On January 12, 2009, in an effort to hold state nonmember banking institutions more accountable for their participation in the Troubled Assets Relief Program (TARP) Capital Purchase Program (CPP), the Federal Deposit Insurance Corporation (FDIC) issued a Financial Institution Letter (FIL-1-2009) recommending that its supervised institutions implement a process to monitor and document the use of their CPP funds.

In this podcast with Pepper partner Dan Murray and Pepper associate Bill Quirk, they discuss the rationale for this new monitoring and disclosure and why some banks and financial institutions are rethinking accepting TARP CPP funds.