Emergency Capital Investment Program

David Meyer

ECIP Operations Program Manager

Emergency Capital Investment Program

U.S. Department of the Treasury

Carol Rodrigues

Attorney-Adviser (Finance)

Office of the General Counsel 

U.S. Department of the Treasury

August 2022

1

Presenters
Topics

 Background 

 Quarterly Supplemental Report Timeline

 Report Structure and Overview

 Rate Reduction Calculation

 Submission of Comments

 Q&A 

2

Emergency Capital Investment Program
 Background 

 Quarterly Supplemental Report Timeline

 Report Structure and Overview

 Rate Reduction Calculation 

 Submission of Comments

 Q&A 

3

Emergency Capital Investment Program
• Emergency Capital Investment Program (ECIP) investments are in the form 

of preferred stock or subordinated debt.

• The relevant Securities Purchase Agreement requires participating 

institutions (Recipients or Participants) to submit a Quarterly Supplemental 

Report (QSR). 

• The QSR is used to:

• Calculate eligibility for rate reductions; and

• Collect data required for Treasury to assess and evaluate the program. 

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Emergency Capital Investment Program

Background
• Draft QSR has been published for notice and comment in the Federal 

Register. 

• Treasury is seeking comments on, among other things:

• The accuracy of Treasury’s estimate of the burden of the collection;

• Ways to enhance the quality, utility, and clarity of the information to be 

collected; and

• Specific questions included in the Federal Register notice, such as how 

frequently Treasury should update reference data. 

• Comment period closes Monday, August 29, 2022.

• Federal Register notice and QSR forms and instructions are on the ECIP 

webpage: ECIP Homepage Link.

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Emergency Capital Investment Program

Background
 Background 

 Quarterly Supplemental Report 

Timeline

 Report Structure and Overview

 Rate Reduction Calculation 

 Submission of Comments

 Q&A 

6

Emergency Capital Investment Program
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Emergency Capital Investment Program

Timeline

QSR Release Timeline 

June 30, 2022: Treasury 

posted proposed QSR 

forms and PRA Notice. 

August 29, 

2022: Deadline 

to submit 

comments. 

Starting in September 

2022: Treasury reviews 

comments and may make 

changes to forms and 

instructions based on 

comments.

Office of Management 

and Budget 30-day notice 

period.

Treasury finalizes 

forms and 

instructions.
• First QSR will not need to be submitted until after the reporting forms are 

effective, which will be after the comment period closes and an additional 

Office of Management and Budget 30-day comment period. 

• Treasury expects that quarterly supplemental reporting will not begin any 

earlier than January 2, 2023. 

• Treasury expects that once the QSR is effective, Participants will be required 

to submit data about their lending starting from the closing date. 

• Treasury advises Participants to be prepared to report on all data points in 

the proposed QSR from the closing date of the investment. 

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Emergency Capital Investment Program

Timeline
 Background 

 Quarterly Supplemental Report Timeline

 Report Structure and Overview

 Rate Reduction Calculation 

 Submission of Comments

 Q&A 

9

Emergency Capital Investment Program
• QSRs are generally due concurrent with submission of:

• Call Report, for Recipients that are insured depository institutions (IDIs);

• IDI Subsidiary’s Call Report, for Recipients that are holding companies filing on 

Form FR Y-9SP;

• Form FR Y-9C, for Recipients that are holding companies filing on Form FR Y-9C

• Call Report, for Recipients that are credit unions. 

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Emergency Capital Investment Program

Submission Deadline
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Emergency Capital Investment Program

QSR Report Structure

Schedule A – Summary 

Qualified Lending

Schedule B – Disaggregated 

Qualified Lending

Schedule C –

Additional 

Demographic Data

Schedule D –

Additional Placebased Data
• Treasury is proposing to require electronic submission of the QSR via the 

Salesforce-based portal already in use.

• Data input will be via excel .csv upload.

• Treasury will offer training and technical assistance.

• All reports need to be completed in accordance with instructions and 

certified as complete and accurate.

• Recipients are expected to collect all the data needed to complete all the 

schedules in the QSR accurately. 

