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U.S. Department of the Treasury, Emergency Capital Investment Program: "Fall 2025 ECIP Program Update"

Summary

An Emergency Capital Investment Program slide deck, "Program Update – Compliance, Payments, and Disposition", updated September 2025, covering reporting, payments, the Summary Table, the rate reduction calculation and disposition. It states that some participants have been submitting Quarterly Supplemental Reports late and may have the rate on their ECIP instruments set to 2% at the next rate reset date, and that about 1 in 3 participants submitted 2024 Schedule C & D reports that had issues. Payments are made by Fed wire to the Bank of New York Mellon, which acts as Treasury's agent. On disposition, Treasury is not currently entering into additional disposition agreements, and dispositions are anticipated to start in late summer 2026.

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“U.S. Department of the Treasury, Emergency Capital Investment Program: ‘Fall 2025 ECIP Program Update.’” Original at home.treasury.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/u-s-department-of-the-treasury-emergency-capital-investment-program-fa-034f4d21d6/, SHA-256 60918a609dcfc5e468378f9018130ce7e67ea23f78296d6744da0fa64df65d81.

Full text

Emergency Capital Investment Program
Program Update – Compliance, Payments, and Disposition


                                               Updated September 2025

                                                           TLP Amber
Emergency Capital Investment Program
                            Topics


    Reporting Update and Reminders
    Payments Process
    Qualified Lending Summary Table
    Rate Reduction Calculation Refresher
    Disposition Policy Implementation Update


                                                2
Emergency Capital Investment Program
                                                   Reporting Obligations - QSR
QUARTERLY SUPPLEMENTAL REPORTS
• Some participants have been submitting reports late.
• We recommend setting up a reminder so that this important deadline is met.
• Please note that participants that submit reports late may have the rate on their ECIP instruments set
  to 2% at the next rate reset date
• Due Dates
         Quarter                                 Due Date

         Q1 – January – March                    April 30

         Q2 – April - June                       July 31

         Q3 – July - September                   October 31

         Q4 – October – December                 January 31

         Annual (Previous calendar year)         April 30




                                                                                                           3
Emergency Capital Investment Program
                                                   Reporting Obligations - QSR
• About 1 in 3 participants submitted 2024 Schedule C & D reports that had issues. Errors included
  annual schedules that did not logically match one or more data points from combined 2024 Schedule A
  & B data or other errors.
    • Examples
        • Altering the template or not using the latest template – leading to upload issues in Salesforce
        • Grouping loans to Low-Income Borrowers and Low- and Moderate-Income Borrowers
           incorrectly. Either the number of borrowers or the amounts may be different.
        • Schedule D information excludes transactions that were reported in Schedule B.
• Errors cause the need to restate previously submitted reports – taking additional resources to correct
  for both you and ECIP staff.
     • ECIP can only identify mismatches. We cannot determine which report(s) are correct or incorrect.
• Recommendation: Use the Rubric-Error Precheck in the template to learn the logic errors that ECIP
  checks.
    • We’ve released the updated Rubric-Error Precheck tab in the QSR template for use in Q3 2025
      and for all resubmissions of previous QSR quarters.

    Demo – Rubric-Error Precheck

                                                                                                            4
Emergency Capital Investment Program
                                                    Reporting Obligations - QSR
• Some Participants need to improve procedures narratives submitted with the QSR data.
• Why does ECIP ask for the narrative?
   • Can help ECIP to identify mistakes or misunderstandings.
   • Promotes the ability of Participants to reproduce results, if necessary. E.g., Errors discovered
     through subsequent reporting.

• Recommendation: Attach a narrative that references data sources, fields, and procedures that would
  allow a different individual to generate the same results, following the procedures OR a narrative that
  at least references internal procedures.


• Participants are responsible for any overpayment or underpayments that result from incorrect
  dividend/interest rate errors based on incorrect QSR reports. Good process and documentation is
  more likely to result in accurate data.




                                                                                                            6
Emergency Capital Investment Program
                                                          Reporting Obligations - QSR
• Example of a poor narrative:
    • The bank procedures remain the same as before. Procedures for income collection have been implemented,
      and the data is now included. Other demographic data is now collected on all our loans.


