WHY SHOULD BANKS LEND ANY MONEY FOR ANY TYPE OF LOANS-THEY HAVE FREE MONEY RIGHT NOW AND NO RISK!

The banking business always had a certain level of stuffy snobby attitude. I remember taking the commuter train into the downtown terminal and all the "bankers" were always on the 9:11 am arrival train. Going back home they were on the 4:44 train.

Bankers hours, not bad.

The complicated world of banking and bankers with all the derivatives, and new fangled financial instruments came to daylight during the various "too big to fail" scenarios, with government bailouts being synonymous with the banking business.

Everyone is still wondering why with all the money the government has thrown out with TARP funds and other loans, as well as banks being able to essentially borrow from the TREASURY at ZERO interest, why are they NOT LENDING?

That's an easy question.

The banks can borrow money at ZERO from the (US TAXPAYERS AND THE TREASURY), and THEN USE IT TO BUY treasury SECURITIES THAT PAY 3%, WITH NO RISK. THIS IS A NO RISK SPREAD for the bank, so why should it make risky loans to shaky businesses?

Nobody can blame them, the government as usual by interceding in the markets has caused anomalies by its actions, none of which have any benefit for borrowers.

In fact, the news is widely disseminated that tends to forecast worsening financial conditions for businesses, so why risk loan money?

Big banks have raised billions since the stress tests and policymakers are now turning their bailout affections to life insurers and automakers. Is the government trying to tell us the crisis in the financial sector is over?

While it's too soon to say they're out of the woods, "the government has set up a situation where the banks can hardly lose," says James Galbraith, economist, professor and author of The Predator State: How Conservatives Abandoned the Free Market and Why Liberals Should Too.

Beyond the TARP funds - which Galbraith calls an "unproductive use of Federal borrowing" - banks are benefiting from lending programs that effectively allow them to borrow at zero and reinvest in Treasuries at around 3%. ( I TOLD YOU SO)"A bank doesn't have to do anything to make money," he says. "The banks' return on equity is going to be very good. They're going to be able to restore their finances."

While this is good for banks and a justification for the sector's recent rally, the problem is the government's "free money" program means banks have little or no incentive to do any actual lending. Combined with rising unemployment and the ongoing housing crisis, this means any recovery is likely to be muted, at best, Galbraith says. Furthermore, anyone hoping for a return anytime soon to the salad days of the mid-2000s is delusional.

So now what, do we buy bank stocks?

BARNEY FRANK WILL DECIDE HOW MUCH EXECUTIVES AND OTHERS GET PAID! ARE WE ALL NEXT-MINIMUM WAGE AND NOW MAXIMUM WAGE?

With the votes in the majority, the new administration thinks that it can do anything, like setting a new MAXIMUM pay scale. Hello Stalin, Hello Lenin STALIN WAS TIME MAGAZINE'S MAN OF THE YEAR, NO LESS!

America is sure getting transformed into some type of big brother THUGGERY type of government that wants to control everything we do. not only does it now tell us how much our toilets can flush, but now they want to put a cap on pay, pay by private businesses! Socialism is returning to AMERICA.

This is certainly going to be great for the future economic activity. Now, people who have for the most part lived on the public dole as "public servants", now want to tell us all how much to get paid.

The Obama administration has begun serious talks about how it can change compensation practices across the financial-services industry, including at companies that did not receive federal bailout money, according to people familiar with the matter.

The initiative, which is in its early stages, is part of an ambitious and likely controversial effort to broadly address the way financial companies pay employees and executives, including an attempt to more closely align pay with long-term performance.

Administration and regulatory officials are looking at various options, including using the Federal Reserve's supervisory powers, the power of the Securities and Exchange Commission and moral suasion. Officials are also looking at what could be done legislatively.

Among ideas being discussed are Fed rules that would curb banks' ability to pay employees in a way that would threaten the "safety and soundness" of the bank -- such as paying loan officers for the volume of business they do, not the quality. The administration is also discussing issuing "best practices" to guide firms in structuring pay.

Obama Delves into Executive Pay

1:22

What may be the shakeout following President Obama's effort to regulate executive pay in the financial world? Matthew Rose discusses.