• Use of proxy data to classify loans as Qualified or Deep Impact Lending is 

NOT permitted. 

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Emergency Capital Investment Program

General
• Schedule A–Summary Qualified Lending is used to collect the Qualified 

Lending and Deep Impact Lending of the Participant for the reporting period. 

• Used to establish the growth in a Participant’s Qualified Lending over its 

baseline Qualified Lending for the purposes of calculating the payment rate 

on the ECIP instruments. 

• Similar to Schedule A of Initial Supplemental Report.

• Report Total Originations, Qualified Lending and Deep Impact Lending at the 

summary level without double counting loans. 

• Report both the number of loans and the dollar value. 

• Schedule A would be due quarterly. 

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Emergency Capital Investment Program

Schedule A
Schedule A – Credit Unions

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Emergency Capital Investment Program

Schedule A

1 Non-commercial loans / lines of credit 1A 23 1B $ 5,780,152.00 1C 10 1D $ 20,000,000.00 1E 10 1F $ 10,000,000.00

2 Commercial loans / lines of credit 2A 0 2B $ - 2C 0 2D $ - 2E 0 2F $ -

3 Total 3A 23 3B $ 5,780,152.00 3C 10 3D $ 20,000,000.00 3E 10 3F $ 10,000,000.00

Quarterly Supplemental Report (QSR) 

Schedule A - Summary Qualified Lending

Data Upload*

ID Lending Activity Categories

Total Originations Qualified Lending Originations** 

(Column A)

# of Originations

(Column B)

$ of Originations

(Column C)

# of Originations

(Column D)

$ of Originations

Deep Impact Lending Originations

(Column E)

# of Originations

(Column F)

$ of Originations

Sum of Data Uploaded
Schedule A – Holding Companies and IDIs

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Emergency Capital Investment Program

Schedule A
Schedule A – Qualified and Deep Impact Lending Summary

• Summary data calculated based on data in the system and data uploaded. 

• Rate reduction calculations described further in next section of slides.

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Emergency Capital Investment Program

Schedule A

13A $ 100,000,000

13B $ 40,000,000

Qualified Lending Deep Impact Lending

$ 20,000,000 $ 2,000,000

$ 50,000,000 $ 5,000,000

$ 10,000,000 $ 1,000,000

$ 70,000,000 $ 7,000,000

$ 150,000,000 $ 15,000,000

13D $ 180,000,000.00

13E $ 80,000,000.00

13F 200%

14B

Recipient Certification

14A I, the undersigned CEO or CFO (or equivalents) of the Recipient, attest that this Quarterly Supplemental Report Schedule A has been prepared in conformance with the instructions issued by Treasury and is true and 

correct to the best of my knowledge and belief.

Enter the title of the person certifying this report.

Year X Qualified Lending Summary

Baseline Qualified Lending

Initial Investment Amount

13C Qualified Lending Reported by Year X Quarter

Quarter 1

Quarter 2

Difference between Qualified Lending in Year X and Baseline Qualified Lending as a % of Initial Investment by Treasury (13E ÷ 13B)

Quarter 3

Quarter 4

Subtotal

Qualified Lending in Year X ([Sum of Qualified Lending] + [2 * Sum of Deep Impact Lending] in Year X)

Difference between Qualified Lending in Year X and Baseline Qualified Lending (13D - 13A)
• Schedule B–Disaggregated Qualified Lending is used to present further 

detail on the composition of the Participant’s Qualified and Deep Impact 

Lending. 

• Similar to Schedule B of Initial Supplemental Report, but Schedule B for the 

QSR must be certified as true, complete, and accurate. 

• Double-counting of loans across categories is expected.

• Example: A loan to a Low-income Borrower in a Persistent Poverty 

County must be reported in both the Low-income Borrower and Persistent 

Poverty County columns. 

• Schedule B would be due quarterly. 