• Example of an excellent narrative:
    • To calculate the number and dollar value of loans disaggregated by the demographic categories and lending
      activity, the datasets for Schedule A and B are used. SQL queries and the output data is saved in the Excel file
      named “xyz”. The calculations and results obtained from these queries follow the ECIP guidelines specified in
      the Instructions for the Quarterly Supplemental Report for Credit Unions, and are explained below:

     …. To be able to extract the raw data, all the tables described at the beginning are linked, and follow the ECIP
     methodology described in the QSR instructions…

     …The queries for Schedule C and D are saved as abc_sql, and def_sql and are stored in the folder “ECIP
     Reporting”…

     …For mortgage lending, the bank uses the same process used for HMDA compliance…



                                                                                                                         7
Emergency Capital Investment Program
                                                         Late or Inaccurate QSRs
• Late or Missing Reports: Under the terms of the ECIP Certificate of Designations or
  Subordinated Security, as applicable, Participants that fail to timely submit a
  complete and accurate QSR may have their rate set to 2% for the next Annual Reset
  Period.
• Inaccurate QSR Reports: Participants will generally have 10 business days to
  resubmit a QSR after an error has been identified.
   • The ECIP Securities Purchase Agreement requires Participants to notify Treasury of any
     inaccuracies in a QSR within 3 business days of the discovery of the inaccuracy.
   • To the extent the error results in a change in the payment rate, the payment rate will be
     adjusted for the remainder of the Annual Reset Period.
   • If the error resulted in the Participant paying less than they should have, Treasury will
     seek to recoup the difference, consistent with the ECIP Securities Purchase Agreement.
   • Treasury will not refund the difference for payments that have already been made if the
     error resulted in the Participant paying more than it should have, consistent with the ECIP
     Securities Purchase Agreement.


                                                                                                   8
Emergency Capital Investment Program
                                                                  ISR Revisions
• Inaccurate ISRs:
    • Participants will generally have 10 business days to resubmit a revised ISR after the ECIP team
      agrees with the proposed correction.
        • If the error resulted in the Participant paying less than it should have, Treasury will seek to
           recoup the difference, and the corrected ISR will be used for all future rate resets.
    • For errors in ISRs that result in the original baseline being higher than it should have been,
      Participants are required to notify Treasury of the error prior to their first payment date in order for
      Treasury to use the revised baseline for the first rate reset calculation and all future rate reset
      calculations.
        • Participants that notify Treasury of such an error after their first payment date will not be
           permitted to restate their baseline for purposes of the rate reduction calculation.
        • Participants will only be permitted to restate their baseline if they can credibly demonstrate that
           the error was the result of a misunderstanding of the ISR instructions or a failure to correctly
           follow the instructions.
• Revisions to ISRs due to M&A activity:
    • Continue to reference the QSR Instructions, Section I.F for ISR & QSR due dates.
    • Errors identified in ISRs submitted in connection with M&A activity will be handled on an as-needed
      basis.


                                                                                                                 9
Emergency Capital Investment Program
                         Other required reporting – “Real-time Reporting”
• Under the ECIP agreements, additional reports are also required to be submitted. We refer to these as
  “real-time reports.” Most submissions are based on events or conditions.
• As of October 2025, many reporting items have been waived until further notice. Certain reports are still
  required for all ECIP participants are listed in the Guidance on Submission for Common Reports
  document found on the ECIP website.

                                      Reporting Requirements Waived until Further Notice


 Item #1 – Financials                                       Consolidated fiscal year financials

 Item #2 – Quarterly Reports                                Quarterly reports provided to other stockholders, equity holders, or interest holders
                                                            of the Participant
 Item #3 – Stockholder, Member, Equity Holder Information   Information or documents sent by the Participant to its stockholders, members or
                                                            equity holders

 Item #9 - Form of Process & Controls Attestation of the    Certain ECIP participants are required to submit an attestation from their
 Independent Auditor                                        independent auditor that the processes and controls used to generate the Initial
                                                            and Quarterly Supplemental Reports (the Supplemental Reports) are satisfactory




                                                                                                                                                    10
Emergency Capital Investment Program
                            Topics


    Reporting Update and Reminders
    Payments Process
    Qualified Lending Summary Table
    Rate Reduction Calculation Refresher
    Disposition Policy Implementation Update


