How To Repay TARP

Goldman is agitating to pay back its TARP funds once again but say they don’t know when they will be allowed to do so.

Well the rules are out and here is the relevant section from Fox News:

Under the original terms of the CPP, banks were prohibited from repaying within the first three years unless they completed a qualified equity offering. However, the provisions introduced by the American Recovery and Reinvestment Act of 2009 indicate that once an institution notifies Treasury that it would like to repay its CPP investment, the Treasury must permit a TARP recipient to repay subject to consultation with the appropriate Federal Banking Agency.

All institutions seeking to repay CPP will be subject to the existing supervisory procedures for approving redemption requests for capital instruments. Supervisors will carefully weigh an institution’s desire to redeem outstanding CPP preferred stock against the contribution of Treasury capital to the institution’s overall soundness, capital adequacy, and ability to lend, including confirming that the institution has a comprehensive internal capital assessment process. The 19 BHCs that were subject to the SCAP process must have a post-repayment capital base at least consistent with the SCAP buffer, and must be able to demonstrate its financial strength by issuing senior unsecured debt for a term greater than five years not backed by FDIC guarantees, in amounts sufficient to demonstrate a capacity to meet funding needs independent of government guarantees.

Lots of government speak in there but I’m willing to bet that Goldman and JPMorgan Chase can comply. In fact, they’ve probably already got whatever they need to do to comply in the works right now and when they get it done the two of them are going to enjoy a significant advantage over their competition for some time to come.

Just a reminder that government intervention always skews the markets in some manner.

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