UNITED STATES DEPARTMENT OF THE TREASURY

OFFICE OF FINANCIAL STABILITY

Warrant Disposition Report

Troubled Asset Relief Program

Office of Financial Stability

Table of Contents

Executive Summary 1

Background 

Warrant Disposition Process 4

Treasury’s Evaluation of Issuer’s Bid 5

Repurchases of Warrants 8

Auctions of Warrants 9

Warrant Portfolio as of December 31, 2009 11

 Appendix I – Legislative Background .

 Appendix II – Detailed Tables of Warrant Repurchases and Auctions 14

 Appendix III – Warrant Disposition Details  .

 Appendix IV – Changes in Market Conditions from Issuer Bid to Auction 52

 Appendix V – Qualified Equity Offerings  .

Warrant Disposition Report

Warrant

The Emergency Economic Stabilization Act of 2008 (EESA) requires that Treasury receive warrants in 

connection with the purchase of troubled assets. 

A major part of the TARP was the CPP. It was created in October 2008 to stabilize the financial system by providing 

capital to viable banks of all sizes nationwide. Under this program, Treasury invested $205 billion in 707 banks. 

Under the CPP, Treasury purchased shares of senior preferred stock or other securities from qualifying U.S.-

controlled banks, savings associations, and other financial institutions. As part of its investment, Treasury also 

received warrants to purchase shares of common stock or other securities from the banks. The purpose of the 

warrants was to provide taxpayers with an additional potential return on the government’s investment. 

To date, the disposition of warrants has succeeded in significantly increasing taxpayer returns on the CPP preferred 

investments that have been repaid. As of December 31, 2009, Treasury has received $4 billion in gross proceeds on 

the disposition of warrants in 34 banks, consisting of (i) $2.9 billion from repurchases by the issuers at agreed upon 

fair market values and (ii) $1.1 billion from auctions.1 For those 34 institutions, Treasury received an absolute return 

of 3.1% from dividends and an added 5.7% return from the sale of the warrants for a total absolute return of 8.8%.2 

These returns are not predictive of the eventual return on the entire CPP portfolio. 

When a bank repays the CPP investment, it has the right to repurchase its warrants at an agreed upon fair market 

value. The warrants do not trade on any market and do not have observable market prices. Accordingly, Treasury has 

established a methodology for evaluating a company’s determination of fair market value. If a bank chooses not to 

repurchase its warrants, then Treasury intends to sell the warrants to a third party. 

The first CPP warrant repurchase was completed in May 2009, and Treasury began the public sale of warrants 

to third parties in December 2009. Treasury follows a consistent process to dispose of the CPP warrants for all 

banks, regardless of the size of the institution or the warrant position. This process is designed to ensure that 

taxpayers receive fair market value for the CPP warrants whether they are repurchased by the issuer or sold to a 

third party. 

At the end of 2009, Treasury held warrants in 18 institutions that have fully redeemed the CPP investment, and 

Treasury intends to sell those positions in the near future. Treasury also holds warrants in 230 public companies 

that have not repaid the CPP investments. In addition, Treasury also holds warrants in public companies in 

connection with other TARP programs, such as the Targeted Investment Program (TIP) and the Asset Guarantee 

Program (AGP). For example, Treasury holds warrants in Bank of America Corporation associated with both 

CPP (121,792,790 shares with an exercise price of $30.79) and TIP (150,375,940 shares with an exercise price of 

$13.30). Treasury’s disposition process is the same for warrants acquired under all TARP programs.

1 Six private banks have also repurchased the warrant preferred shares that Treasury exercised at the time of purchase. 

See Footnote 4 and the last table in Appendix II. 

2 Returns not annualized. 

The U.S. Department of the Treasury (Treasury) is pleased to present its TARP Warrant Disposition 

Report as of December 31, 2009. This report provides an overview of the warrants received by 

Treasury under the Capital Purchase Program (CPP) of the Troubled Asset Relief Program (TARP) 

and an explanation of the warrant disposition process and the results achieved on behalf of taxpayers. 

Executive Summary

Executive Summary
2 Warra

Institution Name

REPURCHASES

GS 6/17/09 $10,000.0 7/22/09 $1,100.0

MS 6/17/09 $10,000.0 8/12/09 $950.0

AXP 6/17/09 $3,388.9 7/29/09 $340.0

USB 6/17/09 $6,599.0 7/15/09 $139.0

BK 6/17/09 $3,000.0 8/5/09 $136.0

NTRS 6/17/09 $1,576.0 8/26/09 $87.0

BBT 6/17/09 $3,133.6 7/22/09 $67.0

STT 6/17/09 $2,000.0 7/8/09 $60.0 

Others $1,558.2 $38.0

Total 31 $41,255.7 $2,917.0

AUCTIONS

JPM 6/17/09 $25,000.0 12/10/09 $950.3

COF 6/17/09 $3,555.2 12/3/09 $148.7

TCF 4/22/09 $361.2 12/15/09 $9.6

Total 3 $28,916.4 $1,108.6

Ticker

Preferred 

Repurchase 

Date 

Preferred 

Amount

($millions)

Warrant 

Repurchase/ 

Auction 

Date 

Gross 

Warrant 

Proceeds 

($millions)

Goldman Sachs Group, Inc.

Morgan Stanley

American Express Company

U.S. Bancorp

Bank of New York Mellon

Northern Trust Corporation

BB&T Corporation

State Street Corporation

JPMorgan Chase & Co.

Capital One Financial Corp.

TCF Financial Corporation

Figure 1 : Summary of Gross Proceeds from Sale of Public Warrants as of December 31, 2009

The table below shows the proceeds from the eight largest warrant repurchases and the three warrant auctions as 

of December 31, 2009.

Executive Summary
Warrant

As required by EESA, Treasury received warrants from CPP banks to provide taxpayers with an additional 

potential return on the government’s investment.3 

For each CPP investment in a publicly traded company, Treasury received warrants to purchase, at a fixed exercise price, 

shares of common stock equal to 15 percent of the aggregate liquidation preference of the senior preferred investment. 

The per share exercise price was set at the 20-trading day trailing average of the bank’s common stock price as of the 

time it was given preliminary approval for the CPP investment. The warrants may be exercised at any time over a ten 

year period. These public warrants include certain customary anti-dilution provisions for Treasury’s protection. 

For CPP investments in a privately-held company, an S-corporation, or certain mutual institutions, Treasury received 

warrants to purchase, at a nominal cost, additional preferred stock (warrant preferreds) or subordinated debentures 

(warrant sub debt) equivalent to five percent of the aggregate liquidation preference of the primary CPP investment. 

These warrant preferreds and warrant sub debt securities pay a higher dividend or interest rate than the primary CPP 

investment. Treasury exercised these kinds of warrants at the closings of the investments.

Institutions may repay Treasury for its investment under the conditions established in the CPP purchase agreements 

as amended by the American Recovery and Reinvestment Act of 2009 (ARRA). The repayment price is equal to what 

Treasury invested, plus any unpaid dividends or interest. Originally, the CPP contracts provided that an institution 

could not redeem the investment within the first three years except with the proceeds of a “qualified equity offering” 

(QEO), which is an offering of securities that would qualify as Tier 1 capital. The repayment terms of the contracts 

were later effectively amended by the ARRA, which provides that an institution can repay from any source of funds and 

without regard to any waiting period. 

In addition, in order to encourage institutions to seek additional private capital, the CPP contracts provided that 

participants could halve the number of shares subject to their warrants by completing before December 31, 2009 one 

or more QEOs with aggregate gross proceeds equivalent to the value of Treasury’s CPP investment. Thirty-eight CPP 

participants completed a QEO in time to reduce their warrants. (See Appendix V for a list of all completed QEOs.)

The CPP contracts further provide that once the preferred investment is redeemed or sold by Treasury, the institution has a 

right to repurchase the warrants at the fair market value. In addition, Treasury has the contractual right to sell the warrants. 

The ARRA affected Treasury’s authority to dispose of warrants, as it provided that when an institution repaid, 

“the Secretary shall liquidate warrants [of such institution]... at the current market price.” The ARRA was 

subsequently amended in May 2009 through the Helping Families Save Their Homes Act of 2009 (HFSTHA), 

which provides that the Secretary “may liquidate the warrants” following repayment. (See Appendix I for excerpts 

from EESA, AARA, and HFSTHA, which govern the warrant sales.) 

3 EESA provides that the Secretary may establish a “de minimus” exception to the requirement to issue warrants in the case of an institution 

that receives less than $100 million in TARP funds. Treasury has exercised that authority by not requiring warrants in the case of investments in Community Development Financial Institutions in order to encourage their participation in CPP.

Background

Background
4 Warra

Upon redemption of the preferred stock issued to Treasury, an institution has a contractual right to repurchase its 

warrants at the fair market value.4 The banks have 15 days from repayment of the preferred to submit a bid, and 

Treasury then has 10 days to respond. In June 2009, Treasury announced that, in the event that an issuer does 

not repurchase its warrants, Treasury would sell the warrants to third parties “as quickly as practicable” and, when 

possible, by public auction.

Issuer Repurchases

If a company wishes to repurchase its warrants, the issuer and Treasury must agree on the warrants’ fair market 

value. Accordingly, Treasury has established a methodology for evaluating a bank’s determination of fair market 

value. As described below, Treasury’s evaluation of an issuer’s bid is based on three categories of input: (i) market 

quotes, (ii) independent, third party valuations, and (iii) model valuations.

If the issuer and Treasury fail to agree on a price, an appraisal procedure may be invoked by either party within 

30 days following Treasury’s response to the issuer’s first bid. In the appraisal process, each party selects an 

independent appraiser. These independent appraisers conduct their own valuations and attempt to agree upon 

the fair market value. If they agree on a fair market value, that valuation becomes the basis for repurchase. If 

these appraisers fail to agree, a third appraiser is hired, and subject to some limitations, a composite valuation of 

the three appraisals is used to establish the fair market value. To date, no institution has invoked the appraisal 

procedure. 

Even if agreement is not reached within the specified timeframe, a bank that has repaid its preferred stock may 

bid to repurchase its warrants at any time, and Treasury will determine whether to accept the bid. 

Sale to Third Party

Treasury retains the right to sell the warrants to a third party at a mutually agreed upon price. Following 

repayment of the preferred stock, if a bank notifies Treasury that it does not intend to repurchase its warrants or 

cannot agree with Treasury on the fair market value, Treasury intends to dispose of the warrants, when possible, 

through public auctions. 

Treasury held the first three of such auctions in December 2009. These auctions were conducted as public 

modified “Dutch” auctions which were registered under the Securities Act of 1933. Only one bank’s warrants 

were sold in each auction. In this format, bidders were able to submit one or more independent bids at different 

price-quantity combinations and the warrants were sold at a uniform price that cleared the auction.

4 Privately-held companies, S-corporations, and certain mutual institutions typically redeem their warrant preferred or subordinated 

debentures at par when redeeming the primary CPP investment. (See Appendix II for table of warrant preferred repurchases as of 

December 31, 2009.)

Warrant Disposition Process

Warrant Disposition Process
Warrant

Treasury adheres to a consistent process for evaluating bids from institutions to repurchase their warrants. 