                                                11
Emergency Capital Investment Program
                                                        Payment Notices and Tips
• Payments should be made to the Bank of New York Mellon (BNY), which acts as Treasury’s
  agent.
• Approximately a month in advance, BNY will send courtesy payment notices to all Participants
  that have a payment due.
• To ensure you receive notices, be sure to whitelist: UST.Cares.Program@bnymellon.com
• Treasury previously requested that each organization with payments due provide at least one
  payment POC. The CEO, CFO, and the POC(s) will receive payment notices from BNYM,
  using the last information provided to Treasury.
    • Treasury and BNY are not responsible for outdated information and blocked emails.
    • Timely payment is required even if notice is not received on time or at all.
• Payments must be made by Fed wire, as instructed in the payment notice.
• Pay the exact amount listed in the payment notice.




                                                                                                 12
Emergency Capital Investment Program
                            12/15/2025 Payment
                      • 10/31 – Q3 2025 QSR due


                      • 11/16 – Participant receives Payment Notice and
                        wire instructions from BNY


                      • 12/10 – Last day to notify Treasury of decision to
                        not pay a declared dividend or interest payment or
                        the determination not to declare a dividend


                      • 12/12 – Last day to notify Treasury of ISR
                        error/revision (resulting in lower baseline)


                      • 12/15 4:30pm EST – payments due (BNY will send
                        reminder around 2pm EST)


                                                                             13
Emergency Capital Investment Program
         Example of Preferred Shares Payment Email from Bank of New York Mellon

            In accordance with Sections 3(a)(2) and 3(b) of the Standard Provisions included in the
            Certificate of Designations setting forth the voting and other powers, preferences and relative,
            participating, optional or other rights, and the qualifications, limitations and restrictions thereof
            of $(aggregate liquidation preference) of the Senior Non-Cumulative Perpetual Preferred Stock
            purchased by the U.S. Department of the Treasury pursuant to the Emergency Capital Investment
            Program established by the Consolidated Appropriations Act, 2021, on (payment date) (the
            Dividend Payment Date), the following cash dividend amount for the dividend period from
            (second anniversary date), 2024 to but not including June 15, 2024, based on the Applicable
            Dividend Rate of (dividend rate), is payable no later than 4:30 Eastern Time on (dividend
            payment date).


            CASH DIVIDEND:
            $XXX

            Cash payments must be made via Fed wire to:

            The Bank of New York Mellon
            ABA: 021000018
            Account Number: xxx
            Account Name: xxx
            CUSIP: xxx
                                                                                                                    14
Emergency Capital Investment Program
                     Example of Interest Payment Email from Bank of New York Mellon

          In accordance with Section 6.4(a) of the Securities Purchase Agreement and Sections 2(a)(i)(B)
          and 2(b) of the $(aggregate principal amount) of Subordinated Security purchased by the U.S.
          Department of the Treasury pursuant to the Emergency Capital Investment Program established
          by the Consolidated Appropriations Act, 2021, on (payment date) (the Interest Payment Date),
          the following cash interest amount for the interest period from (second anniversary date), 2024
          to but not including June 15, 2024, based on the Applicable Interest Rate of (interest rate), is
          payable no later than 4:30 Eastern Time on (interest payment date).
          Please note, in accordance with Section 6.4(b) of the Securities Purchase Agreement, failure to
          make payment in full by the Interest Payment Date will result in overdue interest, which will
          accrue interest at the Applicable Interest Rate until paid in full.
          CASH INTEREST:
          $XXX

          Cash payments must be made via Fed wire to:
          The Bank of New York Mellon
          ABA: 021000018
          Account Number: XXX
          Account Name: XXXX
          CUSIP: XXX


                                                                                                             15
Emergency Capital Investment Program
                                                            Payment Notices and Tips
• ECIP continues to experience a small number of issues each quarter where participants pay
  late or incorrect amounts.
     • May result in additional interest accrual.
     • Late payments increase administrative costs to the program.

• ECIP and BNY will continue to send courtesy notices each quarter approximately 30 days prior
  to the payment date.
• ECIP calculates the payment amount based on the amount of investment and the applicable
  rate reduction – 2%, 1.25%, or 0.5%.
    • Participants that closed on or before 6/15/2022 will see any rate adjustments reflected in
       the August notices for the September 15, 2025 payment date. See later slides for
       additional information.
• A new self-service functionality will be available soon. You will be able to update your
  Payments Point of Contact directly in the ECIP portal.


