Thursday 26 March 2009

GEITHNER PLAN FOR BAD ASSETS

For the full plan text click on 'comment' at the end of this blog. The popular criticism of this deal assumes that these assets will not recover value in the medium term and that they are so toxic that the defaults on the underlying assets will merely cost the government and FDIC (aka taxpayers) while banks and hedge funds (who will buy the bonds with TARP subsidy and FDIC insurance guarantee) will both make money. Geithner believes that the interest on the loans to the bank asset buyers plus a shared risk/return will in time prove profitable or negligible loss for government? This is part of a masterplan.Prof. James Galbraith, Univ. Texas, author of 'The Predator State' and Prof. Paul Krugman both are highly critical of the Geithner Plan. Krugman's view is that it is a complete mess based on a misunderstanding of how important 'confidence' is and that this is merely a repeat of the response to the S&L crisis. One context for this is the stress-tests dictated by FDIC for the top 19 banks. Krugman finds the stress factors to be too mild (see 3 charts on US economy below). The forecasts may be politically adjudged or simply the usual consensus type that smoothe everything and are unable to foresee short term shocks. Galbraith says that from Obama to Geithner to Bernanke, policymakers are like doctors dealing with a "mildly ill" patient vs. treating one who is "gravely" ill. The economist fears the economy is in terminal condition requiring much more intervention than already prescribed. Certainly, when for the first time in memory world GDP in aggregate is in recession and there are no external pull factors, only internal push, then fiscal stance and other measures have to be that much stronger. Krugman accuses Geithner of believing that if only the problem of toxic collateralized debt assets and their writedown effects can be cured, then the economy will pull through. Another way of putting this would be the idea that Geithner thinks if the CDOs are quarantined the following charts could be replayed backwards? Galbraith believes government "doctors" are engaged in a lot of "happy talk" about recovery based on a "fundamentally flawed model," hinged on the idea the economy is self-healing and only needs a booster shot before it "naturally" returns to trend growth and unemployment in the 5% range (the natural rate of unemployment concept that he rightly despises). He says success for the Geithner Plan is highly unlikely as it is framed so far, with limited direct scope for helping millions of Americans grapple with a crushing level of household debt. To help replace consumer spending, massive additional government action is necessary, he says, as discussed in the accompanying video link (URL at end of this blog) and in a recent Washington Monthly article.
I disagree that the assets are so toxic as the economists broadly suppose. The loan pools are amortising fast in the period when other measures are mitigating foreclosures and will in the medium term naturally improve in quality with much of the edge taken off by credit enhancements and foreclosure mitigation measures. Therefore, the defaults will not rise as high as otherwise. If the assets are representative of RMBS then 25% is sub-prime and default rates are heading for half of that. But the assets are already discounted 12-20% at the highest rated end, and first loss tranches may be witheld and kept on banks' books for work-out, assuming that is the nature of the $3-400bn of ABS and other impaired bank-credit derivatives left on the books on the top six US banks. My numbers are: Therefore the Geithner Plan may work in a contributory fashion, maybe, by helping the banks maintain a higher regulatory and economic capital reserve. My view is that these reserves need to be up around the $1 trillion level to cushion the next waves of credit risk losses that will eat into all of this. Geithner's economic modeling I believe, along with Krugman, is based on factor values of the mid-1990s to the 2001 recession. The world context is however more severe more aligned cyclically thanks to financial and trade globalisation than in previous recessions. The world's trade patterns are wholly disrupted and we have no certainty about the new shape to global trade and payments. In moving from a period of a decade or more when the US deficit was the counterpart to most of the rest of the world's trade supluses, now the rest of the world has to resort to domestic growth policies and had politically and otherwise almost forgotten how to do that! Geithner is buying time until end of September when the next federal budget is formed and the stress-tests are part of this. The banks will have their capital reserves next re-set in September. meantime he may hope that the credit default spreads that price the banks' CDOs will continue at a more realistic level. And then one consequence of that could be an easing of the interbank funding market. In my view, the Fed and US Treasury should simply de facto nationalize the interbank funding market for financing the banks' funding gaps. But there is immense political objection to more £trillions being facilitated. the general public do not understand what is on and off the taxpayers' federal budget balance sheet. The bailout measures are almost all off-budget and there is a balancing of assets and liabilities achieved to do this. It is not therefore taxpayers' money except in the broadest democratic political sense. To be effective the fiscal deficit needs the support of bank lending levels being kept up. The fear is