Upon receiving a bid for a warrant repurchase, Treasury utilizes (i) market quotes, (ii) independent, third party 

valuations, and (iii) model valuations to assess the bid. 

(i) Market Quotes

There is little comparable market data for long-dated options. In order to perform its valuation analysis, Treasury 

seeks indications of value from various market participants active in the options markets. The range of estimated 

valuations is included in Treasury’s analysis along with the average of the market indications collected. In the 

future, Treasury will utilize the market information from the trading of the recently auctioned CPP warrants 

as some indication of the market’s expectations for long-term volatility, as well as continue to collect valuation 

estimates from market participants.

(ii) Third Party Valuations

Treasury engages outside consultants or external asset managers to provide independent, third party valuations for 

the warrants. The third party provides Treasury with an estimated valuation along with a range of potential values 

given a reasonable variance in the assumptions underlying their models. 

(iii) Model Valuations 

Treasury uses a number of financial models to estimate warrant valuations. The primary model that 

Treasury uses is a binomial option model adjusted for American style options, which is a well-accepted 

method for valuing options by both academics and market participants. Valuation estimates generated 

from the binomial model are presented in the Treasury’s analysis along with a range of potential values given 

a reasonable variance in key model inputs, such as assumptions about the expected future volatility and 

dividend yield of the underlying stock. Treasury’s internal valuation modeling was reviewed by Dr. Robert 

Jarrow, an options expert and professor at Cornell University, who concluded that “the Treasury’s modeling 

methodology for valuing the warrants is consistent with industry best practice and the highest academic 

standards.” More information on Treasury’s internal valuation modeling and the report written by Dr. 

Jarrow can be found at www.FinancialStability.gov/roadtostability/CapitalPurchaseProgram.html. 

Treasury and its external asset managers use the 20-trading day trailing average stock price of a company in their 

valuations to minimize the effects of day-to-day market fluctuations. Market participants who provide Treasury 

with market indications utilize the stock price at the time that they provide the valuation. If the discussions with 

an institution continue over an extended period of time, Treasury and its external asset managers will update their 

estimates as necessary. Treasury may also collect new market quotes or adjust the market quotes based on changes 

in market conditions from when the quotes were collected. (See Appendix II for information on the timing of 

issuers’ bids.)

Determination by Warrant Committee

Based on the range of estimated warrant values provided by these sources, a committee of Treasury officials within 

the Office of Financial Stability (OFS), who comprise the OFS Warrant Committee, makes a recommendation to 

the Assistant Secretary for Financial Stability as to whether to agree with the bank’s determination of fair market 

value. Each member of the Warrant Committee and the Assistant Secretary weigh the three valuation metrics as 

they deem appropriate. 

Treasury’s Evaluation of Issuer’s Bid

Treasury’s Evaluation of Issuer’s Bid
6 Warra

Additional factors presented to the Warrant Committee, along with the three valuation metrics discussed above 

include: 

 • how quickly Treasury would have to monetize the warrants if the issuer does not repurchase based on 

legislation in place at the time as discussed in the “Background” section of this report,

 • the expertise and experience of the outside consultant providing the third party valuation,

 • the quality and number of market indications received, 

 • any significant movements in the stock price of the issuer since market indications were collected, 

 • deviations of the current stock price from the 20-trading day trailing average of the company’s stock price,

 • the size of the warrant position and potential investor interest in the warrants, 

 • the liquidity of the underlying common stock, and

 • fixed transaction costs associated with selling the warrants to a third party.

Treasury’s Evaluation of Issuer’s Bid
Warrant

Figure 2 demonstrates the three elements of Treasury’s warrant valuation analysis together with an institution’s 

bid for the warrants, using Northern Trust Corporation as an example. The market quotes are presented 

as a range from the low to the high estimate of value provided by market participants (black bar) as well as 

the average of all the market indications collected (red point). The third party estimate of value (red point) 

is presented along with a reasonable range (black bar) that is also prepared by the third party. Treasury’s 

estimate of value (red point) based on its internal model is presented along with a reasonable range (black 

bar). The ranges of estimates presented below show the final estimates utilized by Treasury officials to analyze 

the bank’s final bid. 

Appendix III presents charts for all of the CPP warrant sales conducted as of December 31, 2009. As with 

the example below, all of the valuation estimates presented in Appendix III represent the final estimates used 

by Treasury officials when analyzing a repurchase request. Appendix III also notes additional relevant factors 

that were presented to the Warrant Committee.

Graphical Representation of Treasury’s Warrant Valuation Analy

Figure 2: Example of Treasury’s Warrant Valuation Analysis

$30,000 

$40,000 

$50,000 

$60,000 

$70,000 

$80,000 

$90,000 

$100,000 

$110,000 

$120,000 

Northern Trust (NTRS) 

Fair Market Value Estimates of Treasury's Warrant Position 

First Bid - $37,000,000 

Final Bid - $87,000,000

Second Bid - $75,000,000

Market Quotes Third Party Model Valuation 

$ Thousands

Treasury’s Evaluation of Issuer’s Bid
8 Warra

Treasury began the sale of warrants back to banks that had repaid the CPP investment and wanted to repurchase 

their warrants in May 2009. In aggregate, as of December 31, 2009, Treasury has realized $2.9 billion in gross 

proceeds from 31 warrant repurchases, which compares favorably to initial bids of $1.7 billion and estimates of 

aggregate value of $2.2 billion based on market indications, $2.7 billion based on third party estimates, and $2.6 

billion based on Treasury’s internal financial models. 

The initial repurchases that took place in May 2009 and their accompanying warrant valuations should be viewed in light of two 

factors particular to those transactions. First, the expertise and experience of the outside third parties affected the independent 

valuations provided. Second, at that time, Treasury was required to liquidate the warrants upon an issuer’s repayment pursuant 

to the terms of ARRA. Although it was not clear how quickly liquidation was required, Treasury believed that sales should be 

made promptly and attempted to complete sales expeditiously. This standard was later modified by HFSTHA to provide that 

Treasury “may liquidate” the warrants following repayment. (See Appendix I – Legislative Background.).

In all cases, Treasury has agreed to let an issuer repurchase its warrants only when the issuer’s bid was within the 

range of what Treasury determined to be fair market value. 

The table below shows all of the warrant the repurchases as of December 31, 2009, arrayed by amount of proceeds.

Institution Name Ticker

Preferred 

Redemption Date

Preferred Amount 

Redeemed

($thousands)

Warrant 

Repurchase Date

Gross Warrant 

Proceeds

($thousands)

QEO? (i.e. 

warrants cut 

by 50%)

GS 6/17/09 $10,000,000 7/22/09 $1,100,000 -

MS 6/17/09 10,000,000 8/12/09 950,000 -

AXP 6/17/09 3,388,890 7/29/09 340,000 -

USB 6/17/09 6,599,000 7/15/09 139,000 -

BK 6/17/09 3,000,000 8/5/09 136,000 -

NTRS 6/17/09 1,576,000 8/26/09 87,000 -

BBT 6/17/09 3,133,640 7/22/09 67,010 -

STT 6/17/09 2,000,000 7/8/09 60,000 Yes

TRMK 12/9/09 215,000 12/30/09 10,000 -

FMER 4/22/09 125,000 5/27/09 5,025 -

FNFG 5/27/09 184,011 6/24/09 2,700 Yes

OZRK 11/4/09 75,000 11/24/09 2,650 -

INDB 4/22/09 78,158 5/27/09 2,200 -

SNBC 4/8/09 89,310 5/27/09 2,100 -

SCBT 5/20/09 64,779 6/24/09 1,400 -

BARI 8/5/09 30,000 9/30/09 1,400 -

CVBF 9/2/09 130,000 10/28/09 1,307 Yes

ONB 3/31/09 100,000 5/8/09 1,200 -

IBKC 3/31/09 90,000 5/20/09 1,200 Yes

BHLB 5/27/09 40,000 6/24/09 1,040 -

WSBC 9/9/09 75,000 12/23/09 950 -

ALNC 5/13/09 26,918 6/17/09 900 -

FFIC 10/28/09 70,000 12/30/09 900 Yes

HFFC 6/3/09 25,000 6/30/09 650 -

WAIN 11/24/09 22,000 12/16/09 569 -

LSBX 11/18/09 15,000 12/16/09 560 -

UBSH 11/18/09 59,000 12/23/09 450 Yes

SOMH 5/20/09 7,414 6/24/09 275 -

OLBK 7/15/09 7,000 9/2/09 225 -

CSFL 9/30/09 27,875 10/28/09 212 Yes

MNHN 9/16/09 1,700 10/14/09 63 -

TOTAL 31 $41,255,695 $2,916,986 7

Goldman Sachs Group, Inc.

Morgan Stanley

American Express Company

U.S. Bancorp

Bank of New York Mellon

Northern Trust Corporation

BB&T Corporation

State Street Corporation

Trustmark Corporation

FirstMerit Corp

First Niagra Financial Group

Bank of the Ozarks, Inc.

Indpendent Bank Corp

Sun Bancorp, Inc.

SCBT Financial Corporation

Bancorp Rhode Island, Inc.

CVB Financial Corp.

Old National Bancorp

IBERIABANK Corporation

Berkshire Hills Bancorp

Wesbanco, Inc.

Alliance Financial Corporation

Flushing Financial Corporation 

HF Financial Corp.

Wainwright Bank and Trust

LSB Corporation

Union Bankshares Corporation

Somerset Hills Bancorp

Old Line Bancshares, Inc.

CenterState Banks, Inc. 

Manhattan Bancorp

Figure 3: Issuer Repurchases of Public Warrants as of December 31, 2009

Repurchases of Warrants

Repurchases of Warrants
Warrant

In the event an issuer does not repurchase its warrants, Treasury sells each institution’s warrants as quickly 

as practicable and, when possible, by public auctions. Treasury’s public auctions of CPP warrants began in 

December 2009 with the auctions of its warrants in JPMorgan Chase & Co., Capital One Financial Corp., and 

TCF Financial Corporation. These auctions generated $1.109 billion in gross proceeds ($1.092 billion net of 

underwriting fees). The net proceeds of the auctions exceeded the issuers’ bids by an aggregate amount of $217 

million. (See tables in Appendix II for details on individual bank’s bids and the auction proceeds received.)

Market conditions had changed between the time of the banks’ bids to repurchase their warrants directly from 

Treasury and the commencement of the auctions. In the case of JPMorgan and Capital One Financial, their share 

prices increased from the time of their bids to the auctions; however, this beneficial effect on the value of the 

warrants held by Treasury was at least partially offset by declines in the expected future volatility of their stocks. 

For TCF Financial, both its stock price and the expected future volatility of its stock declined, but Treasury still 

received about three times as much as the issuer’s bid for the warrants. (See Appendix IV for charts detailing 

the change in stock prices and the implied volatilities of the underlying stock for the three auctioned warrants 

between the date of the issuer’s bid to Treasury and the date of the auction.) 

These auctions demonstrate Treasury’s ability to dispose of the warrants at fair market values if an issuer chooses 

not to repurchase.

The table below shows the warrants sold to third parties as of December 31, 2009.

