Sonnenschein is pleased to share with you the comment letter we submitted to the FDIC on Friday, April 10, regarding the Legacy Loans Program. The Program, proposed in conjunction with the United States Treasury, seeks to assist U.S. depository institutions to divest problem loans and other assets that have adversely affected balance sheets, earnings potential and market perception of these institutions.

Our comment letter addresses:

  • eligible asset categories and management strategy;
  • PPIF structure;
  • structure for indirect retail investment;
  • seller concerns;
  • investor concerns;
  • asset diligence and valuation;
  • auction procedures;
  • FDIC-guaranteed debt;
  • asset administration;
  • affiliation/conflict issues; and
  • executive compensation issues.

View a Copy of the Letter >>