that banks would have to deleverage by 30% or more if their capital reserves get wiped before debt recoveries start to flow back onto the banks' books. A remaining problem for the banks is financing their funding gaps. The US banks have had low issuance last year and this too so far compared to Europe. And that seems a major problem right now as I do not see the $1 trillion of assets to be sold off (beginning with $500bn only) to approved buyers as sufficient to solve that. There is little evidence of what the banks are acheiving in filling the $5 trillion or so refinancing they require for their funding gaps. Covered bonds and MT Note programs by banks are either down or out of sight. There is a fear that deleveraging will hit industry and corporate bond defaults will balloon. But, the publiv mood when the $trillion numbers get aired is very hostile and fearfully so. The government, banks and hedge funds all look like carpetbaggers to an angry mob. Underlying all this is the risk of prolonged recession (already 15 months old). Currently, it looks as if the majority of businesses are just about earning enough profit to make their debt interest payments. New corporate bonds are high coupon (junk bond rates) even for top retailers and manufacturers. Therefore, not a sign of restructuring of corporate debt to take advantage of historically low central bank rates. (For an exhaustive rip through the carpetbagger culture develeoping in the US see bankingeconomics.blogspot.com. 'The Great Game'). I prefer more repo swaps (after 25-30% haircuts) of the assets at the Fed liquidity window along the lines of the Bank of England's SLS and APS. In the US, if the assets all come off the top six banks' books who hold over 80% of banks' impaired securitised structured-credit assets then $1 trillion is a substantial cleaning out that should restore the banks' ability to hold or grow lending in the recession. This is not all totally toxic. In my alternative defaulting mortgagees motivated by negative equity to quit their homes should be banded together to gain direct benefit from the discounting of their mortgage debts and remortgaged to reflect that fall in the value of their mortgages. This is better than hedge funds being subsidised to gain the 17%-25% returns they are seeking from buying these bank assets. Hedge funds are evidencing some distress with number being bandied about that their funds are down from over $2tn to $1.4tn or $1tn only and how 20% of hedge funds are folding. But there are thousands of hedge funds and a mass of them are always folding, especially among the 1-5 man little hedge fund LLCs. And, sure, some big ones are in trouble, but there is no talk of these 'shadow-banks', including big private equity funds, are posing a systemic risk, unless maybe to some 'money market funds' but these are mostly bank-owned and robust. At the same time I also agree with Galbraith's alternative recommendations, which he says will cost $1-$1.2 trillion above plans already enacted, include: - Higher Social Security benefits: This will aid seniors hurt by the downturn in home prices, financial assets and the dollar's purchasing power. - More government hiring: Infrastructure spending can help, but major building projects can take years to gear up (a point also made by Prof Larry Summers, Geithner's colleague and ex-boss), and they can, for the most part, provide jobs only for those who have the requisite skills. Galbraith wrote, "So the federal government should sponsor projects that employ people to do what they do best, including art, letters, drama, dance, music, scientific research, teaching, conservation, and the nonprofit sector, including community organizing - why not?" I totally agree with this for a whole raft of reasons. Galbraith proposes a payroll tax holiday: "This is a particularly potent suggestion, because it is large and immediate," and puts income in the pockets of working families, he says. For me a key to recession-busting as it also is for development aid to poor developing countries, how to productively put money into the pockets of the poor, including poor pensioners especially, who all have the virtue that they spend what they get. Also, from Galbraith, Fix Housing: Put a moratorium on foreclosures and have the government buy homes from those homeowners who have no hope of making their mortgage payments, as detailed in a forthcoming segment. We may assume that the mortgage debts are thereby wiped out. This is implicit in the USA where the only collateral for the mortgage is the value of the home. In other countries any remaining debt remains an obligation on the mortgagee, and in Japan that can be multi-generational! Helping Main Street is already on the US policy agenda in the form of Fannie Mae and Freddy Mac re-negotiating mortgage contracts to restructure the interest and repayment burden to not more than 30% of mortgagee incomes. I would go for a halfway solution too, that of passing the debt discount right back into the original mortgage agreement thereby cutting back much of the negative equity problem. There is a logic, however, to the public housing solution in that the sub-prime crisis had its origins in the cutbacks by governments of spending on social housing to zero for nigh on two decades! Galbraith's view is that any or all of these programs "can be scaled back" as growth resumes, but that the government cannot afford to hold back any ammunition in its fight against the deflationary forces of the credit crisis. This echoes a similar view expressed by Martin Wolfe in the FT that I also very much agree with.