Figure 4: Warrant Auctions

Institution Name Ticker

Auction 

Date

Gross Warrant 

Proceeds

($thousands)

QEO? (i.e. 

warrants cut 

by 50%)

JPMorgan Chase & Co JPM 6/17/09 $25,000,000 12/10/09 $950,318 -

Capital One Financial Corp. COF 6/17/09 3,555,199 12/3/09 148,731 -

TCF Financial Corporation TCF 4/22/09 361,172 12/15/09 9,600 -

TOTAL 3 $28,916,371 $1,108,649 0

Preferred 

Redemption Date

Preferred Amount 

Redeemed

($thousands)

Auctions of Warrants

Auctions of Warrants
10 Warra

For the first three warrant auctions, 

Treasury utilized modified “Dutch” 

auctions to dispose of the warrants. 

The public auctions were registered 

under the Securities Act of 1933. Only 

one bank’s warrants were sold in each 

auction. With advice from its external 

asset managers and the auction agent, 

Treasury publicly disclosed a minimum 

bid and privately set a reserve price 

for each auction. Bidders were able to 

submit one or more independent bids 

at different price-quantity combinations 

at or above the set minimum price. The 

auction agent did not provide bidders 

with any information about the bids 

of other bidders or auction trends, or 

with advice regarding bidding strategies, 

in connection with the auction. The 

issuers of the warrants were able to bid 

for their warrants in the auctions. Bids 

were accepted by the auction agent from 

8:00 a.m. to 6:30 p.m. on the day of the 

auction. The warrants were sold to all 

winning bids at the uniform price that 

cleared the auction. 

Deutsche Bank Securities Inc. was 

Treasury’s auction agent for the first 

three auctions. Deutsche Bank received 

fees equal to approximately 1.5% of the 

gross proceeds ($16.6 million) which 

is significantly below typical secondary 

equity offering fees that run around 

3.5% to 4.5% depending on the size of 

the offering. 

For illustrative purposes only, Figures 5 

and 6 are example charts of the demand 

in a theoretical auction of an 8 million 

share position with a minimum price of 

$3.00 per share and a clearing price of 

$5.75 per share.

Modified “Dutch” Auctio

Figure 5: Illustrative Cumulative Auction 

Demand by Price 

Figure 6: Illustrative Auction Demand by Price

0.0 

0.5 

1.0 

1.5 

2.0 

2.5 

3.0 

3.5 

$3.00 $3.25 $3.50 $3.75 $4.00 $4.25 $4.50 $4.75 $5.00 $5.25 $5.50 $5.75 $6.00 $6.25 $6.50 $6.75 $7.00 $7.25 $7.50 $7.75 $8.00 

# of shares (millions) 

price per share 

Example of Demand by Price 

Example Auction Clearing Price $5.75 

0.0

1.0

1.5

2.0

2.5

3.0

3.5

$3.00 $3.25 $3.50 $3.75 $4.00 $4.25 $4.50 $4.75 $5.00 $5.25 $5.50 $5.75 $6.00 $6.25 $6.50 $6.75 $7.00 $7.25 $7.50 $7.75 $8.00 

# of shares (millions) 

price per share 

Example of Cumulative Demand by Price 

Example Auction Clearing Price $5.75 

Auctions of Warrants
Warrant 

At the end of 2009, Treasury continued to hold warrants in 18 institutions that have fully redeemed the CPP 

investment as wells as warrants in 230 public companies that have not repaid.

The table below shows the warrants still held in institutions that have redeemed their CPP investment.

12/9/09

12/23/09

12/23/09

12/23/09

5/27/09

5/5/09

3/31/09

9/9/09

11/18/09

5/13/09

7/8/09

12/30/09

3/31/09

4/15/09

12/23/09

12/23/09

10/21/09

10/7/09

Institution Name Ticker

Preferred 

Repurchase Date

Preferred 

Investment

($thousands) Warrant Shares Strike Price

QEO? (i.e. 

warrants cut 

by 50%)

Bank of America Corporation BAC $25,000,000 121,792,790 $30.79 -

Wells Fargo & Company WFC $25,000,000 110,261,688 $34.01 -

Valley National Bancorp VLY $300,000 2,411,945 $18.66 -

SVB Financial Group

Washington Federal, Inc.

SIVB $235,000 354,058 $49.78 Yes

WFSL $200,000 1,707,456 $17.57 -

Sterling Bancshares, Inc SBIB $125,198 2,615,557 $7.18 -

Signature Bank SBNY $120,000 595,829 $30.21 -

F.N.B. Corporation FNB $100,000 651,042 $11.52 Yes

Westamerica Bancorporation

Texas Capital Bancshares, Inc.

WABC $83,726 246,640 $50.92 -

TCBI $75,000 758,086 $14.84 -

FCBC $41,500 88,273 $35.26 Yes

OceanFirst Financial Corp. OCFC $38,263 190,427 $15.07 Yes

Bank of Marin Bancorp BMRC $28,000 154,242 $27.23 -

Shore Bancshares, Inc. SHBI $25,000 172,970 $21.68 -

Middleburg Financial Corporation MBRG $22,000 104,101 $15.85 Yes

Monarch Financial Holdings, Inc. MNRK $14,700 132,353 $8.33 Yes

LCNB Corporation LCNB $13,400 217,063 $9.26 -

Commerce National Bank CNBF $5,000 87,209 $8.60 -

TOTAL 18 $51,426,787 6

First Community Bancshares, Inc.

Figure 7: Warrants Held in Institutions that have Fully Redeemed 

CPP Investment as of December 31, 2009

Warrant Portfolio as of December 31, 2009

Warrant Portfolio as of December 31, 2009
12 Warra

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Warrant 

Emergency Economic Stabilization Act of 2008 October 3, 2008

http://frwebgate.access.gpo.gov/cgibin/getdoc.cgi?dbname=110_cong_public_laws&docid=f:publ343.110.pdf

Section 113 (d)(1). In general.--The Secretary may not purchase, or make any commitment to purchase, any 

troubled asset under the authority of this Act, unless the Secretary receives from the financial institution from 

which such assets are to be purchased—

 (A) in the case of a financial institution, the securities of which are traded on a national securities 

exchange, a warrant giving the right to the Secretary to receive nonvoting common stock or preferred 

stock in such financial institution, or voting stock with respect to which, the Secretary agrees not to 

exercise voting power, as the Secretary determines appropriate; or 

 (B) in the case of any financial institution other than one described in subparagraph (A), a warrant for 

common or preferred stock, or a senior debt instrument from such financial institution, as described in 

paragraph (2)(C).

American Recovery and Reinvestment Act of 2009 February 17, 2009

http://frwebgate.access.gpo.gov/cgibin/getdoc.cgi?dbname=111_cong_public_laws&docid=f:publ005.111.pdf

Section 7001. “(g) NO IMPEDIMENT TO WITHDRAWAL BY TARP RECIPIENTS.— Subject to 

consultation with the appropriate Federal banking agency (as that term is defined in section 3 of the Federal 

Deposit Insurance Act), if any, the Secretary shall permit a TARP recipient to repay any assistance previously 

provided under the TARP to such financial institution, without regard to whether the financial institution has 

replaced such funds from any other source or to any waiting period, and when such assistance is repaid, the 

Secretary shall liquidate warrants associated with such assistance at the current market price.”

Helping Families Save Their Homes Act of 2009 May 20, 2009

http://frwebgate.access.gpo.gov/cgi-bin/getdoc.cgi?dbname=111_cong_public_laws&docid=f:publ022.111.pdf

Section 403. REMOVAL OF REQUIREMENT TO LIQUIDATE WARRANTS UNDER THE TARP. Section 

111(g) of the Emergency Economic Stabilization Act of 2008 (12 U.S.C. 5221(g)) is amended by striking ‘‘shall 

liquidate warrants associated with such assistance at the current market price’’ and inserting ‘‘, at the market price, 

may liquidate warrants associated with such assistance’’.

Appendix I – Legislative Background

Appendix I – Legizlative Background
14 Warrant Disposition Report Issuer Bids and Warrant Sales

Appendix II – Detailed Tables of Warrant 

Repurchases and Auctions 

Company Ticker

Redemption 

Date Bid #1 Bid #2 Bid #3 Bid #4

Final Price

($thousands) Bid #1 Bid #2 Bid #3 Bid #4

Warrant 

Repurchase 

Date

ONB $100,000 3/31/09 $559 $1,200 $1,200 4/15/09 5/6/09 5/8/09IBKC 90,000 3/31/09 620 1,200 1,200 4/14/09 5/12/09 5/20/09SNBC 89,310 4/8/09 1,049 2,100 2,100 4/21/09 5/19/09 5/27/09FMER 125,000 4/22/09 3,186 5,025 5,025 5/15/09 5/21/09 5/27/09INDB 78,158 4/22/09 880 2,200 2,200 5/2/09 5/21/09 5/27/09ALNC 26,918 5/13/09 320 900 900 5/26/09 6/12/09 6/17/09SCBT 64,779 5/20/09 694 1,400 1,400 6/3/09 6/16/09 6/24/09BHLB 40,000 5/27/09 875 1,040 1,040 6/8/09 6/17/09 6/24/09SOMH 7,414 5/20/09 193 275 275 6/4/09 6/17/09 6/24/09FNFG 184,011 5/27/09 1,500 2,700 2,700 6/4/09 6/19/09 6/24/09STT 2,000,000 6/17/09 60,000 60,000 6/22/09 7/8/09USB 6,599,000 6/17/09 115,000 131,000 139,000 139,000 6/18/09 7/1/09 7/8/09 7/15/09BBT 3,133,640 6/17/09 20,854 41,707 64,925 67,010 67,010 6/24/09 7/8/09 7/14/09 7/14/09 7/22/09GS $10,000,000 6/17/09 600,000 900,000 1,100,000 1,100,000 6/17/09 7/20/09 7/21/09 7/22/09AXP 3,388,890 6/17/09 230,000 260,000 340,000 340,000 7/1/09 7/20/09 7/27/09 7/29/09BK 3,000,000 6/17/09 79,000 118,000 130,000 136,000 136,000 6/30/09 7/29/09 7/30/09 7/31/09 8/5/09MS 10,000,000 6/17/09 500,000 800,000 900,000 950,000 950,000 6/30/09 8/3/09 8/4/09 8/5/09 8/12/09

NTRS 1,576,000 6/17/09 37,000 75,000 87,000 87,000 6/18/09 8/17/09 8/19/09 8/26/09

OLBK 7,000 7/15/09 175 205 225 225 7/29/09 8/19/09 8/20/09 9/2/09BARI 30,000 8/5/09 857 1,125 1,400 1,400 8/19/09 9/16/09 9/21/09 9/30/09MNHN 1,700 9/16/09 63 63 9/29/09 10/14/09CSFL 27,875 9/30/09 168 212 212 10/9/09 10/20/09 10/28/09CVBF 130,000 9/2/09 1,002 1,307 1,307 9/17/09 10/21/09 10/28/09OZRK 75,000 11/4/09 2,161 2,650 2,650 11/5/09 11/18/09 11/24/09WAIN 22,000 11/24/09 569 569 12/3/09 12/16/09LSBX 15,000 11/18/09 500 560 560 12/4/09 12/8/09 12/16/09WSBC 75,000 9/9/09 825 950 950 950 9/22/09 10/20/09 12/11/09 12/23/09UBSH 59,000 11/18/09 400 450 450 11/24/09 12/16/09 12/23/09FFIC 70,000 10/28/09 597 700 860 900 900 11/10/09 12/14/09 12/23/09 12/28/09 12/30/09TRMK 215,000 12/9/09 8,167 9,200 9,600 10,000 10,000 12/23/09 12/28/09 12/28/09 12/29/09 12/30/09

Total $41,255,695 $1,667,679 $2,916,986

Note: The first bid date is the date that an issuer submitted its bid. Subsequent bid dates are the dates the 

Warrant Committee met to consider those bids. 