More

• Table: See what 200 top CEOs get paid
• Interactive Guide: How to read a proxy
• Discuss: Should the government limit executive pay?
• WSJ.com/ExecutivePay: News, pay data, more

At the same time, House Financial Services Committee Chairman Barney Frank (D., Mass.) is working on legislation that could strengthen the government's ability both to monitor compensation and to curb incentives that threaten a company's viability or pose a systemic risk to the economy.

It is unclear how such a bill would fit with what the Fed and others are already considering. But any legislation passed would make it harder for policy makers to dial back limits once the financial crisis subsides.

Any new compensation rules would likely be rolled out alongside a broader revamp of financial-markets regulation that the Treasury is pushing. The compensation effort is the latest example of the government's increasing focus on aspects of the financial sector that once were untouched.

Regulators have long had the power to sanction a bank for excessive pay structures, but have rarely used it. The Office of the Comptroller of the Currency last year quietly pressed an unidentified large bank to make changes "pertaining to compensation incentives for bank personnel responsible for assigning risk ratings," a spokesman said. Since 2007, it has privately directed 15 banks to change their executive compensation practices.

Government officials said their effort, which is just beginning, isn't aimed at setting pay or establishing detailed rules. "This is not going to be about capping compensation or micro-management," said an administration official. "It will be about understanding what is the best way to align compensation with sound risk management and long-term value creation."

Despite the banking industry's weakened state, it would likely try to push back against curbs on how financial firms can compensate people. Bank executives have complained to federal officials that strict rules could prompt some of their best employees to move to parts of the financial industry that aren't regulated, such as hedge funds, private-equity firms and foreign banks. They've also argued that paying substantial bonuses is integral to how the industry works.

"Our companies have already enhanced, strengthened and expanded the number of compensation programs that are tied to long-term incentives," said Scott Talbott, a senior vice president at the Financial Services Roundtable, a trade group.

Edward Yingling, chief executive of the American Bankers Association, said banks might be able to accept new rules "as long as they are general in nature and could be enforced on a case-by-case basis. What would never work is detailed regulation of compensation."

President Barack Obama and Treasury Secretary Timothy Geithner have both blamed the way banks structured compensation plans for contributing to the financial mess. In February, Mr. Obama said executive pay helped lead to a "reckless culture and a quarter-by-quarter mentality that in turn helped to wreak havoc in our financial system."

Mr. Geithner recently instructed his staff to begin discussions with the Fed, the SEC and others about ways to address compensation practices.

During a recent congressional hearing, Chairman Ben Bernanke said the Fed was working on rules that will "ask or tell banks to structure their compensation, not just at the very top level but down much further, in a way that is consistent with safety and soundness -- which means that payments, bonuses and so on should be tied to performance and should not induce excessive risk."

In an indication of how broad the effort may become, Federal Deposit Insurance Corp. Chairman Sheila Bair said regulators need to examine compensation practices in the mortgage industry, suggesting new limits could stretch beyond banks.

"We need to make sure that incentives are aligned among all parties by making compensation contingent on the long-run performance of the underlying loans," Ms. Bair said on Tuesday.

The discussions follow a narrower effort by the administration to clip pay at firms that get federal aid. Earlier this year, it issued guidelines limiting salaries for top executives at firms that received funds under the Troubled Asset Relief Program.

Congress chimed in with even tougher rules curbing bonuses for top earners at the same firms, among other things. One rule bars firms receiving federal funds from paying top earners bonuses that equal more than a third of their total compensation.

The administration is still wrestling with how to marry those two efforts, which in combination are more punitive than officials intended. The Treasury is expected to issue new rules sometime in the next few weeks.

Parts Printed in The Wall Street Journal

STRESS TESTS, ARE THEY REALLY , OR ARE THEY STRESS REDUCERS FOR THE TAXPAYERS?

It is sure stressful when looking at a headline one discovers that the bank with all my savings and other accounts is STRESSED, and that it "only" needs $34 billion to be "ok."

There was good news too, the original commitment of TARP funds was $45 billion, so this is "good." This proves that the management did well, they only will blow $34 billion of our tax money, instead of the $45 billion that was budgeted for them to blow.