                                                                                                   16
Emergency Capital Investment Program
                                                      Late Payments
• Participants are expected to pay the payment amount in full no later than the payment
  date unless they have advised Treasury that they are eligible to defer the interest on their
  subordinated debt securities or they have not declared dividends on the ECIP preferred
  stock.
    • For subordinated debt, please see Section 6.14 of the ECIP Securities Purchase
      Agreement for the conditions under which interest may be deferred. Deferred interest is
      not capitalized.
    • Participants are required to notify Treasury at least three business days before the
      payment date of a decision to not make an interest payment or pay a declared dividend
      in full, or a determination not to declare a dividend.
• For the subordinated debt, interest will accrue on any unpaid interest payments starting on
  the original interest payment due date, unless the interest has been deferred in accordance
  with the ECIP Securities Purchase Agreement.
• Preferred stock dividends are non-cumulative, and thus, if they are not declared, they will not
  become due in the future.
                                                                                                    17
Emergency Capital Investment Program
                            Topics


    Reporting Update and Reminders
    Payments Process
    Qualified Lending Summary Table
    Rate Reduction Calculation Refresher
    Disposition Policy Implementation Update


                                                18
Emergency Capital Investment Program
                                                           Summary Table
• Participants can track reported Qualified and Deep Impact Lending each quarter, immediately
  after submission of the QSR.
• The Summary Table is “live” in the ECIP Portal (salesforce reporting platform). Data is subject
  to change based on the latest QSR submission data.
• The Summary Table does not display the payment rate, but Participants can use the data
  presented in the table to calculate their payment rate.
• Demo – Accessing the Summary Table
• Please refer to Section III.B of the QSR instructions for details on the items in the Summary
  Table.
• The lending that is used to calculate the payment rate for each year is lending during the 12
  months ending on the last day of the calendar quarter immediately preceding the anniversary
  of the Participant’s ECIP closing date.
• Once a Participant submits its final of the 4 QSRs, all four QSRs used in the payment
  calculation are shown in the Summary Table.
• Tip: The quarterly payments are calculated on a 30/360 basis. Participants can use the
  Summary Table to determine their payment rate and calculate the quarterly payment due.
  There is no requirement to wait to receive the payment notice from BNY.
                                                                                                    19
Emergency Capital Investment Program
                         Summary Table




                                         21
Emergency Capital Investment Program
                         Summary Table




                                         (a)
                                         (b)




                                         (c) = QLO + 2*DILO


                                         (d) = (c) – (a)


                                         (e) = (d) / (b)

                                                              22
Emergency Capital Investment Program
                                                          Summary Table
How to determine Annual Interest Rate or Dividend Rate from the Summary Table?




•   The estimated interest rate or dividend rate can be determined by the
    summary table.
•   In the example above, the increase in Qualified Lending Compared to
    Baseline is 200%, therefore the estimated annual interest rate is 2%.
•   The final rate is provided by BNY in the Payment Notification Letter with
    Wire Instructions.
•   The Summary Table is live and is subject to change when QSRs are
    submitted or resubmitted for the period.



                                                                                 23
       Emergency Capital Investment Program
                                                                                                                             Estimated Annual Rate
       Refer to Term Sheet to determine estimated Annual Rate

                            Increase in Qualified Lending Compared to Business
                                                                                                                         Rate (Interest Rate or Dividend Rate)
                                [Insert Rate from Summary Table (e.g.,200%)]

                          Increase of less than 200% of capital investment                                                               2.0%


                          Increase between 200% and 400% of capital
                                                                                                                                        1.25%
                          investment


                          Increase greater than 400% of capital investment                                                               0.5%


       •       Table consolidated for illustrative purposes but rates still applicable for both
               financial instruments ( senior preferred stock and subordinated debt)
       •       After the tenth anniversary of issuance of investment, the dividend rate will
               be fixed based on the average annual amount of lending in years 2 through
               10 compared to the Baseline

https://home.treasury.gov/system/files/136/Senior_Preferred_Stock_Term_Sheet.pdf
https://home.treasury.gov/system/files/136/Subordinated_Debt_Term_Sheet_for_Credit_Unions.pdf
https://home.treasury.gov/system/files/136/Subordinated_Debt_Term_Sheet_for_Mutual_Institutions_and_S_Corporations.pdf                                           24
Emergency Capital Investment Program
                            Topics