Company Ticker

CPP 

Preferred 

($thousands)

Redemption 

Date Bid #1 Bid #2 Bid #3 Bid #4

Auction 

Proceeds

($thousands) Bid #1 Bid #2 Bid #3 Bid #4

Auction 

Date

COF 3,555,199 6/17/09 46,500 148,731 6/30/09 12/3/09JPM 25,000,000 6/17/09 825,539 950,318 6/17/09 12/10/09TCB 361,172 4/22/09 3,200 9,600 5/5/09 12/15/09

Total 28,916,371 875,239 1,108,649

Date of Issuer BidsDate of Issuer Bids

Issuer BidsIssuer Bids

HFFC 25,000 6/3/09 465 600 650 650 6/9/09 6/29/09 6/29/09 6/30/09

CPP 

Preferred 

($thousands)

Old National BancorpIBERIABANK CorporationSun Bancorp, Inc.FirstMerit CorpIndpendent Bank CorpAlliance Financial CorporationSCBT Financial CorporationBerkshire Hills BancorpSomerset Hills BancorpFirst Niagra Financial GroupHF Financial Corp.State Street CorporationU.S. BancorpBB&T CorporationGoldman Sachs Group, Inc.American Express CompanyBank of New York MellonMorgan StanleyNorthern Trust CorporationOld Line Bancshares, IncBancorp Rhode Island, Inc.Manhattan BancorpCenterState Banks, Inc. CVB Financial Corp.Bank of the Ozarks, Inc.Wainwright Bank and TrustLSB CorporationWesbanco, Inc.Union Bankshares CorporationFlushing Financial Corporation Trustmark Corporation 

Capital One Financial Corp.JPMorgan Chase & Co.TCF Financial Corporation

Appendix II – Detailed Tables of Warrant Repurchases and Auctions
Warrant 

Warrant Sales Ordered by Amount of Proceeds

Institution Name Ticker

Strike 

Price 

Stock 

Price

Goldman Sachs Group, Inc. GS 7/21/09 7/22/09 10/28/18 $122.90 - 12,205,045 $90.13 $1,100,000,000 $159.80 $148.16 1.30 x

Morgan Stanley MS 8/5/09 8/12/09 10/28/18 22.99 - 65,245,759 14.56 950,000,000 31.05 28.16 1.35 x

American Express Company AXP 7/27/09 7/29/09 1/9/19 20.95 - 24,264,129 14.01 340,000,000 28.38 25.71 1.35 x

U.S. Bancorp USB 7/8/09 7/15/09 11/14/18 30.29 - 32,679,102 4.25 139,000,000 16.59 17.69 0.55 x

Bank of New York Mellon BK 7/31/09 8/5/09 10/28/18 31.00 - 14,516,129 9.37 136,000,000 27.34 27.98 0.88 x

Northern Trust Corporation NTRS 8/19/09 8/26/09 11/14/18 61.81 - 3,824,624 22.75 87,000,000 60.38 60.00 0.98 x

BB&T Corporation BBT 7/14/09 7/22/09 11/14/18 33.81 - 13,902,573 4.82 67,010,402 21.65 21.64 0.64 x

State Street Corporation STT 7/1/09 7/8/09 10/28/18 53.80 Yes 2,788,104 21.52 60,000,000 47.35 46.98 0.88 x

Trustmark Corporation TRMK 12/29/09 12/30/09 11/21/18 19.57 - 1,647,931 6.07 10,000,000 22.80 20.84 1.17 x

FirstMerit Corp. FMER 5/21/09 5/27/09 1/9/19 19.69 - 952,260 5.28 5,025,000 17.54 19.27 0.89 x

First Niagra Financial Group FNFG 6/19/09 6/24/09 11/21/18 14.48 Yes 953,096 2.83 2,700,000 11.93 12.05 0.82 x

Bank of the Ozarks, Inc. OZRK 11/18/09 11/24/09 12/12/18 29.62 - 379,811 6.98 2,650,000 27.48 24.46 0.93 x

Independent Bank Corp. INDB 5/21/09 5/27/09 1/9/19 24.34 - 481,664 4.57 2,200,000 19.60 19.92 0.81 x

Sun Bancorp, Inc. SNBC 5/19/09 5/27/09 1/9/19 8.27 - 1,620,545 1.30 2,100,000 6.25 6.36 0.76 x

Bancorp Rhode Island BARI 9/21/09 9/30/09 12/19/18 23.32 - 192,967 7.26 1,400,000 24.66 25.57 1.06 x

SCBT Financial Corporation SCBT 6/16/09 6/24/09 1/16/19 32.06 - 303,083 4.62 1,400,000 23.16 23.45 0.72 x

CVB Financial Corp. CVBF 10/21/09 10/28/09 12/5/18 11.68 Yes 834,761 1.57 1,307,000 8.81 7.73 0.75 x

IBERIABANK Corporation IBKC 5/12/09 5/20/09 12/5/18 48.74 Yes 138,490 8.66 1,200,000 47.22 48.23 0.97 x

Old National Bancorp ONB 5/6/09 5/8/09 12/12/18 18.45 - 813,008 1.48 1,200,000 14.33 14.18 0.78 x

Berkshire Hills Bancorp BHLB 6/17/09 6/24/09 12/19/18 26.51 - 226,330 4.60 1,040,000 20.17 21.38 0.76 x

Wesbanco, Inc. WSBC 12/11/09 12/23/09 12/5/18 25.61 - 439,282 2.16 950,000 12.41 12.71 0.48 x

Alliance Financial Corporation ALNC 6/12/09 6/17/09 12/19/18 23.33 - 173,069 5.20 900,000 26.61 25.50 1.14 x

Flushing Financial Corporation FFIC 12/28/09 12/30/09 12/19/18 13.97 Yes 375,806 2.39 900,000 11.73 10.92 0.84 x

HF Financial Corp. HFFC 6/29/09 6/30/09 11/21/18 12.40 - 302,419 2.15 650,000 11.95 12.08 0.96 x

Wainwright Bank and Trust WAIN 12/11/09 12/16/09 12/19/18 8.46 - 390,071 1.46 568,700 7.00 6.75 0.83 x

LSB Corporation LSBX 12/8/09 12/16/09 12/12/18 10.74 - 209,497 2.67 560,000 11.28 11.00 1.05 x

Union Bankshares Corporation UBSH 12/16/09 12/23/09 12/19/18 20.94 Yes 211,318 2.13 450,000 11.93 11.93 0.57 x

Somerset Hills Bancorp SOMH 6/17/09 6/24/09 1/16/19 6.82 - 163,065 1.69 275,000 7.80 7.73 1.14 x

Old Line Bancshares OLBK 8/20/09 9/2/09 12/5/18 7.40 - 141,892 1.59 225,000 6.10 6.21 0.82 x

CenterState Banks, Inc. CSFL 10/21/09 10/28/09 11/21/18 16.67 Yes 125,413 1.69 212,000 7.47 7.64 0.45 x

Manhattan Bancorp MNHN 10/9/09 10/14/09 12/5/18 8.65 - 29,480 2.15 63,364 6.60 6.53 0.76 x

TOTAL 31 - - - - 7 - - $2,916,986,466 - - -

* Volatility implied by the repurchase price using stock price on decision date and UST estimates for dividend yield and borrow cost; reflects discounts to a modeled valuation for illiquidity, risk of cash takeout, etc.

Institution Name Ticker

Announce 

Date

Auction 

Date

Expiration 

Date

Strike 

Price 

Warrant Shares Stock Price

Underlying 

/ Strike

JPMorgan Chase & Co. JPM 12/8/09 12/10/09 10/28/18 $42.42 - 88,401,697 $10.75 23.8% - 27.5% $41.27 0.26 0.97 x

Capital One Financial Corp. COF 12/1/09 12/3/09 11/14/18 42.13 - 12,657,960 11.75 34.6% - 38.2% 36.92 0.32 0.88 x

TCF Financial Corporation TCB 12/14/09 12/15/09 11/14/18 16.93 - 3,199,988 3.00 9,599,964 28.8% - 32.1% 13.22 0.23 0.78 x

TOTAL 3 - - - - 0 - - - - - - - -

* Volatility implied by the repurchase price using stock price on auction date and UST estimates for dividend yield and borrow cost; reflects discounts to a modeled valuation for illiquidity, risk of cash takeout, etc.

Decision Date

Decision Date

- -

Warrant 

Repurchase 

Price/Share

Warrant 

Repurchase 

Proceeds

20-day Avg 

Stock Price

QEO? (i.e. 

warrants cut by 

50%)

Estimated 

Implied 

Volatilty*

Decision 

Date

Payment 

Date

Expiration 

Date

QEO? (i.e. 

warrants cut 

by 50%)

Final Warrant 

Shares

Estimated

Implied

Volatility*

40.6% - 44.5%33.3% - 38.7%37.6% - 40.7%39.3% - 42.6%35.7% - 39.6%31.1% - 35.9%32.0% - 35.1%37.9% - 43.8%19.0% - 22.9%34.9% - 38.3%28.5% - 31.7%20.9% - 25.1%28.5% - 31.6%16.0% - 19.9%21.9% - 26.6%24.1% - 27.4%26.4% - 29.2%17.5% - 20.8%20.3% - 23.6%24.0% - 28.0%38.1% - 40.7%13.8% - 17.0%22.4% - 25.9%18.3% - 21.5%27.8% - 30.7%22.1% - 25.3%30.3% - 33.0%14.8% - 18.4%26.3% - 30.1%34.9% - 38.2%29.7% - 34.8%

Warrant 

Price / Stock 

Price

0.560.470.490.260.340.380.220.450.270.300.240.250.230.210.290.200.180.180.100.230.170.200.200.180.210.240.180.220.260.230.33

Underlying / 

Strike

Warrant

Auction 

Price Per Share 

Warrant Auction

Gross Proceeds

$950,318,243

148,731,030

$1,108,649,237

20-day Avg Stock Price 

$42.24

38.6612.78

Warrant Price / 

Stock Price

Appendix II – Detailed Tables of Warrant Repurchases and Auctions
16 Warra

Institution Name

 Repurchase 

Date

CPP Investment

($thousands)

Warrant 

Repurchase

Gross Warrant 

Proceeds

($thousands)