Earlier this week, The Financial Times reported Bank of America needed to raise about $10 billion as a result of the stress tests. The FT's report was "completely inaccurate," a bank spokesman told Reuters.

Turns out the spokesman was technically right, as suggested here: The FT dramatically underestimated BofA's capital needs, which are closer to $34 billion, according to The New York Times. Notably, The NYT quoted BofA chief administrative officer J. Steele Alphin, who confirmed the figure.

Now, $34 billion (technically $33.9 billion) is a lot of money and a lot more than $10 billion. But this is being spun as a "good news" story for Bank of America and embattled CEO Ken Lewis because $33.9 billion is less than the $45 billion on TARP funds the government has pledged to the bank.

As a result, the bank "could satisfy regulators' demands simply by converting non-voting preferred shares it gave the government in return for the capital, into common stock," as The NYT reports.

Of course, it's not so simple. Remember, the idea here is to increase bank's tangible common equity, a key ratio of a banks health, not put actual dollars into the bank and/or force it to write-down its toxic loans. Also, the government converting its preferred shares has major ramifications, including:

• It would make the government one of BofA's largest shareholders.
• Taxpayers would lose the dividend and seniority rights granted by the preferred shares, and be at more direct risk of loss if BofA (inevitably) suffers additional losses and needs to raise yet more capital.
• Existing shareholders would suffer further dilution, depending on the conversion ratio used. (Of course, the government's recent history with Citigroup - which, oh by the way needs $50 billion to $55 billion in additional capital -- suggests the conversion rate will be very favorable to the bank and current shareholders, which may explain why BofA shares rebounded from steep pre-market declines and were recently up more than 7.5%.)

If this all sounds like something out of Superman's Bizarro world, well...it is! But wait, there's more.

Since the capital BofA needs is less than the government's pledge, the bank would be left with an $11 billion "surplus" that it would seek to use to pay back its TARP loans.

So in sum, in all makes perfect sense: the government will use the TARP to help the bank repay its TARP loans. Peter, meet Paul. Paul, meet Peter.

TARP FUNDS CREATING A HOUSE OF CARDS FOR 555 FINANCIAL INSTITUTIONS!

The latest report of the TARP funds, or otherwise known as the HOUSE OF CARDS bailout program is detailed below. Most financial institutions have received capital infusions via the Treasury’s Capital Assistance Program, a bank-share purchase program intended to restore confidence in banks and get them to lend. This program is funded with $250 billion of the $700 billion Troubled Assets Relief Program authorized by Congress in October 2008 via the Emergency Economic Stabilization Act. Below, see a list of participating companies.

As you may recall, the going joke was that we all need to re-incorporate as banks so that we could all get the TARP money.

