29/2010 8/13/2010 9/29/2010 9/24/2010 9/24/2010 9/29/2010 9/3/2010 7/30/2010 9/24/2010 9/29/2010 9/24/2010 9/29/2010 9/24/2010 This institution qualified to participate in the Community Development Capital Initiative (CDCI), and has exchanged its Capital Purchase Program investment for an equivalent amount of investment with Treasury under the CDCI program terms. under the CDCI program Treasury investment for an equivalent amount of with Program This institution qualified to participate in the Community Development Capital Initiative (CDCI), and has exchanged its Purchase the CDCI program. made an additional investment in this institution at the time it entered Treasury the CDCI program. made an additional investment in this institution after the time it entered Treasury into on 6/29/2011. A ccrued and and Carver entered between Treasury of Carver common stock, pursuant to the terms agreement for 2,321,286 shares stock held by Treasury completed the exchange of all Carver B ancorp, Inc. (“Carver”) preferred On 10/28/2011, Treasury paid on the date of exchange. unpaid dividends were previously Regulation — Division of B anking, and the Federal Deposit Insurance Corporation (FDIC) was named Receiver. B ancorp, Inc., was closed by the Illinois Department B ank, Wilmette, of Financial and Professional I L , the banking subsidiary of Premier On 3/23/2012, Premier A greement. Repayment pursuant to Section 5.2 of the CDCI Securities Purchase CDCI PROGRAM TRANSACTION DETAIL, AS OF 6/30/2012 CDCI PROGRAM TRANSACTION DETAIL, 1, 2 Note 1 1 2a 1 1, 4 1 1 1, 2 1, 2 1 1, 2 1 1 1, 2 Transactions Report . 6/27/2012 Transactions Treasury’s taken verbatim from notes are Data as of 6/30/2012. Numbered Notes: Numbers may not total due to rounding. 1  2  2a 3  4 5 Report, 7/11/2012. Dividends and Interest Report , 6/27/2012; Treasury, Transactions Treasury, Sources: 262 Appendix D I Transaction Detail I July 25, 2012 Treasury Dividend/ $756,714,508 Interest Paid to Interest $2,870,909,382 Continued on next page $— $— $— 1 36.9% 32.04% Equity % Amount/ Remaining Investment $935,805,085 $890,805,085 $874,917,290 $874,772,846 $855,882,552 $849,169,063 $5,676,779,986 $4,676,779,986 $6,711,864,407 $5,711,864,407 N/ A N/ A N/ A Debt Debt Debt Debt Debt Debt Debt Debt Debt Debt Stock Stock Common Common Payment or Disposition Obligation Obligation Obligation Obligation Obligation Obligation Obligation Obligation Obligation Obligation Remaining Investment Description Amount/ $144,444 Proceeds $6,713,489 $50,000,000 $45,000,000 $15,887,795 $18,890,294 $35,084,421 $360,624,198 $2,139,406,778 $1,000,000,000 $4,676,779,986 $1,000,000,000 $2,667,000,000 $1,761,495,577 $11,743,303,903 28 25 25 Type Partial Partial Partial Partial Partial Partial Partial Partial Partial Partial Partial Partial Repayment Repayment Repayment Repayment Repayment Repayment Repayment Repayment Repayment Repayment Repayment Repayment Disposition Disposition Disposition 11/18/2010 3/2/2011 4/5/2011 5/3/2011 12/16/2011 12/23/2011 1/11/2012 3/31/2011 12/15/2010 3/31/2010 4/20/2010 12/18/2009 1/21/2010 7/10/2009 Date 11/26/2010 60.8% 73.8% Equity % Amount/ $985,805,085 $2,670,000,000 $2,100,000,000 $7,072,488,605 $5,937,500,000 Common Stock Trust Trust Preferred Securities Debt Obligation Preferred Preferred Stock Common Stock Debt Obligation Description Convertible Preferred Stock 3, 25 27 29 24 32 12 22 10, 11, 10, 11, 26, 11, 21, Note Treasury Investment After Treasury Exchange/Transfer/Other General Motors Company GM A C ( lly) Motors L iquidation Company General Motors Company GM A C ( lly) General Motors Holdings LL C Obligor GM A C ( lly) 7 9 9 9 7 3 7 7 26 27 Note Amount $985,805,085 $884,024,131 $360,624,198 $4,000,000,000 $5,500,000,000 $2,670,000,000 $7,072,488,605 $3,000,000,000 $2,000,000,000 $5,000,000,000 $22,041,706,310 $13,400,000,000 E xchange for and preferred common stock in New GM Partial conversion of stock for preferred common stock E xchange for amended and Trust restated Securities Preferred E xchange for and preferred common stock in New GM of debt to Transfer New GM Debt left at Old GM Partial conversion of stock for preferred common stock E xchange for and preferred common stock in New GM E xchange for convertible preferred stock E xchange for equity in GM A C interest E xchange for and preferred common stock in New GM E xchange for and preferred common stock in New GM Type 7/10/2009 12/30/2010 3/1/2011 7/10/2009 7/10/2009 7/10/2009 12/30/2009 7/10/2009 12/30/2009 7/10/2009 5/29/2009 7/10/2009 Date Exchange/Transfer/Other Details Exchange/Transfer/Other 5 8 4 2 6 26 22 22, Note Amount $884,024,131 $360,624,198 $2,540,000,000 $4,000,000,000 $1,250,000,000 $5,000,000,000 $7,500,000,000 $2,000,000,000 $30,100,000,000 $13,400,000,000 Trust Preferred Preferred Trust Securities w/ E xercised Warrants Debt Obligation w/ A dditional Note Convertible Stock Preferred w/ E xercised Warrants Debt Obligation w/ A dditional Note Preferred Stock Preferred w/ E xercised Warrants Convertible Stock Preferred w/ E xercised Warrants Debt Obligation w/ A dditional Note Debt Obligation w/ A dditional Note Debt Obligation Debt Obligation w/ A dditional Note Description Initial Investment GM A C General Motors Corporation GM A C General Motors Corporation GM A C GM A C General Motors Corporation General Motors Corporation General Motors Corporation General Motors Corporation Seller Purchase Purchase Purchase Purchase Purchase Purchase Purchase Purchase Purchase Purchase Trans- action Type 12/30/2009 5/20/2009 12/30/2009 6/3/2009 12/29/2008 5/21/2009 12/31/2008 4/22/2009 12/29/2008 5/27/2009 Date

b,c AIFP TRANSACTION DETAIL, AS OF 6/30/2012 AIFP TRANSACTION DETAIL, Detroit, MI Detroit, General Motors, GM A C ( lly), MI Detroit, Table D.4 Table Transaction detail I Appendix D I July 25, 2012 263 Treasury Dividend/ $7,405,894 Interest Paid to Interest $1,171,263,942 Continued on next page N/ A $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — $ ­ — N/ A N/ A N/ A 1 Equity % Amount/ Remaining Investment $403,000,000 $1,496,500,945 $1,464,690,823 $1,413,554,739 $1,369,197,029 $34,894,279,433 $40,896,959,538 N/ A N/ A N/ A N/ A N/ A Debt Debt Debt Debt Note Note Note Note Note recover recover recover recover recover recover Right to Right to Right to Right to proceeds proceeds proceeds proceeds A dditional Payment or Disposition Obligation Obligation Obligation Obligation Remaining Investment Description w/ A dditional w/ A dditional w/ A dditional w/ A dditional Amount/ Proceeds $9,666,784 $7,844,409 $9,302,185 $3,499,055 $30,544,528 $31,810,122 $51,136,084 $44,357,710 $15,000,000 $280,130,642 $560,000,000 $100,000,000 $288,000,000 $5,076,460,000 $1,369,197,029 $1,900,000,000 $2,065,540,000 20 31 and Note Note Type Partial Partial Partial Partial facility Principal collateral collateral collateral collateral Proceeds Proceeds Proceeds Proceeds Proceeds Proceeds payment settlement - A dditional Disposition of undrawn Repayment Repayment Repayment Repayment Repayment Repayment Termination Termination Termination Termination from sale of from sale of from sale of from from sale of from Repayment - Repayment* Repayment* Zero Coupon Zero Repayment* - Date 5/24/2011 5/24/2011 9/9/2010 12/29/2010 4/30/2012 5/14/2010 5/10/2010 3/17/2009 4/17/2009 5/18/2009 6/17/2009 7/14/2009 7/14/2009 7/10/2009 7/21/2011 Payments Total Investment Amount Treasury Total Additional Proceeds* 5/24/2011 5/24/2011 N/ A 6.6% Equity % Amount/ $7,142,000,000 $3,500,000,000 Debt obligation w/ additional note & zero coupon note Debt obligation w/ additional note Right to recover proceeds Description Common equity Transfer/Other 31 20 23 30 19, Note Treasury Investment After Exchange/ Treasury Chrysler LL C Group Chrysler Holding Old Carco Old Carco L iquidation Trust Obligor Chrysler LL C Group 19 23 Note $ ­ — Amount $500,000,000 ($1,888,153,580) Issuance of equity in New Chrysler Transfer of debt to Transfer New Chrysler Completion of bankruptcy transfer proceeding; of collateral security to liquidation trust Type 6/10/2009 6/10/2009 4/30/2010 Date Exchange/Transfer/Other Details Exchange/Transfer/Other (CONTINU E D) 18 17 13 16 14 15 Note $ ­ — $ ­ — Amount $280,130,642 $6,642,000,000 $4,000,000,000 $1,500,000,000 $1,888,153,580 $81,344,932,551 Debt Obligation w/ A dditional Note, Zero Coupon Note, E quity Debt Obligation w/ A dditional Note Debt Obligation w/ A dditional Note Debt Obligation w/ A dditional Note Debt Obligation w/ A dditional Note Debt Obligation w/ A dditional Note Debt Obligation w/ A dditional Note Description Initial Investment Seller New Chrysler Old Chrysler Chrysler Holding Chrysler FinCo Old Chrysler Chrysler Holding Chrysler Holding Purchase Purchase Purchase Purchase Purchase Total Initial Investment Amount Total Purchase Purchase Trans- Trans- action Type 5/27/2009 5/20/2009 1/2/2009 1/16/2009 5/1/2009 4/29/2009 4/29/2009 Date AIFP TRANSACTION DETAIL, AS OF 6/30/2012 AIFP TRANSACTION DETAIL, Chrysler, Chrysler, A uburn Hills, MI Chrysler FinCo, Farmington Hills, MI 264 Appendix D I Transaction Detail I July 25, 2012

.

est) of Chrysler Holdco, and upon receipt of such payment to terminate all obligations. est) of Chrysler Holdco, and upon receipt

exit.”

bankruptcy LL C. of out 22.) A mericas LL C).

footnote “ E xchanged Services and Chrysler 10. was (fka above Financial LL C footnote warrant 12/15/2010. in table on GM Carco Carco the Chrysler the in Old to explained line to completed as refers refers Treasury, Treasury, refers refers was GM, orange to by FinCo” new the Chrysler” This table includes A WCP transactions. ccording A ccording on a debt obligation, which must be paid at the time of principal repayment. Payment amount does not include accrued and unpaid interest the final level of funding. rights offering. The amount has been updated to reflect the level of investor participation committed to lend General Motors Corporation up $1,000,000,000. The ultimate funding was dependent upon in GM A C LL C’s Treasury on 12/30/2009. (See transactions in GM A C until the transactions reported held a 35.4% common equity interest in GM A C. Treasury common equity interest exchanged its $884 million loan to Old GM for a portion of Old GM’s on 12/29/2008, Treasury with Old GM reported Pursuant to its rights under the loan agreement marked the total loan amount to $15,400,000,000. with Old GM (the “Old L oan”), which brought 12/31/2008 agreement This transaction is an amendment to Treasury’s the total loan amount to $19,400,000,000. This transaction was a further amendment to the Old GM L oan, which brought by Old GM. On 7/10/2009, the principal amount was included in $7.07 billion of debt assumed LL C, a special purpose vehicle created the total loan amount to $19,760,624,198. The $360,624,198 was used capitalize GM Warranty This transaction was a further amendment to the Old GM L oan, which brought by lines in the table above.) and common equity in New GM. (See green extinguished and exchanged for privately placed preferred were accrued thereunder On 7/10/2009, the principal amount outstanding under Old GM L oan and interest by Canadian government entities. A s of 7/9/2009, $30.1 billion funds had been $2.2 billion of the financing was provided commitment amount was $30.1 billion. The remaining dated 6/3/2009 with Old GM (the “GM DIP L oan”), Treasury’s agreement Under the terms of $33.3 billion debtor-in-possession credit disbursed by Treasury. and common equity in New GM, except for (i) $7.07 billion, which was assumed by GM as a new obligation under the terms of extinguished and exchanged for privately placed preferred were accrued thereunder and Old GM amended the DIP L oan, principal amount interest On 7/10/2009, Treasury a debt obligation of Old GM. lines in table above) and (ii) $986 million, which remained and New GM (see transactions marked by green between Treasury agreement separate credit oan (other than as explained in footnote 9), Treasury received $2.1 billion in preferred shares and 60.8% of the common shares of New GM. (See transactions marked by green lines in the table above.) of New GM. (See transactions marked by green and 60.8% of the common shares shares $2.1 billion in preferred received In total, for the exchange of Old GM L oan and DIP (other than as explained in footnote 9), Treasury “General Motors Company” company of New GM), which was renamed of General Motors Holding Company (the ultimate parent and common stock, became shareholders preferred to Treasury’s of New GM, including with respect completed on or about 10/19/2009, the shareholders Pursuant to a corporate reorganization in New GM, and GM was converted to “General Motors LL C”. General C is a wholly owned subsidiary of Holdings C, and Company. on an equal basis to their shareholdings loan with New GM was assigned and assumed by General Motors Holdings LL C. completed on 10/19/2009, Treasury’s Pursuant to a corporate reorganization the maximum amount of $1.5 billion on 4/9/2009. funded until it reached the maximum loan amount. The was incrementally by Chrysler FinCo. The amount of $1,500,000,000 represents a special purpose vehicle created Chrysler LB Receivables Trust, The loan was funded through disbursed. obligation to lend any funds committed under this amendment had terminated. No were with Chrysler Holding. A s of 4/30/2009, Treasury’s 1/2/2009 agreement This transaction was an amendment to Treasury’s by Old Chrysler. SPV LL C, a special purpose vehicle created The loan was used to capitalize Chrysler Warranty facility (the “Chrysler DIP L oan”). A s of commitment was $3.04 billion of the total $4.1 debtor-in-possession credit with Old Chrysler fully executed on 5/5/2009 following a term sheet 5/1/2009 and made effective on 4/30/2009. Treasury’s agreement This transaction was set forth in a credit the final amount of funds disbursed under Chrysler DIP L oan. principal amount reflects commitment to lend under the Chrysler DIP L oan had terminated. The remaining 6/30/2009, Treasury’s obligation to lend funds committed under the Chrysler DIP L oan had L oan. A s of 6/30/2009, Treasury’s commitment by an amount $756,857,000 to a total of $3.8 billion under the Chrysler DIP Treasury’s commitment under the Chrysler DIP L oan, which increased This transaction was an amendment to Treasury’s terminated. made a new commitment to New Chrysler of up $6.642 billion. Treasury agreement, with New Chrysler fully executed on 6/10/2009. Under the terms of credit reported agreement was set forth based on a term sheet fully executed 5/27/2009 for an amount up to $6.943 billion, This transaction, first in a credit When the sale to new by a first priority lien on the assets of New Chrysler. secured with Chrysler Holding. The debt obligations are agreement 1/2/2009 credit under Treasury’s Chrysler Holding originally incurred The total loan amount is up to $7.142 billion including $500 million of debt assumed on 6/10/2009 from the rights to 9.85% of common equity in new Chrysler. acquired Chrysler was completed, Treasury explained in footnote 18, $500 million of this debt obligation was assumed by New Chrysler. Pursuant to the agreement to accept a settlement payment agreed dated 5/14/2010, Treasury of $1.375 billion or 40% the equity value Chrysler FinCo. Pursuant to a termination agreement Chrysler FinCo equal to the greater from Chrysler Holdco received was entitled to proceeds as amended on 7/23/2009, Treasury Under loan agreement, of $1.9 billion as satisfaction in full all existing debt obligations (including additional notes and accrued unpaid inter will mandatorily convert to common stock under the conditions and conversion price as set forth shares in the terms of agreement. dated 12/30/2009, the convertible preferred Under the terms of an agreement to a transferred and all assets of Old Chrysler were to Old Chrysler was extinguished without repayment, had provided bankruptcy court became effective by the respective (the “ L iquidation Plan”). Under the Plan, loan Treasury On 4/30/2010, the Plan of L iquidation for debtors Old Chrysler approved time to of the specified collateral security attached such loan. the liquidation from from the proceeds the right to recover retained liquidation trust. Treasury common stock. The initial public offering of GM’s subject to the closing of proposed of $25.50, which is equal to 102% the liquidation preference, stock at a price per share $2.1 billion preferred all of the approximately accepted an offer by General Motors Company (GM) to repurchase On 10/27/2010, Treasury repurchase $11,743,303,903. On 11 For the purpose of this table, income (dividends and interest) are presented in aggregate for each A IFP participant. in aggregate presented are For the purpose of this table, income (dividends and interest)      initial investments. Treasury’s warrants from investment exchange includes the exercised A mount of the Treasury       

Dividends and Interest Report , 7/11/2012. Dividends and Interest Treasury, www.treasury.gov/initiatives/financial-stability/briefing-room/reports/tarp-transactions/Pages/default.aspx; to the following web address: Report , please refer web version of its Transactions Report , 6/27/2012; For Treasury’s Transactions Treasury, Sources: Transaction Report 6/27/2012 Transaction Treasury’s taken verbatim from notes were Data as of 6/30/2012. Numbered Notes: Numbers may not total due to rounding. to GM A C Inc., formerly known as LL C., and now lly Financial, Inc. (“ lly”). GM A C refers to General Motors Corporation, which is now known as L iquidation Company. “Old GM” refers assets on 7/10/2009 in a sale pursuant to section 363 of the B ankruptcy Code. See also footnote 11. Old GM’s the company that purchased to General Motors Company, “New GM” refers 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 a b c “Chrysler “Old “Chrysler Holding” refers to CGI Holding LL C, the company formerly known as “Chrysler C.” “Chrysler Holding” refers assets on 6/10/2009 in a sale pursuant to section 363 of the B ankruptcy Code. Old Chrysler’s LL C, the company that purchased to Chrysler Group “New Chrysler” refers Transaction detail I Appendix D I July 25, 2012 265 Treasury Dividends/ $9,087,808 $5,787,176 Interest Paid to Interest $1,568,888,889 $1,435,555,556 Paid to Treasury Dividend/Interest Dividend/Interest Outstanding Amount Warrant Shares Warrant $1,427,190,941 Market and Warrant Data Market and Warrant $50,000,000 $56,541,893 $44,533,054 $140,000,000 $100,000,000 $123,076,735 $413,076,735 Price $8.18 Stock $27.41 Final None None Proceeds Disposition Remaining Investment Description $190,386,428 A dditional Note A dditional Note A dditional Note A dditional Note $1,236,804,513 Total Warrant Proceeds Warrant Total Debt Obligation w/ Debt Obligation w/ Total Repayments Total Final 5 5 6 7 Warrants Warrants Disposition Description Type Partial Partial Final Disposition A A Payment Payment repayment repayment 3 Repayment Repayment Final 4 Date 3/3/2010 1/25/2011 Disposition 2/11/2010 3/4/2010 11/20/2009 3/9/2010 4/7/2010 4/5/2010 Date Repayment Capital Warrants Warrants Remaining Description Amount Adjusted Investment $— $— $123,076,735 $290,000,000 $2,500,000,000 $1,000,000,000 Capital Amount Adjustment Details Remaining Treasury Investment Treasury Remaining After Capital Repayment 2 Amount Date Capital Adjustment 12/9/2009 Repayment $413,076,735 $101,074,947 ($500,000,000) 12/23/2009 ($1,000,000,000) 3 3 $ ­ — Capital Date Amount Repayment 7/8/2009 7/8/2009 Adjustment Adjusted Total Adjusted Total $20,000,000,000 $20,000,000,000 $40,000,000,000 Capital Repayment Details N/ A N/ A Par Par Pricing Pricing Repayment Mechanism Total Capital Total Mechanism Total Proceeds from Additional Notes from Proceeds Total Amount Amount Investment Investment $3,500,000,000 $1,500,000,000 $20,000,000,000 $20,000,000,000 $40,000,000,000 Total Treasury TIP Investment Amount Treasury Total Investment Description Debt Obligation w/ A dditional Note Debt Obligation w/ A dditional Note Transaction Transaction Type Purchase Purchase Trust Preferred Securities w/ Preferred Trust Warrants Total Investment Total Preferred Stock w/ Warrants Preferred Investment Description Purchase Purchase Transaction Transaction Type Citigroup Inc. Citigroup B ank of A merica Corporation Institution Name Seller Seller Institution Name GM Supplier Receivables LL C Wilmington, D E Chrysler Receivables SPV LL C Wilmington, D E $5,000,000,000 Date 4/9/2009 4/9/2009 12/31/2008 1/16/2009 Date C, a special purpose vehicle created by General Motors Corporation. The amount of $3,500,000,000 represents the maximum loan amount. The loan will be incrementally funded. The credit agreement was fully executed on 4/9/2009, but agreement funded. The credit the maximum loan amount. The will be incrementally by General Motors Corporation. The amount of $3,500,000,000 represents GM Supplier Receivables, LL C, a special purpose vehicle created The loan was funded through made effective as of 4/3/2009. General Motors Company assumed GM Supplier Receivables LL C on 7/10/2009. was fully executed on 4/9/2009, but made effective as agreement funded. The credit the maximum loan amount. The will be incrementally by Chrysler LL C. The amount of $1,500,000,000 represents Chrysler Receivables SPV LL C, a special purpose vehicle created The loan was funded through LL C assumed Chrysler Receivables SPV on 6/10/2009. of 4/7/2009. Chrysler Group was effective on 7/1/2009. commitment on 7/8/2009; the reduction issued notice to the institution of permanent reduced Treasury must be paid at the time of principal repayment. which interest due on the amount of principal repayment, Does not include accrued and unpaid interest reflects the total funds disbursed under loan, all of to the A dditional Note. The final investment amount has paid its obligations with respect had terminated and the borrower agreement commitment to lend under the credit commitment was $2.5 billion (see note 3). A s of 4/5/2010, Treasury’s Treasury’s which have been repaid. reflects the total funds disbursed under loan, all of to the A dditional Note. The final investment amount has paid its obligations with respect had terminated and the borrower agreement commitment to lend under the credit commitment was $1 billion (see note 3). A s of 4/7/2010, Treasury’s Treasury’s which have been repaid. 1 GP for a total of $49 billion. On 6/9/2009, Treasury entered into an agreement with Citigroup to exchange all of Treasury’s investments. On 7/30/2009, Treasury exchanged all of its Fixed Rate Cumulative investments. On 7/30/2009, Treasury to exchange all of Treasury’s with Citigroup into an agreement entered and A GP for a total of $49 billion. On 6/9/2009, Treasury TIP, under CPP, Inc. (“Citigroup”) separate investments in Citigroup made three Treasury Securities. Preferred “dollar for dollar” Trust Stock, Series I (TIP Shares) Perpetual Preferred Repayment pursuant to Title VII, Section 7001 of the A merican Recovery and Reinvestment ct 2009. public offering of the warrants issued by financial institution. in a registered a sale by Treasury after underwriting fees, from to Treasury, the proceeds of warrants by the financial institution, and “ A ” represents repurchase a from proceeds represents For final disposition of warrants, “R” was repaid. agreement a ll outstanding principal drawn under the credit

ASSP TRANSACTION DETAIL, AS OF 6/30/2012 ASSP TRANSACTION DETAIL, Note 1 2 3 4 5 6 7 AS OF 6/30/2012 TIP TRANSACTION DETAIL, 1 2 Initial Total Report . 6/27/2012 Transactions Treasury’s taken verbatim from notes were Data as of 6/30/2012. Numbered Notes: Numbers may not total due to rounding. Treasury, Dividends and Interest Report, 7/11/2012. Dividends and Interest Report , 6/27/2012; Treasury, Transactions Treasury, Sources: Note Transactions Report. 6/27/2012 Transactions Treasury’s taken verbatim from notes were Data as of 6/30/2012. Numbered Notes: Numbers may not total due to rounding. 1 2 3 P, accessed 7/2/2012. L P, Report , 7/11/2012; B loomberg Dividends and Interest Report, 6/27/2012; Treasury, Transactions Treasury, Sources: Table D.5 Table D.6 Table 266 Appendix D I Transaction Detail I July 25, 2012 Dividends/ to Treasury Interest Paid Interest $442,964,764 Price Stock $27.41 Market and Warrant Data Market and Warrant Outstanding Warrant Shares $— $— Amount Premium Premium Remaining $2,234,000,000 Remaining Premium Description Trust Preferred Securities w/ Warrants Warrants None Amount Payment or Disposition Payment $67,197,045 $2,246,000,000 ($1,800,000,000) $2,313,197,045 Type Partial A uction Warrant Warrant for early Payment Disposition termination cancellation of guarantee Total Proceeds Total Date Adjusted 1/25/2011 9/30/2010 12/23/2009 $4,300,000,000 Investment Amount Amount $4,034,000,000 $2,246,000,000 Trust Trust Trust Warrants Warrants Adjusted Investment Date 7/19/2010 Preferred Preferred Preferred Description Securities w/ Securities w/ Exchange/Transfer/Other Details Exchange/Transfer/Other Type preferred preferred preferred securities securities E xchange E xchange securities for stock for trust trust preferred trust preferred trust preferred Pricing Mechanism N/ A Date 6/9/2009 9/29/2010 $4,300,000,000 $20,000,000,000 Investment Amount Amount Premium $4,034,000,000 Description Preferred Preferred Stock w/ Warrants Investment Description Debt Obligation w/ A dditional Note Total $5,000,000,000 Guarantee Limit ($5,000,000,000) $ ­ — Description Termination A greement Total Master A greement Transaction Transaction Type Purchase C entered into an amendment of the credit agreement previously entered into on 3/3/2009, which amendment reduced Treasury’s maximum loan amount to Treasury’s into on 3/3/2009, which amendment reduced entered previously agreement into an amendment of the credit AL F LL C entered Transaction Transaction Type Termination Guarantee NY”). The amount of $20,000,000,000 represents the maximum loan amount. The (“FR B NY”). The amount of $20,000,000,000 represents by The Federal Reserve B ank of New York AL F LL C, a special purpose vehicle created AL F LL C, Wilmington, D E Institution Name Inc. Citigroup Citigroup Inc., Citigroup NY New York, Seller Institution T Initial Investment Date 3/3/2009 Date 12/23/2009 1/16/2009 In consideration for the guarantee, Treasury received $4.03 billion of preferred stock, which pays 8% interest. $4.03 billion of preferred received In consideration for the guarantee, Treasury exchanged all of its Fixed Rate Cumulative Perpetual Preferred investments. On 7/30/2009, Treasury to exchange all of Treasury’s with Citigroup into an agreement entered and A GP for a total of $49 billion. On 6/9/2009, Treasury TIP, under CPP, Inc. (“Citigroup”) separate investments in Citigroup made three Treasury Securities. Preferred “dollar for dollar” Trust with the A GP agreement, as premium received Stock Series G ( A GP Shares), to cancel $1.8 billion of the A GP agreed In connection with the early termination of guarantee, Treasury guarantee and obligations under the Master A greement. which served to terminate Treasury’s with the other parties to the Master A greement A greement into a Termination entered On 12/23/2009, Treasury L iquidity Temporary participation in the FDIC’s at the close of Citigroup’s Securities to Treasury Preferred the FDIC may transfer $800 million of Trust A greement, that, subject to the conditions set out in Termination agreed Securities, and the Federal Deposit Insurance Corporation (FDIC) Treasury Preferred Trust Guarantee Program. Inc. securities with certain modified terms. A t the time of exchange, Citigroup of trust preferred liquidation preference securities for $2,246,000,000 in aggregate of its trust preferred liquidation preference Inc. to exchange $2,234,000,000 in aggregate with Citigroup into an agreement entered On 9/29/2010, Treasury paid the outstanding accrued and unpaid dividends. the closing date. the date of exchange through of which do not include accumulated and unpaid distributions from proceeds securities, the gross into underwritten offering of the trust preferred entered On 9/30/2010, Treasury T The loan was funded through the FR B NY and T On 7/19/2010, Treasury, will be incrementally funded. will be incrementally $4,300,000,000.