Centra Financial Holdings, Inc. 3/31/09 $15,000 4/15/09 $750

First Manitowoc Bancorp, Inc. 5/27/09 $12,000 5/27/09 600

Midland States Bancorp, Inc. 12/23/09 $10,189 12/23/09 509

1st United Bancorp, Inc. 11/18/09 $10,000 11/18/09 500

First ULB Corp. 4/22/09 $4,900 4/22/09 245

Midwest Regional Bancorp, Inc. 11/10/09 $700 11/10/09 35

TOTAL $52,789 $2,639

Issuer Repurchases of Warrant Preferreds or Warrant Sub Debt

Appendix II – Detailed Tables of Warrant Repurchases and Auctions
Warrant 

Institution Ticker Decision Date on 

Issuer's Final Bid

Old National Bank ONB May 6, 2009

IBERIABANK IBKC May 12, 2009

Sun Bancorp SNBC May 19, 2009

FirstMerit FMER May 21, 2009

Indpendent Bank INDB May 21, 2009

Alliance Financial ALNC June 12, 2009

SCBT Financial SCBT June 16, 2009

Berkshire Hills BHLB June 17, 2009

Somerset Hills SOMH June 17, 2009

First Niagra FNFG June 19, 2009

HF Financial HFFC June 29, 2009

State Street STT July 1, 2009

U.S. Bancorp USB July 8, 2009

BB&T BBT July 14, 2009

Goldman Sachs GS July 21, 2009

American Express AXP July 27, 2009

Bank of New York Mellon BK July 31, 2009

Morgan Stanley MS August 5, 2009

Northern Trust NTRS August 19, 2009

Old Line Bancshares OLBK August 20, 2009

Bancorp Rhode Island BARI September 21, 2009

Manhattan Bancorp MNHN October 9, 2009

CenterState Banks, Inc. CSFL October 20, 2009

CVB Financial CVBF October 21, 2009

Bank of the Ozarks OZRK November 18, 2009

LSB Corporation LSBX December 8, 2009

Wainwright Bank and Trust WAIN December 11, 2009

Wesbanco, Inc. WSBC December 11, 2009

Union Bankshares Corporation UBSH December 16, 2009

Flushing Financial Corporation FFIC December 28, 2009

Trustmark Corporation TRMK December 29, 2009

Institution Ticker Auction Date

Capital One Financial COF December 3, 2009

JPMorgan JPM December 10, 2009

TCF Financial TCB December 15, 2009

Appendix III – Warrant Disposition Details

Appendix III – Warrant Disposition Details
18 Warra

Old National Bancorp (ONB)

Repurchase of ONB Warrant

On May 6, 2009, Old National Bancorp (ONB) agreed to pay $1.2 million for the warrant held by Treasury 

which entitled the holder of the warrant to purchase 813,008 shares of ONB at a strike price of $18.45 per share. 

The warrant had an expiration date of December 12, 2018. 

NOTE: 1) At the time of the decision, the external asset managers had not been hired. Treasury relied on financial modeling 

consultants to provide third party input. The modeling consultants may not have had market expertise necessary to make reasonable assumptions for key inputs such as volatility and dividend yield. 2) At that time, legislation may have required that Treasury 

dispose of the warrants immediately. The fixed cost of disposing of the warrants was taken into consideration when analyzing the 

company’s determination of fair market value. 

$500

$1,000

$1,500

$2,000

$2,500

$3,000

$3,500

Old National Bancorp (ONB) 

Fair Market Value Estimates of Treasury's Warrant Position 

First Bid - $559,000

Final Bid - $1,200,000

Market Quotes Third Party Model Valuation 

$ Thousands

Valuation Estimates for Warrant

($thousands) Low High Estimate Details

Market Quotes $1,220 $1,490 $1,353 Three market indications.

Third Party $1969 $3,054 $3,054 Binomial option model adjusted for American style options

Model Valuation $1,070 $1,652 $1,326 Binomial option model adjusted for American style options

Appendix III – Warrant Disposition Details
Warrant 

IBERIABANK Corporation (IBKC) 

Repurchase of IBKC Warrant

On May 12, 2009, IBERIABANK Corporation (IBKC) agreed to pay $1.2 million for the warrant held by 

Treasury which entitled the holder of the warrant to purchase 138,490 shares of IBKC at a strike price of $48.74 

per share. The warrant had an expiration date of December 5, 2018.

NOTE: 1) At the time of the decision, the external asset managers had not been hired. Treasury relied on financial modeling 

consultants to provide third party input. The modeling consultants may not have had market expertise necessary to make reasonable assumptions for key inputs such as volatility and dividend yield. 2) At that time, legislation may have required that Treasury 

dispose of the warrants immediately. The fixed cost of disposing of the warrants was taken into consideration when analyzing the 

company’s determination of fair market value.

Valuation Estimates for Warrant

($thousands) Low High Estimate Details

Market Quotes $1,350 $1,662 $1,566 Four market indications.

$1,370 $2,334 $2,334 Binomial option model adjusted for American style options

Model Valuation $1,156 $1,682 $1,421 Binomial option model adjusted for American style options

Third Party 

$500

$700

$900

$1,100

$1,300

$1,500

$1,700

$1,900

$2,100

$2,300

$2,500

IBERIABANK Corporation (IBKC) 

Fair Market Value Estimates of Treasury's Warrant Position 

Market Quotes Third Party Model Valuation 

Final Bid - $1,200,000

First Bid - $620,000

$ Thousands

Appendix III – Warrant Disposition Details
20 Warra

Sun Bancorp, Inc. (SNBC

Repurchase of SNBC Warrant

On May 19, 2009, Sun Bancorp, Inc. (SNBC) agreed to pay $2.1 million for the warrant held by Treasury which 

entitled the holder of the warrant to purchase 1,620,545 shares of SNBC at a strike price of $8.27 per share. The 

warrant had an expiration date of January 9, 2019. 

NOTE: The third party valuation assumed volatility of over 50% and provided no discount for the illiquidity, take out risk or bankruptcy. Treasury’s volatility inputs more closely reflected market assumptions. Treasury also considered the large size of the SNBC 

warrant position (7% of outstanding shares) and the relative illiquidity of the stock (the position represented 30X the average 

trading volume of 60,000 shares) in determining a liquidity discount. 

$800

$1,300

$1,800

$2,300

$2,800

$3,300

$3,800

$4,300

Sun Bancorp (SNBC) 

Fair Market Value Estimates of Treasury's Warrant Position 

First Bid - $1,049,000 

Market Quotes Third Party Model Valuation 

Final Bid - $2,100,000

$ Thousands

Valuation Estimates for Warrant

($thousands) Low High Estimate Details

Market Quotes $1,080 $2,778 $2,096 Three market indications.

$2,000 $4,028 $4,028 Binomial option model adjusted for American style options

Model Valuation $1,974 $2,771 $2,252 Binomial option model adjusted for American style options

Third Party 

Appendix III – Warrant Disposition Details
Warrant 

FirstMerit Corp (FMER)

Repurchase of FMER Warrant

On May 21, 2009, FirstMerit Corp (FMER) agreed to pay $5.025 million for the warrant held by Treasury which 

entitled the holder of the warrant to purchase 952,260 shares of FMER at a strike price of $19.69 per share. The 

warrant had an expiration date of January 9, 2019. 

NOTE: At the time of the decision, the common share price of FMER was $17.54 compared to the 20 day average price of $19.27. 

This difference was taken under consideration in Treasury’s analysis of the company’s determination of fair market value.

Valuation Estimates for Warrant

($thousands) Low High Estimate Details

Market Quotes $4,082 $6,543 $4,918 Four market indications.

$5,428 $7,532 $6,485 Binomial option model adjusted for American style options

Model Valuation $4,871 $5,930 $5,400 Binomial option model adjusted for American style options

Third Party 

$2,000

$3,000

$4,000

$5,000

$6,000

$7,000

$8,000

FirstMerit Corp (FMER) 

Fair Market Value Estimates of Treasury's Warrant Position 

First Bid - $3,186,000 

Final Bid - $5,025,000

Market Quotes Third Party Model Valuation 

$ Thousands

Appendix III – Warrant Disposition Details
22 Warra

Independent Bank Corp (INDB)

Repurchase of INDB Warrant

On May 21, 2009, Independent Bank Corp (INDB) agreed to pay $2.2 million for the warrant held by Treasury 

which entitled the holder of the warrant to purchase 481,664 shares of INDB at a strike price of $24.34 per 

share. The warrant had an expiration date of January 9, 2019. 

$800

$1,300

$1,800

$2,300

$2,800

$3,300

$3,800

Independent Bank (INDB) 

Fair Market Value Estimates of Treasury's Warrant Position 

First Bid - $880,000 

Final Bid - $2,200,000

Market Quotes Third Party Model Valuation 

$ Thousands

Valuation Estimates for Warrant

($thousands) Low High Estimate Details

Market Quotes $1,444 $2,432 $2,104 Three market indications.

$2,293 $3,482 $2,885 Binomial option model adjusted for American style options

Model Valuation $1,754 $2,965 $2,345 Binomial option model adjusted for American style options

Third Party 

Appendix III – Warrant Disposition Details
Warrant 

Alliance Financial Corporation (ALNC)

Repurchase of ALNC Warrant

On June 12, 2009, Alliance Financial Corporation (ALNC) agreed to pay $900,000 for the warrant held by 

Treasury which entitled the holder of the warrant to purchase 173,069 shares of ALNC at a strike price of $23.33 

per share. The warrant had an expiration day of December 19, 2018. 

$300

$400

$500

$600

$700

$800

$900

$1,000

$1,100

$1,200

$1,300

Alliance Financial (ALNC) 

Fair Market Value Estimates of Treasury's Warrant Position 

Market Quotes Third Party Model Valuation 

Final Bid - $900,000

 First Bid - $320,000 

$ Thousands

Valuation Estimates for Warrant

($thousands) Low High Estimate Details

Market Quotes $554 $952 $762 Three market indications.

$899 $1,244 $990 Binomial option model adjusted for American style options

Model Valuation $741 $895 $818 Binomial option model adjusted for American style options

Third Party 

Appendix III – Warrant Disposition Details
24 Warra

SCBT Financial Corporation (SCBT) 

Repurchase of SCBT Warrant

On June 16, 2009, SCBT Financial Corporation (SCBT) agreed to pay $1.4 million for the warrant held by 

Treasury which entitled the holder of the warrant to purchase 303,083 shares of SCBT at a strike price of $32.06 

per share. The warrant had an expiration date of January 16, 2019. 

NOTE: The third party modeled valuation assumed volatility of 46%. Treasury’s model assumed a significantly lower volatility 

closer to the historic volatility of the company and observable market prices. 

Third Party 

Valuation Estimates for Warrant

($thousands) Low High Estimate Details

Market Quotes $555 $1,789 $1,159 Five market indications.

$2,322 $3,261 $2,888 Binomial option model adjusted for American style options

Model Valuation $1,137 $1,436 $1,281 Binomial option model adjusted for American style options

$500

$1,000

$1,500

$2,000

$2,500

$3,000

$3,500

SCBT Financial Corporation (SCBT) 

Fair Market Value Estimates of Treasury's Warrant Position 

First Bid - $694,060 

Final Bid - $1,400,000

Market Quotes Third Party Model Valuation 

$ Thousands

Appendix III – Warrant Disposition Details
Warrant 

Berkshire Hills Bancorp (BHLB) 

Repurchase of BHLB Warrant

On June 17, 2009, Berkshire Hills Bancorp (BHLB) agreed to pay $1.04 million for the warrant held by Treasury 

which entitled the holder of the warrant to purchase 226,330 shares of BHLB at a strike price of $26.51 per 

share. The warrant had an expiration date of December 19, 2018. 