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Emergency Capital Investment Program

Schedule B
Schedule B – example fields

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Emergency Capital Investment Program

Schedule B
• Schedule C–Additional Demographic Data on Qualified Lending collects additional 

demographic data on certain categories of Qualified Lending and Deep Impact 

Lending:

• Schedule C1–People is used for loans to:

• LMI Borrowers, disaggregated by income category;

• Other Targeted Populations, disaggregated by race or ethnicity; and

• Mortgage lending to Other Targeted Populations, disaggregated by race or 

ethnicity.

• Schedule C2–Businesses is used for loans to Underserved Small Businesses, 

disaggregated by business size, owner income, or owner race and ethnicity.

• Schedule C is proposed to be due annually, concurrently with quarterly data for 

quarter ending December 31 of each year. 

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Emergency Capital Investment Program

Schedule C
Schedule C1–People – example fields 

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Emergency Capital Investment Program

Schedule C
Schedule C2–Businesses – example fields 

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Emergency Capital Investment Program

Schedule C
• Schedule D–Additional Place-based Data on Qualified Lending collects 

additional geographic data on certain categories of Qualified Lending and 

Deep Impact Lending.

• Report the counties, census tracts, or other geographic area the lending or 

investment was made to and the total number and dollar value of originations 

to each geographic area.

• Eight sub-schedules, in list form – one for each place-based Target 

Community and one for borrowers or projects that create direct benefits for 

LMI communities or to Other Targeted Populations.

• Schedule D is proposed to be due annually, concurrently with quarterly data 

for quarter ending December 31 of each year. 

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Emergency Capital Investment Program

Schedule D
Schedule D – example 

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Emergency Capital Investment Program

Schedule D
• For borrowers or projects that create direct benefits for LMI communities or to 

Other Targeted Populations, report each county the lending or investment 

was made to and the total number and dollar value of originations to each 

county on Schedule D8.

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Emergency Capital Investment Program

Schedule D
• If the Participant completes a merger, acquisition, or other business combination 

with another institution after the date of closing of the ECIP investment, include the 

lending of the acquired institution in the Participant’s QSR beginning with the first full 

quarter after the merger, acquisition or other business combination is completed.

• Participant’s Baseline will also be adjusted by adding in the Baseline Qualified 

Lending for the acquired institution, which will be calculated based on the Initial 

Supplemental Report submitted by the acquired institution:

• If the acquired institution is also an ECIP participant, the Initial Supplemental 

Report that was submitted by the acquired ECIP participant will be used.

• If the acquired institution is not an ECIP participant, the Participant must submit 

an Initial Supplemental Report for the acquired institution covering the annual 

period ending on the last day of the last completed quarter before the merger, 

acquisition or other business combination was completed.

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Emergency Capital Investment Program

M&A
• Lending Activity includes purchases of or participations in loans during the reporting 

period made by non-depository CDFI loan funds that were originated within one year of 

purchase by the Participant . 

• Only eligible to qualify as Qualified Lending or Deep Impact Lending if the underlying loan 

is made to a Target Community listed in the table. 

• Include as Deep Impact Lending purchases of or participations in loans during the 

reporting period made by non-profit non-depository CDFI loan funds that were originated 

within one year of purchase by the institution AND that were made to a Target Community 

listed under Deep Impact Lending in the table (e.g., Persistent Poverty Counties).

• Purchases of or participations in loans during the reporting period made by for-profit nondepository CDFI loan funds may only be included as Qualified Lending and not Deep 

Impact Lending even if they were made to a Target Community listed under Deep Impact 

Lending in the table.

26

Emergency Capital Investment Program

CDFI Loan Funds
 Background 

 Quarterly Supplemental Report Timeline

 Report Structure and Overview

 Rate Reduction Calculation

 Submission of Comments

 Q&A 

27

Emergency Capital Investment Program
Payment Dates

• Payments are due on fixed dates – March 15, June 15, September 15, December 15

First Two Years

• No interest or dividends accrue for the first two years (24 months after the Closing 

Date) and no payments are due. 

Years Three to Ten 

• Starting in year three after the Closing Date, Participants will make dividend or 

interest payments to Treasury on a quarterly basis. 