Note 3 Report . 6/27/2012 Transactions Treasury’s taken verbatim from notes were Data as of 6/30/2012. Numbered Notes: Numbers may not total due to rounding. 1,2,3, 4,5 Note AGP TRANSACTION DETAIL, AS OF 6/30/2012 AGP TRANSACTION DETAIL, 1 2 3 4 5 AS OF 6/30/2012 TRANSACTION DETAIL, TALF 1 2 P, accessed 7/2/2012. L P, Report , 7/11/2012; B loomberg Dividends and Interest Report , 6/27/2012; Treasury, Transactions Treasury, Sources: Transactions Report , 6/27/2012. Transactions Treasury, Sources: 1,2 Transactions Report . 6/27/2012 Transactions Treasury’s taken verbatim from notes were Data as of 6/30/2012. Numbered Notes: Numbers may not total due to rounding. Table D.7 Table D.8 Table Transaction detail I Appendix D I July 25, 2012 267 $— to Treasury $641,275,676 Continued on next page Dividends/Interest Paid Dividends/Interest 10 11 12 12 $— $— 150 70% 63% 61% 77% $— 2,686,938 Outstanding Warrant Shares Warrant 1,059,616,821 1,084,206,984 1,248,141,410 1,455,037,962 9 Remaining Recap Shares, or Equity % Shares, Investment Amount, Par Par Par Par Par Par Par Par Par Par Par Par Par N/ A N/ A N/ A N/ A N/ A $32.09 $32.09 Pricing Mechanism Stock Price 8 Par $— Pricing Pricing Proceeds Proceeds Mechanism Mechanism $55,833,333 $97,008,351 $55,885,302 $44,941,843 $749,999,972 $185,726,192 $971,506,765 $4,999,999,993 $6,000,000,008 $2,153,520,000 $5,576,121,382 $1,521,632,096 $1,493,250,339 $5,800,000,000 $5,511,067,614 $2,009,932,072 $1,383,888,037 $38,610,313,300 Amount Final Disposition Proceeds $40,000,000,000 1 Partial Disposition Partial Disposition Transaction Transaction Type Partial Disposition Payment Payment Payment Payment Payment Payment Payment Payment Payment Payment Partial Disposition Payment Payment Payment Cancellation Transaction Transaction Type 5/6/2012 5/7/2012 Total Date Preferred Stock w/ Preferred (Series E ) Warrants 3/8/2012 Investment Description 2/14/2011 3/15/2011 8/17/2011 8/18/2011 9/2/2011 11/1/2011 3/8/2012 3/15/2012 3/22/2012 3/15/2012 5/24/2011 3/8/2011 2/14/2011 3/8/2011 5/27/2011 Warrants Warrants (Series E ) Warrants (Series F) Investment $562,868,096 Amount / Shares E xchange $924,546,133 Transaction Type Transaction $16,916,603,568 $167,623,733 $3,375,328,432 $2,000,000,000 Final Disposition Date See table below for exchange/transfer details in connection with the conducted on recapitalization 1/14/2011. 4/17/2009 Exchange/Transfer Details Exchange/Transfer Date Treasury Holdings Post-Recapitalization Treasury Par Investment Description Par Pricing Mechanism Preferred Units A I Preferred Common Stock ICO Junior Preferred Interests AL ICO Junior Preferred Preferred Stock (Series G) Preferred Amount Investment $29,835,000,000 $40,000,000,000 $69,835,000,000 Pricing Mechanism N/ A N/ A Par Preferred Stock Preferred w/ Warrants (Series F) Preferred Stock Preferred w/ Warrants (Series D) Investment Description Initial Total Purchase Transaction Type Purchase Transfer Transaction Transaction Type Purchase Details Purchase E xchange E xchange E xchange E xchange Recapitalization A RP) IG, New York, NY A IG, New York, Investment Description IG, New York, NY A IG, New York, Common Stock (non-T Name of Institution Seller Stock Preferred (Series E ) Preferred Stock Preferred (Series F) 4/17/2009 Date 11/25/2008 1/14/2011 Date 1/14/2011 1/14/2011 2, 3 Note 1 6 5 SSFI (AIG) PROGRAM TRANSACTION DETAIL, AS OF 6/30/2012 SSFI (AIG) PROGRAM TRANSACTION DETAIL, Note 4,7,8 Table D.9 Table 268 Appendix D I Transaction Detail I July 25, 2012 $169,441 $449,518 $371,355 $414,561 $348,599 $479,508 $368,608 $287,624 $657,863 $146,030 $255,370 $423,725 $140,130 $181,124 $335,082 $213,319 $433,852 $386,326 $425,545 $209,956 $447,356 $354,302 $156,481 $239,527 $111,165 $512,131 $1,089,741 $1,286,450 $1,254,222 Continued on next page Interest Paid to Treasury Interest 5, 6 Amount Disposition $3,457,746 $6,462,972 $6,555,383 $7,045,774 $9,482,247 $8,985,818 $6,051,772 $7,105,304 $2,052,702 $7,078,089 $5,029,356 $9,994,806 $9,230,008 $6,556,341 $8,269,277 $7,703,610 $5,764,858 $4,693,918 $3,698,411 $25,039,989 $10,550,917 $13,886,504 $16,658,561 $36,072,056 $29,142,474 $14,182,379 $10,223,264 $11,314,651 $11,818,944 6, 8 Final Disposition Amount $3,151,186 $5,891,602 $5,964,013 $6,542,218 $9,819,270 $8,483,188 $8,171,159 $5,656,049 $6,520,875 $1,903,407 $9,531,446 $6,425,217 $4,580,543 $9,030,539 $8,403,846 $6,236,800 $7,503,681 $7,053,867 $5,473,724 $4,307,881 $3,367,168 $22,350,367 $12,570,392 $15,030,712 $32,656,125 $25,930,433 $12,704,841 $10,099,555 $10,592,775 Current Face Current 1, 8 $82,832 Principal $902,633 $932,112 $328,604 $261,145 $246,658 $348,107 $339,960 $478,520 $694,797 $188,009 $419,457 $969,461 $868,636 $250,445 $663,200 $996,133 $276,276 $889,646 $1,685,710 $2,022,652 $1,149,633 $2,357,796 $2,089,260 $1,784,934 $2,278,652 $1,853,831 $1,398,549 $1,433,872 Received Life-to-date 6/21/2011 10/19/2011 6/21/2011 6/7/2011 6/7/2011 6/7/2011 6/7/2011 6/7/2011 6/7/2011 9/20/2011 6/21/2011 9/20/2011 6/21/2011 10/19/2011 6/21/2011 1/24/2012 6/21/2011 9/20/2011 10/19/2011 10/19/2011 9/20/2011 10/19/2011 Trade Date Trade 1/24/2012 1/24/2012 1/24/2012 1/24/2012 1/24/2012 10/19/2011 1/24/2012 4 Senior $2,184 $4,130 $4,348 $4,783 $5,741 $7,057 $4,844 $4,635 $9,377 $3,200 $3,722 $7,373 $1,408 $5,187 $4,561 $2,752 $5,541 $5,123 $5,820 $3,652 $4,966 $4,458 $3,061 $3,172 $1,912 $6,535 $12,983 $19,077 $15,801 Security Proceeds 3 — — — — — — — — — — — — — — — — — — — — — — — — — — — — — PMF TBA or 2, 3 Amount Investment $4,377,249 $8,279,156 $8,716,265 $9,598,523 $9,717,173 $9,294,363 $6,416,804 $7,462,726 $2,826,678 $9,150,989 $5,520,652 $7,319,688 $9,962,039 $8,940,780 $6,134,172 $6,361,173 $3,834,428 $26,041,643 $11,511,052 $14,151,229 $18,801,712 $38,273,995 $31,693,810 $14,789,302 $10,394,984 $11,115,031 $10,277,319 $11,672,766 $13,109,070 Settlement Details 3/24/2010 3/24/2010 3/24/2010 5/28/2010 4/30/2010 6/30/2010 6/30/2010 6/30/2010 7/30/2010 7/30/2010 8/30/2010 8/30/2010 9/30/2010 9/30/2010 9/30/2010 9/30/2010 10/29/2010 9/30/2010 10/29/2010 10/29/2010 9/29/2010 10/29/2010 Settlement Date 11/30/2010 10/29/2010 11/30/2010 11/30/2010 11/30/2010 11/30/2010 12/30/2010 3 — — — — — — — — — — — — — — — — — — — — — — — — — — — — — PMF TBA or 109 107.5 106.5 110.5 107.75 109.42 111.86 106.75 Pricing 108.875 110.502 106.806 110.798 110.125 109.553 110.785 112.028 106.625 108.505 108.438 110.198 110.088 110.821 110.515 112.476 105.875 111.584 110.759 110.875 113.838 Mechanism 3 Amount $4,070,000 $7,617,617 $8,030,000 $8,900,014 $8,744,333 $8,417,817 $6,004,156 $6,860,835 $2,598,386 $9,719,455 $8,279,048 $5,000,000 $9,272,482 $6,900,000 $8,902,230 $8,050,000 $5,750,000 $5,741,753 $3,450,000 $23,500,000 $10,751,382 $12,898,996 $17,119,972 $34,441,059 $28,209,085 $13,183,361 $10,000,000 $10,350,000 $11,482,421 Purchase Face Purchase A 7 83164KYN7 83165 A DC5 83165 A D E 1 83165 A D84 83164KZH9 83165 AEE 0 83164K2Q5 83165 AE D2 83164K3 B 7 83165 AE K6 83165 AE Q3 83165 AE P5 83164K3Y7 83164K4J9 83165 AE 42 83164K4 E 0 83164K4M2 83165 AE Z3 83165 A F B 5 83165 AE 91 83165 AE W0 83165 A F 83164K5H2 CUSIP 83165 A FC3 83165 A FK5 83164K5F6 83164K5 L 3 83164K5M1 83165 A FT6 1 Coastal Securities Coastal Securities Coastal Securities Coastal Securities Coastal Securities Coastal Securities Coastal Securities Coastal Securities Coastal Securities Coastal Securities Coastal Securities Coastal Securities Coastal Securities Shay Financial Shay Financial Coastal Securities Shay Financial Shay Financial Coastal Securities Coastal Securities Shay Financial Shay Financial Coastal Securities Institution Name Shay Financial Shay Financial Coastal Securities Coastal Securities Coastal Securities Coastal Securities Purchase Details Purchase Floating Rate S BA 7a security due 2025 Floating Rate S BA 7a security due 2022 Floating Rate S BA 7a security due 2022 Floating Rate S BA 7a security due 2034 Floating Rate S BA 7a security due 2016 Floating Rate S BA 7a security due 2020 Floating Rate S BA 7a security due 2035 Floating Rate S BA 7a security due 2033 Floating Rate S BA 7a security due 2029 Floating Rate S BA 7a security due 2033 Floating Rate S BA 7a security due 2020 Floating Rate S BA 7a security due 2034 Floating Rate S BA 7a security due 2020 Floating Rate S BA 7a security due 2025 Floating Rate S BA 7a security due 2034 Floating Rate S BA 7a security due 2017 Floating Rate S BA 7a security due 2034 Floating Rate S BA 7a security due 2020 Floating Rate S BA 7a security due 2019 Floating Rate S BA 7a security due 2020 Floating Rate S BA 7a security due 2020 Floating Rate S BA 7a security due 2024 Floating Rate S BA 7a security due 2020 Investment Description Floating Rate S BA 7a security due 2020 Floating Rate S BA 7a security due 2021 Floating Rate S BA 7a security due 2029 Floating Rate S BA 7a security due 2026 Floating Rate S BA 7a security due 2035 Floating Rate S BA 7a security due 2034 Preferred Shares, it had an additional obligation to Treasury of it had an additional obligation to Treasury Shares, E Preferred the Series for A IG to fully redeem initial investment amount. In addition, in order with no change to Treasury’s Shares for Series E Fixed Rate Non-Cumulative Preferred Shares exchanged its Series D Fixed Rate Cumulative Preferred On 4/17/2009, Treasury and including the exchange date. through Treasury due to Shares the cumulative unpaid dividends for Series D Preferred $1,604,576,000 to reflect 2009. made to its employees in March retention payments A IG Financial Products representing reduction of $165 million commitment to invest up $30 billion less a Treasury’s The investment amount reflected on 5/27/2011. by Treasury $110 million payment was received on 12/17/2010. The remaining by Treasury A $55 million payment was received its operating income over the life of facility. commitment fee of an additional $165 million paid from This transaction does not include A IG’s and interests SPV preferred for (i) the transferred Stock (Series F) which is equal to the amount funded (including amounts drawn at closing) under Series F equity capital facility, Fixed Rate Non-Cumulative Perpetual Preferred investment in A IG’s exchanged $27,835,000,000 of Treasury’s On 1/14/2011, ( A ) Treasury Stock equity capital facility under which A IG has the right to draw up $2,000,000,000. stock under the new Series G Cumulative Mandatory Convertible Preferred of preferred exchanged $2,000,000,000 of undrawn Series F for 20,000 shares of A IG Common Stock, and ( B ) Treasury (ii) 167,623,733 shares of A IG Common Stock. Stock (Series E ) for 924,546,133 shares the A pril 2009 exchange (see note 1 above) of Fixed Rate Non-Cumulative Perpetual Preferred from exchanged an amount equivalent to the $40 billion initial investment plus capitalized interest On 1/14/2011, Treasury and terminated pursuant to this recapitalization facility was repaid This credit facility between A IG and the Federal Reserve B ank of New York. which trust was established in connection with the credit Facility Trust, the A IG Credit of A IG Common Stock from 562,868,096 shares received On 1/14/2011, Treasury Treasury. held by the trust for benefit of U.S. Stock, which was previously Series C Perpetual, Convertible Participating of A IG common stock in exchange for IG’s Preferred 562,868,096 shares transaction. The trust had received returns on the securities that accrue quarterly. preferred holdings do not reflect Interests Units and AL ICO Junior Preferred A I Preferred The amount of Treasury’s the outstanding liquidation amount. and (ii) redeem returns include amounts applied to pay (i) accrued preferred Proceeds executed on 5/24/2011. amount equal to $5,800,000,000, pursuant an underwriting agreement for an aggregate of common stock at $29.00 per share completed the sale of 200,000,000 shares On 5/27/2011, Treasury IG’s primary offering of its common stock and the Preferred Stock (Series G) was cancelled. primary offering of its common stock and the Preferred of A IG’s to $0 as a result Stock (Series G) was reduced Stock (Series G), the available amount of Preferred governing the Preferred On 5/27/2011, pursuant to the terms of agreements executed on 3/8/2012. amount equal to $6,000,000,008, pursuant an underwriting agreement for an aggregate of common stock at $29.00 per share completed the sale of 206,896,552 shares On 3/13/2012, Treasury executed on 5/6/2012. of $5,749,999,965, pursuant to an underwriting agreement for total proceeds of common stock at $30.50 per share completed the sale of 188,524,589 shares On 5/10/2012, Treasury

3/19/2010 3/19/2010 3/19/2010 4/8/2010 4/8/2010 5/11/2010 5/11/2010 5/11/2010 5/25/2010 5/25/2010 6/17/2010 6/17/2010 7/14/2010 7/14/2010 7/14/2010 7/29/2010 7/29/2010 8/17/2010 8/17/2010 8/17/2010 8/31/2010 8/31/2010 8/31/2010 Purchase Purchase Date Dividends and Interest Report. 7/10/2012 Dividends and Interest Report , and Treasury’s 6/27/2012 Transactions the Treasury’s taken verbatim from notes were Data as of 6/30/2012. Numbered Notes: Numbers may not total due to rounding. 1 2 3 4 5 6 7 8 9 10 11 12 AS OF 6/30/2012 UCSB TRANSACTION DETAIL, 9/14/2010 9/14/2010 9/14/2010 9/14/2010 9/28/2010 9/28/2010 P, accessed 7/2/2012. L P, Report , 7/11/2012; B loomberg Dividends and Interest Report , 6/27/2012; Treasury, Transactions Treasury, Sources: Table D.10 Table Transaction detail I Appendix D I July 25, 2012 269 Paid to Treasury Interest/ Interest/ $342,176 Distributions $516,624 $681,819 Continued on next page $13,347,352 $1,223 $48,922 $502,302 Proceeds $20,091,872 Interest Paid to Treasury Interest 5, 6 Distribution Final Distribution Distribution Final Distribution Description Amount Distribution or Disposition Disposition $14,433,039 $16,383,544 $334,924,711 1/29/2010 2/24/2010 1/29/2010 2/24/2010 6, 8 Final Disposition Description Date Amount $12,963,737 $14,562,161 Current Face Current Debt Obligation w/ Membership Interest Contingent Proceeds Contingent Proceeds 1, 8 — — Principal $438,754 $387,839 Total Disposition Proceeds Disposition Proceeds Total Amount Received Life-to-date $166,000,000 Investment After Capital Repayment Amount 10/19/2011 1/24/2012 Trade Date Trade Repayment $34,000,000 4 $166,000,000 $156,250,000 Senior $7,632 $8,521 Security $183,555 Proceeds Date Capital Repayment Details 1/11/2010 1/12/2010 1/15/2010 3 Repayment Total Total — 9 — Senior PMF TBA or Security Proceeds Final Amount Amount 2, 3 Investment $200,000,000 $156,250,000 Amount 7 Investment $15,308,612 $17,092,069 Settlement Details $368,145,452 Amount $200,000,000 $156,250,000 11/30/2010 12/30/2010 Settlement Date 3 Final Commitment Amount 1/4/2010 1/4/2010 Date — — PMF TBA or 3 Total Investment Amount* Total Amount 113.9 Pricing $200,000,000 $156,250,000 114.006 Mechanism 3 Adjusted Investment 1/4/2010 1/4/2010 Date Amount Par Par $13,402,491 $14,950,000 Pricing $332,596,893 Purchase Face Purchase Mechanism (C ontinu e d ) Amount Investment 83165 A FM1 83165 A FQ2 CUSIP $2,222,222,222 $1,111,111,111 1 Debt Obligation w/ Contingent Proceeds Membership Interest Investment Description Shay Financial Shay Financial Total Purchase Face Amount Purchase Total Institution Name Purchase Details Purchase Purchase Purchase Transaction Transaction Type Seller D E D E State Wilmington Wilmington City Floating Rate S BA 7a security due 2034 Floating Rate S BA 7a security due 2035 Investment Description UST/TCW Senior Mortgage Securities Fund, L .P. UST/TCW Senior Mortgage Securities Fund, L .P. Institution Dividends and Interest Report available at www.FinancialStability.gov. on the monthly Dividends and Interest reported payments are The amortizing principal and interest paid at settlement, if applicable. factor and includes accrued interest month’s Investment A mount is stated after applying the appropriate is listed terms. If a purchase will be adjusted within the variance permitted under program face amount, investment amount and senior security proceeds B e- A nnounced, the underlying loans in S BA Pool have yet to come market, and T pricing mechanism, purchase is listed as T BA , or To- If a purchase will be adjusted after publication of the applicable month’s The PMF investment amount and senior security proceeds factor. to the prior-month’s priced according factor being published and the S BA 7a security senior are the trade was made prior to applicable month’s or Prior-Month-Factor, as PMF, factor (on or about the 11th business day of each month). principal amount equal to the E ach Senior Security will (i) have an aggregate S BA 7a Security. the seller of each respective a senior indebtedness instrument (a Senior Security) from will acquire E conomic Stabilization A ct of 2008, Treasury under Section 113 of the E mergency to satisfy the requirements In order outstanding with the terms and conditions as set forth in the Master at par value immediately upon issuance, or remain may be redeemed seller, and (ii) at the option of respective S BA 7a Security, for the respective paid by Treasury of ( A ) 0.05% and B the Investment mount (excluding accrued interest) product A greement. Purchase factor. the disposition amount will be adjusted after publication of applicable month’s at settlement, if applicable. If the disposition is listed as PMF, received factor and includes accrued interest month’s Disposition A mount is stated after applying the appropriate factor (on or about the 11th The PMF disposition amount will be adjusted after publication of the applicable month’s factor. to the prior-month’s factor being published and the S BA 7a security is priced according the trade was made prior to applicable month’s or Prior-Month-Factor, If a disposition is listed as PMF, business day of each month). (excluding accruals). and senior security proceeds received, life-to-date interest life-to-date principal received, Date includes life-to-date disposition proceeds, To Proceeds Program Total payments have been received. factor has been published and trailing principal & interest BA s only after the applicable month’s as T originally purchased Face A mount for CUSIPs that were Face A mount and L ife-to-date Principal Received will equal Purchase The sum of Current

9/28/2010 9/28/2010 Report . 6/27/2012 Transactions Treasury’s taken verbatim from notes were Data as of 6/30/2012. Numbered Notes: Numbers affected by rounding. *Subject to adjustment Purchase Purchase Date UCSB TRANSACTION DETAIL, AS OF 6/30/2012 UCSB TRANSACTION DETAIL, 1 2 3 4 5 6 7 8 Dividends and Interest Report , 7/11/2012. Dividends and Interest Report , 6/27/2012, Treasury, Transactions Treasury, Sources: 9/30/2009 9/30/2009 Date PPIP TRANSACTION DETAIL, AS OF 6/30/2012 PPIP TRANSACTION DETAIL, Table D.11 Table 2,4,5 1,4,5 Note 270 Appendix D I Transaction Detail I July 25, 2012 Paid to Treasury Interest/ Interest/ $99,336,742 Distributions Continued on next page Proceeds $3,434,460 $56,390,209 5 5 Distribution Distribution Description Distribution or Disposition 3/29/2012 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 Description Date Debt Obligation w/ Debt Obligation w/ Debt Obligation w/ Debt Obligation w/ Debt Obligation w/ Debt Obligation w/ Debt Obligation w/ Debt Obligation w/ Debt Obligation w/ Debt Obligation w/ Debt Obligation w/ Debt Obligation w/ Debt Obligation w/ Debt Obligation w/ Debt Obligation w/ Debt Obligation w/ Debt Obligation w/ Contingent Proceeds Contingent Proceeds Contingent Proceeds Contingent Proceeds Contingent Proceeds Contingent Proceeds Contingent Proceeds Contingent Proceeds Contingent Proceeds Contingent Proceeds Contingent Proceeds Contingent Proceeds Contingent Proceeds Contingent Proceeds Contingent Proceeds Contingent Proceeds Contingent Proceeds 3/29/2012 Contingent Proceeds Membership Interest Membership Interest Membership Interest Membership Interest Membership Interest Membership Interest Membership Interest Membership Interest Membership Interest Membership Interest Membership Interest Membership Interest Membership Interest Membership Interest Membership Interest Membership Interest Membership Interest Membership Interest Membership Interest — — Amount $574,982,454 $957,013,546 $925,324,316 $897,968,726 $805,668,588 $677,641,052 $522,231,766 $447,146,281 $428,886,768 $365,906,960 $345,144,428 $307,759,854 $300,656,067 $294,078,924 $284,468,750 $544,971,267 $478,507,285 $462,662,749 $448,985,023 $400,461,178 $331,695,634 $253,991,380 $225,107,647 $215,977,938 $184,916,192 $174,534,977 $168,304,246 $167,120,288 $166,024,103 $164,422,415 $161,386,870 $578,515,653 Investment After Capital Repayment $1,157,031,282 $1,149,964,848 $1,089,942,174 Amount $3,533,199 $4,888,718 $7,066,434 $7,103,787 $6,577,144 $9,610,173 $9,129,709 $6,230,731 $1,183,959 $1,096,185 $1,601,688 $3,035,546 $2,444,347 Repayment $60,022,674 $31,689,230 $27,355,590 $92,300,138 $75,085,485 $18,259,513 $62,979,809 $20,762,532 $37,384,574 $30,011,187 $66,463,982 $15,844,536 $13,677,726 $48,523,845 $68,765,544 $77,704,254 $28,883,733 $31,061,747 $10,381,214 $132,928,628 $128,027,536 $155,409,286 $284,468,750 $161,386,870 Date Capital Repayment Details 4/15/2010 2/18/2010 4/15/2010 9/15/2010 1/14/2010 2/14/2011 3/14/2011 4/14/2011 5/20/2011 6/14/2011 7/15/2011 8/12/2011 1/17/2012 2/14/2012 3/14/2012 9/15/2010 1/14/2011 2/14/2011 3/14/2011 4/14/2011 5/20/2011 6/14/2011 7/15/2011 8/12/2011 1/17/2012 2/14/2012 3/14/2012 3/29/2012 2/18/2010 Repayment 11/15/2010 12/14/2010 10/17/2011 12/14/2011 11/15/2010 12/14/2010 10/17/2011 12/14/2011 9 Final Amount Amount Investment $580,960,000 $1,161,920,000 7 Amount $856,000,000 $1,161,920,000 Final Commitment Amount 9/26/2011 Date 7/16/2010 3 Amount $2,488,875,000 $1,244,437,500 Adjusted Investment 3/22/2010 Date 3/22/2010 Par Par Pricing Mechanism Amount (CONTINU E D) Investment $2,222,222,222 $1,111,111,111 Debt Obligation w/ Contingent Proceeds Investment Description Membership Interest Purchase Transaction Transaction Type Purchase Seller D E State D E Wilmington City Wilmington Invesco L egacy Securities Master Fund, L .P. Institution Invesco L egacy Securities Master Fund, L .P. 9/30/2009 Date 9/30/2009 2,6,8 PPIP TRANSACTION DETAIL, AS OF 6/30/2012 PPIP TRANSACTION DETAIL, Note 1,6 Transaction detail I Appendix D I July 25, 2012 271 Paid to Paid to Treasury Treasury Interest/ Interest/ Interest/ $99,336,742 $33,658,950 Distributions Distributions $215,789,752 $158,206,437 $230,852,891 Continued on next page Continued on next page Proceeds Proceeds $3,434,460 $56,390,209 5 5 Distribution Distribution Description Description Distribution or Disposition Distribution or Disposition 3/29/2012 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 Description Date Description Date Debt Obligation w/ Debt Obligation w/ Debt Obligation w/ Debt Obligation w/ Debt Obligation w/ Debt Obligation w/ Debt Obligation w/ Debt Obligation w/ Debt Obligation w/ Debt Obligation w/ Debt Obligation w/ Debt Obligation w/ Debt Obligation w/ Debt Obligation w/ Debt Obligation w/ Debt Obligation w/ Debt Obligation w/ Debt Obligation w/ Debt Obligation w/ Debt Obligation w/ Debt Obligation w/ Debt Obligation w/ Debt Obligation w/ Debt Obligation w/ Debt Obligation w/ Debt Obligation w/ Debt Obligation w/ Debt Obligation w/ Contingent Proceeds Contingent Proceeds Contingent Proceeds Contingent Proceeds Contingent Proceeds Contingent Proceeds Contingent Proceeds Contingent Proceeds Contingent Proceeds Contingent Proceeds Contingent Proceeds Contingent Proceeds Contingent Proceeds Contingent Proceeds Contingent Proceeds Contingent Proceeds Contingent Proceeds 3/29/2012 Contingent Proceeds Contingent Proceeds Contingent Proceeds Contingent Proceeds Contingent Proceeds Contingent Proceeds Contingent Proceeds Contingent Proceeds Contingent Proceeds Contingent Proceeds Contingent Proceeds Contingent Proceeds Membership Interest Membership Interest Membership Interest Membership Interest Membership Interest Membership Interest Membership Interest Membership Interest Membership Interest Membership Interest Membership Interest Membership Interest Membership Interest Membership Interest Membership Interest Membership Interest Membership Interest Membership Interest Membership Interest Membership Interest Membership Interest Membership Interest Membership Interest Membership Interest Membership Interest Membership Interest Membership Interest Membership Interest — — Amount Amount $574,982,454 $957,013,546 $925,324,316 $897,968,726 $805,668,588 $677,641,052 $522,231,766 $447,146,281 $428,886,768 $365,906,960 $345,144,428 $307,759,854 $300,656,067 $294,078,924 $284,468,750 $544,971,267 $478,507,285 $462,662,749 $448,985,023 $400,461,178 $331,695,634 $253,991,380 $225,107,647 $215,977,938 $184,916,192 $174,534,977 $168,304,246 $167,120,288 $166,024,103 $164,422,415 $161,386,870 $808,734,092 $981,713,808 $578,515,653 Investment After Capital Repayment Investment After Capital Repayment $1,157,031,282 $1,149,964,848 $1,089,942,174 $1,149,667,172 $1,142,950,845 $1,135,832,457 $1,095,832,657 $1,056,713,433 $2,312,350,000 $2,113,425,000 $1,963,425,000 $1,156,175,436 $2,173,974,000 $2,270,602,425 $2,270,514,339 $2,190,514,339 $2,160,514,339 $1,660,514,339 $1,616,314,339 $1,496,314,339 $1,150,379,457 Amount Amount $88,087 $44,043 $712,284 $3,533,199 $4,888,718 $7,066,434 $7,103,787 $6,577,144 $9,610,173 $9,129,709 $6,230,731 $1,183,959 $1,096,185 $1,601,688 $3,035,546 $6,716,327 $7,118,388 $2,444,347 Repayment Repayment $60,022,674 $31,689,230 $27,355,590 $92,300,138 $75,085,485 $18,259,513 $62,979,809 $20,762,532 $37,384,574 $30,011,187 $66,463,982 $15,844,536 $13,677,726 $48,523,845 $68,765,544 $77,704,254 $28,883,733 $31,061,747 $10,381,214 $39,999,800 $99,462,003 $74,999,625 $87,099,565 $30,244,575 $80,000,000 $30,000,000 $44,200,000 $132,928,628 $128,027,536 $155,409,286 $284,468,750 $161,386,870 $287,098,565 $174,200,000 $198,925,000 $150,000,000 $125,000,000 $500,000,000 $120,000,000 Date Date 5/3/2012 Capital Repayment Details Capital Repayment Details 4/15/2010 2/18/2010 4/15/2010 9/15/2010 1/14/2010 2/14/2011 3/14/2011 4/14/2011 5/20/2011 6/14/2011 7/15/2011 8/12/2011 1/17/2012 2/14/2012 3/14/2012 9/15/2010 1/14/2011 2/14/2011 3/14/2011 4/14/2011 5/20/2011 6/14/2011 7/15/2011 8/12/2011 1/17/2012 2/14/2012 3/14/2012 3/29/2012 2/14/2011 3/14/2011 4/14/2011 5/14/2012 6/14/2012 3/14/2012 5/14/2012 2/14/2012 3/14/2012 5/14/2012 2/14/2012 2/18/2010 6/26/2012 5/16/2011 6/14/2011 5/14/2012 5/23/2012 6/14/2012 6/25/2012 1/15/2010 Repayment Repayment 11/15/2010 12/14/2010 10/17/2011 12/14/2011 11/15/2010 12/14/2010 10/17/2011 12/14/2011 9 9 Final Final Amount Amount Amount Amount Investment Investment $580,960,000 $1,161,920,000 7 7 Amount Amount $694,980,000 $856,000,000 $1,161,920,000 $1,389,960,000 $2,486,550,000 $1,243,275,000 $2,298,974,000 $1,149,487,000 $2,300,847,000 $1,150,423,500 Final Commitment Amount Final Commitment Amount 9/26/2011 7/16/2010 7/16/2010 7/16/2010 7/16/2010 Date 7/16/2010 Date 7/16/2010 7/16/2010 7/16/2010 7/16/2010 3 3 Amount Amount $2,488,875,000 $2,488,875,000 $1,244,437,500 $2,542,675,000 $1,271,337,500 $1,244,437,500 $2,524,075,000 $1,262,037,500 $2,488,875,000 $1,244,437,500 Adjusted Investment Adjusted Investment 3/22/2010 3/22/2010 3/22/2010 3/22/2010 3/22/2010 Date 3/22/2010 Date 3/22/2010 3/22/2010 3/22/2010 3/22/2010 Par Par Par Par Par Par Par Par Par Par Pricing Pricing Mechanism Mechanism Amount Amount (CONTINU E D) (CONTINU E D) Investment Investment $2,222,222,222 $2,222,222,222 $1,111,111,111 $2,222,222,222 $1,111,111,111 $1,111,111,111 $2,222,222,222 $1,111,111,111 $2,222,222,222 $1,111,111,111 Debt Obligation w/ Contingent Proceeds Debt Obligation w/ Contingent Proceeds Membership Interest Debt Obligation w/ Contingent Proceeds Membership Interest Investment Description Membership Interest Investment Description Debt Obligation w/ Contingent Proceeds Membership Interest Debt Obligation w/ Contingent Proceeds Membership Interest Purchase Purchase Purchase Purchase Purchase Transaction Transaction Type Purchase Transaction Type Purchase Purchase Purchase Purchase Seller Seller D E D E D E D E D E State D E State D E D E D E D E Wilmington Wilmington Wilmington Wilmington Wilmington City Wilmington City Wilmington Wilmington Wilmington Wilmington Invesco L egacy Securities Master Fund, L .P. lackrock PPIF, PPIF, B lackrock L .P. lackrock PPIF, PPIF, B lackrock L .P. A G E CC PPIF Master Fund, L .P. A G E CC PPIF Master Fund, L .P. Institution Invesco L egacy Securities Master Fund, L .P. Institution Wellington Management L egacy Securities PPIF Master Fund, L P Wellington Management L egacy Securities PPIF Master Fund, L P A lliance B ernstein L egacy Securities Master Fund, L .P. A lliance B ernstein L egacy Securities Master Fund, L .P. 9/30/2009 10/2/2009 10/2/2009 10/30/2009 10/30/2009 Date 9/30/2009 Date 10/1/2009 10/1/2009 10/2/2009 10/2/2009 2,6,8 PPIP TRANSACTION DETAIL, AS OF 6/30/2012 PPIP TRANSACTION DETAIL, AS OF 6/30/2012 PPIP TRANSACTION DETAIL, 2,6 1,6 2,6 1,6 Note 1,6 Note 2,6 1,6 2,6 1,6 272 Appendix D I Transaction Detail I July 25, 2012 Paid to Treasury Interest/ Interest/ $66,007,835 $22,479,266 Distributions $143,961,297 Proceeds $80,468,989 Description Total Proceeds Total Distribution or Disposition 10 10 10 10 Description Date Debt Obligation w/ Debt Obligation w/ Debt Obligation w/ Contingent Proceeds Contingent Proceeds Contingent Proceeds Membership Interest Membership Interest Membership Interest Membership Interest Amount $615,853,465 $619,375,301 Investment After Capital Repayment $1,081,896,544 $2,242,568,200 $1,121,284,298 $2,163,792,299 $1,227,624,986 Amount $3,521,835 $1,202,957 Repayment $39,387,753 $79,000,000 $39,499,803 $78,775,901 $13,531,530 $4,409,958,040 Date Total Total Capital Capital Repayment Details 4/14/2011 3/14/2012 7/15/2011 7/15/2011 3/14/2012 5/13/2011 3/14/2011 Repayment Repayment 9 Final Amount Amount Investment 7 Amount $949,100,000 $474,550,000 $620,578,258 $2,321,568,200 $1,160,784,100 $1,241,156,516 Final Commitment Amount 7/16/2010 7/16/2010 7/16/2010 7/16/2010 Date 7/16/2010 7/16/2010 3 Amount $2,488,875,000 $1,244,437,500 $2,488,875,000 $1,244,437,500 $2,488,875,000 $1,244,437,500 Final Investment Amount $21,856,403,574 Adjusted Investment 3/22/2010 3/22/2010 3/22/2010 3/22/2010 Date 3/22/2010 3/22/2010 Par Par Par Par Par Par Pricing Mechanism Amount (CONTINU E D) Investment $2,222,222,222 $1,111,111,111 $2,222,222,222 $1,111,111,111 $2,222,222,222 $1,111,111,111 $30,000,000,000 Debt Obligation w/ Contingent Proceeds Membership Interest Debt Obligation w/ Contingent Proceeds Membership Interest Investment Description Debt Obligation w/ Contingent Proceeds Membership Interest Purchase Purchase Purchase Purchase Transaction Transaction Type Purchase Purchase Seller D E D E D E D E State D E D E Initial Investment Amount Wilmington Wilmington Wilmington Wilmington City Wilmington Wilmington Marathon L egacy Securities Public-Private Investment Partnership, L .P. Marathon L egacy Securities Public-Private Investment Partnership, L .P. Oaktree PPIP Oaktree Fund, L .P. Oaktree PPIP Oaktree Fund, L .P. Institution R L J Western A sset Public/ Private Master Fund, L .P. R L J Western A sset Public/ Private Master Fund, L .P. 11/25/2009 11/25/2009 12/18/2009 12/18/2009 Date 11/4/2009 11/4/2009 The equity amount may be incrementally funded. Commitment amount represents Treasury’s maximum obligation if the limited partners other than Treasury fund their maximum equity capital obligations. maximum obligation if the limited partners other than Treasury Treasury’s funded. Commitment amount represents The equity amount may be incrementally fund 100% of their maximum equity obligations. and the limited partners other than Treasury maximum obligation if Treasury Treasury’s funded. Commitment amount represents The loan may be incrementally into a Winding-Up and L iquidation A greement. and the fund manager entered On 1/4/2010, Treasury (reported on proceeds gross investment Treasury of pro-rata distributions to exclude These figures to their membership interests. in proportion Treasury, partners, including to the fund’s Treasury) to rata (subject to prior distribution of Contingent Proceeds paid pro and are profit will be considered Distributions after capital repayments L imited PartnershipA greement. with the terms of fund’s time to in accordance Report) , which may be made from the Dividends and Interest per fund, after adjustment for the reallocated dated as of 3/22/2010. $133 million maximum equity capital obligation and $267 debt were Treasury eight funds pursuant to consent letters from to the remaining Following termination of the TCW fund, $3.33 billion obligations have been reallocated total maximum S-PPIP investment amount. Treasury’s remain a part of The $356 million of final investment in the TCW fund will fund and the A G E CC fund, respectively. private investors in the TCW fund to Wellington from $17.6 million and $26.9 equity capital reallocations to the cumulative amount of debt funded. debt obligation, has been reduced Treasury’s the Final Investment A mount, representing A s a result, with the L imited Partnership A greement. that the Investment Period was terminated in accordance Treasury On 9/26/2011, the General Partner notified Cumulative capital drawn at end of the Investment Period. The amount is adjusted to reflect pro-rata equity distributions that have been deemed to be capital repayments to Treasury. repayments to equity distributions that have been deemed to be capital pro-rata The amount is adjusted to reflect