    Reporting Update and Reminders
    Payments Process
    Qualified Lending Summary Table
    Rate Reduction Calculation Refresher
    Disposition Policy Implementation Update


                                                25
Emergency Capital Investment Program
Payment Dates
                                                            Payment Due Dates
• Payments are due on fixed dates – March 15, June 15, September 15, December 15.
First Two Years
• No interest or dividends accrued for the first two years (24 months after the Closing Date) and no
  payments were due.
Years Three to Ten
• Starting in year three after the Closing Date, Participants are required to make dividend or interest
  payments to Treasury on a quarterly basis.
• First payment is due on the first Payment Date after the second anniversary of the Closing Date.
  Examples:
     • Closing Date of 5/24/2022. First payment due on 6/17/2024, which is a stub payment for period
       from 5/24/2024 to 6/14/2024.
     • Closing Date of 6/21/2022. First payment due on 9/15/2024, which is a stub payment for period
       from 6/21/2024 to 9/14/2024.




                                                                                                          26
Emergency Capital Investment Program
                                                          Payment Rate Calculation
Years Three to Ten
• Rate adjusted annually based on increase in Qualified Lending and Deep Impact Lending in the
  preceding year compared to the Baseline Qualified Lending reported in the Initial Supplemental Report
  (ISR), as a percentage of the ECIP investment in the Participant.
• The QSR measures loan originations, not loan balances. The payment rate is therefore calculated
  based on the increase in loan originations and not increases in the balance sheet.
• The QSR used to calculate the first payment rate is the QSR for the most recently completed calendar
  quarter for which the due date has occurred as of the second anniversary of the Closing Date. For
  Participants that closed between May 1, 2022 and June 30, 2022, this is the QSR dated 3/31/2024.
    • For these Participants, the lending used to calculate the payment rate for year three is from
       4/1/2023 to 3/31/2024.




                                                                                                          27
 Emergency Capital Investment Program
                                                      Rate Reduction Example
Years Three to Ten
• Participant receives a $40 million investment from Treasury on June 28, 2022.
• Baseline Qualified Lending = $100 million.
• In its QSRs for year 2 (QSRs for Q2 2023, Q3 2023, Q4 2023, and Q1 2024), Participant
  reported a total of $150 million in Qualified Lending (not including Deep Impact Lending) and
  an additional $15 million in Deep Impact Lending.
• Annual Qualified Lending in Year 2 = Qualified Lending + 2 * Deep Impact Lending = $150
  million + (2 * $15 million) = $180 million.
• % change in Qualified Lending = ((Annual Qualified Lending in Year 2 – Baseline Qualified
  Lending)/ Investment Amount)*100 = (($180 million – $100 million)/$40 million)*100 = 200%.
• As per the ECIP legal agreements, a 200% increase in Qualified Lending would correspond
  with a payment rate of 1.25%.
• Rate of 1.25% would be for the period from 6/28/2024 to 9/14/2025.
• Next rate reset would be on 9/15/2025 and would be based on QSRs for Q2 2024, Q3 2024,
  Q4 2024 and Q1 2025.                                                                            28
Emergency Capital Investment Program
                                          Rate Reduction – No notification

• ECIP does not plan to send out notices regarding any changes in the rate following the rate
  reset date.
• Payment notices will incorporate any changes to the rate qualification.
• In the event of M&A, ECIP incorporates baseline adjustments. These are not immediately
  reflected in the Summary Table.
    • If engaged in M&A and there are questions about the baseline, contact ECIP.




                                                                                                29
 Emergency Capital Investment Program
                                                      Example 1
Example 1 – Participant closed between 5/1/2022 and 6/14/2022
• Year 3:
    • Year 3 rate calculated based on lending from 4/1/2023 to 3/31/2024, i.e., four quarters
      ending with the Q1’24 QSR.
    • First payment due on 6/15/2024; this is a payment for the stub period from the closing
      date anniversary to 6/14/2024.
    • Year 3 rate is used to calculate payments due 9/15/2024, 12/15/2024, 3/15/2025, and
      6/15/2025.
• Year 4:
    • Next rate reset is on 6/15/2025. Year 4 rate calculated based on lending from 4/1/2024 to
      3/31/2025, i.e., four quarters ending with Q1’25 QSR.
    • Year 4 rate is used to calculate payments due 9/15/2025 (for the period from 6/15/2025 to
      9/14/2025), 12/15/2025, 3/15/2026, and 6/15/2026.


