Timing of TARP Capital Infusions

November 23, 2008

Authored by: Ken Achenbach

A representative of the Federal Reserve Bank of Atlanta has informed us that the Treasury does not intend to process any applications for private companies until all public company applications have been processed.  As a result, we expect (and the Federal Reserve did not deny) that a December 31 funding date is probably a realistic expectation only for public companies at this point.  We hope that Treasury will begin to realize some efficiencies in the processing of closing documents, but December 31 is approaching rapidly.

To the extent that any privately-held clients may be expecting a potential TARP infusion to keep them “well-capitalized” at December 31, 2008, they may need to also be working on Plan B.