maximum obligations to a fund. a djusted to show Treasury’s with the L oan A greement. debt obligation that may be drawn down in accordance Treasury’s and the maximum amount of final capital commitment (membership interest) a mount adjusted to show Treasury’s Transactions Report . 6/27/2012 Transactions Treasury’s taken verbatim from notes were Data as of 6/30/2012. Numbered Notes: Numbers may not total due to rounding. PPIP TRANSACTION DETAIL, AS OF 6/30/2012 PPIP TRANSACTION DETAIL, 2,6 1 2 3 4 5 6 7 8 9 10 1,6 2,6 1,6 Dividends and Interest Report , 7/11/2012. Dividends and Interest Report , 6/27/2012; Treasury, Transactions Treasury, Sources: Note 2,6 1,6 Transaction detail I Appendix D I July 25, 2012 273 Paid to Treasury Interest/ Interest/ $66,007,835 $22,479,266 Distributions $143,961,297 Incentive Payments Total TARP TARP Total $167,964,731 Proceeds Continued on next page $80,468,989 Servicers Incentives $59,049,968 Description Total Proceeds Total Distribution or Disposition Investors Lenders/ 10 10 10 10 Incentives TARP Incentive Payments TARP $74,497,723 Description Date Debt Obligation w/ Debt Obligation w/ Debt Obligation w/ Contingent Proceeds Contingent Proceeds Contingent Proceeds Membership Interest Membership Interest Membership Interest Membership Interest Incentives Borrower’s Borrower’s $34,417,040 Amount $615,853,465 $619,375,301 Investment After Capital Repayment $1,081,896,544 $2,242,568,200 $1,121,284,298 $2,163,792,299 $1,227,624,986 Amount $3,521,835 $1,202,957 Repayment $39,387,753 $79,000,000 $39,499,803 $78,775,901 $13,531,530 $4,409,958,040 Date Total Total Capital Capital Repayment Details 4/14/2011 3/14/2012 7/15/2011 7/15/2011 3/14/2012 5/13/2011 3/14/2011 A initial cap Repayment Repayment 9 Transfer of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer Updated portfolio data from servicer Updated portfolio data from servicer Updated portfolio data from of cap due to servicing transfer Transfer Initial FH A -H MP cap and initial -2 L P cap of cap due to servicing transfer Transfer servicer Updated portfolio data from of cap due to servicing transfer Transfer Updated portfolio data from servicer Updated portfolio data from servicer & Updated portfolio data from HPDP initial cap servicer & Updated portfolio data from H A F servicer Updated portfolio data from servicer Updated portfolio data from Reason for Adjustment Final Amount Amount Investment Adjusted Cap 7 $851,289,605 $851,284,429 $842,579,605 $842,499,605 $840,599,605 $816,206,410 $816,106,410 $816,099,605 $815,999,605 $815,799,605 $815,799,605 $815,907,145 $815,906,410 $815,806,410 $815,699,605 $815,599,605 $750,807,784 $814,507,784 $812,307,145 $691,000,000 $750,107,784 $814,507,145 $812,207,145 $660,590,000 $782,500,000 $913,840,000 $558,310,000 $687,000,000 Adjustment Details Amount ($735) ($639) Amount ($5,176) ($6,805) $949,100,000 $474,550,000 $620,578,258 $80,000 $400,000 $200,000 $100,000 $2,321,568,200 $1,160,784,100 $1,241,156,516 ($100,000) ($100,000) ($200,000) ($100,000) ($100,000) ($100,000) ($700,000) $8,710,000 $1,900,000 $3,600,000 $4,000,000 ($2,300,000) $24,800,000 $59,807,784 $64,400,000 $284,590,000 $121,910,000 $131,340,000 $128,690,000 ($355,530,000) Cap Adjustment Final Commitment Amount 7/16/2010 7/16/2010 7/16/2010 7/16/2010 Date 7/16/2010 7/16/2010 Date 3 1/6/2011 6/28/2012 6/14/2012 5/16/2012 4/16/2012 6/16/2011 6/29/2011 8/16/2011 9/15/2011 3/15/2012 3/30/2011 4/13/2011 5/13/2011 1/13/2012 3/16/2011 9/30/2010 1/13/2011 2/16/2011 7/14/2010 9/30/2010 6/12/2009 9/30/2009 3/26/2010 Adjustment Amount 10/14/2011 11/16/2011 11/16/2010 12/15/2010 12/30/2009 $2,488,875,000 $1,244,437,500 $2,488,875,000 $1,244,437,500 $2,488,875,000 $1,244,437,500 Final Investment Amount $21,856,403,574 Note Adjusted Investment 3/22/2010 3/22/2010 3/22/2010 3/22/2010 Date 3/22/2010 3/22/2010 N/ A Pricing Mechanism Par Par Par Par Par Par 1 Pricing Mechanism $376,000,000 Investors (Cap) Amount Cap of Incentive (CONTINU E D) Investment of Borrowers and to of Borrowers Payments on Behalf Servicers & Lenders/ $2,222,222,222 $1,111,111,111 $2,222,222,222 $1,111,111,111 $2,222,222,222 $1,111,111,111 $30,000,000,000 Debt Obligation w/ Contingent Proceeds Membership Interest Debt Obligation w/ Contingent Proceeds Membership Interest Investment Description Debt Obligation w/ Contingent Proceeds Membership Interest Financial Instrument for Home L oan Modifications Investment Description Purchase Purchase Purchase Purchase Transaction Transaction Type Purchase Purchase Seller Purchase Transaction Transaction Type D E D E D E D E State D E D E Initial Investment Amount Wilmington Wilmington Wilmington Wilmington City Wilmington Wilmington Servicer Modifying Borrowers’ Loans Servicer Modifying Borrowers’ Select Portfolio Servicing, UT Salt L ake City, Name of Institution Marathon L egacy Securities Public-Private Investment Partnership, L .P. Marathon L egacy Securities Public-Private Investment Partnership, L .P. Oaktree PPIP Oaktree Fund, L .P. Oaktree PPIP Oaktree Fund, L .P. Institution R L J Western A sset Public/ Private Master Fund, L .P. R L J Western A sset Public/ Private Master Fund, L .P. 4/13/2009 HAMP TRANSACTION DETAIL, AS OF 6/30/2012 HAMP TRANSACTION DETAIL, Date 11/25/2009 11/25/2009 12/18/2009 12/18/2009 Date 11/4/2009 11/4/2009 Table D.12 Table The equity amount may be incrementally funded. Commitment amount represents Treasury’s maximum obligation if the limited partners other than Treasury fund their maximum equity capital obligations. maximum obligation if the limited partners other than Treasury Treasury’s funded. Commitment amount represents The equity amount may be incrementally fund 100% of their maximum equity obligations. and the limited partners other than Treasury maximum obligation if Treasury Treasury’s funded. Commitment amount represents The loan may be incrementally into a Winding-Up and L iquidation A greement. and the fund manager entered On 1/4/2010, Treasury (reported on proceeds gross investment Treasury of pro-rata distributions to exclude These figures to their membership interests. in proportion Treasury, partners, including to the fund’s Treasury) to rata (subject to prior distribution of Contingent Proceeds paid pro and are profit will be considered Distributions after capital repayments L imited Partnership A greement. with the terms of fund’s time to in accordance Report) , which may be made from the Dividends and Interest per fund, after adjustment for the reallocated dated as of 3/22/2010. $133 million maximum equity capital obligation and $267 debt were Treasury eight funds pursuant to consent letters from to the remaining Following termination of the TCW fund, $3.33 billion obligations have been reallocated total maximum S-PPIP investment amount. Treasury’s remain a part of The $356 million of final investment in the TCW fund will fund and the A G E CC fund, respectively. private investors in the TCW fund to Wellington from $17.6 million and $26.9 equity capital reallocations to the cumulative amount of debt funded. debt obligation, has been reduced Treasury’s the Final Investment A mount, representing A s a result, with the L imited Partnership A greement. that the Investment Period was terminated in accordance Treasury On 9/26/2011, the General Partner notified Cumulative capital drawn at end of the Investment Period. The amount is adjusted to reflect pro-rata equity distributions that have been deemed to be capital repayments to Treasury. repayments to equity distributions that have been deemed to be capital pro-rata The amount is adjusted to reflect

