U.S. Department of the Treasury, Emergency Capital Investment Program: "ECIP Real Time Reporting Guidance"
Summary
Treasury guidance dated September 25, 2025, telling participants in the Emergency Capital Investment Program how to submit and label common reports through the Real-Time Reporting portal. Its chart covers internal-control assessments, amendments to organizational documents, an annual certification by December 31 of compliance with excessive compensation, severance pay and luxury expenditures limits, and a written description within 3 business days after the discovery of any inaccuracy in a supplemental report. The guidance states that it does not cover the Quarterly Supplemental Report and does not constitute an interpretation of the requirements. Effective September 2025, the requirement to submit consolidated fiscal year financials and several other reports has been waived until further notice.
Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used
Cite this document
“U.S. Department of the Treasury, Emergency Capital Investment Program: ‘ECIP Real Time Reporting Guidance.’”
Original at home.treasury.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/u-s-department-of-the-treasury-emergency-capital-investment-program-ec-a3b2393804/
, SHA-256 81972be4ae4dd34337cdd0f91b761cf3d510d6319964d9d6c0da61933bd9b259.Full text
September 25, 2025
EMERGENCY CAPITAL INVESTMENT PROGRAM
U.S. Department of the Treasury
Guidance on Submission of Common Reports
Institutions participating (Participants) in the Emergency Capital Investment Program (ECIP) are
required to submit certain information, documents, or reports to the U.S. Department of the
Treasury (Treasury) in accordance with the ECIP Interim Final Rule (IFR), the Participant’s
Securities Purchase Agreement (SPA) with Treasury, and the Certificate of Designations of ECIP
Preferred Shares (CoD) or Subordinated Note, as applicable.
Please refer to the chart below regarding how to label various documents for submission to
Treasury. Please note that that the items listed cover the most commonly required reporting,
do not cover submission of the Quarterly Supplemental Report, and do not address all reporting
requirements.
This guidance, including the description of the requirement in the table below, is provided for
the convenience of Participants but does not constitute an interpretation of the applicable
requirement. Terms that are not defined in this document are defined in the Interim Final Rule,
Securities Purchase Agreement, Certificate of Designations, or Subordinated Note, as
applicable.
Treasury encourages Participants to contact the ECIP at ecip@treasury.gov with any questions.
1
September 25, 2025
Reporting Items
Item # Description of Requirement Frequency and Deadline Submission Method Reference
1 Deliver a copy of any assessment As soon as available after Real-Time Reporting portal (item #1) SPA – 4.1(c)(ii)(C)
of the internal controls of the the Participant receives any and label the document using the
Participant (except those assessment following title: ‘IC Assessment –
specified in the SPA) (relevant year)’ Example Title: IC
Assessment – 2023 SPA – 4.1(c)(ii)(C)
5
2 Deliver any amendments to the As soon as such Real-Time Reporting portal (item #2) SPA – 4.1(c)(ii)(D)
Charter, bylaws, or other amendments become and label the document(s) using the
organizational documents of the effective following title: ‘Org Documents
Participant (relevant document above) –
(relevant year)’ Example Title: Org
Documents (Bylaws) – 2023
3 Certify that the Participant is in Annually, by December 31 of Real-Time Reporting portal (item #3) SPA – 4.1(d)(iii); 31 CFR § 35.24
compliance with all the each calendar year
excessive compensation,
severance pay, and excessive or
luxury expenditures
requirements and limitations on
capital distributions in the ECIP
IFR
4 After making any material Within 90 days of adopting Real-Time Reporting portal (item #4) 31 CFR § 35.22(c)(2)
amendments to the luxury any material amendments to and label the document using the
expenditures policy, the a Participant’s luxury following title: ‘Lux Policy Update –
Participant must provide it to expenditures policy (relevant year)’ Example Title: Lux
Treasury and the appropriate Policy Update – 2023
Federal banking agency and post
it on the website of the
Participant (if applicable)
2
September 25, 2025
5 Certify that the processes and Annually, within 120 days of Real-Time Reporting portal (item #5) SPA – 4.1(d)(ii)
controls the Participant used to the end of the fiscal year of
generate the submitted the Participant
Supplemental Report(s) are
satisfactory
6 Notify the Investor about the Immediately upon the Real-Time Reporting portal (item #6) SPA – 4.1(d)
occurrence of any breach of any occurrence of a breach and label any associated document(s)
of the covenants set forth in using the following title: ‘6.1 Breach –
Section 4.1(d) (relevant year), (relevant quarter)’
Example Title: 5.1 Breach – 2023, Q4
7 Provide the Investor with a Variable, within 3 business Real-Time Reporting portal (item #7) Credit Union SPA – 4.1(h)(ii) Mutual / S
written description of any days after the discovery of and label any associated document(s) Corp SPA – 4.1(h)(iii) C Corp SPA –
inaccuracy found in any Initial any inaccuracy using the following title: ‘ISR/QSR 4.1(g)(iii)
Supplemental Report or Inaccuracy – (relevant year), (relevant
Quarterly Supplemental Report quarter)’ Example Title: ISR/QSR
Inaccuracy – 2023, Q4
8 Submit any other documents, As required Real-Time Reporting portal (item #8) Other
requests or certifications as and label any associated document(s)
required under the IFR, SPA, using the following title: ‘Other –
Certificate of Designations, or (relevant year), (relevant quarter)’
Subordinated Note Example Title: Other – 2023, Q4
9 Provide the notification and As required Real-Time Reporting portal (item #9) Other
details of announced, ending or and label any associated document(s)
completed Merger & Acquisition using the following title: ‘M&A
announced ending or completed Activity – (relevant year), (relevant
Merger & Acquisition. quarter)’ Example Title: M&A Activity
– 2023, Q4
3
September 25, 2025
Effective September 2025, the requirement to submit the following reports has been waived until further notice:
Reporting Items
Item # Description of Requirement Frequency and Deadline Submission Method Reference
1 Deliver consolidated fiscal year Waived Until Further Notice N/A SPA – 4.1(c)(ii)(A)
financials (balance sheet, income
statement, retained earnings,
cash flow)
2 Deliver a copy of any quarterly Waived Until Further Notice N/A SPA – 4.1(c)(ii)(B)
reports provided to other
stockholders, equity holders, or
interest holders of the Participant
3 Deliver copies of any information Waived Until Further Notice N/A SPA – 4.1(c)(ii)(E)
or documents sent by the
Participant to its stockholders,
members or equity holders
4 Pursuant to 4.1(d)(ii)(2) of each Waived Until Further Notice N/A SPA - 4.1(d)(ii)
ECIP participant’s Securities
Purchase Agreement, an ECIP
participant that is required to
include an attestation as to its
internal control over financial
reporting in connection with the
filing of audited financial
statements with any
Governmental Entity or self-
regulatory agency must also
submit an auditor attestation to
ECIP regarding the participant’s
processes and controls used to
generate ISRs and QSRs.
4
File and source
- File
- TREAS-ECIP-Real-Time-Reporting-Guidance-10.6.25.pdf
- Size
- 187,038 bytes
- SHA-256
- 81972be4ae4dd34337cdd0f91b761cf3d510d6319964d9d6c0da61933bd9b259
- Original
- home.treasury.gov