SIGTARP Activity Report – Is Your Bank Next?

In a June 2012 article published in The American Banker, we noted the that the Office of the Special Inspector General for the Troubled Asset Relief Program ("SIGTARP") had taken an expansive view of its jurisdiction in investigating offenses affecting financial institutions.  As that piece noted, SIGTARP's opinion – and practice – has been that an institution's mere receipt of TARP funds sufficed to provide the agency with jurisdiction to conduct an investigation and recommend charges (despite its vast resources, SIGTARP cannot file charges on its own – it must convince a federal prosecutor to do so).  Using this  approach, the agency was able to move forward on a substantial number of charges where TARP funds were not misused, threatened, or even involved.