• First payment will be due on the first Payment Date after the second anniversary of 

the Closing Date. Examples:

• Closing Date of 5/24/2022. First payment due on 6/15/2024, which will be a stub 

payment for period from 5/24/2024 to 6/14/2024.

• Closing Date of 6/21/2022. First payment due on 9/15/2024, which will be a stub 

payment for period from 6/21/2024 to 9/14/2024.

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Emergency Capital Investment Program

Payment Due Dates
Years Three to Ten 

• Rate adjusted annually based on increase in Qualified Lending and 

Deep Impact Lending in the preceding year compared to the Baseline 

Qualified Lending reported in the Initial Supplemental Report (ISR) as 

a percentage of the ECIP investment in the Participant.

• The QSR measures loan originations, not loan balances. The payment 

rate is therefore calculated based on the increase in loan originations 

and not increases in the balance sheet. 

• QSR used to calculate the first payment rate is the QSR for the most 

recently completed calendar quarter for which the due date has 

occurred as of the second anniversary of the Closing Date. For 

Participants that closed between May 1, 2022 and June 30, 2022, this 

will be the QSR dated 3/31/2024. 

• For these Participants, the lending used to calculate the payment 

rate for year three will be from 4/1/2023 to 3/31/2024. 

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Emergency Capital Investment Program

Payment Rate Calculation
Years Three to Ten 

• Participant receives a $40 million investment from Treasury on May 24, 2022.

• Baseline Qualified Lending = $100 million. 

• In its QSRs for year 2 (QSRs dated 6/30/2023, 9/30/2023, 12/31/2023, and 

3/31/2024), reported a total of $150 million in Qualified Lending (not including Deep 

Impact Lending) and an additional $15 million in Deep Impact Lending. 

• Annual Qualified Lending in Year 2 = Qualified Lending + 2 * Deep Impact Lending = 

$150 million + (2 * $15 million) = $180 million

• % change in Qualified Lending = ((Annual Qualified Lending in Year 2 – Baseline 

Qualified Lending)/ Investment Amount)*100 = (($180 million – $100 million)/$40 

million)*100 = 200%

• As per the ECIP legal agreements, a 200% increase in Qualified Lending would 

correspond with a payment rate of 1.25%

• Rate of 1.25% would be for the period from 5/24/2024 to 6/14/2025. 

• Next rate reset would be on 6/15/2025. 

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Emergency Capital Investment Program

Rate Reduction Example
Years 11+

• Rate is fixed based on average annual increase in Qualified Lending and Deep 

Impact Lending over the preceding nine years compared to the Baseline Qualified 

Lending as a percentage of the ECIP investment in the Participant.

• Example: $40 million investment from Treasury 

• Baseline Qualified Lending = $100 million, which was not adjusted in the first ten 

years due to a merger or other business combination. 

• Participant reports the following (Qualified Lending does not include Deep Impact 

Lending):

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Emergency Capital Investment Program