                                                                                                  30
 Emergency Capital Investment Program
                                                      Example 2
Example 2 – Participant closed between 6/16/2022 and 6/30/2022
• Year 3:
    • Year 3 rate calculated based on lending from 4/1/2023 to 3/31/2024, i.e., four quarters
      ending with the Q1’24 QSR.
    • First payment due on 9/15/2024; this is a payment for the stub period from the closing
      date anniversary to 9/14/2024.
    • Year 3 rate is used to calculate payments due 12/15/2024, 3/15/2025, 6/15/2025, and
      9/15/2025.
• Year 4:
    • Next rate reset is on 9/15/2025. Year 4 rate is calculated based on lending from 4/1/2024
      to 3/31/2025, i.e., four quarters ending with the Q1’25 QSR.
    • Year 4 rate is used to calculate payments due 12/15/2025 (for the period from 9/15/2025
      to 12/14/2025), 3/15/2026, 6/15/2026, and 9/15/2026.


                                                                                                  31
 Emergency Capital Investment Program
                                                      Example 3
Example 3 – Participant closed between 10/1/2022 and 12/14/2022
• Year 3:
    • Year 3 rate calculated based on lending from 10/1/2023 to 9/30/2024, i.e., four quarters
      ending with the Q3’24 QSR.
    • First payment due on 12/15/2024; this is a payment for the stub period from the closing
      date anniversary to 12/14/2024.
    • Year 3 rate is used to calculate payments due 3/15/2025, 6/15/2025, 9/15/2025, and
      12/15/2025.
• Year 4:
    • Next rate reset is on 12/15/2025. Year 4 rate is calculated based on lending from
      10/1/2024 to 9/30/2025, i.e., four quarters ending with the Q3’25 QSR.
    • Year 4 rate is used to calculate payments due 3/15/2026 (for the period from 12/15/2025
      to 3/14/2026), 6/15/2026, 9/15/2026, and 12/15/2026.


                                                                                                 32
 Emergency Capital Investment Program
                                                      Example 4
Example 4 – Participant closed between 8/1/2023 and 9/14/2023
• Year 3:
    • Year 3 rate calculated based on lending from 7/1/2024 to 6/30/2025, i.e., four quarters
      ending with the Q2’25 QSR.
    • First payment due on 9/15/2025; this is a payment for the stub period from the closing
      date anniversary to 9/14/2025.
    • Year 3 rate is used to calculate payments due 12/15/2025, 3/15/2026, 6/15/2026, and
      9/15/2026.
• Year 4:
    • Next rate reset is on 9/15/2026. Year 4 rate is calculated based on lending from 7/1/2025
      to 6/30/2026, i.e., four quarters ending with the Q2’26 QSR.
    • Year 4 rate is used to calculate payments due 12/15/2026 (for the period from 9/15/2026
      to 12/14/2026), 3/15/2027, 6/15/2027, and 9/15/2027.


                                                                                                  33
  Emergency Capital Investment Program
                                                              Fixed Rate Reduction
Years 11+
• Rate is fixed based on average annual increase in Qualified Lending and Deep Impact Lending over the
  preceding nine years compared to the Baseline Qualified Lending as a percentage of the ECIP
  investment in the Participant.
• Example: $40 million investment from Treasury.
• Baseline Qualified Lending = $100 million, which was not adjusted in the first ten years due to a merger
  or other business combination.
• Participant reports the following (Qualified Lending does not include Deep Impact Lending):
Reported Years                          Baseline                Qualified Lending          Deep Impact Lending
Year 2                    $   100,000,000             $   150,000,000               $    15,000,000
Year 3                    $   100,000,000             $   200,000,000               $    20,000,000
Year 4                    $   100,000,000             $   240,000,000               $    28,000,000
Year 5                    $   100,000,000             $   320,000,000               $    28,000,000
Year 6                    $   100,000,000             $   360,000,000               $    28,000,000
Year 7                    $   100,000,000             $   320,000,000               $    28,000,000
Year 8                    $   100,000,000             $   320,000,000               $    28,000,000
Year 9                    $   100,000,000             $   320,000,000               $    28,000,000
Year 10                   $   100,000,000             $   320,000,000               $    28,000,000
Subtotal                  $   900,000,000             $ 2,550,000,000               $   231,000,000