Some big banks that have received financial help are buying the 'toxic' assets. Citigroup and Bank of America, other banks and hedge funds, have been aggressively scooping up the discount-price securities in the secondary market. The banks' purchase of AAA-rated mortgage-backed securities, including some that use alt-A and option ARM as collateral, is raising eyebrows. Alt-A and option ARM loans have widely been seen as the next mortgage type to see increases in defaults. Yet both banks have been aggressive in their buying, sometimes paying higher prices than competing bidders are willing to pay. Recently, securities rated AAA have changed hands for roughly 30 cents on the dollar, and most of the buyers have been hedge funds acting opportunistically on a bet that prices will rise over time. However, sources said Citi and BofA have trumped those bids. Geithner's Plan (PPIP) offers banks an arbitrage opportunity to neutralize the writedowns that the problem may require. A bank that will sell $10bn MBS to the PPIP that are on the books for 70c/1$and will sell for 50c/$1, requires writing down the 20s difference. The government has however tasked the banks to buy such assets and thereby try to bring more liquidity to the secondary market. The buying can also have been on behalf of customers. But it is also much cheaper to buy these assets than to create new assets, for the purpose of keeping up the bank's ;evel of loans to satisfy government requirement of not deleveraging in the recession. If the banks can buy artificially (turbulent market distressed prices) marked-down MBS for 30c/$1 and keep it on the books, as the PPIP makes a market for MBS off the bottom, the 30c cost basis MBS, if bought before the program starts, will now be marked up to the market price of 50c/$1, counterbalancing the bank's write down of the assests when
bought. The banks may also be helping to push up the market prices thereby revaluing all their holdings.
FDIC head, Sheila Bair, said she is open to banks taking equity stakes in those the public-private partnership funds as partial payment that will buy up illiquid loans from banks. The banks would be allowed to pay for their stakes with the very loans they are selling into the partnerships!
Citigroup, say, has CMB and RMB securities that have become toxic because Citi says they are worth 87c/$1 but the market thinks they are worth 30c/$1. Now, Bair, offers loans to buyers to pay much higher amounts for the assets because most of the purchase price will be subsidised by cheap government loans and exit clause contract. The bank then sells the assets to a special vehicle (SIV,SPE,or SPV) set up to pay for the assets. It gets an ownership stake in that vehicle in exchange for the assets. So the bank will trade the assets for ownership in a special purpose vehicle that owns those assets. Why would the bank want equity in a fund that is buying assets it is trying to get off their balance sheet - because the scheme involves a huge subsidy, allowing buyers to make double-digit returns even if half the assets they buy are worth nothing, or nothing until the property collateral is foreclosed on. Essentially, the PPIP deals allow banks to move their risk off-balance sheet, but with much of the risk also taken by government, which in itself builds in a price gain. Geithner et al is convinced that off-balance entities are the key to restoring the banks. The same has been happening in the UK with SLS and APS.

And for Tim Geithner's own views in the WSJ see: http://online.wsj.com/article/SB123776536222709061.html
Also See: http://finance.yahoo.com/tech-ticker/article/yftt_216311/Part-I-Geithner's-Plan-%22 and: http://finance.yahoo.com/tech-ticker/article/216690/%22Happy-Talk%22-Won't-Solve-Crisis-Galbraith-Says-Much-More-Govt.-Action-Needed;_ylt=AtCWuOtcOPiFarNfSB_.sHpk7ot4?Extremely-Dangerous%22-Economist-Galbraith-Says
and also
http://krugman.blogs.nytimes.com/2009/03/21/despair-over-financial-policy/
see also: http://topics.nytimes.com/top/opinion/editorialsandoped/oped/columnists/paulkrugman/index.html
Roubini echoes Krugman. He is the ultimate doomster. His economics consultancy estimates a total of $3.6tn of loan and securities losses in the U.S., including writedowns on $10.84tn securities and losses on $12.37tn unsecuritized loans ( emphasis on the word 'on' since these numbers are total outstanding). Roubini's view is that bank nationalizations are inevitable. I don't think he sees the technical problems of nationalizing without a change in the law first - the FDIC's legalistic view of the problem.
http://www.bloomberg.com/apps/news?pid=20601087&sid=aZXiD0hnsSD8&refer=home

1 comment:

ROBERT MCDOWELL said...

