Treasury released a FAQs sheet yesterday evening to address the changes made to the Capital Purchase Program (CPP) by the American Recovery and Reinvestment Act of 2009 (ARRA). Under ARRA, Section 111 of the Emergency Economic Stabilization Act of 2008 (EESA) was amended to permit recipients of investments under Treasury’s Troubled Asset Relief Programs (TARP), including the CPP, to repay such investments “without regard to whether the financial institution had replaced such funds from any other source or to any waiting period” after consultation (and presumably approval by) the appropriate federal regulator. Section 111 of EESA previously provided that the preferred securities issued to Treasury under the CPP could not be redeemed for a period of three years, except with the proceeds from a sale of a qualifying offering. The FAQs provide that the warrants issued in connection with the CPP investment (or the preferred shares acquired by Treasury after immediately exercising the warrant in the case of privately-held financial institutions) may also be redeemed at the same time.