Letter to the Treasury on the Proposed Disposition Guidelines for the Emergency Capital Investment Program

Dear Secretary Yellen,

The American Bankers Association (ABA) appreciates the opportunity to offer our feedback on the proposed Disposition Guidelines for the Emergency Capital Investment Program (ECIP). The ABA represents banks of all sizes and business models across all 50 states, including Community Development Financial Institution (CDFI) banks, which are a critical part of the overall banking ecosystem.

We commend the Treasury's dedication to CDFIs and MDIs through the ECIP program and recognize the efforts made to maximize the impact of this initiative. However, as we review the proposed guidelines, we have several recommendations that we believe will further enhance the program's effectiveness while aligning with the statutory intent of Congress.

Key Recommendations

1. Comprehensive Disposition Guidelines

The ECIP was designed by Congress to support mission-driven financial institutions focused on underserved communities, with long-term protections to ensure their sustainability despite potential policy changes. Congress aimed to give ECIP participants clear options for exiting the program, unlike past initiatives like TARP and CDCI. The statute allows participants to choose from various disposition options and limits the Secretary's authority to restrict these choices.

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