Early Repurchase Option--resubmission

Community Development Capital Initiative
Early Repurchase Option
FAQs
1. Who is eligible to participate?
Only institutions currently in the Community Development Capital Initiative (CDCI) are
eligible. Institutions with other TARP or Treasury investments are ineligible to
participate. The remaining eligibility criteria are listed in the eligibility section of the
notification letter found here: https://www.treasury.gov/initiatives/financialstability/TARP-Programs/bank-investment-programs/cdci/Pages/default.aspx.
2. How do I submit a proposal?
First review the notification letter ensuring your institution is eligible, then fill out the
proposal form and submit with the required supporting documents to cdci@treasury.gov.
Proposals and supporting materials must be submitted by 5:00PM ET, Friday, November
18, 2016.
3. Where can I find the notification letter and the proposal form?
Both documents can be found on Treasury’s website here:
https://www.treasury.gov/initiatives/financial-stability/TARP-Programs/bank-investmentprograms/cdci/Pages/default.aspx.
4. Does the institution with CDCI securities outstanding have to submit the proposal?
Yes, the proposal must come from the institution with the CDCI securities outstanding.
5. Does my proposal have to be for all of my outstanding CDCI securities?
No, but you must repurchase at least 50 percent of your outstanding CDCI securities as
part of the early repurchase process.
6. How will my proposal be evaluated?
Treasury will first determine if the institution meets the eligibility criteria as set forth in
the notification letter. If so, Treasury, in its sole discretion, will then determine if the
institution’s early repurchase offer meets or exceeds Treasury’s determination of fair
value. Treasury is under no obligation to accept any offer and will only accept proposals
from institutions that are deemed eligible and whose early repurchase offer meets or
exceeds its determination of fair value.

7. How Will Treasury determine fair value?
Treasury will use internally generated values and a third-party valuation to determine fair
value for each security. These values will be determined based on a “hold value” and will
not take into account liquidity discounts or adjustments based on factors other than those
driving the intrinsic fair value of the security.
8. What supporting documents should I submit with the completed proposal form?
The list of required supporting documents can be found in the procedures and timing
section of the notification letter found here:
https://www.treasury.gov/initiatives/financial-stability/TARP-Programs/bank-investmentprograms/cdci/Pages/default.aspx.
9. How long will Treasury take to respond to my proposal?
Treasury will seek to respond to each proposal within 15 business days.
10. Do I need approval from my banking regulator before submitting a proposal or for
the proposal to be accepted?
Treasury does not require that an institution consult its primary federal regulator prior to
submission of a proposal. If the proposal is accepted, however, as part of the closing
process Treasury will request that your primary federal regulator directly contact
Treasury to consent to your repurchase. Treasury cannot accept correspondence between
your institution and its appropriate federal banking agency in lieu of the formal
notification described above. Treasury recommends that you alert your regulator as soon
as you decide to submit a proposal.
11. My institution doesn’t have audited financials, what should I submit as my
supporting documentation?
If audited financials are unavailable, the institution must submit a letter explaining why
this is the case and submit the latest unaudited annual financials (balance sheet, income
statement, regulatory capital, etc.) for both the bank and bank holding company (if
applicable), or credit union. The letter should also contain a signed statement from the
Chief Executive Officer, the Chief Financial Officer, and the directors of the bank and
bank holding company (if applicable), or credit union, certifying the accuracy of the
submitted financials.
12. What type of dividend history should be included?
Include the dates and amounts of any dividends paid on any securities junior or pari passu
to the CDCI securities in your institutions capital structure. This should include all
payments made from the last dividend payments made prior to the CDCI investments up
to and including those made prior to the submission of your latest proposal.

13. I don’t know if my institution is in compliance with the executive compensation
rules. How do I find out?
Email Treasury at CDCICompliance@treasury.gov to inquire about the status of your
executive compensation compliance.
14. If my proposal is declined by Treasury, may I submit a revised proposal?
Yes, an institution may revise and resubmit its proposal within 60 calendar days of its
first submission, as long as that time is prior to 5:00PM ET, Friday, November 18, 2016.
15. If I submit a revised proposal, what should I include? Do I need to attach new
supporting documentation?
Please resubmit only the proposal form, unless you are updating supporting
documentation to reflect more recent information (i.e., new quarterly financials, new
dividend payment information, etc.) that wasn’t included with the previous proposal.
16. When is the deadline to submit a proposal?
The submission deadline is the earlier of a) 5:00PM ET, Friday, November 18, 2016, or
b) 5:00PM ET, 60 calendar days after submission of the first proposal.
17. Does my institution have to close the transaction?
Yes, the CDCI participant that submitted the proposal must be the counterparty in the
repurchase transaction.
18. If the proposal is accepted, how long do I have to complete the repurchase?
Treasury expects that repurchases will be completed within a commercially reasonable
period, and anticipates that all repurchases of CDCI securities under this early repurchase
option will be completed by Friday, December 30, 2016.
19. Do I have to pay all my dividends or interest at closing?
Yes, the early repurchase price only applies to the par value of the securities and not the
outstanding dividends or interest, which are due at closing.
20. I have other questions, who should I contact?
All questions may be directed to cdci@treasury.gov.