maximum obligations to a fund. a djusted to show Treasury’s with the L oan A greement. debt obligation that may be drawn down in accordance Treasury’s and the maximum amount of final capital commitment (membership interest) a mount adjusted to show Treasury’s Transactions Report . 6/27/2012 Transactions Treasury’s taken verbatim from notes were Data as of 6/30/2012. Numbered Notes: Numbers may not total due to rounding. PPIP TRANSACTION DETAIL, AS OF 6/30/2012 PPIP TRANSACTION DETAIL, 2,6 1 2 3 4 5 6 7 8 9 10 1,6 2,6 1,6 Dividends and Interest Report , 7/11/2012. Dividends and Interest Report , 6/27/2012; Treasury, Transactions Treasury, Sources: Note 2,6 1,6 274 Appendix D I Transaction Detail I July 25, 2012 Incentive Payments Total TARP TARP Total $221,270,328 Continued on next page Servicers Incentives $70,121,075 Investors Lenders/ Incentives TARP Incentive Payments TARP $116,114,690 Incentives Borrower’s Borrower’s $35,034,563 A initial cap Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer Initial FH A -H MP cap and initial -2 L P cap servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from servicer & Updated portfolio data from HPDP initial cap servicer & Updated portfolio data from H A F servicer & Updated portfolio data from 2MP initial cap of cap to Service One, Inc. due Transfer servicing transfer of cap to Specialized L oan Transfer Servicing, LL C due to servicing transfer of cap to multiple servicers due Transfer servicing transfer servicer Updated portfolio data from of cap to multiple servicers due Transfer servicing transfer of cap to multiple servicers due Transfer servicing transfer of cap to multiple servicers due Transfer servicing transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer servicer Updated portfolio data from of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer Reason for Adjustment Adjusted Cap $998,290,000 $989,990,000 $1,050,566,341 $1,065,766,341 $1,050,340,843 $1,051,466,341 $1,049,866,341 $1,062,866,341 $1,057,866,341 $1,056,966,341 $1,055,866,341 $1,054,166,341 $1,053,566,341 $1,053,226,341 $1,050,346,341 $1,065,966,341 $1,073,575,472 $1,066,375,472 $1,065,975,472 $1,022,390,000 $1,123,677,484 $1,073,475,472 $1,079,420,000 $2,089,600,000 $1,984,190,000 $1,784,890,000 $1,784,660,000 $1,781,660,000 $1,769,380,000 $1,011,700,000 $1,004,590,000 $1,122,277,484 $1,119,077,484 $1,119,076,503 $1,108,576,503 $1,103,976,503 $1,073,476,503 Adjustment Details ($981) Amount ($5,498) ($9,131) ($1,031) $700,000 $100,000 ($900,000) ($600,000) ($340,000) ($400,000) ($230,000) ($1,600,000) ($2,900,000) ($5,000,000) ($1,100,000) ($1,700,000) ($2,880,000) ($7,200,000) ($3,000,000) ($7,110,000) ($6,300,000) ($8,300,000) ($1,400,000) ($3,200,000) ($4,600,000) $15,200,000 $32,400,000 ($14,500,000) ($12,280,000) ($10,500,000) ($30,500,000) $101,287,484 ($991,580,000) ($105,410,000) ($199,300,000) ($757,680,000) $1,010,180,000 Cap Adjustment Date 1/6/2011 8/16/2011 9/15/2011 1/13/2012 2/16/2012 3/15/2012 4/16/2012 5/16/2012 6/14/2012 6/28/2012 7/14/2011 5/13/2011 6/16/2011 6/29/2011 9/30/2010 4/13/2011 6/12/2009 9/30/2009 3/26/2010 4/19/2010 5/14/2010 6/16/2010 7/14/2010 7/16/2010 8/13/2010 9/15/2010 9/30/2010 1/13/2011 2/16/2011 3/16/2011 3/30/2011 Adjustment 10/14/2011 11/16/2011 12/15/2011 12/30/2009 10/15/2010 11/16/2010 Note N/ A Pricing Mechanism 1 (CONTINU E D) $2,071,000,000 Investors (Cap) Cap of Incentive of Borrowers and to of Borrowers Payments on Behalf Servicers & Lenders/ Financial Instrument for Home L oan Modifications Investment Description Purchase Transaction Transaction Type Servicer Modifying Borrowers’ Loans Servicer Modifying Borrowers’ CitiMortgage, Inc., O’Fallon, MO Name of Institution 4/13/2009 HAMP TRANSACTION DETAIL, AS OF 6/30/2012 HAMP TRANSACTION DETAIL, Date Transaction detail I Appendix D I July 25, 2012 275 Incentive Payments Total TARP TARP Total $487,625,315 Continued on next page Servicers Incentives $166,763,508 Investors Lenders/ Incentives TARP Incentive Payments TARP $227,817,344 Incentives Borrower’s Borrower’s $93,044,464 A initial cap Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from Updated due to quarterly assessment and reallocation of cap due to servicing transfer Transfer Transfer of cap (from Wachovia) due to Wachovia) of cap (from Transfer merger servicer Updated portfolio data from of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer Initial FH A -H MP cap, initial -2 L P and initial RD-H A MP Updated portfolio data from servicer Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer & Updated portfolio data from HPDP initial cap Initial 2MP cap servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from servicer & Updated portfolio data from H A F due to Wachovia) of cap (from Transfer merger due to Wachovia) of cap (from Transfer merger Reason for Adjustment Adjusted Cap $5,126,387,058 $5,126,587,058 $5,129,050,914 $5,128,450,914 $5,128,387,058 $5,126,087,058 $5,124,987,058 $5,126,387,058 $5,126,187,058 $5,125,887,058 $5,125,687,058 $5,124,687,058 $5,123,887,058 $5,123,277,058 $5,121,237,058 $5,121,197,135 $5,138,964,397 $5,138,750,914 $5,128,950,914 $5,116,764,397 $5,138,958,085 $5,138,858,085 $5,138,758,085 $5,108,351,172 $5,051,700,000 $4,764,351,172 $2,475,080,000 $6,406,790,000 $7,089,920,000 $2,410,010,000 $3,688,390,000 $5,738,626,344 $5,738,681,110 Adjustment Details Amount ($7,171) ($6,312) $54,767 ($63,856) ($39,923) $200,000 $100,000 ($600,000) ($200,000) ($200,000) ($300,000) ($200,000) ($800,000) ($610,000) ($100,000) ($100,000) $1,400,000 $8,413,225 ($2,300,000) ($1,100,000) ($1,000,000) ($2,040,000) ($9,800,000) $22,200,000 $65,070,000 $344,000,000 $668,108,890 $683,130,000 ($287,348,828) ($462,990,000) $1,213,310,000 $2,050,236,344 Cap Adjustment ($2,038,220,000) Date 1/6/2011 6/16/2011 6/29/2011 7/14/2011 8/16/2011 9/15/2011 1/13/2012 2/16/2012 3/15/2012 4/16/2012 5/16/2012 6/14/2012 6/28/2012 4/13/2011 5/13/2011 1/13/2011 3/16/2011 3/30/2011 12/3/2010 9/30/2010 9/30/2010 3/26/2010 7/14/2010 6/17/2009 9/30/2009 2/17/2010 3/12/2010 3/19/2010 Adjustment 10/14/2011 11/16/2011 12/15/2011 12/15/2010 12/30/2009 Note N/ A Pricing Mechanism 1 (CONTINU E D) $2,873,000,000 Investors (Cap) Cap of Incentive of Borrowers and to of Borrowers Payments on Behalf Servicers & Lenders/ Financial Instrument for Home L oan Modifications Investment Description Purchase Transaction Transaction Type Servicer Modifying Borrowers’ Loans Servicer Modifying Borrowers’ Wells Fargo B ank, N A , Fargo Wells Des Moines, I A Name of Institution 4/13/2009 HAMP TRANSACTION DETAIL, AS OF 6/30/2012 HAMP TRANSACTION DETAIL, Date 276 Appendix D I Transaction Detail I July 25, 2012 Incentive Payments Total TARP TARP Total $163,764,096 Continued on next page Servicers Incentives $55,138,210 Investors Lenders/ Incentives TARP Incentive Payments TARP $80,202,635 Incentives Borrower’s Borrower’s $28,423,250 A initial cap Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation of cap due to servicing transfer Transfer Initial FH A -H MP cap, initial -2 L P and initial 2MP cap servicer Updated portfolio data from Updated due to quarterly assessment and reallocation of cap due to servicing transfer Transfer Transfer of cap from Wilshire Credit Credit Wilshire of cap from Transfer Corporation due to servicing transfer servicer Updated portfolio data from of cap due to servicing transfer Transfer servicer Updated portfolio data from servicer Updated portfolio data from of cap due to servicing transfer Transfer Updated portfolio data from servicer Updated portfolio data from servicer & Updated portfolio data from H A F servicer Updated portfolio data from Updated portfolio data from servicer & Updated portfolio data from HPDP initial cap Reason for Adjustment Adjusted Cap $1,504,075,924 $1,502,475,924 $1,502,075,924 $1,501,975,924 $1,501,175,924 $1,500,185,924 $1,500,173,461 $1,502,475,924 $1,501,675,924 $1,501,475,924 $1,502,275,924 $1,499,094,381 $1,499,075,924 $1,498,875,924 $1,301,400,000 $1,518,398,139 $1,517,794,381 $1,516,994,381 $2,067,430,000 $1,185,900,000 $1,182,200,000 $1,517,898,139 $1,517,896,405 $1,517,796,405 $1,017,650,000 $1,875,370,000 $2,065,550,000 $3,554,890,000 Adjustment Details Amount ($2,024) ($1,734) ($12,463) ($18,457) $200,000 ($400,000) ($100,000) ($800,000) ($990,000) ($800,000) ($200,000) ($200,000) ($800,000) ($500,000) ($100,000) $2,600,000 $3,400,000 $1,880,000 ($1,600,000) ($3,700,000) ($17,900,000) $119,200,000 $216,998,139 $384,650,000 $190,180,000 ($881,530,000) $2,537,240,000 Cap Adjustment ($1,679,520,000) Date 1/6/2011 1/13/2012 3/15/2012 4/16/2012 5/16/2012 6/14/2012 6/28/2012 9/15/2011 6/29/2011 7/14/2011 8/16/2011 9/30/2010 4/13/2011 5/13/2011 7/14/2010 8/13/2010 9/30/2010 3/16/2011 3/30/2011 5/14/2010 6/12/2009 9/30/2009 3/26/2010 Adjustment 10/14/2011 11/16/2011 12/15/2011 12/15/2010 12/30/2009 Note N/ A Pricing Mechanism 1 (CONTINU E D) $633,000,000 Investors (Cap) Cap of Incentive of Borrowers and to of Borrowers Payments on Behalf Servicers & Lenders/ Financial Instrument for Home L oan Modifications Investment Description Purchase Transaction Transaction Type A Servicer Modifying Borrowers’ Loans Servicer Modifying Borrowers’ GM A C Mortgage, Inc., P Ft. Washington, Name of Institution 4/13/2009 HAMP TRANSACTION DETAIL, AS OF 6/30/2012 HAMP TRANSACTION DETAIL, Date Transaction detail I Appendix D I July 25, 2012 277 $— Incentive Payments Total TARP TARP Total $101,750,667 Continued on next page $— Servicers Incentives $39,799,597 $— Investors Lenders/ Incentives TARP Incentive Payments TARP $42,179,792 $— Incentives Borrower’s Borrower’s $19,771,279 A A initial cap Termination of SP Termination Updated due to quarterly assessment and reallocation Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation Transfer of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation Initial FH A -H MP cap and initial -2 L P cap servicer Updated portfolio data from of cap due to servicing transfer Transfer servicer Updated portfolio data from of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from servicer & Updated portfolio data from HPDP initial cap servicer & Updated portfolio data from H A F servicer Updated portfolio data from of cap due to multiple servicing Transfer transfers Updated portfolio data from servicer Updated portfolio data from of cap to Ocwen Financial Transfer Corporation, Inc. due to servicing transfer Reason for Adjustment $0 Adjusted Cap $277,983,483 $277,985,314 $633,035,314 $632,275,314 $650,535,314 $650,535,314 $650,435,314 $633,835,314 $633,735,314 $633,035,314 $633,641,458 $633,635,314 $631,542,112 $631,541,458 $503,320,000 $619,542,668 $619,642,668 $628,542,668 $630,842,112 $493,520,000 $628,542,112 $632,040,000 $886,420,000 $514,700,000 $491,720,000 $1,242,130,000 $1,184,410,000 $1,028,360,000 Adjustment Details ($654) ($556) Amount ($1,831) ($6,144) $100,000 $200,000 $700,000 $100,000 ($760,000) ($100,000) ($100,000) ($700,000) $2,100,000 $9,800,000 $8,900,000 $2,300,000 $1,800,000 $17,500,000 ($17,500,000) ($22,980,000) ($57,720,000) $116,222,668 $225,040,000 $254,380,000 $355,710,000 ($354,290,000) ($156,050,000) ($513,660,000) Cap Adjustment ($3,552,000,000) Date 1/6/2011 7/31/2009 6/28/2012 5/16/2012 6/14/2012 4/16/2012 2/16/2012 3/15/2012 8/16/2011 9/15/2011 6/29/2011 7/14/2011 3/30/2011 4/13/2011 9/30/2010 3/16/2011 9/30/2010 1/13/2011 7/16/2010 9/15/2010 6/17/2009 9/30/2009 3/26/2010 6/16/2010 7/14/2010 Adjustment 12/15/2011 10/15/2010 12/15/2010 12/30/2009 2 Note N/ A N/ A Pricing Mechanism 1 (CONTINU E D) $407,000,000 $3,552,000,000 Investors (Cap) Cap of Incentive of Borrowers and to of Borrowers Payments on Behalf Servicers & Lenders/ Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Investment Description Purchase Purchase Transaction Transaction Type Servicer Modifying Borrowers’ Loans Servicer Modifying Borrowers’ Chase Home Finance, LL C, Iselin, NJ Saxon Mortgage Services, Inc., Irving, TX Name of Institution 4/13/2009 4/13/2009 HAMP TRANSACTION DETAIL, AS OF 6/30/2012 HAMP TRANSACTION DETAIL, Date 278 Appendix D I Transaction Detail I July 25, 2012 Incentive Payments Total TARP TARP Total $31,278,513 $229,489,717 Continued on next page Servicers Incentives $9,159,439 $81,497,510 Investors Lenders/ Incentives TARP Incentive Payments TARP $17,852,012 $108,999,326 Incentives Borrower’s Borrower’s $4,267,062 $38,992,881 A initial cap A initial cap Updated portfolio data from servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation of cap due to servicing transfer Transfer Initial FH A -H MP cap, initial -2 L P and initial RD-H A MP servicer Updated portfolio data from of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation Updated portfolio data from servicer & Updated portfolio data from HPDP initial cap servicer & Updated portfolio data from H A F Initial 2MP cap servicer Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation Transfer of cap due to servicing transfer Transfer Updated portfolio data from servicer Updated portfolio data from of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation of cap due to servicing transfer Transfer Initial FH A -H MP cap servicer Updated portfolio data from of cap due to servicing transfer Transfer Transfer of cap from Saxon Mortgage of cap from Transfer Services, Inc. due to servicing transfer Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from servicer & Updated portfolio data from HPDP initial cap servicer & Updated portfolio data from H A F servicer Updated portfolio data from Saxon Mortgage of cap from Transfer Services, Inc. due to servicing transfer Reason for Adjustment Adjusted Cap $967,120,000 $804,440,000 $972,452,740 $968,710,000 $968,610,000 $944,900,000 $553,380,000 $655,960,000 $933,600,000 $980,460,000 $1,555,141,084 $1,555,136,337 $1,555,113,000 $1,554,813,000 $1,332,200,000 $1,555,138,885 $1,434,113,000 $1,433,213,000 $1,433,013,000 $1,432,995,107 $1,632,630,000 $2,433,020,000 $1,603,650,000 $1,236,900,000 $1,339,340,562 $1,462,870,562 $1,817,160,562 $1,817,154,254 $1,339,240,562 $1,143,252,740 $1,144,151,720 $1,144,150,606 $1,144,140,562 $1,338,840,562 $1,143,251,720 $1,144,040,562 $1,136,510,000 Adjustment Details Amount ($2,548) ($2,199) ($6,308) ($1,114) ($1,020) ($23,337) ($17,893) ($10,044) $100,000 $400,000 $900,000 $100,000 ($300,000) ($900,000) ($200,000) ($100,000) $5,540,000 $3,742,740 $95,300,000 $23,710,000 $46,860,000 $222,941,084 $162,680,000 $665,510,000 $800,390,000 $123,530,000 $354,290,000 $170,800,000 $194,800,000 $102,580,000 $277,640,000 $156,050,000 ($120,700,000) ($829,370,000) ($366,750,000) ($191,610,000) ($105,620,000) Cap Adjustment Date 1/6/2011 1/6/2011 6/29/2011 8/16/2011 9/30/2010 3/30/2011 5/16/2012 6/28/2012 3/26/2010 7/14/2010 9/30/2010 9/30/2009 1/26/2010 5/16/2012 6/14/2012 6/28/2012 6/12/2009 3/15/2012 3/30/2011 6/29/2011 2/16/2012 9/30/2010 2/16/2011 1/13/2012 9/15/2010 7/16/2010 6/16/2010 7/14/2010 6/12/2009 9/30/2009 3/26/2010 Adjustment 10/14/2011 11/16/2011 12/30/2009 10/15/2010 10/14/2011 12/30/2009 Note N/ A N/ A Pricing Mechanism 1 (CONTINU E D) $798,900,000 $659,000,000 Investors (Cap) Cap of Incentive of Borrowers and to of Borrowers Payments on Behalf Servicers & Lenders/ Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Investment Description Purchase Purchase Transaction Transaction Type Servicer Modifying Borrowers’ Loans Servicer Modifying Borrowers’ B ank of A merica, N. ., C A Simi Valley, Ocwen Financial Corporation, Inc., Palm B each, F L West Name of Institution 4/17/2009 as amended on 1/26/2010 4/16/2009 HAMP TRANSACTION DETAIL, AS OF 6/30/2012 HAMP TRANSACTION DETAIL, Date Transaction detail I Appendix D I July 25, 2012 279 Incentive Payments Total TARP TARP Total $593,332,513 Continued on next page Servicers Incentives $198,293,222 Investors Lenders/ Incentives TARP Incentive Payments TARP $278,785,183 Incentives Borrower’s Borrower’s $116,254,108 A initial cap Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer Home L oan Services, of cap from Transfer Corporation due Credit Inc. and Wilshire to merger. of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Transfer of cap due to servicing transfer Transfer Initial FH A -H MP cap, initial -2 L P and initial RD-H A MP servicer Updated portfolio data from servicer Updated portfolio data from of cap due to servicing transfer Transfer Updated portfolio data from servicer Updated portfolio data from servicer Updated portfolio data from Transfer of cap from Wilshire Credit Credit Wilshire of cap from Transfer Corporation due to servicing transfer Transfer of cap from Wilshire Credit Credit Wilshire of cap from Transfer Corporation due to servicing transfer Initial 2MP cap servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from servicer & Updated portfolio data from HPDP initial cap servicer & Updated portfolio data from H A F Reason for Adjustment Adjusted Cap $6,350,155,436 $6,349,155,436 $6,349,073,089 $6,348,873,089 $6,345,473,089 $6,344,073,089 $6,464,673,089 $6,782,629,378 $6,783,429,378 $6,349,855,436 $6,765,829,378 $6,763,729,378 $6,739,829,378 $6,676,029,378 $6,676,049,378 $6,667,189,378 $6,667,130,828 $6,349,655,436 $6,349,664,626 $6,726,300,000 $6,111,772,638 $6,347,772,638 $6,349,564,626 $6,620,800,000 $6,347,764,626 $8,408,100,000 $8,121,590,000 $7,206,300,000 $8,111,310,000 $5,182,840,000 $4,465,420,000 $6,756,200,000 Adjustment Details Amount ($9,190) ($8,012) $20,000 ($82,347) ($58,550) $300,000 $800,000 $200,000 $100,000 ($200,000) $1,800,000 ($1,000,000) ($3,400,000) ($1,400,000) ($2,100,000) ($8,860,000) $10,280,000 ($17,600,000) ($23,900,000) ($63,800,000) $120,600,000 $317,956,289 $105,500,000 $236,000,000 $286,510,000 $450,100,000 $905,010,000 ($614,527,362) ($717,420,000) $3,318,840,000 $2,290,780,000 Cap Adjustment ($1,787,300,000) Date 1/6/2011 6/16/2011 6/29/2011 7/14/2011 8/16/2011 9/15/2011 5/13/2011 2/16/2012 3/15/2012 4/16/2012 5/16/2012 6/14/2012 6/28/2012 4/13/2011 3/30/2011 9/30/2010 3/16/2011 9/30/2010 2/16/2011 7/14/2010 6/16/2010 3/26/2010 4/19/2010 6/12/2009 9/30/2009 1/26/2010 Adjustment 10/14/2011 10/19/2011 11/16/2011 12/15/2011 12/15/2010 12/30/2009 Note N/ A Pricing Mechanism 1 (CONTINU E D) $1,864,000,000 Investors (Cap) Cap of Incentive of Borrowers and to of Borrowers Payments on Behalf Servicers & Lenders/ Financial Instrument for Home L oan Modifications Investment Description Purchase Transaction Transaction Type Servicer Modifying Borrowers’ Loans Servicer Modifying Borrowers’ Countrywide Home L oans Servicing L P ( BA C Home L oans Servicing, P), C A Simi Valley, Name of Institution 4/17/2009 as amended on 1/26/2010 HAMP TRANSACTION DETAIL, AS OF 6/30/2012 HAMP TRANSACTION DETAIL, Date 280 Appendix D I Transaction Detail I July 25, 2012 Incentive Payments Total TARP TARP Total $1,657,394 $6,309,233 Continued on next page Servicers Incentives $1,167,000 $3,698,607 Investors Lenders/ $490,394 Incentives $2,440,768 TARP Incentive Payments TARP $— $169,858 Incentives Borrower’s Borrower’s A A A initial cap A initial cap Updated due to quarterly assessment and reallocation of SP Termination Updated portfolio data from servicer Updated portfolio data from servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from Servicing Tree of cap to Green Transfer LL C due to servicing transfer of cap due to servicing transfer Transfer Updated portfolio data from servicer Updated portfolio data from of cap to Countrywide Home Transfer L oans due to servicing transfer Updated portfolio data from servicer Updated portfolio data from servicer Updated portfolio data from Updated due to quarterly assessment and reallocation of SP Termination servicer & Updated portfolio data from HPDP initial cap servicer & Updated portfolio data from H A F servicer Updated portfolio data from of cap to Countrywide Home Transfer L oans due to servicing transfer of cap to GM A C Mortgage, Inc. Transfer due to servicing transfer Initial FH A -2 L P cap servicer Updated portfolio data from of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation of cap due to servicing transfer Transfer Updated portfolio data from servicer Updated portfolio data from servicer & Updated portfolio data from HPDP initial cap servicer & Updated portfolio data from H A F servicer Updated portfolio data from servicer Updated portfolio data from Reason for Adjustment $1,657,394 $6,309,233 $96,300,000 $96,090,000 $95,990,000 $76,760,000 Adjusted Cap $164,552,462 $164,555,782 $164,555,535 $164,555,241 $453,130,000 $478,973,590 $164,073,590 $161,370,454 $203,460,000 $323,160,000 $375,430,000 $365,150,000 $363,270,000 $556,100,000 $164,073,357 $162,173,357 $161,773,357 $161,773,079 $161,373,079 $447,300,000 $494,030,000 $639,850,000 $622,410,000 $549,400,000 Adjustment Details ($247) ($294) ($233) ($278) Amount ($2,779) ($2,625) ($210,000) ($100,000) ($400,000) ($400,000) $6,700,000 ($1,880,000) ($1,900,000) $68,565,782 $19,540,000 $87,130,000 $52,270,000 $46,730,000 ($10,280,000) ($77,126,410) ($73,010,000) ($17,440,000) $119,700,000 $128,300,000 $145,820,000 ($162,895,068) ($286,510,000) ($314,900,000) ($155,061,221) ($249,670,000) Cap Adjustment Date 1/6/2011 1/6/2011 3/30/2011 6/29/2011 7/16/2010 8/13/2010 9/30/2010 7/14/2010 6/12/2009 4/19/2010 5/14/2010 6/16/2010 9/30/2010 2/16/2011 3/16/2011 3/30/2011 5/13/2011 6/29/2011 9/30/2009 3/26/2010 7/14/2010 9/30/2010 6/12/2009 9/30/2009 3/26/2010 Adjustment 10/19/2011 12/15/2010 10/19/2011 12/30/2009 12/30/2009 13 13 Note N/ A N/ A Pricing Mechanism 1 (CONTINU E D) $366,000,000 $319,000,000 Investors (Cap) Cap of Incentive of Borrowers and to of Borrowers Payments on Behalf Servicers & Lenders/ Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Investment Description Purchase Purchase Transaction Transaction Type A Servicer Modifying Borrowers’ Loans Servicer Modifying Borrowers’ Wilshire Credit Corporation, Credit Wilshire B eaverton, OR Home L oan Services, Inc., P Pittsburgh, Name of Institution 4/20/2009 4/20/2009 HAMP TRANSACTION DETAIL, AS OF 6/30/2012 HAMP TRANSACTION DETAIL, Date Transaction detail I Appendix D I July 25, 2012 281 Incentive Payments Total TARP TARP Total $6,174,718 Continued on next page Servicers Incentives $2,456,938 Investors Lenders/ Incentives $2,815,171 TARP Incentive Payments TARP $902,609 Incentives Borrower’s Borrower’s A initial cap Transfer of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation Transfer of cap due to servicing transfer Transfer Updated portfolio data from servicer Updated portfolio data from of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer Initial FH A -2 L P cap and -H MP servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Initial 2MP cap Transfer of cap due to servicing transfer Transfer Transfer of cap from Wilshire Credit Credit Wilshire of cap from Transfer Corporation due to servicing transfer Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from servicer & Updated portfolio data from HPDP initial cap servicer & Updated portfolio data from H A F servicer Updated portfolio data from Reason for Adjustment $96,310,000 $94,110,000 $93,900,000 $91,010,000 Adjusted Cap $156,272,325 $156,270,703 $155,352,325 $152,092,325 $151,992,325 $150,492,325 $150,692,325 $151,092,325 $150,292,325 $148,392,325 $148,394,627 $146,695,090 $147,095,090 $148,294,627 $136,510,000 $147,094,877 $147,094,627 $130,910,000 $221,790,000 $105,040,000 $118,120,000 Adjustment Details ($213) ($250) Amount ($1,622) ($2,302) $920,000 $100,000 $900,000 $200,000 $200,000 $400,000 $100,000 $400,000 $210,000 $3,260,000 $1,900,000 $1,200,000 $5,600,000 $2,200,000 $10,185,090 $34,600,000 $13,080,000 ($24,220,000) ($64,990,000) $130,780,000 ($116,750,000) Cap Adjustment Date 1/6/2011 6/28/2012 6/14/2012 5/16/2012 3/15/2012 2/16/2012 9/15/2011 7/14/2011 6/29/2011 6/16/2011 9/30/2010 3/30/2011 5/13/2011 9/30/2010 9/10/2010 8/13/2010 7/16/2010 7/14/2010 6/17/2009 9/30/2009 3/26/2010 Adjustment 10/14/2011 11/16/2011 10/15/2010 12/30/2009 Note N/ A Pricing Mechanism 1 (CONTINU E D) $156,000,000 Investors (Cap) Cap of Incentive of Borrowers and to of Borrowers Payments on Behalf Servicers & Lenders/ Financial Instrument for Home L oan Modifications Investment Description Purchase Transaction Transaction Type Servicer Modifying Borrowers’ Loans Servicer Modifying Borrowers’ Green Tree Servicing LL C, Tree Green Saint Paul, MN Name of Institution 4/24/2009 HAMP TRANSACTION DETAIL, AS OF 6/30/2012 HAMP TRANSACTION DETAIL, Date 282 Appendix D I Transaction Detail I July 25, 2012 Incentive Payments Total TARP TARP Total $82,572,012 $28,962,212 Continued on next page Servicers Incentives $27,897,267 $10,053,971 Investors Lenders/ Incentives TARP Incentive Payments TARP $39,290,553 $14,313,396 Incentives Borrower’s Borrower’s $4,594,845 $15,384,192 A initial cap A initial cap Updated portfolio data from servicer & Updated portfolio data from HPDP initial cap servicer & Updated portfolio data from H A F servicer Updated portfolio data from servicer Updated portfolio data from Initial FH A -H MP cap servicer Updated portfolio data from of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from servicer Updated portfolio data from Updated due to quarterly assessment and reallocation of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from servicer Updated portfolio data from of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from servicer & Updated portfolio data from HPDP initial cap servicer & Updated portfolio data from H A F servicer Updated portfolio data from servicer Updated portfolio data from Reason for Adjustment Adjusted Cap $447,690,000 $469,020,000 $478,170,000 $401,300,000 $401,700,000 $393,245,731 $411,245,015 $411,241,742 $411,141,742 $410,641,742 $410,639,974 $459,550,000 $393,245,389 $393,245,015 $411,041,742 $293,649,384 $293,646,864 $291,409,384 $290,559,384 $290,459,384 $288,359,384 $289,359,384 $288,259,384 $286,459,384 $286,462,976 $283,763,685 $284,063,685 $286,463,360 $280,000,000 $284,063,360 $131,020,000 $222,010,000 $279,990,000 $354,510,000 $278,900,000 Adjustment Details ($342) ($374) ($384) ($325) Amount ($3,273) ($1,768) ($2,520) ($3,592) $400,000 $100,000 $850,000 $100,000 $100,000 $300,000 ($500,000) ($200,000) $9,150,000 $2,240,000 $1,100,000 $1,000,000 $1,800,000 $3,763,685 $2,400,000 $1,100,000 ($8,454,269) $21,330,000 $18,000,000 $90,990,000 $57,980,000 $74,520,000 ($76,870,000) ($11,860,000) ($75,610,000) ($63,980,000) ($338,450,000) Cap Adjustment Date 9/1/2010 1/6/2011 1/6/2011 7/14/2010 9/30/2010 6/29/2011 4/16/2012 6/28/2012 9/30/2009 3/26/2010 3/30/2011 5/13/2011 3/15/2012 6/28/2012 6/17/2009 6/14/2012 5/16/2012 4/16/2012 2/16/2012 9/15/2011 8/16/2011 6/29/2011 3/30/2011 9/30/2010 1/13/2011 7/14/2010 8/13/2010 6/17/2009 9/30/2009 3/26/2010 Adjustment 12/30/2009 10/14/2011 11/16/2011 12/15/2010 12/30/2009 Note N/ A N/ A Pricing Mechanism 1 (CONTINU E D) $798,000,000 $195,000,000 Investors (Cap) Cap of Incentive of Borrowers and to of Borrowers Payments on Behalf Servicers & Lenders/ Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Investment Description Purchase Purchase Transaction Transaction Type Servicer Modifying Borrowers’ Loans Servicer Modifying Borrowers’ urora L oan Services, LL C, A urora L ittleton, CO Carrington Mortgage Services, LL C, Santa A na, C Name of Institution 5/1/2009 4/27/2009 HAMP TRANSACTION DETAIL, AS OF 6/30/2012 HAMP TRANSACTION DETAIL, Date Transaction detail I Appendix D I July 25, 2012 283 Incentive Payments Total TARP TARP Total $3,609,266 $53,351,657 Continued on next page Servicers Incentives $1,312,289 $19,043,370 Investors Lenders/ Incentives $1,717,443 TARP Incentive Payments TARP $24,123,922 $579,534 Incentives Borrower’s Borrower’s $10,184,365 A initial cap A initial cap Updated due to quarterly assessment and reallocation Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from servicer Updated portfolio data from Initial FH A -H MP cap, initial -2 L P and initial 2MP cap Updated portfolio data from servicer Updated portfolio data from Updated due to quarterly assessment and reallocation servicer & Updated portfolio data from HPDP initial cap servicer & Updated portfolio data from H A F servicer Updated portfolio data from Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation Transfer of cap due to servicing transfer Transfer servicer Updated portfolio data from of cap due to servicing transfer Transfer Updated portfolio data from servicer Updated portfolio data from servicer Updated portfolio data from Initial FH A -H MP cap, initial -2 L P and initial 2MP cap initial RD-H A MP, Transfer of cap due to servicing transfer Transfer Updated portfolio data from servicer Updated portfolio data from servicer & Updated portfolio data from HPDP initial cap servicer & Updated portfolio data from H A F servicer Updated portfolio data from servicer Updated portfolio data from Reason for Adjustment $40,666,241 $40,666,554 $32,606,554 $29,386,554 $32,186,554 $31,286,883 $31,286,554 $31,186,883 $31,186,954 $31,186,920 $30,600,000 $30,200,000 $17,540,000 $45,460,000 $44,070,000 Adjusted Cap $400,980,993 $403,363,950 $400,983,950 $403,278,198 $403,273,950 $403,373,950 $403,273,950 $383,201,123 $383,200,695 $350,801,486 $352,501,486 $353,401,123 $350,101,486 $352,501,123 $316,300,000 $313,400,000 $117,140,000 $251,700,000 $331,950,000 $399,200,000 $313,300,000 Adjustment Details ($37) ($34) ($313) ($329) ($428) ($363) Amount ($2,957) ($4,248) $90,000 $420,000 $100,000 $586,954 $400,000 $100,000 $700,000 $900,000 $100,000 ($100,000) $8,060,000 $2,800,000 $1,700,000 $2,900,000 ($1,900,000) ($1,860,000) ($2,380,000) ($1,390,000) $27,920,000 $20,077,503 $29,800,000 $33,801,486 $16,140,000 $80,250,000 $67,250,000 ($13,870,000) ($85,900,000) $134,560,000 Cap Adjustment Date 1/6/2011 1/6/2011 6/28/2012 6/14/2012 5/16/2012 6/29/2011 9/15/2011 4/13/2011 3/30/2011 9/30/2010 9/30/2010 9/30/2009 7/14/2010 6/14/2012 6/28/2012 3/26/2010 6/29/2011 3/15/2012 5/16/2012 3/30/2011 5/26/2011 3/16/2011 2/16/2011 9/30/2010 9/30/2010 7/14/2010 8/13/2010 6/12/2009 9/30/2009 3/26/2010 Adjustment 11/16/2011 12/30/2009 11/16/2011 11/16/2010 12/15/2010 12/30/2009 Note N/ A N/ A Pricing Mechanism 1 (CONTINU E D) $19,400,000 $101,000,000 Investors (Cap) Cap of Incentive of Borrowers and to of Borrowers Payments on Behalf Servicers & Lenders/ Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Investment Description Purchase Purchase Transaction Transaction Type Servicer Modifying Borrowers’ Loans Servicer Modifying Borrowers’ Residential Credit Residential Credit Solutions, Fort Worth,TX Nationstar Mortgage LL C, L ewisville, TX Name of Institution 6/12/2009 5/28/2009 HAMP TRANSACTION DETAIL, AS OF 6/30/2012 HAMP TRANSACTION DETAIL, Date 284 Appendix D I Transaction Detail I July 25, 2012 $— Incentive $678,877 $793,769 Payments Total TARP TARP Total $6,019,345 Continued on next page $— $210,613 $401,334 Servicers Incentives $2,122,605 $— Investors Lenders/ $374,719 $227,582 Incentives $2,828,713 TARP Incentive Payments TARP $— $93,546 $164,853 Incentives Borrower’s Borrower’s $1,068,026 A A A initial cap A initial cap A initial cap A initial cap Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer of SP Termination Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer & Updated portfolio data from HPDP initial cap servicer Updated portfolio data from Updated portfolio data from servicer & Updated portfolio data from H A F servicer Updated portfolio data from of SP Termination servicer & Updated portfolio data from H A F servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated portfolio data from servicer & Updated portfolio data from HPDP initial cap servicer & Updated portfolio data from H A F servicer Updated portfolio data from servicer Updated portfolio data from servicer Updated portfolio data from servicer Updated portfolio data from servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer & Updated portfolio data from HPDP initial cap servicer & Updated portfolio data from H A F servicer Updated portfolio data from Reason for Adjustment $0 $678,877 $870,000 $1,668,877 $2,551,664 $4,351,664 $4,351,666 $4,351,668 $2,800,000 $1,300,000 $2,790,000 $3,100,000 $3,490,000 $14,160,000 $17,360,000 $37,040,114 $37,039,652 $45,700,000 $69,130,000 $54,660,000 $45,800,000 $41,340,846 $37,040,846 $37,040,730 $42,645,793 $42,645,484 $37,040,795 $42,646,346 $42,646,245 $34,800,000 $42,646,300 $29,590,000 $58,150,000 Adjusted Cap $175,100,000 Adjustment Details ($2) ($2) ($65) ($51) ($55) ($46) ($616) ($462) ($452) ($309) Amount $990,000 $330,000 $1,551,668 $1,500,000 $2,020,000 $7,846,346 ($1,800,000) ($1,872,787) ($1,800,000) ($8,860,000) ($4,459,154) ($4,300,000) $11,370,000 $16,490,000 $65,640,000 $13,070,000 ($14,160,000) ($14,260,000) ($11,300,000) ($42,210,000) ($14,470,000) ($23,350,000) $145,510,000 ($116,950,000) Cap Adjustment Date 6/3/2011 1/6/2011 4/9/2010 1/6/2011 1/6/2011 6/14/2012 5/13/2011 3/30/2011 9/30/2010 7/30/2010 5/26/2010 9/30/2009 7/14/2010 6/28/2012 3/26/2010 3/26/2010 7/14/2010 9/30/2010 6/29/2011 6/28/2012 9/30/2009 3/26/2010 3/30/2011 6/29/2011 9/30/2010 3/30/2011 7/14/2010 9/30/2009 3/26/2010 Adjustment 12/30/2009 12/30/2009 12/30/2009 12/15/2010 12/30/2009 9,12 Note N/ A N/ A N/ A N/ A Pricing Mechanism 1 (CONTINU E D) $540,000 $770,000 $57,000,000 $16,520,000 Investors (Cap) Cap of Incentive of Borrowers and to of Borrowers Payments on Behalf Servicers & Lenders/ Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Investment Description Purchase Purchase Purchase Purchase Transaction Transaction Type A Servicer Modifying Borrowers’ Loans Servicer Modifying Borrowers’ Wescom Central Credit Central Credit Wescom Union, A naheim, C First Federal Savings and L oan, Port A ngeles, W RG Mortgage Corporation, San Juan, PR CCO Mortgage, Glen A llen, V Name of Institution 6/19/2009 6/19/2009 6/17/2009 6/17/2009 HAMP TRANSACTION DETAIL, AS OF 6/30/2012 HAMP TRANSACTION DETAIL, Date Transaction detail I Appendix D I July 25, 2012 285 $— Incentive $163,089 Payments Total TARP TARP Total $8,096,738 Continued on next page $— $42,417 Servicers Incentives $2,706,837 $— $96,423 Investors Lenders/ Incentives $4,218,459 TARP Incentive Payments TARP $— $24,250 Incentives Borrower’s Borrower’s $1,171,443 A A initial cap A initial cap A initial cap Updated due to quarterly assessment and reallocation Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer Updated portfolio data from servicer Updated portfolio data from servicer Updated portfolio data from Initial FH A -H MP cap, -2 L P and initial 2MP cap Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer & Updated portfolio data from HPDP initial cap servicer & Updated portfolio data from H A F servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer & Updated portfolio data from H A F servicer Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from of SP Termination Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer & Updated portfolio data from HPDP initial cap servicer & Updated portfolio data from H A F servicer Updated portfolio data from Reason for Adjustment $0 $20,000 $30,000 $145,056 $100,000 $610,000 $1,160,422 $1,160,431 $1,160,443 $1,160,444 $1,160,445 $2,250,000 $1,530,000 $1,100,000 Adjusted Cap $558,602,227 $558,618,998 $558,608,998 $558,318,998 $558,318,998 $558,618,998 $558,518,998 $558,418,998 $561,028,195 $558,728,195 $558,528,195 $558,328,195 $558,318,998 $561,129,176 $561,029,176 $560,930,004 $560,929,176 $489,700,000 $409,100,000 $610,150,000 $700,430,000 $681,740,000 Adjustment Details $0 ($9) ($12) ($981) ($828) Amount ($6,771) ($9,197) $60,445 $45,056 $70,000 ($10,000) ($10,000) $200,000 $300,000 $200,000 $200,000 $590,000 ($100,000) ($200,000) ($200,000) ($300,000) ($100,000) ($720,000) ($430,000) ($145,056) ($580,000) $2,180,000 ($2,300,000) $71,230,004 $80,600,000 $90,280,000 ($18,690,000) $315,170,000 ($272,640,000) Cap Adjustment Date 1/6/2011 1/6/2011 6/14/2012 6/28/2012 8/16/2011 2/16/2012 3/15/2012 4/13/2011 5/13/2011 6/16/2011 6/29/2011 1/13/2012 3/16/2011 3/30/2011 2/16/2011 9/30/2010 9/30/2010 7/14/2010 9/30/2009 3/26/2010 6/28/2012 6/29/2011 3/30/2011 3/26/2010 7/14/2010 9/30/2010 2/17/2011 9/30/2010 9/30/2009 3/26/2010 7/14/2010 Adjustment 10/14/2011 11/16/2011 12/30/2009 12/30/2009 12/30/2009 Note N/ A N/ A N/ A Pricing Mechanism 1 (CONTINU E D) $70,000 $30,000 $294,980,000 Investors (Cap) Cap of Incentive of Borrowers and to of Borrowers Payments on Behalf Servicers & Lenders/ Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Investment Description Purchase Purchase Purchase Transaction Transaction Type Servicer Modifying Borrowers’ Loans Servicer Modifying Borrowers’ National City B ank, OH Miamisburg, Technology Credit Union, Credit Technology San Jose, C A Citizens First Wholesale Mortgage Company, The Villages, F L Name of Institution 6/26/2009 6/26/2009 6/26/2009 HAMP TRANSACTION DETAIL, AS OF 6/30/2012 HAMP TRANSACTION DETAIL, Date 286 Appendix D I Transaction Detail I July 25, 2012 $10,651 Incentive $238,890 Payments Total TARP TARP Total $18,788,745 Continued on next page $4,000 $162,000 Servicers Incentives $6,726,046 $3,651 $76,890 Investors Lenders/ Incentives $8,113,932 TARP Incentive Payments TARP $— $3,000 Incentives Borrower’s Borrower’s $3,948,767 A initial cap A initial cap A initial cap Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer & Updated portfolio data from H A F Updated portfolio data from servicer & Updated portfolio data from HPDP initial cap Transfer of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Updated portfolio data from servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Initial FH A -2 L P cap servicer Updated portfolio data from Updated portfolio data from servicer & Updated portfolio data from HPDP initial cap servicer & Updated portfolio data from HPDP initial cap servicer & Updated portfolio data from H A F servicer Updated portfolio data from Initial 2MP cap servicer Updated portfolio data from Transfer of cap (to Wells Fargo B ank) due Fargo of cap (to Wells Transfer to merger Reason for Adjustment servicer & Updated portfolio data from H A F B ank) due Fargo of cap (to Wells Transfer to merger $435,165 $435,159 $435,155 $435,167 $435,166 $400,000 $430,000 $380,000 $250,000 $238,890 $293,656 $85,786,770 $85,786,262 $83,976,770 $83,946,770 $83,846,770 $83,746,770 $81,446,770 $99,446,770 $80,546,770 $98,846,770 $98,847,541 $98,747,541 $98,347,697 $98,347,541 $98,347,627 $68,110,000 Adjusted Cap $113,600,000 $111,700,000 $146,240,000 $147,250,000 $113,000,000 $1,357,890,000 $2,050,530,000 Adjustment Details ($6) ($4) ($86) ($70) ($508) ($771) Amount $35,167 $50,000 $30,000 ($30,000) ($54,767) $130,000 $150,000 $200,000 $900,000 $600,000 $100,000 $400,000 $600,000 ($100,000) $1,810,000 $2,400,000 $1,010,000 $23,850,000 $43,590,000 $34,540,000 ($18,900,000) ($15,252,303) ($34,250,000) $723,880,000 $692,640,000 Cap Adjustment ($2,050,236,344) Date 1/6/2011 1/6/2011 5/7/2010 6/29/2011 6/28/2012 3/30/2011 9/30/2010 7/14/2010 3/26/2010 6/28/2012 9/30/2009 6/14/2012 5/16/2012 3/15/2012 4/16/2012 2/16/2012 1/13/2012 9/15/2011 6/29/2011 5/13/2011 4/13/2011 9/30/2010 3/30/2011 7/14/2010 9/30/2010 9/30/2009 9/30/2009 3/26/2010 3/12/2010 2/17/2010 Adjustment 12/30/2009 10/14/2011 12/30/2009 12/30/2009 3 Note N/ A N/ A N/ A Pricing Mechanism 1 (CONTINU E D) $100,000 $44,260,000 $634,010,000 Investors (Cap) Cap of Incentive of Borrowers and to of Borrowers Payments on Behalf Servicers & Lenders/ Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Investment Description Purchase Purchase Purchase Transaction Transaction Type Servicer Modifying Borrowers’ Loans Servicer Modifying Borrowers’ L ake National B ank, OH Mentor, Wachovia Mortgage, Wachovia FS B , Des Moines, I A B ayview L oan Servicing, LL C, Coral Gables, F L Name of Institution 7/10/2009 7/1/2009 7/1/2009 HAMP TRANSACTION DETAIL, AS OF 6/30/2012 HAMP TRANSACTION DETAIL, Date Transaction detail I Appendix D I July 25, 2012 287 $— $48,394 Incentive $493,077 Payments Total TARP TARP Total $4,628,165 Continued on next page $— $16,000 $221,250 Servicers Incentives $1,977,321 $— $23,394 Investors Lenders/ $245,244 Incentives $2,305,003 TARP Incentive Payments TARP $— $9,000 $26,583 $345,841 Incentives Borrower’s Borrower’s A A A initial cap A initial cap A initial cap A initial cap Updated portfolio data from servicer Updated portfolio data from of SP Termination Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer & Updated portfolio data from HPDP initial cap servicer & Updated portfolio data from H A F Transfer of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Initial FH A -2 L P cap and initial 2MP Updated portfolio data from servicer & Updated portfolio data from HPDP initial cap servicer Updated portfolio data from Termination of SP Termination cap equals distribution amount) (remaining servicer & Updated portfolio data from H A F servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from of cap due to servicing transfer Transfer Updated portfolio data from servicer Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer & Updated portfolio data from HPDP initial cap servicer & Updated portfolio data from H A F servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer & Updated portfolio data from HPDP initial cap servicer & Updated portfolio data from H A F Reason for Adjustment $0 $80,000 $145,056 $100,000 $230,000 $130,000 $870,311 $870,320 $870,332 $870,334 $870,333 $700,000 $860,000 $4,628,165 $1,100,000 $1,110,000 $81,275,921 $81,274,539 $80,974,539 $80,973,536 $81,376,191 $81,376,068 $81,375,921 $58,300,000 $18,230,000 $22,800,000 $37,510,000 $39,980,000 $24,705,668 $54,105,739 $24,705,702 $62,300,000 $54,105,702 $42,010,000 $66,520,000 $84,880,000 Adjusted Cap Adjustment Details ($9) ($34) ($37) ($12) ($123) ($147) Amount ($1,382) ($1,003) $45,056 $50,000 ($90,000) ($10,000) ($10,000) $100,000 $170,334 $250,000 ($145,056) ($130,000) ($100,000) ($300,000) ($400,000) $2,470,000 ($8,194,261) $23,076,191 $35,500,000 $19,280,000 $18,530,000 $24,510,000 $18,360,000 ($36,240,000) ($17,180,000) ($20,077,503) ($29,400,000) ($22,580,000) Cap Adjustment Date 1/6/2011 1/6/2011 1/6/2011 5/20/2011 9/30/2010 7/14/2010 3/26/2010 6/29/2011 6/28/2012 9/30/2009 3/30/2011 5/13/2011 9/30/2010 9/30/2010 9/30/2009 7/14/2010 5/26/2011 3/26/2010 3/30/2011 9/30/2010 3/16/2011 7/14/2010 9/30/2009 3/26/2010 6/28/2012 6/29/2011 3/30/2011 9/30/2010 7/14/2010 9/30/2009 3/26/2010 Adjustment 12/30/2009 10/14/2011 12/30/2009 12/30/2009 12/30/2009 11 Note N/ A N/ A N/ A N/ A Pricing Mechanism 1 (CONTINU E D) $170,000 $870,000 $54,470,000 $23,480,000 Investors (Cap) Cap of Incentive of Borrowers and to of Borrowers Payments on Behalf Servicers & Lenders/ Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Investment Description Purchase Purchase Purchase Purchase Transaction Transaction Type A Servicer Modifying Borrowers’ Loans Servicer Modifying Borrowers’ Farmers State B ank, Salem, OH West PNC B ank, National A ssociation, P Pittsburgh, quity, Inc., Mor E quity, E vansville, IN I B M Southeast E mployees’ Union, Federal Credit Delray B each,F L Name of Institution 7/17/2009 7/17/2009 7/17/2009 7/10/2009 HAMP TRANSACTION DETAIL, AS OF 6/30/2012 HAMP TRANSACTION DETAIL, Date 288 Appendix D I Transaction Detail I July 25, 2012 Incentive $383,365 $346,986 Payments Total TARP TARP Total $200,670,091 Continued on next page $166,278 $143,165 Servicers Incentives $69,454,750 Investors Lenders/ $143,149 $153,906 Incentives TARP Incentive Payments TARP $99,560,346 $73,939 $49,915 Incentives Borrower’s Borrower’s $31,654,995 A initial cap A initial cap A initial cap Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Updated portfolio data from servicer & Updated portfolio data from HPDP initial cap servicer Updated portfolio data from servicer Updated portfolio data from Updated due to quarterly assessment and reallocation servicer & Updated portfolio data from H A F servicer Updated portfolio data from Transfer of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from of cap due to servicing transfer Transfer servicer Updated portfolio data from of cap due to servicing transfer Transfer Updated portfolio data from servicer & Updated portfolio data from H A F servicer Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer & Updated portfolio data from HPDP initial cap Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Transfer of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer & Updated portfolio data from HPDP initial cap servicer & Updated portfolio data from H A F servicer Updated portfolio data from servicer Updated portfolio data from Reason for Adjustment $8,558,031 $8,558,125 $8,558,280 $8,558,254 $5,990,000 $5,900,000 $8,558,268 $8,830,000 $2,671,372 $2,671,401 $2,671,439 $3,771,439 $3,771,443 $3,771,446 $2,300,000 $3,560,000 $3,540,000 $3,300,000 $11,630,000 Adjusted Cap $1,306,356,674 $1,308,587,935 $1,308,575,052 $1,307,575,052 $1,307,475,052 $1,306,375,052 $1,306,365,052 $1,306,090,508 $1,305,487,935 $1,305,790,508 $1,305,990,508 $1,305,989,335 $1,305,489,335 $1,469,270,000 $1,594,090,000 $1,304,100,000 $1,218,820,000 Adjustment Details ($4) ($3) ($94) ($14) ($12) ($29) ($38) ($129) Amount ($8,378) ($1,400) ($1,173) ($12,883) ($10,000) ($20,000) $300,000 $471,446 $890,000 ($100,000) ($100,000) ($500,000) ($240,000) $2,658,280 $1,780,000 $2,840,000 $2,800,000 $3,100,000 $1,690,508 $1,260,000 ($5,730,000) ($1,000,000) ($1,100,000) ($1,100,000) ($53,670,000) $250,450,000 $124,820,000 ($289,990,000) Cap Adjustment Date 1/6/2011 1/6/2011 1/6/2011 6/28/2012 6/29/2011 9/30/2010 3/30/2011 9/30/2009 7/14/2010 6/29/2011 9/15/2011 5/16/2012 6/28/2012 3/26/2010 4/13/2011 2/16/2011 3/30/2011 7/14/2010 9/30/2010 3/26/2010 9/30/2009 6/28/2012 6/29/2011 4/13/2011 3/30/2011 7/14/2010 9/30/2010 9/30/2009 3/26/2010 Adjustment 10/14/2011 11/16/2011 12/30/2009 10/15/2010 11/16/2010 12/30/2009 12/30/2009 Note N/ A N/ A N/ A Pricing Mechanism 1 (CONTINU E D) $4,210,000 $1,410,000 $1,272,490,000 Investors (Cap) Cap of Incentive of Borrowers and to of Borrowers Payments on Behalf Servicers & Lenders/ Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Investment Description Purchase Purchase Purchase Transaction Transaction Type Servicer Modifying Borrowers’ Loans Servicer Modifying Borrowers’ Mortgage Center, LL C, Mortgage Center, Southfield, MI A merican Home Mortgage Servicing, Inc (Homeward Residential), Coppell, TX B ank, Shore Chicago, I L Name of Institution 7/22/2009 7/22/2009 7/17/2009 HAMP TRANSACTION DETAIL, AS OF 6/30/2012 HAMP TRANSACTION DETAIL, Date Transaction detail I Appendix D I July 25, 2012 289 $— $3,795 Incentive $185,981 Payments Total TARP TARP Total $2,611,067 Continued on next page $— $2,000 $66,472 $966,528 Servicers Incentives $— $795 $87,921 Investors Lenders/ Incentives $1,146,897 TARP Incentive Payments TARP $— $1,000 $31,588 $497,642 Incentives Borrower’s Borrower’s A A initial cap A initial cap A initial cap A initial cap Updated portfolio data from servicer Updated portfolio data from of SP Termination Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer & Updated portfolio data from HPDP initial cap servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation servicer & Updated portfolio data from H A F Updated portfolio data from servicer Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer & Updated portfolio data from HPDP initial cap servicer & Updated portfolio data from H A F servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer & Updated portfolio data from H A F servicer Updated portfolio data from Updated portfolio data from servicer & Updated portfolio data from HPDP initial cap Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer & Updated portfolio data from HPDP initial cap servicer & Updated portfolio data from H A F servicer Updated portfolio data from Reason for Adjustment $0 $580,220 $580,212 $580,206 $580,222 $580,221 $400,000 $725,272 $725,277 $725,273 $725,278 $600,000 $370,000 $780,000 $8,413,225 $1,030,000 $2,290,000 $4,360,000 $8,123,092 $8,123,095 $8,123,110 $8,123,114 $8,123,112 $5,600,000 $5,610,000 $8,070,000 $4,930,000 $7,120,000 $37,100,000 $47,320,000 $83,300,000 $73,480,000 Adjusted Cap Adjustment Details ($8) ($6) ($3) ($2) ($2) ($4) ($15) Amount ($60,000) $180,222 $680,000 $125,278 ($180,000) ($490,000) $9,820,000 $1,260,000 $2,070,000 $2,523,114 $2,460,000 $6,750,000 ($8,413,225) ($3,960,000) ($2,470,000) ($1,530,000) ($6,340,000) $26,160,000 ($28,686,775) ($46,200,000) ($37,700,000) Cap Adjustment Date 1/6/2011 1/6/2011 12/3/2010 9/30/2010 7/14/2010 6/29/2011 6/28/2012 9/30/2009 3/26/2010 3/30/2011 9/30/2010 7/14/2010 9/30/2009 3/26/2010 6/28/2012 6/29/2011 3/30/2011 9/30/2010 7/14/2010 3/26/2010 9/30/2009 6/29/2011 6/28/2012 3/30/2011 9/30/2010 7/14/2010 9/30/2009 3/26/2010 Adjustment 12/30/2009 12/30/2009 12/30/2009 12/30/2009 Note N/ A N/ A N/ A N/ A Pricing Mechanism 1 (CONTINU E D) $860,000 $1,090,000 $6,460,000 $85,020,000 Investors (Cap) Cap of Incentive of Borrowers and to of Borrowers Payments on Behalf Servicers & Lenders/ Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Investment Description Purchase Purchase Purchase Purchase Transaction Transaction Type Servicer Modifying Borrowers’ Loans Servicer Modifying Borrowers’ Wachovia B ank, N. A ., Wachovia Charlotte, NC Purdue E mployees Federal Purdue Union, Credit L afayette, IN West First B ank, St. L ouis, MO Mission Federal Credit Mission Federal Credit Union, San Diego, C A Name of Institution 7/29/2009 7/29/2009 7/29/2009 7/22/2009 HAMP TRANSACTION DETAIL, AS OF 6/30/2012 HAMP TRANSACTION DETAIL, Date 290 Appendix D I Transaction Detail I July 25, 2012 Incentive Payments Total TARP TARP Total $612,191,506 Continued on next page Servicers Incentives $216,452,100 Investors Lenders/ Incentives TARP Incentive Payments TARP $257,612,401 Incentives Borrower’s Borrower’s $138,127,005 A initial cap Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from Updated due to quarterly assessment and reallocation of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation Initial FH A -H MP cap, -2 L P and initial RD-H A MP servicer Updated portfolio data from of cap due to servicing transfer Transfer Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer & Updated portfolio data from HPDP initial cap servicer & Updated portfolio data from H A F servicer & Updated portfolio data from 2MP initial cap Reason for Adjustment Adjusted Cap $3,346,083,295 $3,865,294,604 $3,346,383,295 $3,345,983,295 $3,345,883,295 $3,862,494,604 $3,862,394,604 $3,862,294,604 $3,736,214,604 $3,734,594,604 $3,734,578,412 $3,223,425,536 $3,223,317,901 $3,223,117,901 $3,345,817,901 $3,345,783,295 $3,007,800,000 $3,223,421,900 $3,223,321,900 $2,935,400,000 $2,684,870,000 $3,863,050,000 $4,869,630,000 Adjustment Details Amount ($3,999) ($3,636) ($16,192) ($34,606) $200,000 $600,000 ($400,000) ($100,000) ($100,000) ($100,000) ($200,000) ($100,000) ($2,800,000) ($1,620,000) $72,400,000 ($14,850,000) $519,211,309 $215,625,536 $122,700,000 ($126,080,000) $1,178,180,000 $1,006,580,000 Cap Adjustment ($1,934,230,000) Date 1/6/2011 8/16/2011 9/15/2011 1/13/2012 2/16/2012 5/16/2012 6/14/2012 6/28/2012 4/13/2011 5/13/2011 6/29/2011 7/14/2011 9/30/2010 3/16/2011 3/30/2011 9/30/2010 9/30/2009 3/26/2010 7/14/2010 Adjustment 10/14/2011 10/19/2011 11/16/2011 12/30/2009 Note N/ A Pricing Mechanism 1 (CONTINU E D) $2,699,720,000 Investors (Cap) Cap of Incentive of Borrowers and to of Borrowers Payments on Behalf Servicers & Lenders/ Financial Instrument for Home L oan Modifications Investment Description Purchase Transaction Transaction Type Servicer Modifying Borrowers’ Loans Servicer Modifying Borrowers’ J.P. Morgan Chase B ank, Morgan J.P. N A , L ewisville, TX Name of Institution 7/31/2009 HAMP TRANSACTION DETAIL, AS OF 6/30/2012 HAMP TRANSACTION DETAIL, Date Transaction detail I Appendix D I July 25, 2012 291 $10,068 $18,751 Incentive Payments Total TARP TARP Total $35,441,779 Continued on next page $6,500 $11,273 Servicers Incentives $16,279,383 $3,568 $3,552 Investors Lenders/ Incentives TARP Incentive Payments TARP $11,592,937 $— $3,926 Incentives Borrower’s Borrower’s $7,569,459 A A A initial cap A initial cap A initial cap Updated due to quarterly assessment and reallocation of SP Termination Transfer of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer & Updated portfolio data from HPDP initial cap servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation servicer & Updated portfolio data from H A F Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer & Updated portfolio data from HPDP initial cap servicer & Updated portfolio data from H A F Transfer of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation of cap due to servicing transfer Transfer of SP Termination Initial FH A -H MP cap and initial -2 L P cap servicer Updated portfolio data from of cap due to servicing transfer Transfer servicer Updated portfolio data from servicer Updated portfolio data from of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation Updated portfolio data from servicer & Updated portfolio data from H A F servicer Updated portfolio data from of cap to Saxon Mortgage Transfer Services, Inc. Updated portfolio data from servicer & Updated portfolio data from HPDP initial cap servicer & Updated portfolio data from 2MP initial cap Reason for Adjustment $10,068 $525,269 $525,276 $725,276 $725,277 $800,000 $725,278 $430,000 $810,000 $290,108 $290,106 $640,000 $290,111 $200,000 $270,000 $600,000 $250,000 $35,441,779 Adjusted Cap $555,261,816 $555,253,088 $554,653,088 $695,570,000 $687,563,543 $687,463,543 $683,063,543 $683,062,741 $682,162,741 $678,162,741 $678,161,816 $683,100,000 $682,470,000 $707,370,000 $1,209,800,000 $1,075,240,000 Adjustment Details ($7) ($3) ($2) ($802) ($925) Amount ($8,728) $90,111 $20,000 ($74,722) ($10,000) ($70,000) ($10,000) $290,000 $170,000 $210,000 $180,000 ($515,201) ($200,000) ($600,000) ($350,000) ($100,000) ($900,000) ($630,000) ($8,006,457) ($4,400,000) ($4,000,000) $13,100,000 $502,430,000 ($122,900,000) ($519,211,309) ($134,560,000) ($392,140,000) Cap Adjustment Date 1/6/2011 1/6/2011 7/22/2011 6/29/2011 4/13/2011 3/30/2011 9/30/2010 7/14/2010 6/28/2012 9/30/2009 3/26/2010 6/29/2011 9/30/2010 7/14/2010 3/26/2010 6/29/2011 7/14/2011 9/30/2009 9/30/2010 2/16/2011 3/16/2011 3/30/2011 5/13/2011 7/16/2010 9/30/2010 9/30/2009 3/26/2010 7/14/2010 Adjustment 12/30/2009 12/30/2009 10/15/2010 12/15/2010 10/19/2011 12/30/2009 12 14 Note N/ A N/ A N/ A Pricing Mechanism 1 (CONTINU E D) $140,000 $420,000 $707,380,000 Investors (Cap) Cap of Incentive of Borrowers and to of Borrowers Payments on Behalf Servicers & Lenders/ Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Investment Description Purchase Purchase Purchase Transaction Transaction Type Servicer Modifying Borrowers’ Loans Servicer Modifying Borrowers’ Oakland Municipal Credit Oakland Municipal Credit Union, Oakland, C A ank, Warsaw, IN L ake City B ank, Warsaw, E MC Mortgage Corporation, L ewisville, TX Name of Institution 8/5/2009 8/5/2009 7/31/2009 HAMP TRANSACTION DETAIL, AS OF 6/30/2012 HAMP TRANSACTION DETAIL, Date 292 Appendix D I Transaction Detail I July 25, 2012 Incentive Payments Total TARP TARP Total $8,308,819 $76,324,760 Continued on next page Servicers Incentives $5,272,500 $27,530,414 Investors Lenders/ Incentives $3,036,319 TARP Incentive Payments TARP $35,353,126 $— Incentives Borrower’s Borrower’s $13,441,220 A initial cap A initial cap Updated portfolio data from servicer Updated portfolio data from of cap due to servicing transfer Transfer servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation servicer & Updated portfolio data from HPDP initial cap servicer & Updated portfolio data from H A F servicer Updated portfolio data from servicer Updated portfolio data from of cap to due servicing transfer Transfer of cap to due servicing transfer Transfer servicer Updated portfolio data from servicer Updated portfolio data from of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from servicer Updated portfolio data from of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation of cap due to servicing transfer Transfer servicer Updated portfolio data from of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer Updated portfolio data from servicer & Updated portfolio data from HPDP initial cap servicer & Updated portfolio data from H A F servicer Updated portfolio data from Reason for Adjustment Adjusted Cap $565,426,728 $394,626,728 $372,426,728 $371,519,358 $371,514,724 $853,966,911 $853,566,911 $853,557,183 $526,800,000 $372,426,179 $371,526,179 $371,525,526 $552,810,000 $516,520,000 $715,840,000 $1,087,950,000 $1,363,320,000 $1,642,230,000 $1,167,500,000 $1,166,800,000 $1,165,800,000 $1,050,782,764 $1,050,782,764 $1,059,581,478 $1,059,580,008 $1,056,280,008 $1,055,980,008 $1,055,280,008 $1,055,266,911 $1,055,066,911 $1,052,166,911 $1,049,982,764 $1,050,781,478 $1,051,866,911 $1,051,366,911 $1,048,766,911 Adjustment Details ($549) ($653) Amount ($6,168) ($4,634) ($1,470) ($9,728) ($1,286) ($13,097) $800,000 ($700,000) ($300,000) ($700,000) ($200,000) ($400,000) ($900,000) ($800,000) ($300,000) ($500,000) $8,800,000 ($1,000,000) ($3,300,000) ($2,900,000) ($2,600,000) $38,626,728 ($22,200,000) ($36,290,000) $313,050,000 $275,370,000 $278,910,000 $199,320,000 ($474,730,000) ($115,017,236) ($170,800,000) ($194,800,000) ($189,040,000) ($121,190,000) Cap Adjustment Date 1/6/2011 1/6/2011 6/28/2012 9/30/2009 7/14/2010 8/13/2010 9/15/2010 9/30/2010 3/30/2011 4/13/2011 5/13/2011 6/16/2011 6/29/2011 7/14/2011 9/15/2011 2/16/2012 6/28/2012 9/30/2010 2/16/2011 3/30/2011 6/29/2011 3/26/2010 3/16/2011 1/13/2012 7/14/2010 9/30/2009 3/26/2010 Adjustment 10/15/2010 12/15/2010 12/30/2009 10/15/2010 12/15/2010 10/14/2011 11/16/2011 12/15/2011 12/30/2009 Note N/ A N/ A Pricing Mechanism 1 (CONTINU E D) $774,900,000 $674,000,000 Investors (Cap) Cap of Incentive of Borrowers and to of Borrowers Payments on Behalf Servicers & Lenders/ Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Investment Description Purchase Purchase Transaction Transaction Type Servicer Modifying Borrowers’ Loans Servicer Modifying Borrowers’ P, L itton oan Servicing P, Houston, TX Hom E q Servicing Name of Institution 8/12/2009 8/5/2009 HAMP TRANSACTION DETAIL, AS OF 6/30/2012 HAMP TRANSACTION DETAIL, Date Transaction detail I Appendix D I July 25, 2012 293 Incentive Payments Total TARP TARP Total $10,397,232 Continued on next page Servicers Incentives $3,576,201 Investors Lenders/ Incentives $4,023,481 TARP Incentive Payments TARP Incentives Borrower’s Borrower’s $2,797,551 A initial cap Updated due to quarterly assessment and reallocation Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Updated portfolio data from servicer Updated portfolio data from of cap due to servicing transfer Transfer servicer Updated portfolio data from of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer Initial FH A -H MP cap and 2MP initial servicer Updated portfolio data from Transfer of cap to due servicing transfer Transfer of cap to due servicing transfer Transfer Transfer of cap from CitiMortgage, Inc. due of cap from Transfer to servicing transfer Updated portfolio data from servicer Updated portfolio data from Transfer of cap from CitiMortgage, Inc. due of cap from Transfer to servicing transfer Updated portfolio data from servicer & Updated portfolio data from HPDP initial cap servicer & Updated portfolio data from H A F servicer Updated portfolio data from Reason for Adjustment $5,010,000 $78,195,485 $78,195,825 $76,855,825 $76,655,825 $74,755,825 $72,855,825 $73,755,825 $74,555,825 $72,555,825 $69,755,825 $67,255,825 $67,256,637 $66,656,637 $60,956,637 $60,856,637 $60,956,731 $51,656,803 $53,056,803 $52,956,803 $57,056,731 $56,956,731 $53,080,000 $52,956,731 $52,980,000 $52,880,000 $50,380,000 $43,700,000 $61,720,000 $35,810,000 $59,010,000 Adjusted Cap Adjustment Details ($94) ($72) ($340) ($812) Amount $200,000 $200,000 $300,000 $900,000 $800,000 $600,000 $200,000 ($100,000) ($100,000) ($100,000) ($100,000) $1,340,000 $1,900,000 $2,800,000 $2,500,000 $5,800,000 $4,000,000 $1,400,000 $4,100,000 $2,600,000 $6,680,000 $2,710,000 ($1,423,197) ($1,200,000) $30,800,000 $23,200,000 ($18,020,000) Cap Adjustment Date 1/6/2011 6/28/2012 6/14/2012 4/16/2012 3/15/2012 1/13/2012 9/15/2011 7/14/2011 6/29/2011 6/16/2011 4/13/2011 5/13/2011 3/30/2011 2/16/2011 3/16/2011 9/30/2010 1/13/2011 9/15/2010 9/30/2010 8/13/2010 7/16/2010 7/14/2010 6/16/2010 9/30/2009 3/26/2010 Adjustment 10/14/2011 11/16/2011 12/15/2011 11/16/2010 12/15/2010 12/30/2009 Note N/ A Pricing Mechanism 1 (CONTINU E D) $6,210,000 Investors (Cap) Cap of Incentive of Borrowers and to of Borrowers Payments on Behalf Servicers & Lenders/ Financial Instrument for Home L oan Modifications Investment Description Purchase Transaction Transaction Type Servicer Modifying Borrowers’ Loans Servicer Modifying Borrowers’ PennyMac L oan Services, LL C, Calasbasa, C A Name of Institution 8/12/2009 HAMP TRANSACTION DETAIL, AS OF 6/30/2012 HAMP TRANSACTION DETAIL, Date 294 Appendix D I Transaction Detail I July 25, 2012 Incentive $681,772 Payments Total TARP TARP Total Continued on next page $220,309 Servicers Incentives Investors Lenders/ $323,870 Incentives TARP Incentive Payments TARP $137,593 Incentives Borrower’s Borrower’s A initial cap Transfer of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer servicer Updated portfolio data from of cap due to servicing transfer Transfer Updated portfolio data from servicer Updated portfolio data from servicer Updated portfolio data from Initial FH A -H MP cap Transfer of cap to due servicing transfer Transfer Initial 2MP cap servicer Updated portfolio data from Transfer of cap from CitiMortgage, Inc. due of cap from Transfer to servicing transfer Updated portfolio data from servicer & Updated portfolio data from HPDP initial cap servicer & Updated portfolio data from H A F servicer Updated portfolio data from Reason for Adjustment $9,500,000 $9,400,000 $9,300,000 $9,300,000 $4,220,000 $4,740,000 $9,070,000 $40,334,438 $40,333,973 $39,854,438 $38,774,438 $39,054,438 $37,954,438 $36,654,438 $32,354,438 $31,754,438 $35,754,438 $36,354,438 $36,554,438 $31,654,438 $31,654,972 $31,554,972 $30,554,972 $29,054,972 $29,055,024 $26,855,024 $26,355,064 $26,455,064 $26,755,024 $26,255,064 $26,455,024 $10,150,000 Adjusted Cap Adjustment Details ($52) ($40) ($465) ($534) Amount $800,000 $100,000 $700,000 $600,000 $200,000 $100,000 $100,000 $100,000 $100,000 $300,000 $100,000 $100,000 $850,000 $230,000 $520,000 ($600,000) ($850,000) $1,560,000 $1,100,000 $1,300,000 $4,000,000 $1,000,000 $1,500,000 $2,200,000 $4,330,000 ($1,080,000) $16,755,064 ($25,510,000) Cap Adjustment Date 1/6/2011 6/28/2012 5/16/2012 6/14/2012 4/16/2012 3/15/2012 2/16/2012 9/15/2011 1/13/2012 8/16/2011 6/29/2011 6/16/2011 5/13/2011 4/13/2011 3/30/2011 3/16/2011 2/16/2011 1/13/2011 9/30/2010 9/30/2010 7/14/2010 9/15/2010 5/19/2010 4/19/2010 9/30/2009 3/26/2010 Adjustment 10/14/2011 11/16/2011 12/15/2011 10/15/2010 12/15/2010 12/30/2009 Note N/ A Pricing Mechanism 1 (CONTINU E D) $29,730,000 Investors (Cap) Cap of Incentive of Borrowers and to of Borrowers Payments on Behalf Servicers & Lenders/ Financial Instrument for Home L oan Modifications Investment Description Purchase Transaction Transaction Type A Servicer Modifying Borrowers’ Loans Servicer Modifying Borrowers’ Servis One, Inc., Titusville, P Name of Institution 8/12/2009 HAMP TRANSACTION DETAIL, AS OF 6/30/2012 HAMP TRANSACTION DETAIL, Date Transaction detail I Appendix D I July 25, 2012 295 $— $20,179 Incentive $495,099 Payments Total TARP TARP Total $161,208,785 Continued on next page $— $6,570 $184,337 Servicers Incentives $47,391,810 $— $10,261 Investors Lenders/ $231,382 Incentives TARP Incentive Payments TARP $87,841,858 $— $3,348 $79,380 Incentives Borrower’s Borrower’s $25,975,117 A A initial cap A initial cap A initial cap A initial cap Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Initial RD-H A MP servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer & Updated portfolio data from H A F servicer Updated portfolio data from HPDP initial cap Updated due to quarterly assessment and reallocation of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from of cap due to servicing transfer Transfer HPDP initial cap servicer Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from of SP Termination servicer & Updated portfolio data from H A F servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from HPDP initial cap servicer & Updated portfolio data from H A F Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation 2MP initial cap servicer Updated portfolio data from servicer Updated portfolio data from HPDP initial cap servicer Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer & Updated portfolio data from H A F Reason for Adjustment $0 $50,000 $290,108 $290,106 $300,000 $290,111 $200,000 $690,000 $700,000 $290,111 $390,000 $370,000 $1,310,000 $1,730,000 $2,500,000 $1,500,000 $3,400,000 $3,050,000 $15,701,125 $15,701,125 $15,700,893 $15,700,719 $16,101,172 $15,701,150 $10,800,000 $16,101,150 Adjusted Cap $814,240,000 $1,836,253,881 $1,836,229,265 $1,836,213,784 $1,888,000,000 $1,836,258,837 $1,836,256,555 $2,291,350,000 $1,882,500,000 $2,170,170,000 Adjustment Details $0 ($3) ($2) ($25) ($22) ($232) ($174) Amount ($9,889) ($2,674) ($2,282) $70,000 ($24,616) ($15,481) $100,000 $130,000 $130,000 $350,000 ($400,000) ($290,111) ($310,000) $1,260,000 $1,040,000 $5,301,172 $8,300,000 $2,110,000 $2,680,000 $5,500,000 ($1,110,000) ($1,680,000) ($1,209,889) ($1,900,000) ($51,741,163) $145,800,000 $121,180,000 ($408,850,000) $1,355,930,000 Cap Adjustment Date 1/6/2011 1/6/2011 6/28/2012 9/30/2010 6/29/2011 9/30/2010 7/14/2010 3/26/2010 5/12/2010 4/13/2011 6/29/2011 6/28/2012 10/2/2009 3/30/2011 9/30/2010 3/16/2011 3/23/2010 10/2/2009 7/14/2010 9/30/2010 3/26/2010 7/14/2010 3/26/2010 6/29/2011 6/28/2012 10/2/2009 9/30/2010 3/30/2011 7/14/2010 9/30/2010 10/2/2009 3/26/2010 Adjustment 12/30/2009 12/30/2009 12/30/2009 12/30/2009 Note N/ A N/ A N/ A N/ A Pricing Mechanism 1 (CONTINU E D) $560,000 $570,000 $300,000 $668,440,000 Investors (Cap) Cap of Incentive of Borrowers and to of Borrowers Payments on Behalf Servicers & Lenders/ Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Investment Description Purchase Purchase Purchase Purchase Transaction Transaction Type Servicer Modifying Borrowers’ Loans Servicer Modifying Borrowers’ Horicon B ank, Horicon, WI RoundPoint Mortgage Servicing Corporation, Charlotte, NC Stanford Federal Credit Federal Credit Stanford Union, Palo A lto, C OneWest B ank, OneWest Pasadena, C A Name of Institution 9/2/2009 8/28/2009 8/28/2009 8/28/2009 HAMP TRANSACTION DETAIL, AS OF 6/30/2012 HAMP TRANSACTION DETAIL, Date 296 Appendix D I Transaction Detail I July 25, 2012 Incentive $232,528 $875,708 Payments Total TARP TARP Total $35,300,799 Continued on next page $106,317 $316,156 Servicers Incentives $13,130,906 $78,776 Investors Lenders/ $373,215 Incentives TARP Incentive Payments TARP $16,302,536 $47,434 $186,337 Incentives Borrower’s Borrower’s $5,867,358 A initial cap A initial cap A initial cap Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Updated portfolio data from servicer & Updated portfolio data from H A F servicer Updated portfolio data from servicer Updated portfolio data from HPDP initial cap Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from HPDP initial cap servicer & Updated portfolio data from H A F servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Transfer of cap due to servicing transfer Transfer Updated portfolio data from servicer Updated portfolio data from of cap due to servicing transfer Transfer servicer Updated portfolio data from of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer servicer Updated portfolio data from HPDP initial cap servicer & Updated portfolio data from H A F servicer Updated portfolio data from servicer Updated portfolio data from Reason for Adjustment $892,044 $870,332 $870,327 $870,334 $870,333 $600,000 $780,000 $900,000 $1,530,000 $8,417,764 $9,217,764 $8,300,000 $7,310,000 $3,920,000 $4,330,000 $3,600,000 $15,217,392 $15,217,539 $15,117,539 $15,017,539 $14,717,728 $14,717,539 $14,417,728 $14,417,747 $11,917,764 $12,617,747 $11,917,747 Adjusted Cap $181,171,935 $181,172,681 $181,174,444 $181,174,284 $181,174,112 $188,550,000 $230,380,000 $144,600,000 $139,140,000 Adjustment Details ($5) ($19) ($17) ($746) ($160) ($172) ($147) ($189) Amount ($1,431) $21,717 $270,334 $280,000 $120,000 $100,000 $100,000 $300,000 $300,000 $117,764 $800,000 $700,000 $410,000 ($300,000) ($750,000) ($730,000) $1,800,000 $2,700,000 $4,700,000 $1,310,000 ($3,390,000) $36,574,444 $49,410,000 $41,830,000 $24,920,000 ($85,780,000) Cap Adjustment Date 1/6/2011 1/6/2011 1/6/2011 6/28/2012 3/30/2011 6/29/2011 7/14/2010 9/30/2010 3/26/2010 10/2/2009 6/29/2011 6/28/2012 3/30/2011 9/30/2010 7/14/2010 10/2/2009 3/26/2010 6/28/2012 9/15/2011 6/29/2011 8/16/2011 4/13/2011 3/30/2011 2/16/2011 9/30/2010 1/13/2011 7/14/2010 9/15/2010 10/2/2009 3/26/2010 Adjustment 12/30/2009 12/30/2009 10/14/2011 11/16/2010 12/15/2010 12/30/2009 10 Note N/ A N/ A N/ A Pricing Mechanism 1 (CONTINU E D) $1,250,000 $6,000,000 $114,220,000 Investors (Cap) Cap of Incentive of Borrowers and to of Borrowers Payments on Behalf Servicers & Lenders/ Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Investment Description Purchase Purchase Purchase Transaction Transaction Type Servicer Modifying Borrowers’ Loans Servicer Modifying Borrowers’ U.S. B ank National A ssociation, KY Owensboro, Central Florida E ducators Union, Federal Credit F L L ake May, Vantium Capital, Inc.dba Vantium A cqura L oan Services, Plano, TX Name of Institution 9/9/2009 9/9/2009 9/2/2009 as amended on 8/27/2010 HAMP TRANSACTION DETAIL, AS OF 6/30/2012 HAMP TRANSACTION DETAIL, Date Transaction detail I Appendix D I July 25, 2012 297 $— $17,000 $22,909 Incentive $175,097 Payments Total TARP TARP Total Continued on next page $— $6,329 $12,251 $67,322 Servicers Incentives $— $7,341 $6,623 $78,063 Investors Lenders/ Incentives TARP Incentive Payments TARP $— $3,329 $4,035 $29,713 Incentives Borrower’s Borrower’s A A initial cap A initial cap A initial cap A initial cap Updated portfolio data from servicer Updated portfolio data from servicer Updated portfolio data from of SP Termination Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from HPDP initial cap servicer & Updated portfolio data from H A F Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from HPDP initial cap servicer & Updated portfolio data from H A F Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer & Updated portfolio data from H A F HPDP initial cap Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from HPDP initial cap servicer & Updated portfolio data from H A F servicer Updated portfolio data from servicer Updated portfolio data from Reason for Adjustment $0 $435,167 $435,166 $400,000 $350,000 $970,000 $145,054 $145,055 $145,056 $100,000 $510,000 $310,000 $230,000 $1,070,000 $6,817,390 $6,817,476 $6,817,613 $6,817,591 $5,000,000 $6,817,603 $5,260,000 $2,530,000 $3,626,289 $3,626,327 $3,626,379 $3,626,385 $3,626,390 $5,300,000 $18,540,000 $11,000,000 $11,740,000 $10,300,000 Adjusted Cap Adjustment Details ($6) ($5) ($86) ($12) ($10) ($38) ($52) ($115) Amount $35,167 $70,000 $45,056 $60,000 ($80,000) $100,000 $620,000 $280,000 $460,000 $950,000 $740,000 ($435,166) ($670,000) ($410,000) $1,817,613 $2,730,000 $5,700,000 ($1,440,000) ($6,673,610) $13,280,000 ($13,540,000) Cap Adjustment Date 1/6/2011 1/6/2011 1/6/2011 1/26/2011 9/30/2010 7/14/2010 3/26/2010 10/2/2009 6/28/2012 6/29/2011 9/30/2010 7/14/2010 3/26/2010 10/2/2009 6/28/2012 6/29/2011 9/30/2010 3/30/2011 7/14/2010 3/26/2010 10/2/2009 6/28/2012 6/29/2011 3/30/2011 7/14/2010 9/30/2010 10/2/2009 3/26/2010 Adjustment 12/30/2009 12/30/2009 12/30/2009 12/30/2009 Note N/ A N/ A N/ A N/ A Pricing Mechanism 1 (CONTINU E D) $280,000 $250,000 $2,070,000 $4,350,000 Investors (Cap) Cap of Incentive of Borrowers and to of Borrowers Payments on Behalf Servicers & Lenders/ Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Investment Description Purchase Purchase Purchase Purchase Transaction Transaction Type Servicer Modifying Borrowers’ Loans Servicer Modifying Borrowers’ Metropolitan National B ank, Metropolitan L ittle Rock, A R A llstate Mortgage L oans & Investments, Inc., Ocala, F L Federal Credit Union, ORN L Federal Credit Oak Ridge, TN CUC Mortgage NY Corporation, A lbany, Name of Institution 9/11/2009 9/11/2009 9/11/2009 9/9/2009 HAMP TRANSACTION DETAIL, AS OF 6/30/2012 HAMP TRANSACTION DETAIL, Date 298 Appendix D I Transaction Detail I July 25, 2012 $— $1,470 Incentive Payments Total TARP TARP Total $1,362,689 Continued on next page $— $— $618,514 Servicers Incentives $— $1,470 Investors Lenders/ $493,734 Incentives TARP Incentive Payments TARP $— $— $250,441 Incentives Borrower’s Borrower’s A A initial cap A initial cap A initial cap Updated due to quarterly assessment and reallocation Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation Transfer of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from of cap due to servicing transfer Transfer Updated portfolio data from servicer Updated portfolio data from servicer Updated portfolio data from HPDP initial cap servicer & Updated portfolio data from H A F servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation of SP Termination Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from servicer Updated portfolio data from HPDP initial cap servicer & Updated portfolio data from H A F Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Transfer of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation of cap due to servicing transfer Transfer Updated portfolio data from servicer Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer & Updated portfolio data from H A F servicer Updated portfolio data from HPDP initial cap Reason for Adjustment $0 $580,220 $580,212 $580,221 $580,222 $500,000 $9,122,933 $9,222,933 $9,023,086 $9,022,933 $8,923,086 $8,723,086 $8,123,114 $8,723,102 $7,800,000 $8,123,102 $5,350,000 $2,260,000 $2,490,000 $2,120,000 $2,000,000 $1,960,000 $7,773,600 $7,673,542 $7,773,667 $7,773,661 $7,673,600 $9,573,670 $9,573,667 $6,600,000 $8,990,000 $10,972,797 $10,972,933 $10,322,933 $13,770,000 $33,520,000 Adjusted Cap Adjustment Details ($8) ($6) ($3) ($16) ($12) ($61) ($58) ($136) ($153) Amount $90,000 $650,000 $100,000 $100,000 $100,000 $200,000 $323,114 $600,000 $960,000 $230,000 $160,000 ($580,212) ($120,000) ($100,000) $1,100,000 $5,310,000 $1,460,000 $2,973,670 $6,010,000 ($3,090,000) ($1,419,778) ($1,800,000) ($2,390,000) ($4,780,000) ($19,750,000) Cap Adjustment Date 1/6/2011 1/6/2011 1/6/2011 6/28/2012 6/14/2012 4/16/2012 6/29/2011 9/15/2011 5/13/2011 4/13/2011 3/30/2011 9/30/2010 3/16/2011 7/14/2010 6/29/2011 1/25/2012 10/2/2009 3/26/2010 3/30/2011 7/14/2010 9/30/2010 3/26/2010 10/2/2009 3/30/2011 6/29/2011 6/28/2012 2/16/2011 9/30/2010 7/14/2010 3/26/2010 10/2/2009 Adjustment 11/16/2011 12/30/2009 12/30/2009 10/14/2011 12/30/2009 Note N/ A N/ A N/ A Pricing Mechanism 1 (CONTINU E D) $410,000 $4,390,000 $27,510,000 Investors (Cap) Cap of Incentive of Borrowers and to of Borrowers Payments on Behalf Servicers & Lenders/ Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Investment Description Purchase Purchase Purchase Transaction Transaction Type Servicer Modifying Borrowers’ Loans Servicer Modifying Borrowers’ A MS Servicing, LL C, B uffalo, NY ay Federal Credit Union, B ay Federal Credit Capitola, C A Franklin Credit Franklin Credit Management Corporation, NJ Jersey City, Name of Institution 9/23/2009 9/16/2009 9/11/2009 HAMP TRANSACTION DETAIL, AS OF 6/30/2012 HAMP TRANSACTION DETAIL, Date Transaction detail I Appendix D I July 25, 2012 299 $— $— $54,388 $10,223 $70,758 Incentive Payments Total TARP TARP Total Continued on next page $— $— $5,000 $29,484 $23,500 Servicers Incentives $— $— $2,223 $14,270 $36,508 Investors Lenders/ Incentives TARP Incentive Payments TARP $— $— $3,000 $10,634 $10,750 Incentives Borrower’s Borrower’s A A A initial cap A initial cap A initial cap A initial cap A initial cap Updated due to quarterly assessment and reallocation of SP Termination Updated portfolio data from servicer Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer & Updated portfolio data from H A F HPDP initial cap Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer & Updated portfolio data from H A F Updated portfolio data from servicer Updated portfolio data from HPDP initial cap Updated portfolio data from servicer Updated portfolio data from of SP Termination Updated portfolio data from servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation HPDP initial cap servicer & Updated portfolio data from H A F Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer & Updated portfolio data from H A F HPDP initial cap Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer & Updated portfolio data from H A F HPDP initial cap Reason for Adjustment $0 $0 $40,000 $145,055 $200,000 $145,056 $270,000 $560,000 $540,000 $435,162 $435,159 $435,167 $435,166 $200,000 $650,000 $145,056 $300,000 $100,000 $170,000 $290,108 $290,106 $160,000 $290,111 $300,000 $410,000 $280,000 $290,000 $300,000 $440,000 $480,000 $2,010,000 $1,450,514 $1,450,530 $1,450,552 $1,450,556 $1,450,554 $1,420,000 Adjusted Cap Adjustment Details ($4) ($3) ($3) ($2) ($2) ($2) ($16) ($22) Amount ($9,889) $20,000 $45,056 $60,000 $10,000 $10,000 $60,000 $90,000 ($54,944) ($70,000) ($70,000) ($10,000) $100,000 $235,167 $350,000 $120,000 $130,000 $940,000 ($145,055) ($290,000) ($145,056) ($110,000) ($140,000) ($980,000) $1,360,000 $1,150,556 ($1,810,000) Cap Adjustment Date 1/6/2011 1/6/2011 4/11/2012 9/30/2010 6/29/2011 7/14/2010 3/26/2010 6/28/2012 10/2/2009 6/29/2011 9/30/2010 7/14/2010 3/26/2010 9/30/2010 10/2/2009 7/14/2010 6/28/2012 10/2/2009 3/26/2010 6/29/2011 9/30/2010 7/14/2010 3/26/2010 10/2/2009 6/28/2012 6/29/2011 3/30/2011 9/30/2010 7/14/2010 3/26/2010 10/2/2009 Adjustment 12/30/2009 12/30/2009 10/29/2010 12/30/2009 12/30/2009 12/30/2009 Note N/ A N/ A N/ A N/ A N/ A Pricing Mechanism 1 30,000 (CONTINU E D) $440,000 $240,000 $230,000 $390,000 Investors (Cap) Cap of Incentive of Borrowers and to of Borrowers Payments on Behalf Servicers & Lenders/ Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Investment Description Purchase Purchase Purchase Purchase Purchase Transaction Transaction Type Servicer Modifying Borrowers’ Loans Servicer Modifying Borrowers’ lbany, NY S E FCU, A lbany, Yadkin Valley B ank, Valley Yadkin E lkin, NC Central Jersey Federal Union, Credit NJ Woodbridge, Glass City Federal Credit Glass City Federal Credit Union, Maumee, OH Schools Financial Credit Schools Financial Credit Union, Sacramento, C A Name of Institution 9/25/2009 9/23/2009 9/23/2009 9/23/2009 9/23/2009 HAMP TRANSACTION DETAIL, AS OF 6/30/2012 HAMP TRANSACTION DETAIL, Date 300 Appendix D I Transaction Detail I July 25, 2012 $— $21,423 Incentive $115,376 Payments Total TARP TARP Total $21,988,606 Continued on next page $— $7,500 $45,446 Servicers Incentives $7,301,320 $— $8,006 $46,028 Investors Lenders/ Incentives TARP Incentive Payments TARP $10,742,313 $— $5,917 $23,901 Incentives Borrower’s Borrower’s $3,944,973 A initial cap A initial cap A A initial cap A initial cap Updated due to quarterly assessment and reallocation Transfer of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Transfer of cap due to servicing transfer Transfer Updated portfolio data from servicer Updated portfolio data from servicer Updated portfolio data from Updated HPDP cap & H A F servicer Updated portfolio data from servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from Updated HPDP cap & H A F Updated portfolio data from servicer Updated portfolio data from of SP Termination Updated portfolio data from servicer & Updated portfolio data from H A F servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer & Updated portfolio data from H A F servicer Updated portfolio data from Reason for Adjustment $0 $580,220 $580,215 $580,211 $580,221 $580,222 $400,000 $830,000 $145,056 $430,000 $100,000 $360,000 $580,220 $580,212 $580,206 $580,222 $580,221 $400,000 $720,000 $1,960,000 $1,600,000 $95,749,818 $95,750,095 $97,150,868 $97,150,095 $97,150,956 $98,030,000 Adjusted Cap $107,051,033 $107,050,956 $121,910,000 $105,300,000 Adjustment Details ($5) ($4) ($8) ($6) ($88) ($77) ($277) ($773) Amount $45,056 $20,000 $180,222 $400,000 $180,222 ($430,000) ($145,056) ($260,000) ($320,000) ($880,000) $1,751,033 $4,370,000 $1,030,000 ($1,400,000) ($9,900,000) ($2,900,000) ($1,600,000) $23,880,000 ($16,610,000) Cap Adjustment Date 1/6/2011 1/6/2011 3/9/2011 1/6/2011 6/28/2012 6/29/2011 3/15/2012 3/30/2011 3/16/2011 7/14/2010 9/30/2010 6/29/2011 6/28/2012 1/22/2010 3/26/2010 3/30/2011 9/30/2010 7/14/2010 3/26/2010 9/30/2010 1/22/2010 7/14/2010 6/29/2011 6/28/2012 3/26/2010 3/30/2011 9/30/2010 7/14/2010 3/26/2010 Adjustment 12/30/2009 12/30/2009 Note N/ A N/ A N/ A N/ A Pricing Mechanism 1 (CONTINU E D) $410,000 $570,000 $4,860,000 $93,660,000 Investors (Cap) Cap of Incentive of Borrowers and to of Borrowers Payments on Behalf Servicers & Lenders/ Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Investment Description Purchase Purchase Purchase Purchase Transaction Transaction Type Servicer Modifying Borrowers’ Loans Servicer Modifying Borrowers’ B ank United, Miami L akes, F United B ank Mortgage Corporation, Grand Rapids, MI Mortgage Clearing OK Corporation, Tulsa, akes Credit Union, L akes Credit Great North Chicago, I L Name of Institution 10/23/2009 10/21/2009 10/14/2009 10/14/2009 HAMP TRANSACTION DETAIL, AS OF 6/30/2012 HAMP TRANSACTION DETAIL, Date Transaction detail I Appendix D I July 25, 2012 301 $— $— $42,321 $25,531 $50,757 Incentive Payments Total TARP TARP Total Continued on next page $— $— $6,214 $20,993 $21,000 Servicers Incentives $— $— $13,790 $16,802 $19,757 Investors Lenders/ Incentives TARP Incentive Payments TARP $— $— $7,538 $2,514 $10,000 Incentives Borrower’s Borrower’s A initial cap A initial cap A initial cap A A Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from servicer Updated portfolio data from Updated HPDP cap & H A F servicer Updated portfolio data from Updated due to quarterly assessment and reallocation servicer Updated portfolio data from Updated due to quarterly assessment and reallocation of SP Termination of SP Termination Updated HPDP cap & H A F servicer Updated portfolio data from Updated due to quarterly assessment and reallocation servicer Updated portfolio data from Updated due to quarterly assessment and reallocation servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from Updated HPDP cap & H A F servicer Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from Reason for Adjustment $0 $0 $80,000 $90,000 $40,000 $740,000 $145,055 $790,000 $145,056 $100,000 $800,000 $2,175,766 $2,175,792 $2,175,827 $2,175,834 $2,175,831 $2,100,000 $2,465,868 $2,465,897 $2,465,937 $2,465,941 $2,465,945 $2,670,000 $1,900,000 Adjusted Cap Adjustment Details ($4) ($3) ($4) ($4) ($26) ($35) ($29) ($40) Amount $75,834 $40,000 $10,000 $50,000 $45,056 $10,000 $10,000 $40,000 $565,945 ($510,000) ($770,000) ($760,000) $1,310,000 $2,630,000 ($1,070,000) Cap Adjustment Date 1/6/2011 1/6/2011 6/28/2012 6/29/2011 3/30/2011 9/30/2010 1/22/2010 7/14/2010 4/21/2010 4/21/2010 1/22/2010 6/29/2011 3/26/2010 6/28/2012 9/30/2010 6/29/2011 3/26/2010 7/14/2010 3/30/2011 7/14/2010 9/30/2010 1/22/2010 3/26/2010 5/12/2010 Adjustment Note N/ A N/ A N/ A N/ A N/ A Pricing Mechanism 1 (CONTINU E D) $70,000 $700,000 $510,000 $760,000 $1,070,000 Investors (Cap) Cap of Incentive of Borrowers and to of Borrowers Payments on Behalf Servicers & Lenders/ Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Investment Description Purchase Purchase Purchase Purchase Purchase Transaction Transaction Type A Servicer Modifying Borrowers’ Loans Servicer Modifying Borrowers’ L os A lamos National B ank, L os A lamos, NM Harleysville National Company, B ank & Trust Harleysville, P Members Mortgage M A Inc, Woburn, Company, Union, DuPage Credit Naperville, I L IC Federal Credit Union, IC Federal Credit M A Fitchburg, Name of Institution 11/6/2009 10/28/2009 10/28/2009 10/30/2009 10/23/2009 HAMP TRANSACTION DETAIL, AS OF 6/30/2012 HAMP TRANSACTION DETAIL, Date 302 Appendix D I Transaction Detail I July 25, 2012 $— $73,311 Incentive $586,733 Payments Total TARP TARP Total Continued on next page $— $36,529 $172,984 Servicers Incentives $— $21,839 Investors Lenders/ $288,189 Incentives TARP Incentive Payments TARP $— $14,943 $125,560 Incentives Borrower’s Borrower’s A initial cap A initial cap A initial cap Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Updated HPDP cap & H A F servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from Updated HPDP cap & H A F servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Updated portfolio data from servicer Updated portfolio data from servicer Updated portfolio data from Updated HPDP cap & H A F servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from Reason for Adjustment $20,000 $10,000 $145,054 $145,055 $145,056 $100,000 $1,160,414 $1,160,426 $1,160,442 $1,160,445 $1,160,444 $1,000,000 $1,750,000 $2,080,000 $35,490,585 $35,491,013 $35,161,013 $35,061,013 $34,961,013 $34,761,013 $34,461,572 $34,461,013 $33,661,572 $33,561,572 $33,461,572 $33,461,630 $32,061,630 $30,461,676 $30,461,630 $19,850,000 $20,800,000 $23,690,000 Adjusted Cap Adjustment Details $0 ($2) ($12) ($16) ($58) ($46) ($428) ($559) Amount $45,056 $90,000 $80,000 ($10,000) $160,445 $330,000 $330,000 $100,000 $100,000 $200,000 $300,000 $800,000 $100,000 $100,000 $890,000 $1,400,000 $1,600,000 $9,661,676 $3,840,000 ($1,080,000) ($2,890,000) Cap Adjustment Date 1/6/2011 1/6/2011 6/28/2012 6/29/2011 9/30/2010 1/22/2010 3/26/2010 7/14/2010 6/28/2012 6/29/2011 3/30/2011 9/30/2010 7/14/2010 1/22/2010 3/26/2010 6/28/2012 6/14/2012 1/13/2012 9/15/2011 8/16/2011 6/29/2011 7/14/2011 6/16/2011 5/13/2011 4/13/2011 3/30/2011 2/16/2011 1/13/2011 9/30/2010 1/22/2010 7/14/2010 3/26/2010 Adjustment Note N/ A N/ A N/ A Pricing Mechanism 1 (CONTINU E D) $20,000 $1,670,000 $18,960,000 Investors (Cap) Cap of Incentive of Borrowers and to of Borrowers Payments on Behalf Servicers & Lenders/ Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Investment Description Purchase Purchase Purchase Transaction Transaction Type Servicer Modifying Borrowers’ Loans Servicer Modifying Borrowers’ Q L ending, Inc., Coral Gables, F L Hillsdale County National B ank, Hillsdale, MI Quantum Servicing F L Corporation, Tampa, Name of Institution 11/18/2009 11/18/2009 11/18/2009 HAMP TRANSACTION DETAIL, AS OF 6/30/2012 HAMP TRANSACTION DETAIL, Date Transaction detail I Appendix D I July 25, 2012 303 $— $14,917 Incentive Payments Total TARP TARP Total $2,162,025 Continued on next page $— $8,718 $839,633 Servicers Incentives $— $3,423 Investors Lenders/ $970,197 Incentives TARP Incentive Payments TARP $— $2,776 $352,196 Incentives Borrower’s Borrower’s A initial cap A initial cap A initial cap A A Updated portfolio data from servicer Updated portfolio data from servicer Updated portfolio data from servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Termination of SP Termination Updated HPDP cap & H A F Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation of cap due to servicing transfer Transfer Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from Updated HPDP cap & H A F servicer Updated portfolio data from servicer Updated portfolio data from Updated due to quarterly assessment and reallocation of SP Termination Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from Initial FH A -H MP cap and initial RD-H Transfer of cap due to servicing transfer Transfer Updated portfolio data from servicer Updated portfolio data from Transfer of cap from CitiMortgage, Inc. due of cap from Transfer to servicing transfer Updated HPDP cap & H A F servicer Updated portfolio data from Reason for Adjustment $0 $10,000 $530,000 $394,917 ($280,000) ($234,944) ($234,945) ($234,946) $1,730,531 $1,830,552 $1,730,552 $1,830,554 $1,830,556 $1,710,000 $2,730,000 $1,780,000 $7,006,969 $7,007,007 $5,657,167 $5,657,168 $4,300,000 $4,100,000 $3,300,000 $4,460,000 $3,430,000 $18,757,007 $16,657,007 $15,357,007 $20,257,007 $19,957,007 $19,857,007 $19,857,161 $18,957,161 $18,657,161 $11,357,167 $11,357,161 $21,310,000 Adjusted Cap Adjustment Details ($2) ($2) ($6) ($21) ($38) ($154) Amount $45,056 $10,000 $50,556 $50,000 $520,000 $300,000 $100,000 $900,000 $300,000 $200,000 $800,000 $950,000 ($810,000) ($100,000) ($950,000) ($230,000) $1,020,000 $7,300,000 $5,700,000 $1,357,168 $1,030,000 ($1,335,614) ($2,100,000) ($1,300,000) ($8,350,000) ($1,500,000) ($1,160,000) ($17,880,000) Cap Adjustment Date 1/6/2011 1/6/2011 7/14/2010 9/30/2010 6/29/2011 6/28/2012 1/22/2010 3/26/2010 7/22/2011 6/16/2011 6/29/2011 3/30/2011 7/14/2010 9/30/2010 1/22/2010 3/26/2010 4/21/2010 6/28/2012 2/16/2012 4/16/2012 6/14/2012 1/13/2012 8/16/2011 7/14/2011 6/29/2011 6/16/2011 5/13/2011 3/30/2011 4/13/2011 3/16/2011 9/30/2010 9/30/2010 8/13/2010 7/14/2010 6/16/2010 1/22/2010 3/26/2010 Adjustment 12 Note N/ A N/ A N/ A Pricing Mechanism 1 (CONTINU E D) $230,000 $1,660,000 $20,360,000 Investors (Cap) Cap of Incentive of Borrowers and to of Borrowers Payments on Behalf Servicers & Lenders/ Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Investment Description Purchase Purchase Purchase Transaction Transaction Type A A , Servicer Modifying Borrowers’ Loans Servicer Modifying Borrowers’ First Keystone B ank, Media, P Clark Summit, P Home Financing Center, Home Financing Center, Inc, Coral Gables F L Marix Servicing, LL C, Phoenix, A Z Name of Institution 11/25/2009, 12/4/2009 11/25/2009 11/25/2009 HAMP TRANSACTION DETAIL, AS OF 6/30/2012 HAMP TRANSACTION DETAIL, Date 304 Appendix D I Transaction Detail I July 25, 2012 $— $— $— $43,972 Incentive $223,909 Payments Total TARP TARP Total Continued on next page $— $— $— $59,189 $19,253 Servicers Incentives $— $— $— $12,550 Investors Lenders/ $134,364 Incentives TARP Incentive Payments TARP $— $— $— $30,356 $12,169 Incentives Borrower’s Borrower’s A initial cap A initial cap A initial cap A initial cap A initial cap A A Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from Updated HPDP cap & H A F servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from Updated HPDP cap & H A F servicer Updated portfolio data from Updated due to quarterly assessment and reallocation of SP Termination Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from Updated HPDP cap & H A F servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from servicer Updated portfolio data from of SP Termination Initial FH A -H MP cap Updated HPDP cap & H A F servicer Updated portfolio data from servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from Updated HPDP cap & H A F servicer Updated portfolio data from Reason for Adjustment $0 $0 $870,319 $870,332 $870,333 $870,334 $800,000 $370,000 $290,108 $290,106 $300,000 $290,111 $150,000 $1,015,358 $1,015,370 $1,015,386 $1,015,389 $1,015,388 $7,400,000 $3,080,000 $9,380,000 $2,175,782 $2,175,803 $2,175,829 $2,175,832 $2,175,834 $1,900,000 $1,970,000 $3,080,000 $1,660,000 $1,370,000 $1,305,500 $1,305,498 $1,200,000 $1,220,000 $1,100,000 $9,870,000 $24,350,000 Adjusted Cap Adjustment Details ($2) ($3) ($2) ($2) ($3) ($2) ($12) ($16) ($21) ($26) ($13) Amount ($9,889) $90,000 $70,334 $70,000 $10,000 $140,000 $275,834 $105,500 $100,000 $850,000 $150,000 $440,000 ($870,319) ($290,000) ($570,000) ($120,000) $6,300,000 $1,110,000 ($6,384,611) ($1,980,000) ($1,180,000) ($1,305,498) $14,480,000 ($24,200,000) Cap Adjustment Date 1/6/2011 1/6/2011 1/6/2011 1/6/2011 6/28/2012 6/29/2011 3/30/2011 9/30/2010 7/14/2010 1/22/2010 3/26/2010 6/28/2012 6/29/2011 3/30/2011 9/30/2010 7/14/2010 1/25/2012 1/22/2010 3/26/2010 6/29/2011 3/30/2011 9/30/2010 3/26/2010 7/14/2010 2/17/2011 1/22/2010 9/30/2010 7/14/2010 9/30/2010 6/28/2012 1/22/2010 3/26/2010 9/30/2010 6/29/2011 7/14/2010 5/26/2010 1/22/2010 3/26/2010 Adjustment Note N/ A N/ A N/ A N/ A N/ A Pricing Mechanism 1 (CONTINU E D) $360,000 $2,940,000 $1,880,000 $1,590,000 $9,430,000 Investors (Cap) Cap of Incentive of Borrowers and to of Borrowers Payments on Behalf Servicers & Lenders/ Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Investment Description Purchase Purchase Purchase Purchase Purchase Transaction Transaction Type Servicer Modifying Borrowers’ Loans Servicer Modifying Borrowers’ Fidelity Homestead Savings B ank, New Orleans, LA Silver State Schools Credit Silver State Schools Credit NV Union, L as Vegas, A merican E agle Federal Union, E ast Credit CT Hartford, Spirit of A laska Federal Union, Fairbanks, A K Credit Idaho Housing and Finance A ssociation, B oise, ID Name of Institution 12/9/2009 12/9/2009 12/9/2009 12/9/2009 12/4/2009 HAMP TRANSACTION DETAIL, AS OF 6/30/2012 HAMP TRANSACTION DETAIL, Date Transaction detail I Appendix D I July 25, 2012 305 $— $— $— $13,323 Incentive $340,020 $872,087 Payments Total TARP TARP Total Continued on next page $— $— $— $5,833 $135,710 $296,559 Servicers Incentives $— $— $— $5,573 Investors Lenders/ $145,764 $453,485 Incentives TARP Incentive Payments TARP $— $— $— $1,917 $58,545 $122,042 Incentives Borrower’s Borrower’s A initial cap A initial cap A initial cap A initial cap A initial cap A initial cap A A A Updated portfolio data from servicer Updated portfolio data from servicer Updated portfolio data from of SP Termination Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from Updated HPDP cap & H A F Updated HPDP cap & H A F servicer Updated portfolio data from of SP Termination Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from servicer Updated portfolio data from Updated HPDP cap & H A F servicer Updated portfolio data from Updated due to quarterly assessment and reallocation servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from Updated HPDP cap & H A F servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from Updated HPDP cap & H A F Updated portfolio data from servicer Updated portfolio data from servicer Updated portfolio data from of SP Termination Updated HPDP cap & H A F servicer Updated portfolio data from Reason for Adjustment $0 $0 $0 $725,278 $725,277 $700,000 $630,000 $390,000 $870,309 $870,319 $870,332 $870,334 $870,333 $330,000 $800,000 $900,000 $600,000 $580,222 $240,000 $680,000 $1,030,000 $1,640,000 $1,450,543 $1,150,000 $1,450,554 $1,450,556 $1,450,555 $2,350,000 $1,610,000 $4,206,560 $4,206,569 $4,206,604 $4,206,608 $4,206,612 $3,600,000 $6,490,000 $6,450,000 Adjusted Cap Adjustment Details ($9) ($4) ($4) ($10) ($13) ($11) ($35) Amount $25,278 $30,000 $20,000 $70,334 $20,000 $40,000 $10,000 ($19,778) ($80,000) $400,000 $820,000 $550,556 $100,000 $606,612 $290,000 $440,000 ($725,277) ($330,000) ($350,000) ($740,000) ($710,000) ($580,222) $1,250,000 ($1,640,000) ($2,890,000) Cap Adjustment Date 1/6/2011 1/6/2011 1/6/2011 1/6/2011 2/17/2011 9/30/2010 7/14/2010 3/26/2010 5/26/2010 1/22/2010 1/22/2010 3/26/2010 6/28/2012 6/29/2011 3/30/2011 9/30/2010 1/22/2010 7/14/2010 6/29/2011 3/26/2010 3/30/2011 9/30/2010 3/26/2010 7/14/2010 1/22/2010 6/28/2012 6/29/2011 3/30/2011 9/30/2010 7/14/2010 3/26/2010 9/30/2010 1/22/2010 7/14/2010 1/22/2010 3/26/2010 Adjustment 10/15/2010 Note N/ A N/ A N/ A N/ A N/ A N/ A Pricing Mechanism 1 (CONTINU E D) $600,000 $370,000 $310,000 $230,000 $2,250,000 $6,160,000 Investors (Cap) Cap of Incentive of Borrowers and to of Borrowers Payments on Behalf Servicers & Lenders/ Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Investment Description Purchase Purchase Purchase Purchase Purchase Purchase Transaction Transaction Type Servicer Modifying Borrowers’ Loans Servicer Modifying Borrowers’ Verity Credit Union, Credit Verity Seatle, W A Glenview State B ank, I L Glenview, 1000558 1000558 HomeStar B ank & Financial Services, Manteno, I L Sterling Savings B ank, Spokane, W A The Golden 1 Credit Union, The Golden 1 Credit Sacramento, C A ay Gulf Credit Union, B ay Gulf Credit F L Tampa, Name of Institution 12/11/2009 12/11/2009 12/11/2009 12/9/2009 12/9/2009 12/9/2009 HAMP TRANSACTION DETAIL, AS OF 6/30/2012 HAMP TRANSACTION DETAIL, Date 306 Appendix D I Transaction Detail I July 25, 2012 $— $— $— $— $— $16,946 $58,555 Incentive Payments Total TARP TARP Total Continued on next page $— $— $— $— $— $4,718 $23,517 Servicers Incentives $— $— $— $— $— $7,510 $26,372 Investors Lenders/ Incentives TARP Incentive Payments TARP $— $— $— $— $— $4,718 $8,667 Incentives Borrower’s Borrower’s A initial cap A initial cap A initial cap A initial cap A initial cap A initial cap A A A A Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from Updated HPDP cap & H A F servicer Updated portfolio data from servicer Updated portfolio data from Updated HPDP cap & H A F servicer Updated portfolio data from Updated HPDP cap & H A F of SP Termination of SP Termination Updated portfolio data from servicer Updated portfolio data from of SP Termination Updated portfolio data from servicer Updated portfolio data from Updated HPDP cap & H A F servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from Updated due to quarterly assessment and reallocation of SP Termination Updated HPDP cap & H A F servicer Updated portfolio data from Updated due to quarterly assessment and reallocation of cap due to servicing transfer Transfer servicer Updated portfolio data from Updated due to quarterly assessment and reallocation servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from Updated HPDP cap & H A F servicer Updated portfolio data from servicer Updated portfolio data from Reason for Adjustment $0 $0 $0 $0 $70,000 $600,000 $460,000 $730,000 $290,111 $200,000 $180,000 $210,000 $650,000 $100,000 $660,000 $1,450,512 $1,450,529 $1,450,552 $1,450,556 $1,450,554 $1,890,000 $1,500,000 $2,470,000 $3,620,000 $1,595,567 $1,595,583 $1,595,607 $1,595,610 $1,160,409 $1,595,612 $1,160,423 $1,500,000 $1,160,441 $1,160,443 $1,160,445 $1,460,000 $1,100,000 Adjusted Cap Adjustment Details ($2) ($2) ($3) ($2) ($2) ($2) ($17) ($23) ($16) ($24) ($14) ($18) Amount $20,000 $30,000 $90,111 $10,000 $30,000 $30,000 $95,612 $60,445 $30,000 ($10,000) $850,556 $160,000 $100,000 $800,000 ($390,000) ($290,111) ($150,000) ($580,000) ($360,000) $1,430,000 $1,740,000 $1,430,000 ($1,870,000) ($3,620,000) ($1,500,000) Cap Adjustment Date 1/6/2011 9/8/2010 1/6/2011 1/6/2011 6/28/2012 6/29/2011 3/30/2011 9/30/2010 7/14/2010 7/14/2010 4/21/2010 1/22/2010 3/26/2010 1/22/2010 3/26/2010 2/17/2011 1/22/2010 9/30/2010 7/14/2010 1/22/2010 3/26/2010 6/28/2012 6/29/2011 3/30/2011 4/21/2010 6/28/2012 1/22/2010 9/30/2010 6/29/2011 6/16/2011 3/26/2010 7/14/2010 3/30/2011 7/14/2010 9/30/2010 1/22/2010 3/26/2010 Adjustment 9 Note N/ A N/ A N/ A N/ A N/ A N/ A N/ A Pricing Mechanism 1 (CONTINU E D) $440,000 $700,000 $170,000 $150,000 $620,000 $630,000 $3,460,000 Investors (Cap) Cap of Incentive of Borrowers and to of Borrowers Payments on Behalf Servicers & Lenders/ Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Investment Description Purchase Purchase Purchase Purchase Purchase Purchase Purchase Transaction Transaction Type A Servicer Modifying Borrowers’ Loans Servicer Modifying Borrowers’ Sound Community B ank, Seatle, W A Horizon B ank, N A , IN Michigan City, First Federal Savings and L oan A ssociation of L akewood, OH Golden Plains Credit Union, Golden Plains Credit KS City, Garden ryn Mawr Trust Co., The B ryn Mawr Trust P B ryn Mawr, Citizens 1st National B ank, I L Spring Valley, Hartford Savings B ank, Hartford WI Hartford, Name of Institution 12/16/2009 12/16/2009 12/16/2009 12/16/2009 12/11/2009 12/16/2009 12/11/2009 HAMP TRANSACTION DETAIL, AS OF 6/30/2012 HAMP TRANSACTION DETAIL, Date Transaction detail I Appendix D I July 25, 2012 307 $— $— $— $24,954 $25,502 $53,937 Incentive Payments Total TARP TARP Total Continued on next page $— $— $— $7,917 $15,000 $19,000 Servicers Incentives $— $— $— $13,204 $10,502 $23,937 Investors Lenders/ Incentives TARP Incentive Payments TARP $— $— $— $— $3,833 $11,000 Incentives Borrower’s Borrower’s A initial cap A initial cap A initial cap A initial cap A initial cap A A A A Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from of SP Termination Updated HPDP cap & H A F servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from servicer Updated portfolio data from of SP Termination servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from Updated HPDP cap & H A F Updated due to quarterly assessment and reallocation of SP Termination Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from Updated HPDP cap & H A F servicer Updated portfolio data from Updated due to quarterly assessment and reallocation of cap due to servicing transfer Transfer Updated HPDP cap & H A F servicer Updated portfolio data from Updated due to quarterly assessment and reallocation servicer Updated portfolio data from servicer Updated portfolio data from of SP Termination servicer Updated portfolio data from Updated due to quarterly assessment and reallocation servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from Updated HPDP cap & H A F servicer Updated portfolio data from Reason for Adjustment $0 $0 $0 $90,000 $60,000 $25,502 $40,000 $580,220 $580,212 $580,206 $580,221 $580,222 $740,000 $600,000 $145,056 $110,000 $100,000 $200,000 $145,056 $150,000 $725,265 $725,276 $725,277 $725,278 $360,000 $800,000 $870,310 $870,320 $870,332 $870,334 $870,333 $800,000 $800,000 $940,000 $4,430,000 $7,252,780 $7,252,756 $6,952,756 $1,400,000 $7,252,769 $2,960,000 Adjusted Cap Adjustment Details $0 $0 ($8) ($6) ($11) ($13) ($10) ($11) ($12) Amount $45,056 $10,000 $50,000 $90,000 $20,000 $70,334 $40,000 ($19,778) ($54,944) ($20,000) ($74,722) $480,000 $200,000 $760,000 $140,000 ($145,056) ($140,000) ($145,056) ($725,265) ($300,000) ($320,000) ($140,000) $5,852,780 ($6,927,254) ($1,560,000) ($1,470,000) Cap Adjustment Date 1/6/2011 1/6/2011 1/6/2011 6/3/2011 1/6/2011 6/29/2011 6/28/2012 3/30/2011 9/30/2010 12/8/2010 3/26/2010 7/14/2010 9/30/2010 9/30/2010 5/20/2011 1/22/2010 3/26/2010 7/14/2010 7/14/2010 3/26/2010 1/25/2012 1/22/2010 6/29/2011 3/30/2011 4/13/2011 9/30/2010 1/22/2010 9/30/2010 3/30/2011 1/22/2010 3/26/2010 7/14/2010 6/28/2012 7/14/2010 6/29/2011 3/26/2010 3/30/2011 9/30/2010 7/14/2010 1/22/2010 3/26/2010 Adjustment 12 Note N/ A N/ A N/ A N/ A N/ A N/ A Pricing Mechanism 1 (CONTINU E D) $60,000 $260,000 $110,000 $340,000 $760,000 $4,230,000 Investors (Cap) Cap of Incentive of Borrowers and to of Borrowers Payments on Behalf Servicers & Lenders/ Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Investment Description Purchase Purchase Purchase Purchase Purchase Purchase Transaction Transaction Type Servicer Modifying Borrowers’ Loans Servicer Modifying Borrowers’ Fresno County Federal Fresno C A Union, Fresno, Credit Tempe Schools Credit Schools Credit Tempe A Z Union, Tempe, E aton National B ank & E aston, OH Company, Trust Iberiabank, Sarasota, F L Grafton Suburban Credit Union, North Grafton, M A Park View Federal Savings B ank, Solon, OH Name of Institution 1/13/2010 12/23/2009 12/23/2009 12/23/2009 12/23/2009 12/16/2009 HAMP TRANSACTION DETAIL, AS OF 6/30/2012 HAMP TRANSACTION DETAIL, Date 308 Appendix D I Transaction Detail I July 25, 2012 $— $— Incentive Payments Total TARP TARP Total $7,388,255 Continued on next page $— $— Servicers Incentives $2,881,598 $— $— Investors Lenders/ Incentives $3,178,518 TARP Incentive Payments TARP $— $— Incentives Borrower’s Borrower’s $1,328,139 A A Updated due to quarterly assessment and reallocation Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation Transfer of cap due to servicing transfer Transfer Updated portfolio data from servicer Updated portfolio data from of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer servicer Updated portfolio data from Transfer of cap due to servicing transfer Transfer Transfer of cap from CitiMortgage, Inc. due of cap from Transfer to servicing transfer Updated portfolio data from servicer Updated portfolio data from Transfer of cap from CitiMortgage, Inc. due of cap from Transfer to servicing transfer Transfer of cap from CitiMortgage, Inc. due of cap from Transfer to servicing transfer Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from servicer Updated portfolio data from of SP Termination Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from of SP Termination Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from servicer Updated portfolio data from Reason for Adjustment $0 $0 $300,000 $290,111 $290,000 $870,333 $870,334 $850,000 $900,000 $34,933,774 $34,833,774 $34,733,774 $34,833,774 $33,133,774 $34,533,774 $34,233,774 $34,134,106 $34,133,774 $33,834,106 $33,734,106 $32,734,106 $32,734,142 $23,934,174 $24,134,174 $25,634,142 $25,630,000 $24,134,142 $25,430,000 $24,730,000 $24,400,000 $20,770,000 $15,910,000 $12,910,000 Adjusted Cap $112,222,716 $112,573,774 $112,223,774 $112,533,774 Adjustment Details ($36) ($32) ($332) Amount ($1,058) ($9,889) $40,000 $10,000 $50,000 ($29,666) $100,000 $100,000 $300,000 $300,000 $100,000 $300,000 $100,000 $200,000 $200,000 $700,000 $330,000 $150,000 $610,000 ($350,000) ($290,111) ($870,333) $1,600,000 $1,000,000 $7,100,000 $1,500,000 $3,630,000 $4,860,000 $3,000,000 ($1,700,000) ($1,695,826) $77,600,000 ($51,240,000) Cap Adjustment Date 1/6/2011 1/6/2011 6/14/2012 6/28/2012 5/16/2012 4/16/2012 3/15/2012 2/16/2012 1/13/2012 9/15/2011 6/29/2011 8/16/2011 6/16/2011 5/13/2011 4/13/2011 3/30/2011 3/16/2011 9/30/2010 1/13/2011 9/15/2010 8/13/2010 7/16/2010 7/14/2010 6/16/2010 5/14/2010 9/30/2010 1/26/2011 3/26/2010 7/14/2010 3/23/2011 3/26/2010 9/30/2010 3/26/2010 7/14/2010 Adjustment 10/14/2011 12/15/2011 11/16/2010 Note N/ A N/ A N/ A Pricing Mechanism 1 (CONTINU E D) $140,000 $240,000 $64,150,000 Investors (Cap) Cap of Incentive of Borrowers and to of Borrowers Payments on Behalf Servicers & Lenders/ Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Investment Description Purchase Purchase Purchase Transaction Transaction Type Servicer Modifying Borrowers’ Loans Servicer Modifying Borrowers’ Specialized L oan Servicing, LL C, Highland Ranch, CO First National B ank of Grant Park, Grant I L Roebling B ank, Roebling, NJ Name of Institution 1/13/2010 1/13/2010 1/13/2010 HAMP TRANSACTION DETAIL, AS OF 6/30/2012 HAMP TRANSACTION DETAIL, Date Transaction detail I Appendix D I July 25, 2012 309 $— $— $— $— $5,032 Incentive $177,823 Payments Total TARP TARP Total Continued on next page $— $— $— $— $3,000 $62,945 Servicers Incentives $— $— $— $— $1,032 $81,717 Investors Lenders/ Incentives TARP Incentive Payments TARP $— $— $— $— $1,000 $33,161 Incentives Borrower’s Borrower’s A A Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation Initial FH A -H MP cap servicer Updated portfolio data from Initial 2MP cap servicer Updated portfolio data from Termination of SP Termination Updated portfolio data from servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from of cap due to servicing transfer Transfer servicer Updated portfolio data from Initial FH A -H MP cap and initial 2MP Updated portfolio data from servicer Updated portfolio data from servicer Updated portfolio data from servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation of SP Termination Updated portfolio data from servicer Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from Reason for Adjustment $0 $0 $725,257 $725,265 $725,276 $725,277 $725,278 $700,000 $535,165 $535,158 $535,152 $435,167 $535,167 $535,166 $800,000 $230,000 $600,000 $870,332 $870,324 $870,320 $870,334 $870,333 $700,000 $5,500,000 $9,450,000 $13,274,517 $13,274,348 $12,474,782 $13,274,782 $13,274,738 $15,600,000 $13,274,762 $28,160,000 $15,500,000 $15,240,000 Adjusted Cap Adjustment Details ($8) ($7) ($6) ($8) ($4) ($24) ($20) ($11) ($221) ($169) Amount $25,278 $800,000 $100,000 $120,000 $160,000 $100,000 $200,000 $370,000 $170,334 ($364,833) ($730,000) $4,440,000 $8,680,000 ($3,125,218) ($5,500,000) ($8,750,000) $12,190,000 ($12,660,000) ($15,240,000) Cap Adjustment Date 1/6/2011 1/6/2011 1/6/2011 1/6/2011 6/28/2012 6/29/2011 9/30/2010 3/30/2011 9/30/2010 9/24/2010 5/26/2010 7/14/2010 7/14/2010 6/28/2012 6/29/2011 3/30/2011 9/30/2010 6/29/2011 6/28/2012 3/26/2010 3/30/2011 9/30/2010 9/30/2010 6/29/2011 6/28/2012 3/26/2010 5/14/2010 3/26/2010 7/14/2010 3/30/2011 9/30/2010 7/14/2010 3/26/2010 Adjustment 11/16/2010 11/16/2010 Note N/ A N/ A N/ A N/ A N/ A N/ A Pricing Mechanism 1 (CONTINU E D) $540,000 $960,000 $770,000 $1,060,000 $3,050,000 $28,040,000 Investors (Cap) Cap of Incentive of Borrowers and to of Borrowers Payments on Behalf Servicers & Lenders/ Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Investment Description Purchase Purchase Purchase Purchase Purchase Purchase Transaction Transaction Type Servicer Modifying Borrowers’ Loans Servicer Modifying Borrowers’ iServe Servicing, Inc., Irving, TX Urban Trust B ank, Urban Trust F L L ake May, United B ank, Griffin, G A Digital Federal Credit Digital Federal Credit M A Union, Marlborough, iServe Residential L ending, LL C , San Diego, A Greater Nevada Mortgage Greater NV Services, Carson City, Name of Institution 3/5/2010 3/3/2010 1/29/2010 1/15/2010 1/29/2010 1/13/2010 HAMP TRANSACTION DETAIL, AS OF 6/30/2012 HAMP TRANSACTION DETAIL, Date 310 Appendix D I Transaction Detail I July 25, 2012 $— $— $— $43,490 Incentive $930,801 Payments Total TARP TARP Total Continued on next page $— $— $— $23,239 $342,715 Servicers Incentives $— $— $— $— Investors Lenders/ $464,920 Incentives TARP Incentive Payments TARP $— $— $— $20,251 $123,165 Incentives Borrower’s Borrower’s A Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated FH A -H MP cap Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Transfer of cap due to servicing transfer Transfer servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from Transfer of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation of SP Termination servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from servicer Updated portfolio data from Updated due to quarterly assessment and reallocation servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from Reason for Adjustment $0 $40,000 $647,807 $647,800 $350,000 $349,998 $647,816 $290,111 $580,220 $580,212 $600,000 $580,221 $725,257 $580,222 $725,265 $725,276 $725,278 $725,277 $700,000 $3,647,816 $3,647,822 $3,647,827 $8,000,000 $6,400,000 $16,971,218 $16,971,073 $16,971,456 $16,971,505 $16,971,482 $15,900,000 Adjusted Cap Adjustment Details ($9) ($7) ($2) ($6) ($5) ($8) ($8) ($11) ($26) ($23) ($238) ($145) Amount $30,000 $59,889 $25,278 ($19,778) $250,111 $300,000 $400,000 ($580,212) ($150,000) $1,600,000 $1,071,505 ($3,000,000) ($4,352,173) ($44,880,000) Cap Adjustment Date 1/6/2011 1/6/2011 1/6/2011 1/6/2011 6/28/2012 5/26/2010 6/28/2012 6/29/2011 6/29/2011 4/13/2011 9/30/2010 3/30/2011 9/30/2010 6/29/2011 7/14/2011 7/14/2010 9/15/2010 3/30/2011 7/14/2010 9/30/2010 6/28/2012 6/29/2011 3/30/2011 9/30/2010 6/28/2012 7/14/2010 6/29/2011 3/30/2011 9/30/2010 7/14/2010 Adjustment 4, 8 Note N/ A N/ A N/ A N/ A N/ A Pricing Mechanism 1 (CONTINU E D) $10,000 $300,000 $300,000 $6,550,000 $60,780,000 Investors (Cap) Cap of Incentive of Borrowers and to of Borrowers Payments on Behalf Servicers & Lenders/ Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Investment Description Purchase Purchase Purchase Purchase Purchase Transaction Transaction Type A A Servicer Modifying Borrowers’ Loans Servicer Modifying Borrowers’ urora Financial Group, Financial Group, A urora Inc., Marlton, NJ Wealthbridge Mortgage Wealthbridge Corp, B eaverton, OR ank and Trust Midwest B ank and Trust Co., E lmwood Park, I L Vist Financial Corp, Wyomissing, P Navy Federal Credit Union, Navy Federal Credit Vienna, V Name of Institution 5/21/2010 4/14/2010 4/14/2010 3/10/2010 3/10/2010 HAMP TRANSACTION DETAIL, AS OF 6/30/2012 HAMP TRANSACTION DETAIL, Date Transaction detail I Appendix D I July 25, 2012 311 $— $— $— $8,886 $71,295 Incentive Payments Total TARP TARP Total Continued on next page $— $— $— $4,517 $21,500 Servicers Incentives $— $— $— $2,453 $36,712 Investors Lenders/ Incentives TARP Incentive Payments TARP $— $— $— $1,917 $13,083 Incentives Borrower’s Borrower’s A Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation of SP Termination servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer Updated portfolio data from servicer Updated portfolio data from servicer Updated portfolio data from Transfer of cap from CitiMortgage, Inc. due of cap from Transfer to servicing transfer of cap due to servicing transfer Transfer Reason for Adjustment $0 $3,481,222 $3,481,265 $3,481,334 $3,481,323 $1,740,634 $3,481,329 $1,740,665 $1,740,662 $1,740,667 $2,465,867 $2,465,897 $2,465,941 $2,465,937 $2,465,945 $3,680,000 $6,980,000 $11,314,108 $11,313,964 $11,314,337 $11,314,300 $11,314,320 $17,333,299 $17,633,517 $17,333,517 $17,623,517 $16,323,517 $17,423,517 $16,223,517 $16,423,790 $16,223,790 $13,523,790 $11,423,831 $13,523,814 $10,023,831 $11,423,814 Adjusted Cap Adjustment Details ($6) ($5) ($2) ($3) ($4) ($4) ($20) ($43) ($17) ($58) ($28) ($30) ($40) ($24) ($17) ($192) ($144) ($218) ($273) Amount $10,000 $200,000 $100,000 ($300,000) ($200,000) $7,014,337 $2,181,334 $1,040,667 $1,585,945 $1,100,000 $2,900,000 $1,400,000 $2,100,000 $3,043,831 $3,680,000 $3,300,000 ($1,740,634) Cap Adjustment Date 1/6/2011 1/6/2011 1/6/2011 1/6/2011 1/6/2011 6/28/2012 6/29/2011 9/30/2010 3/30/2011 6/28/2012 6/29/2011 8/10/2011 9/30/2010 3/30/2011 3/30/2011 6/29/2011 9/30/2010 6/28/2012 3/30/2011 6/29/2011 9/30/2010 6/14/2012 6/28/2012 5/16/2012 4/16/2012 6/16/2011 6/29/2011 4/13/2011 3/30/2011 3/16/2011 9/30/2010 6/16/2010 8/13/2010 Adjustment 10/14/2011 11/16/2011 10/15/2010 9 Note N/ A N/ A N/ A N/ A N/ A Pricing Mechanism 1 $— (CONTINU E D) $700,000 $880,000 $4,300,000 $1,300,000 Investors (Cap) Cap of Incentive of Borrowers and to of Borrowers Payments on Behalf Servicers & Lenders/ Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Investment Description Purchase Purchase Purchase Purchase Purchase Transaction Transaction Type Servicer Modifying Borrowers’ Loans Servicer Modifying Borrowers’ First Financial B ank, N. A ., Haute, ID Terre Pathfinder B ank, Oswego, NY B ramble Savings ank, Cincinati, OH Suburban Mortgage Company of New Mexico, MN A lbuquerque, P, Selene Finance L P, Houston TX Name of Institution 8/27/2010 8/25/2010 8/20/2010 8/4/2010 6/16/2010 HAMP TRANSACTION DETAIL, AS OF 6/30/2012 HAMP TRANSACTION DETAIL, Date 312 Appendix D I Transaction Detail I July 25, 2012 $— $— $4,181 Incentive $769,373 Payments Total TARP TARP Total $1,787,470 Continued on next page $— $— $2,000 $829,551 $196,972 Servicers Incentives $— $— $1,181 Investors Lenders/ $736,559 $381,596 Incentives TARP Incentive Payments TARP $— $— $1,000 $221,360 $190,805 Incentives Borrower’s Borrower’s A Updated portfolio data from servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from servicer Updated portfolio data from of SP Termination Updated due to quarterly assessment and reallocation Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Updated portfolio data from servicer Updated portfolio data from servicer Updated portfolio data from Transfer of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from Reason for Adjustment $0 $70,000 $60,000 $145,056 $580,220 $580,212 $580,206 $580,222 $580,221 $270,000 $145,056 $220,000 $180,000 $4,450,554 $1,450,556 $1,450,554 $1,000,000 $9,367,999 $9,467,999 $9,667,999 $8,668,142 $8,667,999 $8,268,169 $8,268,142 $8,268,157 $31,950,037 $31,950,303 $31,650,303 $26,650,303 $30,750,303 $14,650,530 $14,650,303 $14,650,554 $12,797,894 $13,007,999 $12,797,999 $12,967,999 $11,367,999 Adjusted Cap Adjustment Details ($8) ($6) ($2) ($24) ($15) ($12) ($266) ($227) ($105) ($143) Amount $45,056 $40,000 $50,000 $45,056 $40,000 $34,944 ($10,000) $180,222 $300,000 $900,000 $450,556 $700,000 $100,000 $200,000 $400,000 ($145,056) ($210,000) ($200,000) $4,100,000 $3,000,000 $1,000,000 $1,600,000 $1,700,000 $5,168,169 $12,000,000 $10,200,000 Cap Adjustment Date 2/2/2011 1/6/2011 1/6/2011 1/6/2011 1/6/2011 6/29/2011 6/28/2012 9/30/2010 3/30/2011 9/30/2010 6/28/2012 4/16/2012 1/13/2012 6/29/2011 7/14/2011 3/30/2011 3/16/2011 2/16/2011 9/30/2010 9/15/2010 6/14/2012 6/28/2012 5/16/2012 4/16/2012 6/29/2011 9/15/2011 4/13/2011 3/15/2012 6/14/2012 9/30/2010 3/30/2011 6/29/2011 9/30/2010 3/30/2011 Adjustment 12/15/2011 10/14/2011 11/16/2011 12/15/2011 9 4, 8 Note N/ A N/ A N/ A N/ A N/ A Pricing Mechanism 1 $— (CONTINU E D) $100,000 $400,000 $100,000 $3,100,000 Investors (Cap) Cap of Incentive of Borrowers and to of Borrowers Payments on Behalf Servicers & Lenders/ Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Investment Description Purchase Purchase Purchase Purchase Purchase Transaction Transaction Type Servicer Modifying Borrowers’ Loans Servicer Modifying Borrowers’ A merican Finance House LA RI BA , Pasadena, C A Midwest Community B ank, I L Freeport, Vericrest Financial, Inc., Vericrest OK Oklahoma City, Fay Servicing, LL C, Chicago, I L R B C ank (US A ), Raleigh, NC Name of Institution 9/24/2010 9/15/2010 9/15/2010 9/3/2010 9/1/2010 HAMP TRANSACTION DETAIL, AS OF 6/30/2012 HAMP TRANSACTION DETAIL, Date Transaction detail I Appendix D I July 25, 2012 313 $— $— $— $— $— $— $— $— $— $— Incentive Payments Total TARP TARP Total Continued on next page $— $— $— $— $— $— $— $— $— $— Servicers Incentives $— $— $— $— $— $— $— $— $— $— Investors Lenders/ Incentives TARP Incentive Payments TARP $— $— $— $— $— $— $— $— $— $— Incentives Borrower’s Borrower’s A A A Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from of SP Termination servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from servicer Updated portfolio data from servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from of SP Termination of SP Termination Reason for Adjustment $0 $0 $0 $145,054 $145,055 $145,056 $145,054 $145,055 $145,056 $145,054 $145,055 $145,056 $145,054 $145,055 $145,056 $145,054 $145,056 $145,056 $145,055 $2,901,019 $2,901,112 $2,901,055 $1,160,443 $2,901,108 $2,901,103 $1,160,445 $2,465,872 $2,465,902 $2,465,942 $2,465,938 $2,465,945 $2,756,056 $2,756,052 Adjusted Cap Adjustment Details ($2) ($4) ($5) ($3) ($4) ($4) ($36) ($48) ($30) ($36) Amount $45,056 $45,056 $45,056 $45,056 $45,056 $45,056 $901,112 $360,445 $765,945 $856,056 ($145,056) ($1,160,443) ($2,756,052) Cap Adjustment Date 1/6/2011 1/6/2011 1/6/2011 3/9/2011 1/6/2011 6/28/2012 6/29/2011 9/30/2010 6/28/2012 6/29/2011 9/30/2010 6/28/2012 3/23/2011 9/30/2010 3/30/2011 6/29/2011 9/30/2010 6/28/2012 6/29/2011 9/30/2010 6/28/2012 3/30/2011 6/29/2011 9/30/2010 6/28/2012 6/29/2011 9/30/2010 6/28/2012 9/30/2010 9/30/2010 3/23/2011 9/30/2010 6/29/2011 Adjustment 4, 8 4, 8 6 4, 8 4, 5, 8 4, 8 4, 8 Note N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A Pricing Mechanism 1 (CONTINU E D) $100,000 $100,000 $800,000 $100,000 $100,000 $100,000 $100,000 $2,000,000 $1,700,000 $1,900,000 Investors (Cap) Cap of Incentive of Borrowers and to of Borrowers Payments on Behalf Servicers & Lenders/ Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Investment Description Purchase Purchase Purchase Purchase Purchase Purchase Purchase Purchase Purchase Purchase Transaction Transaction Type Servicer Modifying Borrowers’ Loans Servicer Modifying Borrowers’ First Federal B ank of Florida, L ake City F CU Mortgage Services, Inc., New B righton, MN Community Credit Union of Community Credit Florida, Rockledge, F L Citizens Community B ank, I L Freeburg, Capital International Financial, Inc., Coral Gables, F L B anco Popular de Puerto Rico, San Juan, PR A merican Financial Inc., Resources NJ Parsippany, Centrue B ank, Ottawa, C A B ank, A gFirst Farm Credit Columbia, SC A marillo National B ank, A marillo, TX Name of Institution 9/30/2010 9/30/2010 9/30/2010 9/24/2010 9/30/2010 9/30/2010 9/30/2010 9/24/2010 9/30/2010 9/30/2010 HAMP TRANSACTION DETAIL, AS OF 6/30/2012 HAMP TRANSACTION DETAIL, Date 314 Appendix D I Transaction Detail I July 25, 2012 $— $— $— $— $— $1,750 $1,917 $6,081 $2,000 Incentive Payments Total TARP TARP Total Continued on next page $— $— $— $— $— $1,000 $1,000 $3,000 $1,000 Servicers Incentives $— $— $— $— $— $— $— $— $2,331 Investors Lenders/ Incentives TARP Incentive Payments TARP $— $— $— $— $— $750 $917 $750 $1,000 Incentives Borrower’s Borrower’s A A Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from Updated due to quarterly assessment and reallocation servicer Updated portfolio data from Termination of SP Termination Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from Updated due to quarterly assessment and reallocation servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from servicer Updated portfolio data from of SP Termination servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from Reason for Adjustment $0 $0 $435,167 $435,165 $435,159 $435,155 $145,056 $145,054 $435,166 $145,055 $145,056 $145,054 $145,056 $145,055 $580,222 $580,221 $145,054 $145,055 $145,056 $1,450,512 $1,450,529 $1,450,554 $1,450,552 $1,450,556 $2,465,867 $2,465,945 $2,465,897 $1,160,409 $2,465,937 $1,160,445 $1,160,423 $2,465,941 $1,160,443 $1,160,441 Adjusted Cap Adjustment Details ($2) ($2) ($6) ($4) ($4) ($4) ($2) ($2) ($17) ($23) ($30) ($40) ($14) ($18) Amount $45,056 $45,056 $45,056 $45,056 $450,556 $135,167 $765,945 $360,445 $180,222 ($145,056) ($580,221) Cap Adjustment Date 1/6/2011 1/6/2011 1/6/2011 1/6/2011 1/6/2011 6/28/2012 3/30/2011 6/29/2011 6/29/2011 6/28/2012 9/30/2010 9/30/2010 3/30/2011 3/23/2011 9/30/2010 6/28/2012 6/29/2011 9/30/2010 6/28/2012 9/30/2010 6/29/2011 6/28/2012 9/30/2010 6/29/2011 6/28/2012 3/30/2011 3/23/2011 9/30/2010 3/30/2011 6/29/2011 9/30/2010 6/28/2012 6/29/2011 9/30/2010 Adjustment 4, 8 4, 8 4, 8 4 7, 8 4, 8 Note N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A Pricing Mechanism 1 (CONTINU E D) $300,000 $100,000 $100,000 $100,000 $800,000 $400,000 $100,000 $1,000,000 $1,700,000 Investors (Cap) Cap of Incentive of Borrowers and to of Borrowers Payments on Behalf Servicers & Lenders/ Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Investment Description Purchase Purchase Purchase Purchase Purchase Purchase Purchase Purchase Purchase Transaction Transaction Type Federal Credit Union, A Federal Credit Servicer Modifying Borrowers’ Loans Servicer Modifying Borrowers’ ank and Trust Co, L iberty B ank and Trust New Orleans, LA James B . Nutter & MO Kansas City, Company, Guaranty B ank, Saint Paul, MN Gardner, M A Gardner, GF Gateway Mortgage Group, Gateway Mortgage Group, OK LL C, Tulsa, Franklin Savings, Cincinati, OH Flagstar Capital Markets MI Corporation, Troy, First Safety B ank, Cincinati, OH First Mortgage Corporation, Diamond, C A B ar, Name of Institution 9/30/2010 9/24/2010 9/30/2010 9/30/2010 9/30/2010 9/30/2010 9/30/2010 9/30/2010 9/30/2010 HAMP TRANSACTION DETAIL, AS OF 6/30/2012 HAMP TRANSACTION DETAIL, Date Transaction detail I Appendix D I July 25, 2012 315 $— $— $— $— $— $— $7,767 $56,944 Incentive Payments Total TARP TARP Total $3,656,057 Continued on next page $— $— $— $— $— $— $4,057 $29,587 Servicers Incentives $1,940,729 $— $— $— $— $— $— $— $— Investors Lenders/ $202,355 Incentives TARP Incentive Payments TARP $— $— $— $— $— $— $3,710 $27,357 Incentives Borrower’s Borrower’s $1,512,973 A A Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from of SP Termination Updated portfolio data from servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from Updated portfolio data from servicer Updated portfolio data from of SP Termination Updated portfolio data from servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from servicer Updated portfolio data from Reason for Adjustment $0 $0 $145,054 $145,056 $145,055 $870,333 $870,334 $145,054 $145,055 $145,056 $145,054 $145,055 $145,056 $145,054 $145,055 $145,056 $725,277 $725,278 $2,030,714 $2,030,778 $2,030,739 $1,015,365 $2,030,775 $2,030,772 $1,015,376 $1,015,387 $1,015,389 $1,015,388 $93,413,522 $93,414,319 $93,415,806 $93,415,681 $93,415,542 Adjusted Cap Adjustment Details ($3) ($3) ($25) ($33) ($11) ($11) ($797) ($125) ($139) Amount ($1,223) $45,056 $45,056 $45,056 $45,056 $270,334 $225,278 $630,778 $315,389 ($870,333) ($725,277) $49,915,806 Cap Adjustment Date 1/6/2011 1/6/2011 3/9/2011 1/6/2011 1/6/2011 1/6/2011 6/28/2012 2/17/2011 9/30/2010 6/29/2011 9/30/2010 6/28/2012 6/29/2011 9/30/2010 6/28/2012 6/29/2011 9/30/2010 6/28/2012 3/30/2011 6/29/2011 9/30/2010 6/28/2012 6/29/2011 9/30/2010 9/30/2010 6/28/2012 9/30/2010 3/30/2011 6/29/2011 6/28/2012 6/29/2011 3/30/2011 9/30/2010 Adjustment 4, 8 4, 8 4, 8 4, 5 4, 8 5 4, 8 Note N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A Pricing Mechanism 1 (CONTINU E D) $100,000 $600,000 $100,000 $100,000 $100,000 $500,000 $700,000 $1,400,000 $43,500,000 Investors (Cap) Cap of Incentive of Borrowers and to of Borrowers Payments on Behalf Servicers & Lenders/ Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Investment Description Purchase Purchase Purchase Purchase Purchase Purchase Purchase Purchase Purchase Transaction Transaction Type A Servicer Modifying Borrowers’ Loans Servicer Modifying Borrowers’ Weststar Mortgage, Weststar Inc., V Woodbridge, University First Federal Union, Credit UT Salt L ake City, Stockman B ank of MT Montana, Miles City, Schmidt Mortgage OH Rocky River, Company, Midland Mortgage Oklahoma Company, OK City, Marsh A ssociates, Inc., Charlotte, NC Mainstreet Credit Union, Credit Mainstreet L exena, KS Magna B ank, Germanton, TN M&T B ank, uffalo, NY Name of Institution 9/30/2010 9/30/2010 9/30/2010 9/30/2010 9/30/2010 9/30/2010 9/30/2010 9/30/2010 9/30/2010 HAMP TRANSACTION DETAIL, AS OF 6/30/2012 HAMP TRANSACTION DETAIL, Date 316 Appendix D I Transaction Detail I July 25, 2012 $— $— $42,995 $55,591 $46,973 Incentive $326,518 $816,757 Payments Total TARP TARP Total Continued on next page $— $— $10,917 $15,416 $80,406 $14,200 $245,752 Servicers Incentives $— $— $24,661 $26,218 $26,773 Investors Lenders/ $170,651 $359,748 Incentives TARP Incentive Payments TARP $— $— $7,417 $6,000 $13,957 $75,461 $211,257 Incentives Borrower’s Borrower’s Updated due to quarterly assessment and reallocation Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation Transfer of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation Transfer of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation of cap due to servicing transfer Transfer Updated portfolio data from servicer Updated portfolio data from Updated due to quarterly assessment and reallocation Updated due to quarterly assessment and reallocation servicer Updated portfolio data from Transfer of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation Updated portfolio data from servicer Updated portfolio data from of cap due to servicing transfer Transfer Updated portfolio data from servicer Updated portfolio data from Reason for Adjustment $899,991 $799,991 $500,000 $599,991 $200,000 $217,687 $600,000 $100,000 $799,984 $799,991 $200,000 $600,000 $599,991 $300,000 $5,359,925 $5,359,991 $4,909,991 $3,399,991 $1,333,265 $1,333,268 $1,233,268 $1,000,000 $4,299,968 $4,300,000 $4,299,991 $3,299,859 $4,299,996 $3,299,899 $5,599,899 $3,099,899 $5,599,993 $5,599,984 $5,000,000 $5,499,993 $4,999,993 Adjusted Cap Adjustment Details ($9) ($3) ($7) ($9) ($5) ($4) ($9) ($7) ($66) ($23) ($40) ($85) Amount $17,687 $450,000 $100,000 $200,000 $500,000 $200,000 $100,000 $100,000 $233,268 $100,000 $200,000 $200,000 $300,000 $100,000 $200,000 $100,000 $500,000 $1,510,000 $2,500,000 $1,000,000 $4,300,000 $5,000,000 ($2,500,000) Cap Adjustment Date 1/6/2011 1/6/2011 6/28/2012 6/14/2012 5/16/2012 9/15/2011 7/14/2011 5/13/2011 6/29/2011 4/13/2011 6/29/2011 6/16/2011 6/28/2012 6/29/2011 4/13/2011 4/13/2011 6/28/2012 6/29/2011 8/16/2011 4/13/2011 6/16/2011 6/28/2012 5/13/2011 6/29/2011 6/28/2012 3/15/2012 3/30/2011 6/29/2011 3/16/2011 2/16/2011 Adjustment 11/16/2011 11/16/2011 12/15/2010 11/16/2011 12/15/2010 9 9 9 9 9 9 9 Note N/ A N/ A N/ A N/ A N/ A N/ A N/ A Pricing Mechanism 1 $— $— $— $— $— $— $— (CONTINU E D) Investors (Cap) Cap of Incentive of Borrowers and to of Borrowers Payments on Behalf Servicers & Lenders/ Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Investment Description Purchase Purchase Purchase Purchase Purchase Purchase Purchase Transaction Transaction Type A Servicer Modifying Borrowers’ Loans Servicer Modifying Borrowers’ FCI L ender Services, Inc., A naheim Hills, C Western Federal Credit Federal Credit Western Union, Hawthorne, C A Urban Partnership B ank, Chicago, I L SunTrust Mortgage, Inc., SunTrust Richmond, V mTrust B ank, A Division of A mTrust Community B ank, New York Cleveland, OH Scotiabank de Puerto Rico, San Juan, PR Statebridge Company, LL C, Statebridge Company, CO Denver, Name of Institution 5/13/2011 4/13/2011 4/13/2011 4/13/2011 4/13/2011 12/15/2010 12/15/2010 HAMP TRANSACTION DETAIL, AS OF 6/30/2012 HAMP TRANSACTION DETAIL, Date Transaction detail I Appendix D I July 25, 2012 317 $— $— $— $— $1,000 $91,274 Incentive $144,794 Payments Total TARP TARP Total $3,409,694,944 $— $— $— $— $1,000 $20,250 $36,391 Servicers Incentives $1,177,908,534 $— $— $— $— $— $61,440 $73,993 Investors Lenders/ Incentives TARP Incentive Payments TARP $1,587,471,355 $— $— $— $— $— $9,583 $34,410 Incentives Borrower’s Borrower’s $644,315,055 Totals Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation Transfer of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Transfer of cap due to servicing transfer Transfer Updated due to quarterly assessment and reallocation Transfer of cap due to servicing transfer Transfer of cap due to servicing transfer Transfer Reason for Adjustment $100,000 $940,000 $100,000 $200,000 $799,997 $800,000 $100,000 $200,000 $1,145,242 $1,300,000 $1,299,985 $1,200,000 $1,199,991 $1,100,000 Adjusted Cap Adjustment Details ($3) ($9) ($15) Amount $100,000 $940,000 $205,242 $100,000 $200,000 $600,000 $100,000 $100,000 $200,000 $900,000 $1,300,000 Cap Adjustment $6,049,733,607 $29,881,303,607 Date 3/15/2012 6/14/2012 6/28/2012 1/13/2012 6/28/2012 9/15/2011 6/28/2012 4/16/2012 6/28/2012 9/15/2011 1/13/2012 7/14/2011 Adjustment 12/15/2011 11/16/2011 9 9 9 9 9 9 9 Note Total Cap Adjustments Total Total Cap Total N/ A N/ A N/ A N/ A N/ A N/ A N/ A Pricing Mechanism 1 s with JPMorgan Chase B ank, N A , and E MC Mortgage Corporation. A s with JPMorgan $— $— $— $— $— $— $— (CONTINU E D) A termination. Investors (Cap) Cap of Incentive $23,831,570,000 of Borrowers and to of Borrowers Payments on Behalf Servicers & Lenders/ Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Financial Instrument for Home L oan Modifications Investment Description Total Initial Cap Total Purchase Purchase Purchase Purchase Purchase Purchase Purchase Transaction Transaction Type A with Chase Home Finance, LL C was terminated and superseded by new SP Servicer Modifying Borrowers’ Loans Servicer Modifying Borrowers’ PrimeWest Mortgage PrimeWest Corporation, L ubbock, TX Capital Resurgent Solutions, L P, SC Greenville, Sun West Mortgage Sun West Inc, Cerritos, C A Company, Rushmore L oan Rushmore Management Services LL C, Irvine, C A PHH Mortgage NJ Corporation, Mt. L aurel, B angor Savings ank, M E B angor, Gregory Funding, LL C, Gregory B eaverton, OR Name of Institution ffordable Foreclosure A lternatives program. Foreclosure A ” means the Home ffordable The Cap of Incentive Payments represents the potential total amount allocated to each servicer and includes the maximum amount allotted for all payments on behalf of borrowers and payments to servicers and lenders/investors. The Cap is subject to adjustment based on the total amount allocated to the program and and payments to servicers lenders/investors. The Cap is subject adjustment based on the total amount allocated program amount allotted for all payments on behalf of borrowers the potential total amount allocated to each servicer and includes maximum The Cap of Incentive Payments represents under A djustment Details. modifications. E ach adjustment to the Cap is reflected individual servicer usage for borrower On July 31, 2009, the SP Mortgage, paid to Wachovia FS B prior to such merger. the amount previously A djusted Cap stated above represents B ank, N A , and the remaining Fargo with Wells Mortgage, Wachovia FS B was merged Initial cap amount includes FH A -H MP. Initial cap amount includes RD-H A MP. Initial cap amount includes 2MP. Initial cap amount includes FH A -2 L P. Initial cap does not include H A MP. realized as a cap adjustment and not initial cap. is loan modifications. The amount transferred to all rights and obligations for the transferred with respect (a copy of which is available on www.FinancialStability.gov) This institution executed an A ssignment and ssumption greement The amendment reflects a change in the legal name of institution. The amendment reflects Inc. prior to such agreement. paid to Mor E quity, the amount previously A djusted Cap stated above represents The remaining with Nationstar Mortgage, to Nationstar. LL C, that took effect Inc executed a subservicing agreement transferred A ll mortgage 2/1/2011. loans including all H A MP were Mor E quity, the amount paid to servicer prior SP A djusted Cap stated above represents The remaining paid to each servicer prior such merger. the amount previously A djusted Cap stated above represents into BA C Home L oans Servicing, Inc. and the remaining merged Corporation were Credit Home L oan Services, Inc. and Wilshire paid to E MC Mortgage prior to such transfer. the amount previously A djusted Cap stated above represents Chase B ank, N A . The remaining the servicing of all loans to JPMorgan Chase & Co, transferred subsidiary of JPMorgan In A pril 2011, E MC Mortgage, an indirect