                                                                                                                 34
Emergency Capital Investment Program
                                                    Fixed Rate Reduction
Years 11+
• Aggregate Annual Qualified Lending in years 2 through 10 = Aggregate Qualified Lending +
  2*Deep Impact Lending = $2,550 million + (2 * $231 million) = $3,012 million
• Aggregate Baseline = $900 million($100 million * 9)
• Aggregate Increase in Qualified Lending = Aggregate Annual Qualified Lending - Aggregate
  Baseline = $3,012 million - $900 million = $2,112 million
• Average Annual Increase in Qualified Lending = Aggregate Increase in Qualified Lending / 9
  = $2,112 million / 9 = $234.667 million
• % Change in Qualified Lending = (Average Annual Increase in Qualified Lending/ Investment
  Amount)*100 = ($234.667 million/ $40 million)*100 = 587%
• As per the ECIP legal agreements, a 587% increase in Qualified Lending would correspond
  with an annual payment rate of 0.5% for each quarter from the first payment date after the
  tenth anniversary of the Closing Date until the instruments are redeemed or mature.


                                                                                               35
  Emergency Capital Investment Program
                                                                    Alternate Calculation
Years 11+
Reported Years          Baseline      Qualified Lending       Deep Impact Lending   Annual Qualified Lending     Increase over Baseline
Year 2           $   100,000,000   $   150,000,000        $       15,000,000        $   180,000,000            $     80,000,000
Year 3           $   100,000,000   $   200,000,000        $       20,000,000        $   240,000,000            $    140,000,000
Year 4           $   100,000,000   $   240,000,000        $       28,000,000        $   296,000,000            $    196,000,000
Year 5           $   100,000,000   $   320,000,000        $       28,000,000        $   376,000,000            $    276,000,000
Year 6           $   100,000,000   $   360,000,000        $       28,000,000        $   416,000,000            $    316,000,000
Year 7           $   100,000,000   $   320,000,000        $       28,000,000        $   376,000,000            $    276,000,000
Year 8           $   100,000,000   $   320,000,000        $       28,000,000        $   376,000,000            $    276,000,000
Year 9           $   100,000,000   $   320,000,000        $       28,000,000        $   376,000,000            $    276,000,000
Year 10          $   100,000,000   $   320,000,000        $       28,000,000        $   376,000,000            $    276,000,000
Subtotal         $   900,000,000   $ 2,550,000,000        $      231,000,000        $ 3,012,000,000            $ 2,112,000,000


• Aggregate Increase in Qualified Lending = Sum of annual increase in Qualified Lending over
  the Baseline for years 2 through 10 = $2,112 million
• Average Annual Increase in Qualified Lending = Aggregate Increase in Qualified Lending / 9 =
  $2,112 million / 9 = $234.667 million
• % Change in Qualified Lending = (Average Annual Increase in Qualified Lending/ Investment
  Amount)*100 = ($234.667 million/ $40 million)*100 = 587%

                                                                                                                                          36
Emergency Capital Investment Program
                          Topics


    Reporting Update and Reminders
    Payments Process
    Qualified Lending Summary Table
    Rate Reduction Calculation Refresher
    Disposition Policy Implementation Update


                                                37
Emergency Capital Investment Program
                                                       Disposition Implementation
• ECIP has not released any additional guidance or instructions regarding implementation of the
  disposition policy.
• Treasury is not currently entering into additional disposition agreements.
• Participants that become eligible under the disposition agreement should not expect to have
  agreements closed in the order that agreements were executed.
• Dispositions are anticipated to start in late summer 2026. Participants may request a sale or transfer of
  their instruments once eligible but are not required to do so under the agreement – it’s an option.
• Participants are advised to review the requirements for disposition and to begin preparation early.
  E.g., establishing a de novo affiliated non-profit can take time.
• Treasury will not provide legal, accounting, or tax advice but welcomes questions or concerns by
  emailing:




                                                                                                              38
Emergency Capital Investment Program


  If you have any questions, please email:

     • Preferred: df.ecip.help@treasury.gov
        • Salesforce integration

     • ecip@treasury.gov

  ECIP website:

     • Emergency Capital Investment Program | U.S. Department of the
       Treasury

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