March 23, 2009

Treasury Department Releases Details on Public Private Partnership Investment Program
Fact Sheet
Public-Private Investment Program
View White Paper and FAQs at http://www.treas.gov/cgi-bin/redirect.cgi?http://financialstability.gov/
The Financial Stability Plan – Progress So Far: Over the past six weeks, the Treasury Department has implemented a series of initiatives as part of its Financial Stability Plan that – alongside the American Recovery and Reinvestment Act – lay the foundations for economic recovery:
• Efforts to Improve Affordability for Responsible Homeowners: Treasury has implemented programs to allow families to save on their mortgage payments by refinancing, assist responsible homeowners in avoiding foreclosure through a loan modification plan, and, alongside the Federal Reserve, help bring mortgage interest rates down to near historic lows. This past month, the 30% increase in mortgage refinancing demonstrated that working families are benefiting from the savings due to these lower rates.
• Consumer and Business Lending Initiative to Unlock Frozen Credit Markets: Treasury and the Federal Reserve are expanding the TALF in conjunction with the Federal Reserve to jumpstart the secondary markets that support consumer and business lending. Last week, Treasury announced its plans to purchase up to $15 billion in securities backed by Small Business Administration loans.
• Capital Assistance Program: Treasury has also launched a new capital program, including a forward-looking capital assessment undertaken by bank supervisors to ensure that banks have the capital they need in the event of a worse-than-expected recession. If banks are confident that they will have sufficient capital to weather a severe economic storm, they are more likely to lend now – making it less likely that a more serious downturn will occur.
The Challenge of Legacy Assets: Despite these efforts, the financial system is still working against economic recovery. One major reason is the problem of "legacy assets" – both real estate loans held directly on the books of banks ("legacy loans") and securities backed by loan portfolios ("legacy securities"). These assets create uncertainty around the balance sheets of these financial institutions, compromising their ability to raise capital and their willingness to increase lending.
• Origins of the Problem:The challenge posed by these legacy assets began with an initial shock due to the bursting of the housing bubble in 2007, which generated losses for investors and banks. Losses were compounded by the lax underwriting standards that had been used by some lenders and by the proliferation of complex securitization products, some of whose risks were not fully understood. The resulting need by investors and banks to reduce risk triggered a wide-scale deleveraging in these markets and led to fire sales. As prices declined, many traditional investors exited these markets, causing declines in market liquidity.
• Creation of a Negative Economic Cycle: As a result, a negative cycle has developed where declining asset prices have triggered further deleveraging, which has in turn led to further price declines. The excessive discounts embedded in some legacy asset prices are now straining the capital of U.S. financial institutions, limiting their ability to lend and increasing the cost of credit throughout the financial system. The lack of clarity about the value of these legacy assets has also made it difficult for some financial institutions to raise new private capital on their own.
The Public-Private Investment Program for Legacy Assets
To address the challenge of legacy assets, Treasury – in conjunction with the Federal Deposit Insurance Corporation and the Federal Reserve – is announcing the Public-Private Investment Program as part of its efforts to repair balance sheets throughout our financial system and ensure that credit is available to the households and businesses, large and small, that will help drive us toward recovery.
Three Basic Principles: Using $75 to $100 billion in TARP capital and capital from private investors, the Public-Private Investment Program will generate $500 billion in purchasing power to buy legacy assets – with the potential to expand to $1 trillion over time. The Public-Private Investment Program will be designed around three basic principles:
• Maximizing the Impact of Each Taxpayer Dollar: First, by using government financing in partnership with the FDIC and Federal Reserve and co-investment with private sector investors, substantial purchasing power will be created, making the most of taxpayer resources.
• Shared Risk and Profits With Private Sector Participants: Second, the Public-Private Investment Program ensures that private sector participants invest alongside the taxpayer, with the private sector investors standing to lose their entire investment in a downside scenario and the taxpayer sharing in profitable returns.
• Private Sector Price Discovery: Third, to reduce the likelihood that the government will overpay for these assets, private sector investors competing with one another will establish the price of the loans and securities purchased under the program.