Fixed Rate Reduction

Reported Years Baseline Qualified Lending Deep Impact Lending

Year 2 $ 100,000,000 $ 150,000,000 $ 15,000,000 

Year 3 $ 100,000,000 $ 200,000,000 $ 20,000,000 

Year 4 $ 100,000,000 $ 240,000,000 $ 28,000,000 

Year 5 $ 100,000,000 $ 320,000,000 $ 28,000,000 

Year 6 $ 100,000,000 $ 360,000,000 $ 28,000,000 

Year 7 $ 100,000,000 $ 320,000,000 $ 28,000,000 

Year 8 $ 100,000,000 $ 320,000,000 $ 28,000,000 

Year 9 $ 100,000,000 $ 320,000,000 $ 28,000,000 

Year 10 $ 100,000,000 $ 320,000,000 $ 28,000,000 

Subtotal $ 900,000,000 $ 2,550,000,000 $ 231,000,000 
Years 11+ 

• Aggregate Annual Qualified Lending in years 2 through 10 = Aggregate Qualified 

Lending + 2 * Deep Impact Lending = $2,550 million + (2 * $231 million) = $3,012 

million 

• Aggregate Baseline = $900 million

• Aggregate Increase in Qualified Lending = Aggregate Annual Qualified Lending -

Aggregate Baseline = $3,012 million - $900 million = $2,112 million

• Average Annual Increase in Qualified Lending = Aggregate Increase in Qualified 

Lending / 9 = $2,112 million / 9 = $234.667 million

• % Change in Qualified Lending = (Average Annual Increase in Qualified Lending/ 

Investment Amount)*100 = ($234.667 million/ $40 million)*100 = 587%

• As per the ECIP legal agreements, a 587% increase in Qualified Lending would 

correspond with an annual payment rate of 0.5% for each quarter from the first 

payment date after the tenth anniversary of the Closing Date until the instruments are 

redeemed or mature. 

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Emergency Capital Investment Program

Fixed Rate Reduction
Years 11+

• Aggregate Increase in Qualified Lending = Sum of annual increase in 

Qualified Lending over the Baseline for years 2 through 10 = $2,112 million

• Average Annual Increase in Qualified Lending = Aggregate Increase in 

Qualified Lending / 9 = $2,112 million / 9 = $234.667 million

• % Change in Qualified Lending = (Average Annual Increase in Qualified 

Lending/ Investment Amount)*100 = ($234.667 million/ $40 million)*100 = 

587%

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Emergency Capital Investment Program

Alternate Calculation

Reported Years Baseline Qualified Lending Deep Impact Lending Annual Qualified Lending Increase over Baseline

Year 2 $ 100,000,000 $ 150,000,000 $ 15,000,000 $ 180,000,000 $ 80,000,000 

Year 3 $ 100,000,000 $ 200,000,000 $ 20,000,000 $ 240,000,000 $ 140,000,000 

Year 4 $ 100,000,000 $ 240,000,000 $ 28,000,000 $ 296,000,000 $ 196,000,000 

Year 5 $ 100,000,000 $ 320,000,000 $ 28,000,000 $ 376,000,000 $ 276,000,000 

Year 6 $ 100,000,000 $ 360,000,000 $ 28,000,000 $ 416,000,000 $ 316,000,000 

Year 7 $ 100,000,000 $ 320,000,000 $ 28,000,000 $ 376,000,000 $ 276,000,000 

Year 8 $ 100,000,000 $ 320,000,000 $ 28,000,000 $ 376,000,000 $ 276,000,000 

Year 9 $ 100,000,000 $ 320,000,000 $ 28,000,000 $ 376,000,000 $ 276,000,000 

Year 10 $ 100,000,000 $ 320,000,000 $ 28,000,000 $ 376,000,000 $ 276,000,000 

Subtotal $ 900,000,000 $ 2,550,000,000 $ 231,000,000 $ 3,012,000,000 $ 2,112,000,000 
 Background 

 Quarterly Supplemental Report Timeline

 Report Structure and Overview

 Rate Reduction Calculation 

 Submission of Comments

 Q&A 

34

Emergency Capital Investment Program
• Treasury is collecting comments through August 29, 2022.

• Comments on QSR forms and instructions, including:

• Proposals for alternative data points or methods; and 

• Burden estimate.

• All comments welcome.

• Specific questions in the Federal Register notice:

• Periodic updates to reference datasets & transition time if datasets are 

updated.

• Other sources of the same data that is already reported to the federal 

government. 

• Additional data points that Treasury should collect.

• Additional resources and clarifications to forms and instructions.

• Comments will become public. 

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Emergency Capital Investment Program

Public Comment Process
• To submit comments:

• Go to the Federal E-rulemaking Portal: http:// www.regulations.gov. 

• Follow the instructions for submitting comments. 

• Refer to Docket Number TREAS–DO– 2022–0013 and the specific 

Office of Management and Budget (OMB) control number 1505–0275. 

• Sending a copy of the comment to ecip@treasury.gov is appreciated but 

not required.

• Comments submitted to the ECIP mailbox may also become public. 

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Emergency Capital Investment Program

Public Comment Process
 Background 

 Quarterly Supplemental Report Timeline

 Report Structure and Overview

 Rate Reduction Calculation 

 Submission of Comments

 Q&A 

37

Emergency Capital Investment Program