$500

$700

$900

$1,100

$1,300

$1,500

$1,700

$1,900

$2,100

Berkshire Hills (BHLB) 

Fair Market Value Estimates of Treasury's Warrant Position 

First Bid - $875,000

Final Bid - $1,040,000

Market Quotes Third Party Model Valuation 

$ Thousands

Third Party 

Valuation Estimates for Warrant

($thousands) Low High Estimate Details

Market Quotes $509 $758 $611 Three market indications.

$1,071 $1,974 $1,494 Binomial option model adjusted for American style options

Model Valuation $827 $1,116 $971 Binomial option model adjusted for American style options

Appendix III – Warrant Disposition Details
26 Warra

Somerset Hills Bancorp (SOMH) 

Repurchase of SOMH Warrant

On June 17, 2009, Somerset Hills Bancorp (SOMH) agreed to pay $275,000 for the warrant held by Treasury 

which entitled the holder of the warrant to purchase 163,065 shares of SOMH at a strike price of $6.82 per 

share. The warrant had an expiration date of January 16, 2019. 

Third Party 

Valuation Estimates for Warrant

($thousands) Low High Estimate Details

Market Quotes $122 $406 $266 Five market indications.

$374 $521 $447 Binomial option model adjusted for American style options

Model Valuation $253 $299 $276 Binomial option model adjusted for American style options

$100

$150

$200

$250

$300

$350

$400

$450

$500

$550

$600

Somerset Hills (SOMH) 

Fair Market Value Estimates of Treasury's Warrant Position 

First Bid - $193,000 

Market Quotes Third Party Model Valuation 

Final Bid - $275,000

$ Thousands

Appendix III – Warrant Disposition Details
Warrant 

First Niagara Financial Group (FNFG) 

Repurchase of FNFG Warrant

On June 19, 2009, First Niagara Financial Group (FNFG) agreed to pay $2.7 million for the warrant held by 

Treasury which entitled the holder of the warrant to purchase 953,096 shares of FNFG at a strike price of $14.48 

per share. The warrant had an expiration date of November 21, 2018. 

$900

$1,400

$1,900

$2,400

$2,900

$3,400

$3,900

$4,400

$4,900

$5,400

First Niagara (FNFG) 

Fair Market Value Estimates of Treasury's Warrant Position 

First Bid - $1,500,000 

Final Bid - $2,700,000

Market Quotes Third Party Model Valuation 

$ Thousands

Valuation Estimates for Warrant

($thousands) Low High Estimate Details

Market Quotes $953 $2,383 $1,646 Five market indications.

Third Party $3,455 $4,995 $4,221 Binomial option model adjusted for American style options

Model Valuation $2,444 $3,175 $2,807 Binomial option model adjusted for American style options

Appendix III – Warrant Disposition Details
28 Warra

HF Financial Corp (HFFC) 

Repurchase of HFFC Warrant

On June 29, 2009, HF Financial Corp (HFFC) agreed to pay $650,000 for the warrant held by Treasury which 

entitled the holder of the warrant to purchase 302,419 shares of HFFC at a strike price of $12.40 per share. The 

warrant had an expiration date of November 21, 2018. 

$200 

$300 

$400 

$500 

$600 

$700 

$800 

$900 

HF Financial (HFFC) 

Fair Market Value Estimates of Treasury's Warrant Position 

First Bid - $464,987 

Final Bid - $650,000 

Market Quotes Third Party Model Valuation 

Second Bid - $600,000 

$ Thousands

Valuation Estimates for Warrant

($thousands) Low High Estimate Details

Market Quotes $251 $720 $424 Three market indications.

Third Party $686 $822 $753 Binomial option model adjusted for American style options

Model Valuation $505 $622 $563 Binomial option model adjusted for American style options

Appendix III – Warrant Disposition Details
Warrant 

State Street Corporation (STT) 

Repurchase of STT Warrant

On July 1, 2009, State Street Corporation (STT) agreed to pay $60 million for the warrant held by Treasury 

which entitled the holder of the warrant to purchase 2,788,104 shares of STT at a strike price of $53.80 per 

share. The warrant had an expiration date of October 28, 2018. 

$10,000 

$20,000 

$30,000 

$40,000 

$50,000 

$60,000 

$70,000 

$80,000 

Market Quotes Third Party Model Valuation 

State Street (STT) 

Fair Market Value Estimates of Treasury's Warrant Position 

Final Bid - $60,000,000

$ Thousands

Third Party 

Valuation Estimates for Warrant

($millions) Low High Estimate Details

Market Quotes $16 $48 $33 Seven market indications.

$46 $65 $55 Binomial option model adjusted for American style options

Model Valuation $52 $62 $57 Binomial option model adjusted for American style options

Appendix III – Warrant Disposition Details
30 Warra

U.S. Bancorp (USB

Repurchase of USB Warrant

On July 8, 2009, U.S. Bancorp (USB) agreed to pay $139 million for the warrant held by Treasury which entitled 

the holder of the warrant to purchase 32,679,102 shares of USB at a strike price of $30.29 per share. The warrant had an expiration date of November 14, 2018. 

$11,000

$31,000

$51,000

$71,000

$91,000

$111,000

$131,000

$151,000

$171,000

$191,000

US Bancorp (USB) 

Fair Market Value Estimates of Treasury's Warrant Position 

First Bid - $115,000,000

Final Bid - $139,000,000

Second Bid - $131,000,000

Market Quotes Third Party Model Valuation 

$ Thousands

Valuation Estimates for Warrant

($millions) Low High Estimate Details

Market Quotes $12 $175 $127 Six market indications.

$108 $183 $144 Binomial option model adjusted for American style options

Model Valuation $117 $164 $140 Binomial option model adjusted for American style options

Third Party 

Appendix III – Warrant Disposition Details
Warrant 

BB&T Corporation (BBT) 

Repurchase of BBT Warrant

On July 14, 2009, BB&T Corporation (BBT) agreed to pay $67 million for the warrant held by Treasury which 

entitled the holder of the warrant to purchase 13,902,573 shares of BBT at a strike price of $33.81 per share. 

The warrant had an expiration date of November 14, 2018. 

$18,000 

$28,000 

$38,000 

$48,000 

$58,000 

$68,000 

$78,000 

$88,000 

Market Quotes Third Party Model Valuation 

Final Bid - $67,010,402

Third Bid - $64,925,016

BB&T Corporation (BBT) 

Fair Market Value Estimates of Treasury's Warrant Position 

Second Bid - $41,707,719

First Bid - $20,853,860 

$ Thousands

Third Party 

Valuation Estimates for Warrant

($millions) Low High Estimate Details

Market Quotes $23 $58 $36 Five market indications.

$43 $82 $62 Binomial option model adjusted for American style options

Model Valuation $55 $78 $67 Binomial option model adjusted for American style options

Appendix III – Warrant Disposition Details
32 Warra

Goldman Sachs Group, Inc. (GS)

Repurchase of GS Warrant

On July 21, 2009, Goldman Sachs Group, Inc. (GS) agreed to pay $1.1 billion for the warrant held by Treasury 

which entitled the holder of the warrant to purchase 12,205,045 shares of GS at a strike price of $122.90 per 

share. The warrant had an expiration date of October 28, 2018. 

NOTE: At the time of the decision, the common share price of GS was $159.80 compared to the 20-day average price of $148.16. 

This difference was taken under consideration in Treasury’s analysis of the company’s determination of fair market value.

$550,000

$650,000

$750,000

$850,000

$950,000

$1,050,000

$1,150,000

Goldman Sachs (GS) 

Fair Market Value Estimates of Treasury's Warrant Position

First Bid - $600,000,000

$ Thousands

!T,T##,###,###"

Second Bid - $900,000,000

Market Quotes Third Party Model Valuation 

Final Bid - $1,100,000,000

Valuation Estimates for Warrant

($millions) Low High Estimate Details

Market Quotes $732 $917 $826 Seven market indications.

$899 $1,058 $993 Binomial option model adjusted for American style options

Model Valuation $808 $995 $902 Binomial option model adjusted for American style options

Third Party 

Appendix III – Warrant Disposition Details
Warrant 

American Express Company (AXP)

Repurchase of AXP Warrant

On July 27, 2009, American Express Company (AXP) agreed to pay $340 million for the warrant held by 

Treasury which entitled the holder of the warrant to purchase 24,264,129 shares of AXP at a strike price of 

$20.95 per share. The warrant had an expiration date of January 9, 2019. 

NOTE: At the time of the decision, the common share price of AXP was $28.32 compared to the 20-day average price of $25.71. 

This difference was taken under consideration in Treasury’s analysis of the company’s determination of fair market value.

Market Quotes Third Party Model Valuation 

American Express (AXP)

Fair Market Value Estimates of Treasury's Warrant Position

$150,000

$200,000

$250,000

$300,000

$350,000

$400,000

$450,000

Final Bid - $340,000,000

 First Bid - $230,000,000 

Second Bid - $260,000,000 

$ Thousands

Valuation Estimates for Warrant

($millions) Low High Estimate Details

Market Quotes $175 $298 $219 Six market indications.

$269 $349 $309 Binomial option model adjusted for American style options

Model Valuation $248 $322 $285 Binomial option model adjusted for American style options

Third Party 

Appendix III – Warrant Disposition Details
34 Warra

Bank of New York Mellon Corporation (BK)

Repurchase of BK Warrant

On July 31, 2009, Bank of New York Mellon Corporation (BK) agreed to pay $136 million for the warrant held 

by Treasury which entitled the holder of the warrant to purchase 14,516,129 shares of BK at a strike price of 

$31.00 per share. The warrant had an expiration date of October 28, 2018. 

$45,000 

$85,000 

$105,000 

$125,000 

$145,000 

$165,000 

Market Quotes Third Party Model Valuation 

First Bid - $79,000,000

Final Bid - $136,000,000

Bank of New York Mellon (BK) 

Fair Market Value Estimates of Treasury's Warrant Position 

Third Bid - $130,000,000

$65,000 

$ Thousands

Second Bid - $118,000,000

Valuation Estimates for Warrant

($millions) Low High Estimate Details

Market Quotes $55 $137 $94 Seven market indications.

$108 $164 $136 Binomial option model adjusted for American style options

Model Valuation $110 $162 $135 Binomial option model adjusted for American style options

Third Party 

Appendix III – Warrant Disposition Details
Warrant 

Morgan Stanley (MS)

Repurchase of MS Warrant

On August 5, 2009, Morgan Stanley (MS) agreed to pay $950 million for the warrant held by Treasury which 

entitled the holder of the warrant to purchase 65,245,759 shares of MS at a strike price of $22.99 per share. The 

warrant had an expiration date of October 28, 2018. 

NOTE: At the time of the decision, the common share price of MS was $31.05 compared to the 20-day average price of $28.16. 

This difference was taken under consideration in Treasury’s analysis of the company’s determination of fair market value.

$400,000 

$500,000 

$600,000 

$700,000 

$800,000 

$900,000 

$1,000,000 

$1,100,000 

Market Quotes Third Party Model Valuation 

Morgan Stanley (MS) 

Fair Market Value Estimates of Treasury's Warrant Position 

Third Bid - $900,000,000

Final Bid - $950,000,000

First Bid - $500,000,000 

Second Bid - $800,000,000

$ Thousands

Valuation Estimates for Warrant

($millions) Low High Estimate Details

Market Quotes $495 $944 $731 Seven market indications.

