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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.

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“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.




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         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)




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    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




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        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.




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