Update On The TARP Capital Purchase Program: Action Due By November 14, 2008

The Treasury Department's TARP Capital Purchase Program ("CPP") provides for the Treasury's purchase of up to $250 billion of senior preferred shares in U.S. depository institutions and their U.S. holding companies. Of this amount, $125 billion was committed initially to nine large institutions. On October 24 and 25, 2008, it became apparent that further purchase commitments were going to be made by the Treasury to 20 to 30 regional bank holding companies. The names and amounts committed to these institutions have not been released, and it appears that each institution will separately announce its participation in the CPP. At the end of that week, additional indications began to surface that insurance companies were seeking consideration. The Financial Services Roundtable also asked the Treasury Department to expand the CPP to include securities broker-dealers, insurance companies, automakers, and foreign-controlled firms.