$806 $1,002 $900 Binomial option model adjusted for American style options

Model Valuation $750 $962 $855 Binomial option model adjusted for American style options

Third Party 

Appendix III – Warrant Disposition Details
36 Warra

Northern Trust Corporation (NTRS) 

Repurchase of NTRS Warrant

On August 19, 2009, Northern Trust Corporation (NTRS) agreed to pay $87 million for the warrant held by 

Treasury which entitled the holder of the warrant to purchase 3,824,624 shares of NTRS at a strike price of 

$61.81 per share. The warrant had an expiration date of November 14, 2018. 

Third Party 

Valuation Estimates for Warrant

($millions) Low High Estimate Details

Market Quotes $54 $80 $69 Six market indications.

$71 $101 $86 Binomial option model adjusted for American style options

Model Valuation $71 $97 $84 Binomial option model adjusted for American style options

$30,000 

$40,000 

$50,000 

$60,000 

$70,000 

$80,000 

$90,000 

$100,000 

$110,000 

$120,000 

Northern Trust (NTRS) 

Fair Market Value Estimates of Treasury's Warrant Position 

First Bid - $37,000,000 

Final Bid - $87,000,000

Second Bid - $75,000,000

Market Quotes Third Party Model Valuation 

$ Thousands

Appendix III – Warrant Disposition Details
Warrant 

Old Line Bancshares, Inc. (OLBK

Repurchase of OLBK Warrant

On August 20, 2009, Old Line Bancshares, Inc. (OLBK) agreed to pay $225,000 for the warrants held by 

Treasury which entitled the holder of the warrant to purchase 141,892 shares of OLBK at a strike price of $7.40 

per share. The warrant had an expiration date of December 5, 2018. 

Third Party 

Valuation Estimates for Warrant

($thousands) Low High Estimate Details

Market Quotes $28 $167 $102 Four market indications.

$201 $308 $254 Binomial option model adjusted for American style options

Model Valuation $172 $257 $214 Binomial option model adjusted for American style options

$10 

$60 

$110 

$160 

$210 

$260 

$310 

$360 

Old Line Bancshares (OLBK) 

Second Bid - $205,000

Market Quotes Third Party Model Valuation 

Fair Market Value Estimates of Treasury's Warrant Position 

Final Bid - $225,000

First Bid - $175,000 

$ Thousands

Appendix III – Warrant Disposition Details
38 Warra

Bancorp Rhode Island, Inc. (BARI)

Repurchase of BARI Warrant

On September 21, 2009, Bancorp Rhode Island, Inc. (BARI) agreed to pay $1.4 million for the warrant held by 

Treasury which entitled the holder of the warrant to purchase 192,967 shares of BARI at a strike price of $23.32 

per share. The warrant had an expiration date of December 19, 2018. 

$600

$800

$1,000

$1,200

$1,400

$1,600

$1,800

Market Quotes Third Party Model Valuation 

Bancorp Rhode Island (BARI)

Fair Market Value Estimates of Treasury's Warrant Position

Final Bid - $1,400,000

Second - $1,125,000

First Bid - $856,773

$ Thousands

Third Party 

Valuation Estimates for Warrant

($thousands) Low High Estimate Details

Market Quotes $703 $1,427 $1,166 Three market indications.

$1,196 $1,760 $1,476 Binomial option model adjusted for American style options

Model Valuation $1,200 $1,643 $1,423 Binomial option model adjusted for American style options

Appendix III – Warrant Disposition Details
Warrant 

Manhattan Bancorp (MNHN) 

Repurchase of MNHN Warrant

On October 9, 2009, Manhattan Bancorp (MNHN) agreed to pay $63,363.90 for the warrant held by Treasury 

which entitled the holder of the warrant to purchase 29,480 shares of MNHN at a strike price of $8.65 per share. 

The warrant had an expiration date of December 5, 2018. 

Third Party 

Valuation Estimates for Warrant

($thousands) Low High Estimate Details

Market Quotes $10 $57 $34 Two market indications.

$45 $54 $50 Binomial option model adjusted for American style options

Model Valuation $48 $64 $56 Binomial option model adjusted for American style options

$8 

$18 

$28 

$38 

$48 

$58 

$68 

$78 

Market Quotes Third Party Model Valuation 

Manhattan Bancorp (MNHN) 

Fair Market Value Estimates of Treasury's Warrant Position 

Final Bid - $63,363.90

$ Thousands

Appendix III – Warrant Disposition Details
40 Warra

CenterState Banks, Inc. (CSFL)

Repurchase of CSFL Warrant

On October 20, 2009, CenterState Banks, Inc. (CSFL) agreed to pay $212,000 for the warrants held by Treasury 

which entitled the holder of the warrant to purchase 125,413 shares of CSFL at a strike price of $16.67 per share. 

The warrant had an expiration date of November 21, 2018. 

$90

$140

$190

$240

$290

CenterState Banks, Inc. (CSFL) 

Fair Market Value Estimates of Treasury's Warrant Position 

First Bidnts - $168,053 

Final Bid - $212,000 

Market Quotes Third Party Model Valuation 

$ Thousands

Third Party 

Valuation Estimates for Warrant

($thousands) Low High Estimate Details

Market Quotes $94 $143 $125 Three market indications.

$159 $268 $236 Binomial option model adjusted for American style options

Model Valuation $153 $269 $206 Binomial option model adjusted for American style options

Appendix III – Warrant Disposition Details
Warrant 

CVB Financial Corp. (CVBF)

Repurchase of CVBF Warrant

On October 21, 2009, CVB Financial Corp. (CVBF) agreed to pay $1.307 million for the warrant held by 

Treasury which entitled the holder of the warrant to purchase 834,761 shares of CVBF at a strike price of $11.68 

per share. The warrant had an expiration date of December 5, 2018. 

$400 

$600 

$800 

$1,000 

$1,200 

$1,400 

$1,600 

$1,800 

CVB Financial (CVBF) 

Fair Market Value Estimates of Treasury's Warrant Position 

Market Quotes Third Party Model Valuation 

First Bid - $1,002,000 

Final Bid - $1,307,000 

$ Thousands

Third Party 

Valuation Estimates for Warrant

($thousands) Low High Estimate Details

Market Quotes $551 $1,135 $917 Three market indications.

$785 $1,436 $1,110 Binomial option model adjusted for American style options

Model Valuation $993 $1,711 $1,349 Binomial option model adjusted for American style options

Appendix III – Warrant Disposition Details
42 Warra

Bank of the Ozarks, Inc. (OZRK)

Repurchase of OZRK Warrant

On November 18, 2009, Bank of the Ozarks, Inc. (OZRK) agreed to pay $2.65 million for the warrant held by 

Treasury which entitled the holder of the warrant to purchase 379,811 shares of OZRK at a strike price of $29.62 

per share. The warrant had an expiration date of December 12, 2018. 

$1,000 

$1,500 

$2,000 

$2,500 

$3,000 

$3,500 

Bank of the Ozarks (OZRK) 

Fair Market Value Estimates of US Treasury's Warrant Position 

Market Quotes Third Party Model Valuation 

First Bid - $2,160,743 

Final Bid - $2,650,000 

$ Thousands

Third Party 

Valuation Estimates for Warrant

($thousands) Low High Estimate Details

Market Quotes $1,230 $3,240 $2,210 Three market indications.

$1,880 $3,110 $2,480 Binomial option model adjusted for American style options

Model Valuation $1,917 $3,095 $2,509 Binomial option model adjusted for American style options

Appendix III – Warrant Disposition Details
Warrant 

LSB Corporation (LSBX) 

Repurchase of LSBX Warrant

On December 8, 2009, LSB Corporation (LSBX) agreed to pay $560,000 for the warrant held by Treasury which 

entitled the holder of the warrant to purchase 209,497 shares of LSBX at a strike price of $10.74 per share. The 

warrant had an expiration date of December 12, 2018. 

Valuation Estimates for Warrant

($thousands) Low High Estimate Details

Market Quotes $157 $883 $446 Four market indications.

Third Party $486 $773 $605 Binomial option model adjusted for American style options

Model Valuation $459 $681 $569 Binomial option model adjusted for American style options

$100 

$200 

$300 

$400 

$500 

$600 

$700 

$800 

$900 

$1,000 

Market Quotes Third Party Model Valuation 

LSB Corporation (LSBX) 

Fair Market Value Estimates of Treasury's Warrant Position 

Final Bid - $560,000

First Bid - $500,000 

$ Thousands

Appendix III – Warrant Disposition Details
44 Warra

Wainwright Bank and Trust Company (WAIN) 

Repurchase of WAIN Warrant

On December 11, 2009, Wainwright Bank and Trust Company (WAIN) agreed to pay $568,700 for the warrants 

held by Treasury, which entitled the holder of the warrant to purchase 390,071 shares of WAIN at a strike price of 

$8.46 per share. The warrant had an expiration date of December 19, 2018. 

Valuation Estimates for Warrant

($thousands) Low High Estimate Details

Market Quotes $289 $780 $532 Three market indications.

Third Party $491 $776 $632 Binomial option model adjusted for American style options

Model Valuation $449 $632 $541 Binomial option model adjusted for American style options

$200 

$300 

$400 

$500 

$600 

$700 

$800 

Market Quotes Third Party Model Valuation 

Wainwright Bank and Trust (WAIN) 

Fair Market Value Estimates of Treasury's Warrant Position 

Final Bid - $568,700

$ Thousands

Appendix III – Warrant Disposition Details
Warrant 

WesBanco, Inc. (WSBC)

Repurchase of WSBC Warrant

On December 11, 2009, WesBanco, Inc. (WSBC) agreed to pay $950,000 for the warrant held by Treasury 

which entitled the holder of the warrant to purchase 439,282 shares of WSBC at a strike price of $25.61 per 

share. The warrant had an expiration date of December 5, 2018. 

$0 

$200 

$400 

$600 

$800 

$1,000 

$1,200 

$1,400 

Market Quotes Third Party Model Valuation 

WesBanco, Inc. (WSBC)

Fair Market Value Estimates of Treasury's Warrant Position

Final Bid - $950,000

First Bid - $825,000 

$ Thousands

Valuation Estimates for Warrant

($thousands) Low High Estimate Details

Market Quotes $132 $1,204 $577 Four market indications.

Third Party $371 $955 $643 Binomial option model adjusted for American style options

Model Valuation $585 $1,119 $851 Binomial option model adjusted for American style options

Appendix III – Warrant Disposition Details
46 Warra

Union Bankshares Corporation (UBSH) 

Repurchase of UBSH Warrant

On December 16, 2009, Union Bankshares Corporation (UBSH) agreed to pay $450,000 for the warrant held 

by Treasury which entitled the holder of the warrant to purchase 211,318 shares of UBSH at a strike price of 

$20.94 per share. The warrant had an expiration date of December 19, 2018. 

$100 

$200 

$300 

$400 

$500 

$600 

$700 

$800 

Market Quotes Third Party Model Valuation 

Union Bankshares (UBSH) 

Fair Market Value Estimates of Treasury's Warrant Position 

First Bid - $400,000 

Final Bid - $450,000

$ Thousands

Four market indications.

