November 6, 2008
Authored by: Ken Achenbach
We are beginning to receive some indication of how the Federal Reserve will be reviewing TARP Capital Applications for public member banks. As institutions begin to file applications in greater numbers, we believe the review process is starting to gel from a methodological standpoint (although the regulators still say they receive new guidance daily). We have not yet had any indication as to how consistent this review methodology may be between regulatory agencies.
We understand that the review will generally consist of a 3-part process:
- First, the regional director of applications risk will serve as an initial point-of-contact person who will review the application and any follow-up materials that may be requested. The plan is for this initial review period to take approximately 3 days, although this time period could be extended, depending on the circumstances of a particular application and the volume of applications being processed.
- Second, the application will be passed along to a 5-member panel. This panel will review the application and make the decision as to whether an “invest” recommendation should be made to Treasury.
- Finally, Treasury will make its ultimate investment decision, based in large part on the recommendation of the regulators.
The review process, from the filing of an application to an ultimate decision by Treasury to fund, may be completed in as little as 5-7 days, although this process could be drawn out considerably, based on the circumstances.