On February 2, 2022, the U.S. Department of the Treasury ("Treasury")
released drafts of the definitive transaction documentation with respect to the
capital securities issuable by Community Development Financial Institutions ("CDFIs")
and Minority Depository Institutions ("MDIs") who have received
allocations under the Emergency Capital Investment Program ("ECIP"). These capital securities would be issued in
the form of noncumulative perpetual preferred stock for C corporation issuers
and as subordinated debt securities for S corporation issuers, and are
referenced collectively in...