3/15/2012 6/14/2012 . Report-Housing Programs 7/2/2012, Transactions Treasury’s taken verbatim from notes are Data as of 6/30/2012. Numbered Notes: Numbers may be affected by rounding. 1/13/2012 12/15/2011 9/15/2011 9/15/2011 7/14/2011 HAMP TRANSACTION DETAIL, AS OF 6/30/2012 HAMP TRANSACTION DETAIL, 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Date A s used in this table: “H A F program. “HPDP” means the Home Price Decline Protection “2MP” means the Second L ien Modification Program. Modification Program. “RD-H A MP” means the Rural Housing Service Home ffordable “FH A -2 L P” means the FH Second ien Program. , 7/2/2012. Report-Housing Programs Transactions Treasury, Source: 318 Appendix D I Transaction Detail I July 25, 2012 Pricing Mechanism N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A

1 Continued on next pag e Amount Investment $79,351,573 $20,697,198 $194,026,240 $267,766,006 $498,605,738 $482,781,786 $570,395,099 $220,042,786 $295,431,547 $162,521,345 $148,901,875 $101,888,323 $339,255,819 $221,694,139 $445,603,557 $300,548,144 $1,975,334,096 $1,057,839,136 — — — — — — — — — — — — — — — — — — Additional $34,056,581 $57,169,659 $49,294,215 $82,748,571 $13,570,770 $22,780,803 $58,772,347 $98,659,200 $93,313,825 $63,851,373 $12,970,520 $476,257,070 $799,477,026 $238,864,755 $400,974,381 $142,666,006 $128,461,559 $215,644,179 $120,874,221 $202,907,565 $148,728,864 $249,666,235 $101,848,874 $212,604,832 $138,931,280 $279,250,831 $188,347,507 Investment Amount — — — — — — — — — — — — — — — — — — — — — — — — — — — Amount $7,726,678 $88,000,000 $43,000,000 $60,672,471 $55,588,050 $38,036,950 $82,762,859 $102,800,000 $699,600,000 $418,000,000 $125,100,000 $154,500,000 $159,000,000 $172,000,000 $138,000,000 $126,650,987 $166,352,726 $112,200,637 Initial Investment Financial Instrument for HHF Program Financial Instrument for HHF Program Financial Instrument for HHF Program Financial Instrument for HHF Program Financial Instrument for HHF Program Financial Instrument for HHF Program Financial Instrument for HHF Program Financial Instrument for HHF Program Financial Instrument for HHF Program Financial Instrument for HHF Program Financial Instrument for HHF Program Financial Instrument for HHF Program Financial Instrument for HHF Program Financial Instrument for HHF Program Financial Instrument for HHF Program Financial Instrument for HHF Program Financial Instrument for HHF Program Financial Instrument for HHF Program Financial Instrument for HHF Program Financial Instrument for HHF Program Financial Instrument for HHF Program Financial Instrument for HHF Program Financial Instrument for HHF Program Financial Instrument for HHF Program Financial Instrument for HHF Program Financial Instrument for HHF Program Financial Instrument for HHF Program Financial Instrument for HHF Program Financial Instrument for HHF Program Financial Instrument for HHF Program Financial Instrument for HHF Program Financial Instrument for HHF Program Financial Instrument for HHF Program Financial Instrument for HHF Program Financial Instrument for HHF Program Financial Instrument for HHF Program Financial Instrument for HHF Program Financial Instrument for HHF Program Financial Instrument for HHF Program Financial Instrument for HHF Program Financial Instrument for HHF Program Financial Instrument for HHF Program Financial Instrument for HHF Program Financial Instrument for HHF Program Financial Instrument for HHF Program Investment Description Purchase Purchase Purchase Purchase Purchase Purchase Purchase Purchase Purchase Purchase Purchase Purchase Purchase Purchase Purchase Purchase Purchase Purchase Transaction Transaction Type A Mortgage A ssistance Corporation, Sacramento, C ffordable Housing, Inc., A tlanta, G A ffordable ffordable Housing A ssistance Corporation, Reno, NV Nevada A ffordable CalHF F L Florida Housing Finance Corporation, Tallahassee, Funding Corporation, Phoenix, A Z Prevention A rizona (Home) Foreclosure ssistance Nonprofit Housing Corporation, L ansing, MI Michigan Homeowner A ssistance Nonprofit gency, Raleigh, NC Housing Finance A gency, North Carolina Ohio Homeowner A ssistance LL C, Columbus, OH ffordable Housing A ssistance Corporation, Salem, OR A ffordable Oregon Rhode Island Housing and Mortgage Finance Corporation, Providence, RI Rhode Island Housing and Mortgage Finance Corporation, Providence, SC Housing Corp, Columbia, uthority, Montgomery, AL Montgomery, A labama Housing Finance uthority, Kentucky Housing Corporation, Frankfort, KY Mississippi Home Corporation, Jackson, MS GHF uthority, Indianapolis, IN Indiana Housing and Community Development A uthority, uthority, Chicago, I L Illinois Housing Development A uthority, gency, Trenton, NJ Trenton, New Jersey Housing and Mortgage Finance A gency, gency, Washington, DC Washington, District of Columbia Housing Finance A gency, Seller Name of Institution 6/23/2010 9/23/2010 9/29/2010 9/23/2010 9/29/2010 9/23/2010 9/29/2010 6/23/2010 6/23/2010 6/23/2010 9/29/2010 6/23/2010 9/23/2010 9/29/2010 8/3/2010 9/23/2010 9/29/2010 8/3/2010 9/23/2010 9/29/2010 8/3/2010 9/23/2010 9/29/2010 8/3/2010 9/23/2010 9/29/2010 8/3/2010 9/23/2010 9/29/2010 9/23/2010 9/29/2010 9/23/2010 9/29/2010 9/23/2010 9/29/2010 9/23/2010 9/29/2010 9/23/2010 9/29/2010 9/23/2010 9/29/2010 9/23/2010 9/29/2010 9/23/2010 9/29/2010 Trade Trade Date 2 3 2 3 2 3 3 2 3 2 3 2 3 2 3 2 3 2 3 3 3 3 3 3 3 3 3 HARDEST HIT FUND (HHF) PROGRAM TRANSACTION DETAIL, AS OF 6/30/2012 HARDEST HIT FUND (HHF) PROGRAM TRANSACTION DETAIL, Note Table D.13 Table Transaction detail I Appendix D I July 25, 2012 319 Pricing Mechanism N/ A Pricing Mechanism N/ A N/ A