The Merits of This Approach: This approach is superior to the alternatives of either hoping for banks to gradually work these assets off their books or of the government purchasing the assets directly. Simply hoping for banks to work legacy assets off over time risks prolonging a financial crisis, as in the case of the Japanese experience. But if the government acts alone in directly purchasing legacy assets, taxpayers will take on all the risk of such purchases – along with the additional risk that taxpayers will overpay if government employees are setting the price for those assets.
Two Components for Two Types of Assets: The Public-Private Investment Program has two parts, addressing both the legacy loans and legacy securities clogging the balance sheets of financial firms:
• Legacy Loans:The overhang of troubled legacy loans stuck on bank balance sheets has made it difficult for banks to access private markets for new capital and limited their ability to lend.
• Legacy Securities: Secondary markets have become highly illiquid, and are trading at prices below where they would be in normally functioning markets. These securities are held by banks as well as insurance companies, pension funds, mutual funds, and funds held in individual retirement accounts.


The Legacy Loans Program: To cleanse bank balance sheets of troubled legacy loans and reduce the overhang of uncertainty associated with these assets, the Federal Deposit Insurance Corporation and Treasury are launching a program to attract private capital to purchase eligible legacy loans from participating banks through the provision of FDIC debt guarantees and Treasury equity co-investment. Treasury currently anticipates that approximately half of the TARP resources for legacy assets will be devoted to the Legacy Loans Program, but our approach will allow for flexibility to allocate resources where we see the greatest impact.
• Involving Private Investors to Set Prices: A broad array of investors are expected to participate in the Legacy Loans Program. The participation of individual investors, pension plans, insurance companies and other long-term investors is particularly encouraged. The Legacy Loans Program will facilitate the creation of individual Public-Private Investment Funds which will purchase asset pools on a discrete basis. The program will boost private demand for distressed assets that are currently held by banks and facilitate market-priced sales of troubled assets.
• Using FDIC Expertise to Provide Oversight: The FDIC will provide oversight for the formation, funding, and operation of these new funds that will purchase assets from banks.
• Joint Financing from Treasury, Private Capital and FDIC: Treasury and private capital will provide equity financing and the FDIC will provide a guarantee for debt financing issued by the Public-Private Investment Funds to fund asset purchases. The Treasury will manage its investment on behalf of taxpayers to ensure the public interest is protected. The Treasury intends to provide 50 percent of the equity capital for each fund, but private managers will retain control of asset management subject to rigorous oversight from the FDIC.
• The Process for Purchasing Assets Through The Legacy Loans Program: Purchasing assets in the Legacy Loans Program will occur through the following process:
o Banks Identify the Assets They Wish to Sell: To start the process, banks will decide which assets – usually a pool of loans – they would like to sell. The FDIC will conduct an analysis to determine the amount of funding it is willing to guarantee. Leverage will not exceed a 6-to-1 debt-to-equity ratio. Assets eligible for purchase will be determined by the participating banks, their primary regulators, the FDIC and Treasury. Financial institutions of all sizes will be eligible to sell assets.
o Pools Are Auctioned Off to the Highest Bidder: The FDIC will conduct an auction for these pools of loans. The highest bidder will have access to the Public-Private Investment Program to fund 50 percent of the equity requirement of their purchase.
o Financing Is Provided Through FDIC Guarantee: If the seller accepts the purchase price, the buyer would receive financing by issuing debt guaranteed by the FDIC. The FDIC-guaranteed debt would be collateralized by the purchased assets and the FDIC would receive a fee in return for its guarantee.
o Private Sector Partners Manage the Assets:Once the assets have been sold, private fund managers will control and manage the assets until final liquidation, subject to strict FDIC oversight.
Sample Investment Under the Legacy Loans Program
Step 1: If a bank has a pool of residential mortgages with $100 face value that it is seeking to divest, the bank would approach the FDIC.
Step 2: The FDIC would determine, according to the above process, that they would be willing to leverage the pool at a 6-to-1 debt-to-equity ratio.
Step 3: The pool would then be auctioned by the FDIC, with several private sector bidders submitting bids. The highest bid from the private sector – in this example, $84 – would be the winner and would form a Public-Private Investment Fund to purchase the pool of mortgages.
Step 4: Of this $84 purchase price, the FDIC would provide guarantees for $72 of financing, leaving $12 of equity.
Step 5: The Treasury would then provide 50% of the equity funding required on a side-by-side basis with the investor. In this example, Treasury would invest approximately $6, with the private investor contributing $6.