Third Party 

Valuation Estimates for Warrant

($thousands) Low High Estimate Details

Market Quotes $188 $687 $448

$267 $595 $424 Binomial option model adjusted for American style options

Model Valuation $279 $564 $410 Binomial option model adjusted for American style options

Appendix III – Warrant Disposition Details 
Warrant 

Flushing Financial Corporation (FFIC) 

Repurchase of FFIC Warrant

On December 28, 2009, Flushing Financial Corporation (FFIC) agreed to pay $900,000 for the warrant held by 

Treasury which entitled the holder of the warrant to purchase 375,806 shares of FFIC at a strike price of $13.97 

per share. The warrant had an expiration date of December 19, 2018. 

$400 

$600 

$800 

$1,000 

$1,200 

$1,400 

Market Quotes Third Party Model Valuation 

Flushing Financial (FFIC) 

Fair Market Value Estimates of Treasury's Warrant Position 

Second Bid - $700,000

Third Bid - $860,000

Final Bid - $900,000 

$ Thousands

First Bid - $597,000 

Third Party 

Valuation Estimates for Warrant

($thousands) Low High Estimate Details

Market Quotes $459 $1,240 $742 Three market indications.

$883 $1,131 $1,007 Binomial option model adjusted for American style options

Model Valuation $623 $1,090 $850 Binomial option model adjusted for American style options

Appendix III – Warrant Disposition Details
48 Warra

Trustmark Corporation (TRMK) 

Repurchase of TRMK Warrant

On December 29, 2009, Trustmark Corporation (TRMK) agreed to pay $10,000,000 for the warrant held by 

Treasury which entitled the holder of the warrant to purchase 1,647,931 shares of TRMK at a strike price of 

$19.57 per share. The warrant had an expiration date of November 21, 2018. 

$4,000 

$5,000 

$6,000 

$7,000 

$8,000 

$9,000 

$10,000 

$11,000 

$12,000 

Market Quotes Third Party Model Valuation 

Trustmark Corporation (TRMK) 

Fair Market Value Estimates of Treasury's Warrant Position 

First Bid - $8,167,000 

Second Bid - $9,200,000 

Third Bid - $9,600,000 

Final Bid - $10,000,000 

$ Thousands

Four market indications.

Third Party 

Valuation Estimates for Warrant

($thousands) Low High Estimate Details

Market Quotes $4,120 $10,547 $7,601

$7,103 $10,942 $9,014 Binomial option model adjusted for American style options

Model Valuation $7,876 $11,551 $9,704 Binomial option model adjusted for American style options

Appendix III – Warrant Disposition Details
Warrant 

Capital One Financial Corp. (COF)

Sale of COF Warrant

On December 3, 2009, Treasury auctioned the Capital One Financial Corp. (COF) warrant for $149 million in 

gross proceeds. The warrant entitled the holder to purchase 12,657,960 shares of COF at a strike price of $42.13 

per share and expired on November 14, 2018. 

NOTE: Above analysis was done to evaluate COF’s bid on 6/30/09 and is not directly comparable to the auction results on 12/3/09 

as market conditions changed over the intervening five months. In particular, COF’s stock price appreciated 69% while short-term 

implied volatility in the stock declined slightly. See charts in Appendix IV.

$0 

$20,000 

$40,000 

$60,000 

$80,000 

$100,000 

$120,000 

$140,000 

$160,000 

Market Quotes Third Party Model Valuation 

Bid - $46,500,000 

 Capital One Financial (COF) 

Fair Market Value Estimates of Treasury's Warrant Position 

$ Thousands

Valuation Estimates for Warrant

($millions) Low High Estimate Details

Market Quotes $2 $70 $30 Seven market indications.

Third Party $107 $148 $124 Binomial option model adjusted for American style options

Model Valuation $86 $131 $108 Binomial option model adjusted for American style options

Appendix III – Warrant Disposition Details
50 Warra

JP Morgan Chase & Co. (JPM)

Sale of JPM Warrant

On December 10, 2009, Treasury auctioned the JPMorgan Chase & Co. (JPM) for $950 million in gross proceeds. The warrant entitled the holder to purchase 88,401,697 shares of JPM at a strike price of $42.42 per share 

and expired on October 28, 2018. 

NOTE: Above analysis was done to evaluate JPM’s bid on 6/17/09 and is not directly comparable to the auction results on 

12/10/09 as market conditions changed over the intervening six months. In particular, JPM’s stock price appreciated 26% while 

short-term implied volatility in the stock declined more than 25%. See charts in Appendix IV.

$400,000 

$500,000 

$600,000 

$700,000 

$800,000 

$900,000 

$1,000,000 

$1,100,000 

$1,200,000 

$1,300,000 

$1,400,000 

Market Quotes Third Party Model Valuation 

JPMorgan (JPM) 

Fair Market Value Estimates of Treasury's Warrant Position 

Bid - $825,539,247 

$ Thousands

Third Party 

Valuation Estimates for Warrant

($millions) Low High Estimate Details

Market Quotes $488 $1,137 $658 Seven market indications.

$875 $1,252 $1,063 Binomial option model adjusted for American style options

Model Valuation $900 $1,097 $998 Binomial option model adjusted for American style options

Appendix III – WCarrant Disposition Details
Warrant 

TCF Financial Corporation (TCB) 

Sale of TCB Warrant

On December 15, 2009, Treasury auctioned the TCF Financial Corporation (TCB) warrant for $9.6 million in 

gross proceeds. The warrant entitled the holder to purchase 3,199,988 shares of TCB at a strike price of $16.93 

per share and expired on November 14, 2018. 

NOTE: Above analysis was done to evaluate TCB’s bid on 5/5/09 and is not directly comparable to the auction results on 12/15/09 

as market conditions changed over the intervening seven months. In particular, TCB’s stock price declined 16% while short-term 

implied volatility in the stock declined more than 40%. See charts in Appendix IV.

$0 

$5,000 

$10,000 

$15,000 

$20,000 

$25,000 

Market Quotes Third Party Model Valuation 

TCF Financial (TCB) 

Fair Market Value Estimates of Treasury's Warrant Position 

Bid - $3,200,000 

$ Thousands

Third Party 

Valuation Estimates for Warrant

($millions) Low High Estimate Details

Market Quotes $12.1 $20.5 $15.9 Three market indications.

 $13.4 $19.1 $16.2 Binomial option model adjusted for American style options

Model Valuation $11.3 $17.2 $14.3 Binomial option model adjusted for American style options

Appendix III – Warrant Disposition Details
52 Warra

Appendix IV – Changes in Market Conditions 

from Issuer Bid to Auction

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Warrant 

Appendix V – Qualified Equity Offerings

Sufficient to Halve Warrants

Institution Name Ticker

CPP 

Investment 

Date

CPP 

Investment Size

($millions)

Repurchased 

Date of CPP 

Investment

CPP Investment 

Outstanding

($millions)

Warrant 

Exercise Price

Adjusted 

Number of 

Warrant Shares

State Street STT 10/28/08 2,000.0 6/17/09 -

East West Bancorp EWBC 12/5/08 306.5 N/A 306.5 15.15 1,517,555

PrivateBancorp, Inc. PVTB 1/30/09 243.8 N/A 243.8 28.35 645,013

SVB Financial Group SIVB 12/12/08 235.0 12/23/09 - 49.78 354,058

Umpqua Holdings Corp. UMPQ 11/14/08 214.2 N/A 214.2 14.46 1,110,898

MB Financial Inc. MBFI 12/5/08 196.0 N/A 196.0 29.05 506,024

First Niagara Financial Group FNFG 11/21/08 184.0 5/27/09 -

United Community Banks, Inc. UCBI 12/5/08 180.0 N/A 180.0 12.28 1,099,542

National Penn Bancshares, Inc. NPBC 12/12/08 150.0 N/A 150.0 15.30 735,294

Western Alliance Bancorporation WAL 11/21/08 140.0 N/A 140.0 13.34 787,107

CVB Financial Corp CVBF 12/5/08 130.0 9/2/09 -

F.N.B. Corporation FNB 1/9/09 100.0 9/9/09 - 11.52 651,042

First Busey Corporation BUSE 3/6/09 100.0 N/A 100.0 13.07 573,833

Pinnacle Financial Partners, Inc. PNFP 12/12/08 95.0 N/A 95.0 26.64 267,455

Iberiabank Corporation IBKC 12/5/08 90.0 3/31/09 -

First Financial Bancorp FFBC 12/23/08 80.0 N/A 80.0 12.90 465,117

Columbia Banking System Inc. COLB 11/21/08 76.9 N/A 76.9 14.49 398,023

Flushing Financial Corporation FFIC 12/19/08 70.0 10/28/09 -

Nara Bancorp, Inc. NARA 11/21/08 67.0 N/A 67.0 9.64 521,266

First Financial Holdings Inc. FFCH 12/5/08 65.0 N/A 65.0 20.17 241,696

Union Bankshares Corporation UBSH 12/19/08 59.0 11/18/09 -

Lakeland Financial Corporation LKFN 2/27/09 56.0 N/A 56.0 21.20 198,269

Center Financial Corporation CLFC 12/12/08 55.0 N/A 55.0 9.54 432,390

Home Bancshares, Inc. HOMB 1/16/09 50.0 N/A 50.0 26.03 144,065

Seacoast Banking Corporation of Florida SBCF 12/19/08 50.0 N/A 50.0 6.36 589,623

The Bancorp, Inc. TBBK 12/12/08 45.2 N/A 45.2 3.46 980,203

First Community Bancshares Inc. FCBC 11/21/08 41.5 7/8/09 - 35.26 88,273

OceanFirst Financial Corp. OCFC 1/16/09 38.3 12/30/09 - 15.07 190,427

Eagle Bancorp, Inc.* EGBN 12/5/08 38.2 12/23/09 23.2 7.44 385,434

Centerstate Banks of Florida Inc. CSFL 11/21/08 27.9 9/30/09 -

Washington Banking Company WBCO 1/16/09 26.4 N/A 26.4 8.04 246,082

Heritage Financial Corporation HFWA 11/21/08 24.0 N/A 24.0 13.04 138,037

Middleburg Financial Corporation MBRG 1/30/09 22.0 12/23/09 - 15.85 104,101

MidSouth Bancorp, Inc. MSL 1/9/09 20.0 N/A - 14.37 104,384

Bar Harbor Bankshares** BHB 1/16/09 18.8 N/A 18.8 26.81 52,455

Monarch Financial Holdings, Inc. MNRK 12/19/08 14.7 12/23/09 - 8.33 132,353

Center Bancorp, Inc. CNBC 1/9/09 10.0 N/A 10.0 8.65 86,705

Central Valley Community Bancorp CVCY 1/30/09 7.0 N/A 7.0 6.64 79,067

Total 38 5,327.4 2,280.1

WARRANT REPURCHASED

WARRANT REPURCHASED

WARRANT REPURCHASED

WARRANT REPURCHASED

WARRANT REPURCHASED

WARRANT REPURCHASED

WARRANT REPURCHASED

*Eagle Bancorp has partially redeemed the CPP preferred.

** Bar Harbor has not yet provided an official notice of its QEO for Treasury approval.

Appendix V – Qualified Equity Offerings Sufficient to Halve Warrants
www.FinancialStability.gov