1 $8,117,000,000 $8,117,000,000 Investment Amount Amount Investment $217,315,593 $7,600,000,000 — Additional $136,187,333 Investment Amount Total Investment Amount Total — Amount $81,128,260 Initial Investment Total Investment Amount Total (CONTINU E D) Investment Description Financial Instrument for HHF Program Financial Instrument for HHF Program Transaction Transaction Type Purchase Investment Description greement, dated as of September 3, 2010, between the U.S. Department of the Treasury and Citibank, N. A dated as of September 3, 2010, between the U.S. Department of the Treasury A greement, Facility Purchase and substituted its investment for an amended and restated Financial Instrument. A and substituted its investment for an amended restated Financial Instrument. A and substituted its investment for an amended restated Transaction Type Transaction Purchase Seller Name Citigroup, Inc., New York, NY Inc., New York, Citigroup, Seller Name of Institution Nashville, TN Housing Development A gency, Tennessee Trade Date Trade 9/3/2010 Trade Trade Date 9/23/2010 9/29/2010 The purchase will be incrementally funded up to the investment amount. will be incrementally The purchase additonal investment to this HF provided On 9/23/2010, Treasury additonal investment to this HF provided On 9/29/2010, Treasury (the the issuance of an up to $8 billion, 10-year letter credit Citigroup to demand from which allowed Treasury (the ‘ L /C Facility A greement”), agreement into a facility purchase and Citibank, N. A . entered On September 3, 2010, the U.S. Department of the Treasury time to during the first 2.5 years. A t that time, amount of L /C will be capped at from under the FH A Short to the dollar value of mortgages in proportion Refinance program refinanced availability under the L /C incrementally will increase “ L /C”). Treasury will incur fees for the availability and usage of L /C up to a maximum amount $117 million. Treasury level. Under the terms of L /C Facility A greement, then-current