Step 6: The private investor would then manage the servicing of the asset pool and the timing of its disposition on an ongoing basis – using asset managers approved and subject to oversight by the FDIC.
The Legacy Securities Program: The goal of this program is to restart the market for legacy securities, allowing banks and other financial institutions to free up capital and stimulate the extension of new credit. The resulting process of price discovery will also reduce the uncertainty surrounding the financial institutions holding these securities, potentially enabling them to raise new private capital. The Legacy Securities Program consists of two related parts designed to draw private capital into these markets by providing debt financing from the Federal Reserve under the Term Asset-Backed Securities Loan Facility (TALF) and through matching private capital raised for dedicated funds targeting legacy securities.
1. Expanding TALF to Legacy Securities to Bring Private Investors Back into the Market: The Treasury and the Federal Reserve are today announcing their plans to create a lending program that will address the broken markets for securities tied to residential and commercial real estate and consumer credit. The intention is to incorporate this program into the previously announced Term Asset-Backed Securities Facility (TALF).
o Providing Investors Greater Confidence to Purchase Legacy Assets:As with securitizations backed by new originations of consumer and business credit already included in the TALF, we expect that the provision of leverage through this program will give investors greater confidence to purchase these assets, thus increasing market liquidity.
o Funding Purchase of Legacy Securities: Through this new program, non-recourse loans will be made available to investors to fund purchases of legacy securitization assets. Eligible assets are expected to include certain non-agency residential mortgage backed securities (RMBS) that were originally rated AAA and outstanding commercial mortgage-backed securities (CMBS) and asset-backed securities (ABS) that are rated AAA.
o Working with Market Participants: Borrowers will need to meet eligibility criteria. Haircuts will be determined at a later date and will reflect the riskiness of the assets provided as collateral. Lending rates, minimum loan sizes, and loan durations have not been determined. These and other terms of the programs will be informed by discussions with market participants. However, the Federal Reserve is working to ensure that the duration of these loans takes into account the duration of the underlying assets.
2. Partnering Side-by-Side with Private Investors in Legacy Securities Investment Funds: Treasury will make co-investment/leverage available to partner with private capital providers to immediately support the market for legacy mortgage- and asset-backed securities originated prior to 2009 with a rating of AAA at origination.
 Side-by-Side Investment with Qualified Fund Managers: Treasury will approve up to five asset managers with a demonstrated track record of purchasing legacy assets though we may consider adding more depending on the quality of applications received. Managers whose proposals have been approved will have a period of time to raise private capital to target the designated asset classes and will receive matching Treasury funds under the Public-Private Investment Program. Treasury funds will be invested one-for-one on a fully side-by-side basis with these investors.
 Offer of Senior Debt to Leverage More Financing: Asset managers will have the ability, if their investment fund structures meet certain guidelines, to subscribe for senior debt for the Public-Private Investment Fund from the Treasury Department in the amount of 50% of total equity capital of the fund. The Treasury Department will consider requests for senior debt for the fund in the amount of 100% of its total equity capital subject to further restrictions.
Sample Investment Under the Legacy Securities Program
Step 1: Treasury will launch the application process for managers interested in the Legacy Securities Program.
Step 2: A fund manager submits a proposal and is pre-qualified to raise private capital to participate in joint investment programs with Treasury.
Step 3: The Government agrees to provide a one-for-one match for every dollar of private capital that the fund manager raises and to provide fund-level leverage for the proposed Public-Private Investment Fund.
Step 4: The fund manager commences the sales process for the investment fund and is able to raise $100 of private capital for the fund. Treasury provides $100 equity co-investment on a side-by-side basis with private capital and will provide a $100 loan to the Public-Private Investment Fund. Treasury will also consider requests from the fund manager for an additional loan of up to $100 to the fund.
Step 5: As a result, the fund manager has $300 (or, in some cases, up to $400) in total capital and commences a purchase program for targeted securities.
Step 6: The fund manager has full discretion in investment decisions, although it will predominately follow a long-term buy-and-hold strategy. The Public-Private Investment Fund, if the fund manager so determines, would also be eligible to take advantage of the expanded TALF program for legacy securities when it is launched.
REPORTS
• White Paper
• Legacy Securities Summary of Terms
• Legacy Securities FAQs
• Application for Private Assets Managers
• Legacy Loans Summary of Terms
• Legacy Loans FAQs