REGISTERED LOBBYIST CONTACT DISCLOSURE FORM

This form is to be completed by Executive Branch employees who are contacted by registered lobbyists regarding
EESA. This report includes a written description of each contact, the date and time of the contact, and the names
of the registered lobbyist(s) and the employee(s) with whom the contact took place. Written materials prepared

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To be completed by the employee contacted

Name of the . an
: 7 Brief description of the communication:
Bate and time of contact: em e ona tite) (attach separate sheet if necessary)
6/14/10, 3:30 PM Lori Bettinger, Capita! Email about impact Collins amendment would have on
ger, Uap! tou UT
Purchase Program a CPP institution
Director

Association

Name of the Employee(s) who prepared this form: Date
Lori Bettinger 6/1710
Registered Lobbyist Name: Title: Firm or Organization:, if Client
applicable
Mark Tenhundfeld Senior Vice President American Bankers



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Schaffner, TedDisabled; Bettinge!
Impact of Collins amendment on
Monday, June 14, 2010 3:39:12 PM

Lori;

Ted and Lori,

I wanted to share with you information that we have received from
about the potential impact that the Collins amendment

would have on that institution (and on the industry broadly speaking). While I
suspect you are all-too familiar with that amendment, in short it would require
that the capital rules that currently apply to banks also apply to holding
companies. Since, as we understand it, Treasury invested in

, the investment would not count as Tier 1 capital going forward,
with the results noted by [MM below. They have authorized us to share this
information but I would request that you treat it confidentially. I simply wanted
to make sure that Treasury was made aware of the potential impact on
as people within Treasury consider the Collins amendment. If you need further
information, please let me know.

The Collins amendment, if implemented, could cause the demise of as many as
600 banks, as reported by Banc Investment Daily (May 24, 2010).

For BE, the removal of TruPS from our Tier 1 capital (as Collins mandates)
would eliminate [J million of capital. Such a move imperils our recapitalization
efforts and raises serious questions about our ability to continue as a going
concern.

Using information as of March 31, 2010, EM Tier 1 capital would decline
from with TruPS to a critically undercapitalized level. Under those
conditions, would likely be closed, the FDIC would be faced with a

Depositors Insurance Fund (DIF) expense in excess of [EM and the U.S.
Treasury would face the loss of its [ENE TARP investment.

Even if we were to succeed with our recapitalization, the loss of TruPS as
required under Collins would cause us to reduce our loans (assets) by
and curtail new lending opportunities for our customers across the

Thank you for your consideration of this information.
Best regards,

Mark


Mark Tenhundfeld

Senior Vice President

Office of Regulatory Policy
American Bankers Association
Building Success. Together.
202-663-5042

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