Note HARDEST HIT FUND (HHF) PROGRAM TRANSACTION DETAIL, AS OF 6/30/2012 HARDEST HIT FUND (HHF) PROGRAM TRANSACTION DETAIL, 1 2 3 FHA SHORT REFINANCE PROGRAM, AS OF 6/30/2012 Note 1 . Report-Housing Programs 7/2/2012, Transactions Treasury’s taken verbatim from notes are Data as of 6/30/2012. Numbered Notes: Numbers may be affected by rounding. 1 . Report-Housing Programs 7/2/2012, Transactions Treasury’s taken verbatim from notes are Data as of 6/30/2012. Numbered Notes: Numbers may be affected by rounding. 3 , 7/2/2012. Report-Housing Programs Transactions Treasury, Source: , 7/2/2012. Report-Housing Programs Transactions Treasury, Source: Table D.14 Table 320 Appendix E I Cross-Reference of Report to the Inspector General Act of 1978 | July 25, 2012

Cross-Reference of Report to the Inspector General Act of 1978 This appendix cross-references this report to the reporting requirements under the Inspector General Act of 1978 (P.L. 95-452), as amended, 5 U.S.C. APP.

Section Statute (Inspector General Act of 1978) SIGTARP Action Report Reference

Section “Description of significant problems, abuses, and List problems, abuses, and deficiencies Section 1: “The Office of the SIGTARP” 5(a)(1) deficiencies...” from SIGTARP audits and investigations. Section 5: “SIGTARP Recommendations” “Description of recommendations for corrective Section List recommendations from SIGTARP Section 1: “The Office of the SIGTARP” action…with respect to significant problems, 5(a)(2) audits and investigations. abuses, or deficiencies...” Section 5: “SIGTARP Recommendations” “Identification of each significant recommendation List all instances of incomplete Section described in previous semiannual reports on which corrective action from previous Section 5: “SIGTARP Recommendations” 5(a)(3) corrective action has not been completed...” semiannual reports. “A summary of matters referred to prosecutive Section List status of SIGTARP investigations authorities and the prosecutions and convictions Section 1: “The Office of the SIGTARP” 5(a)(4) referred to prosecutive authorities. which have resulted...” “A summary of each report made to the [Treasury Section Secretary] under section 6(b)(2)...” (instances List TARP oversight reports by Treasury, Appendix G: “Key Oversight Reports and 5(a)(5) where information requested was refused or not GAO, and SIGTARP. Testimony” provided). “A listing, subdivided according to subject matter, Section of each audit report issued...” showing dollar value List SIGTARP audits. Section 1: “The Office of the SIGTARP” 5(a)(6) of questioned costs and recommendations that funds be put to better use. Section “A summary of each particularly significant Provide a synopsis of significant Section 1: “The Office of the SIGTARP” 5(a)(7) report...” SIGTARP audits. “Statistical tables showing the total number of audit Provide statistical tables showing dollar Section Section 1: “The Office of the SIGTARP” reports and the total dollar value of questioned value of questioned costs from SIGTARP 5(a)(8) costs...” audits. Section 5: “SIGTARP Recommendations” As detailed in Section 1: “The Office of the “Statistical tables showing the total number of audit Provide statistical tables showing dollar SIGTARP,” SIGTARP has made important Section reports and the dollar value of recommendations value of funds put to better use by findings in its audit reports. However, to date 5(a)(9) that funds be put to better use by management...” management from SIGTARP audits. SIGTARP’s audits have not included funds put to better use findings. “A summary of each audit report issued before the commencement of the reporting period for Provide a synopsis of significant which no management decision has been made by Section SIGTARP audit reports in which Section 1: “The Office of the SIGTARP” the end of reporting period, an explanation of the 5(a)(10) recommendations by SIGTARP are reasons such management decision has not been Section 5: “SIGTARP Recommendations” still open. made, and a statement concerning the desired timetable for achieving a management decision...” Explain audit reports in which Section “A description and explanation of the reasons for Section 1: “The Office of the SIGTARP” significant revisions have been made to 5(a)(11) any significant revised management decision...” management decisions. Section 5: “SIGTARP Recommendations” “Information concerning any significant Section Provide information where management Section 1: “The Office of the SIGTARP” management decision with which the Inspector 5(a)(12) disagreed with a SIGTARP audit finding. General is in disagreement...” Section 5: “SIGTARP Recommendations” public announcements of audits I Appendix F I July 25, 2012 321

Public Announcements of Audits This appendix provides an announcement of new and GAO3 ongoing public audits by the agencies listed below. See Ongoing Audits Appendix G: “Key Oversight Reports and Testimony” for a • A look at MHA and especially the Hardest Hit program listing of published reports. Italic style indicates narrative which will come in July. taken verbatim from the agencies’ responses to SIGTARP’s • Management and oversight of conflicts of interest in data call. contracts for September. • U.S. Department of Treasury Office of Inspector General • Financial Audit will come in November. (“Treasury OIG”) • Overview report is scheduled for January. • Federal Reserve Board Office of Inspector General (“Federal Reserve OIG”) FDIC OIG4 • Government Accountability Office (“GAO”) Ongoing Audits • Federal Deposit Insurance Corporation Office of Inspector FDIC OIG’s ongoing material loss review of Tennessee General (“FDIC OIG”) Commerce Bank (TCB) will include reference to TARP funds. In October 2008, TNCC (the holding company) submitted Treasury OIG1 an application for the TARP Capital Purchase Program Ongoing Audits and, upon FDIC review and approval, issued $30 million • None in preferred shares to the U.S. Treasury under the Capital Purchase Program on December 19, 2008. Of this amount, Federal Reserve OIG2 approximately $24 million was down-streamed to TCB. This Ongoing Audits work is not yet complete. • None Endnotes 1 Treasury OIG, response to SIGTARP data call, 7/3/2012. 2 Federal Reserve OIG, response to SIGTARP data call, 7/3/2012. 3 GAO, response to SIGTARP data call, 7/3/2012. 4 FDIC OIG, response to SIGTARP data call, 7/2/2012. 322 Appendix g I key oversight reports and testimonY I July 25, 2012

Key Oversight Reports and Testimony This list reflects TARP-related reports and testimony published in the quarter ended June 30, 2012. See previous SIGTARP quarterly reports for lists of prior oversight reports and testimony.

U.S. DEPARTMENT OF THE TREASURY (Treasury) ROLES AND MISSION

The mission of Treasury is to serve the American people and strengthen national security by managing the U.S. Government’s finances effectively; promoting economic growth and stability; and ensuring the safety, soundness, and security of the U.S. and international financial systems. Treasury advises the President on economic and financial issues, encourages sustainable economic growth, and fosters improved governance in financial institutions. OVERSIGHT REPORTS

Treasury, Transactions Report, 4/2/2012 – 6/27/2012, www.treasury.gov/initiatives/financial-stability/briefing-room/reports/tarp-transactions/ Pages/default.aspx, accessed 7/5/2012. (released weekly)

Treasury, Daily TARP Update, 4/2/2012 – 7/2/2012, www.treasury.gov/initiatives/financial-stability/briefing-room/reports/tarp-daily-summary- report/Pages/default.aspx, accessed 7/5/2012.

Treasury, TARP Monthly 105(a) Report, 4/10/2012 – 7/10/2012, www.treasury.gov/initiatives/financial-stability/briefing-room/reports/105/Pages/ default.aspx, accessed 7/10/2012.

Treasury, Dividends and Interest Report, 4/10/2012 – 7/10/2012, www.treasury.gov/initiatives/financial-stability/briefing-room/reports/dividends- interest/Pages/default.aspx, accessed 7/10/2012. (released monthly)

Treasury, Making Home Affordable Program Report, 4/6/2012 – 7/6/2012, www.treasury.gov/initiatives/financial-stability/results/MHA-Reports/ Pages/default.aspx, accessed 7/11/2012. (released monthly)

Treasury, HAMP Activity by Metropolitan Statistical Area, 4/6/2012 – 7/6/2012, www.treasury.gov/initiatives/financial-stability/results/MHA- Reports/Pages/default.aspx, accessed 7/11/2012. (released monthly)

U.S. DEPARTMENT OF THE TREASURY OFFICE OF THE INSPECTOR GENERAL (TREASURY OIG) ROLES AND MISSION

The Office of Inspector General promotes the economy, efficiency, and effectiveness of Treasury programs and operations, and protects against fraud, waste, and abuse, to assist and augment the Treasury’s contribution to stability and public confidence in the nation’s financial system. OVERSIGHT REPORTS

Treasury OIG, Safety and Soundness: Material Loss Review of Integra Bank, National Association, OIG-12-050 (4/12/2012), www.treasury.gov/about/ organizational-structure/ig/Audit%20Reports%20and%20Testimonies/OIG12050.pdf, accessed 7/5/2012. key oversight reports and testimonY I Appendix g I July 25, 2012 323

GOVERNMENT ACCOUNTABILITY OFFICE (GAO) ROLES AND MISSION

GAO is tasked with performing ongoing oversight of TARP’s performance, including:

• evaluating the characteristics of asset purchases and the disposition of assets acquired • assessing TARP’s efficiency in using the funds • evaluating compliance with applicable laws and regulations • assessing the efficiency of contracting procedures • auditing TARP’s annual financial statements and internal controls • submitting reports to Congress at least every 60 days.

OVERSIGHT REPORTS

GAO, “Foreclosure Mitigation: Agencies Could Improve Effectiveness of Federal Efforts with Additional Data Collection and Analysis,” GAO-12-296, June 28, 2012, www.gao.gov/assets/600/592028.pdf, accessed 7/5/2012.

GAO, “Troubled Asset Relief Program: Government’s Exposure to AIG Lessens as Equity Investments Are Sold,” GAO-12-574, May 7, 2012, www.gao.gov/ assets/600/590677.pdf, accessed 7/5/2012.

SPECIAL INSPECTOR GENERAL FOR THE TROUBLED ASSET RELIEF PROGRAM (SIGTARP) ROLES AND MISSION

Under EESA, the Special Inspector General has the responsibility, among other things, to conduct, supervise and coordinate audits and investigations of the purchase, management, and sale of assets under the Troubled Asset Relief Program (“TARP”). SIGTARP’s mission is to advance economic stability by promoting the efficiency and effectiveness of TARP management, through transparency, through coordinated oversight, and through robust enforcement against those, whether inside or outside of Government, who waste, steal or abuse TARP funds. OVERSIGHT REPORTS

SIGTARP, “Factors Affecting Implementation of the Hardest Hit Fund Program,” 4/12/2012, www.sigtarp.gov/Audit%20Reports/SIGTARP_HHF_Audit.pdf, accessed 7/19/2012.

SIGTARP, “Quarterly Report to Congress,” 4/25/2012, www.sigtarp.gov/Quarterly%20Reports/April_25_2012_Report_to_Congress.pdf, accessed 7/6/2012.

SIGTARP, “The NPV Test’s Impact on HAMP,” 6/18/2012, www.sigtarp.gov/Audit%20Reports/NPV_Report.pdf, accessed 7/11/2012.

RECORDED TESTIMONY

SIGTARP, Written Testimony of the Honorable Christy Romero, Special Inspector General for the Troubled Asset Relief Program (SIGTARP), Before the U.S. Senate Committee on Homeland Security and Governmental Affairs Subcommittee on Oversight of Government Management, the Federal Workforce, and the District of Columbia, 4/26/2012, www.sigtarp.gov/Testimony/SIGTARP_Testimony_Financial_Literacy_Hearing_4-26-12.pdf, accessed 7/6/2012.

SIGTARP, Written Testimony of the Honorable Christy Romero, Special Inspector General for the Troubled Asset Relief Program (SIGTARP), Before the U.S. House Committee on Oversight and Reform Subcommittee on TARP, Financial Services and Bailouts of Public and Private Programs, 7/10/2012, www. sigtarp.gov/Testimony/SIGTARP_Testimony_Delphi_Hearing.pdf, accessed 7/19/2012.

Notes: Italic style indicates verbatim narrative taken from source documents.

Sources: Treasury, www.treasury.gov, accessed 7/5/2012; Treasury OIG, www.treasury.gov, accessed 7/5/2012; GAO, www.gao.gov, accessed 7/5/2012; SIGTARP, www.sigtarp.gov, accessed 7/5/2012; GAO, response to SIGTARP data call, 7/3/2012; Treasury, response to SIGTARP data call, 7/5/2012; Treasury OIG, response to SIGTARP data call, 7/3/2012. 324 Appendix h I correspondence I July 25, 2012 324

Correspondence This appendix provides a copy of the following correspondence:

Correspondence Date From To Regarding 5/1/2012 Treasury SIGTARP Response to SIGTARP’s Recommendation on Hardest Hit Fund Information Security 7/10/2012 Treasury SIGTARP Status Update on Recommendations in the SIGTARP Quarterly Report Treasury, Office of 7/10/2012 the Special Master SIGTARP Status Update on Recommendations in the SIGTARP Quarterly Report 7/19/2012 Treasury SIGTARP Treasury Response to SIGTARP HAMP Tier 2 Recommendations correspondence I Appendix h I July 25, 2012 325 326 Appendix h I correspondence I July 25, 2012 correspondence I Appendix h I July 25, 2012 327 328 Appendix h I correspondence I July 25, 2012 correspondence I Appendix h I July 25, 2012 329 330 Appendix h I correspondence I July 25, 2012 correspondence I Appendix h I July 25, 2012 331 332 Appendix h I correspondence I July 25, 2012 organizational chart I Appendix I I July 25, 2012 333

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Michael Rivera Michael

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Investigative Counsel Investigative o nal Chart Organizati

MISSION

SIGTARP’s Mission is to advance economic stability by promoting the efficiency and effectiveness of TARP management, through transparency, through coordinated oversight, and through robust enforcement against those, whether inside or outside of Government, who waste, steal, or abuse TARP funds.

STATUTORY AUTHORITY

SIGTARP was established by Section 121 of the Emergency Economic Stabilization Act of 2008 (“EESA”) and amended by the Special Inspector General for the Troubled Asset Relief Program Act of 2009 (“SIGTARP Act”). Under EESA and the SIGTARP Act, the Special Inspector General has the duty, among other things, to conduct, supervise, and coordinate audits and investigations of any actions taken under the Troubled Asset Relief Program (“TARP”) or as deemed appropriate by the Special Inspector General. In carrying out those duties, SIGTARP has the authority set forth in Section 6 of the Inspector General Act of 1978, including the power to issue subpoenas.

Office of the Special Inspector General for the Troubled Asset Relief Program General Telephone: 202.622.1419 Hotline: 877.SIG.2009 [email protected] www.SIGTARP.gov SIGTARP: Report Quarterly to Congress | July 25, 2012

PECTO INS R G AL EN CI ER E A P L S

T R M O A U R B G L E RO D A F P SSET RELIE

Office of the Special Inspector General Q3 for the Troubled Asset Relief Program SIGTARPSIGTARP 2012 SIGTARPSIGTARP Advancing Economic Stability Through Transparency, Coordinated Oversight, and Robust Enforcement SIG-QR-12-03

202.622.1419 Hotline: 877.SIG.2009 Quarterly Report to Congress [email protected] July 25, 2012 www.SIGTARP.gov