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ARTICLE · 07 APRIL 2009

FDIC Requests Public Comment On Legacy Loans Program

Fried Frank Harris Shriver & Jacobson
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The Federal Deposit Insurance Corporation (FDIC") has requested public comments on all aspects of its proposal, announced on March 23, 2009, to remove troubled "legacy loans" and other assets from banks' and thrifts' balance sheets by creating Public-Private Investment Funds ("PPIFs") to purchase them.

United StatesStrategy
Thomas Vartanian
Thomas Vartanian
David Ansell
David Ansell
Robert Ledig
Robert Ledig
Gordon Miller
Gordon Miller

The Federal Deposit Insurance Corporation ("FDIC") has requested public comments on all aspects of its proposal, announced on March 23, 2009, to remove troubled "legacy loans" and other assets from banks' and thrifts' balance sheets by creating Public-Private Investment Funds ("PPIFs") to purchase them. See Enlisting Private Equity to Rescue "Legacy Assets": Treasury Announces Public-Private Investment Funds Structures, 21st Century Money, Banking & Commerce Alert® (Mar. 25, 2009). The FDIC has announced its intention to launch this program as quickly as possible. The deadline for providing public comments is Friday, April 10, 2009.

The FDIC request includes 17 multiple-part questions. The request for comments and the preliminary program descriptions that have been released indicate the great breadth and depth of the open issues that must be resolved before the first PPIF is organized and the first legacy loans are purchased.

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