Company	Capital	Capital Repayment Announced
1st Constitution Bancorp	$12,000,000	3/31/2009
1st Enterprise Bank	$4,400,000	3/31/2009
1st FS Corporation	$16,369,000	3/31/2009
1st Source Corporation	$111,000,000	3/31/2009
1st United Bancorp, Inc.	$10,000,000	3/31/2009
AB&T Financial Corporation	$3,500,000	3/31/2009
Adbanc, Inc.	$12,720,000	3/31/2009
Alarion Financial Services, Inc.	$6,514,000	3/31/2009
Alaska Pacific Bancshares, Inc.	$4,781,000	3/31/2009
Alliance Financial Corporation	$26,918,000	3/31/2009
Alpine Banks of Colorado	$70,000,000	3/31/2009
AMB Financial Corp.	$3,674,000	3/31/2009
AmeriBank Holding Company	$2,492,000	3/31/2009
American Express Company	$3,388,890,000	3/31/2009
American State Bancshares, Inc.	$6,000,000	3/31/2009
Ameris Bancorp	$52,000,000	3/31/2009
AmeriServ Financial, Inc.	$21,000,000	3/31/2009
Anchor BanCorp Wisconsin Inc.	$110,000,000	3/31/2009
Annapolis Bancorp, Inc.	$8,152,000	3/31/2009
Associated Banc-Corp	$525,000,000	3/31/2009
Avenue Financial Holdings, Inc.	$7,400,000	3/31/2009
BancIndependent, Inc.	$21,100,000	3/31/2009
Bancorp Rhode Island, Inc.	$30,000,000	3/31/2009
BancPlus Corporation	$48,000,000	3/31/2009
BancStar, Inc.	$8,600,000	3/31/2009
BancTrust Financial Group, Inc.	$50,000,000	3/31/2009
Bank of America Corporation	$15,000,000,000	3/31/2009
Bank of America Corporation	$10,000,000,000	3/31/2009
Bank of Commerce	$3,000,000	3/31/2009
Bank of Commerce	$17,000,000	3/31/2009
Bank of George	$2,672,000	3/31/2009
Bank of MarinBancorp	$28,000,000	3/31/2009
Bank of New York Mellon Corporation	$3,000,000,000	3/31/2009
Bank of North Carolina	$31,260,000	3/31/2009
Bank of the Carolinas Corporation	$13,179,000	3/31/2009
Bank of the Ozarks, Inc.	$75,000,000	3/31/2009
Bankers’ Bank of the West Bancorp, Inc.	$12,639,000	3/31/2009
BankFirst Capital Corporation	$15,500,000	3/31/2009
BankGreenville	$1,000,000	3/31/2009
Banner Corporation	$124,000,000	3/31/2009
Banner County Ban Corporation	$795,000	3/31/2009
Bar Harbor Bankshares/Bar Harbor Bank & Trust	$18,751,000	3/31/2009
BB&T Corp.	$3,133,640,000	3/31/2009
BCB Holding Company, Inc.	$1,706,000	3/31/2009
BCSB Bancorp, Inc.	$10,800,000	3/31/2009
Beach Business Bank	$6,000,000	3/31/2009
Berkshire Hills Bancorp, Inc.	$40,000,000	3/31/2009
Bern Bancshares, Inc.	$985,000	3/31/2009
Blackhawk Bancorp, Inc.	$10,000,000	3/31/2009
Blue Ridge Bancshares, Inc.	$12,000,000	3/31/2009
Blue River Bancshares, Inc.	$5,000,000	3/31/2009
Blue ValleyBan Corp.	$21,750,000	3/31/2009
BNB Financial Services Corporation	$7,500,000	3/31/2009
BNC Financial Group, Inc.	$4,797,000	3/31/2009
BNCCORP, Inc.	$20,093,000	3/31/2009
BOH Holdings, Inc.	$10,000,000	3/31/2009
Boston Private Financial Holdings, Inc.	$154,000,000	3/31/2009
Bridge Capital Holdings	$23,864,000	3/31/2009
Bridgeview Bancorp, Inc.	$38,000,000	3/31/2009
Broadway Financial Corporation	$9,000,000	3/31/2009
Butler Point, Inc.	$607,000	3/31/2009
C&F Financial Corporation	$20,000,000	3/31/2009
Cache Valley Banking Company	$4,767,000	3/31/2009
Cadence Financial Corporation	$44,000,000	3/31/2009
California Bank of Commerce	$4,000,000	3/31/2009
California Oaks State Bank	$3,300,000	3/31/2009
Calvert Financial Corporation	$1,037,000	3/31/2009
CalWest Bancorp	$4,656,000	3/31/2009
Capital Bancorp, Inc.	$4,700,000	3/31/2009
Capital Bank Corporation	$41,279,000	3/31/2009
Capital Commerce Bancorp, Inc.	$5,100,000	3/31/2009
Capital One Financial Corporation	$3,555,199,000	3/31/2009
Capital Pacific Bancorp	$4,000,000	3/31/2009
Carolina Bank Holdings, Inc.	$16,000,000	3/31/2009
Carolina Trust Bank	$4,000,000	3/31/2009
Carrollton Bancorp	$9,201,000	3/31/2009
Carver Bancorp, Inc.	$18,980,000	3/31/2009
Cascade Financial Corporation	$38,970,000	3/31/2009
Cathay General Bancorp	$258,000,000	3/31/2009
Catskill Hudson Bancorp, Inc.	$3,000,000	3/31/2009
CBB Bancorp	$2,644,000	3/31/2009
CBS Banc-Corp.	$24,300,000	3/31/2009
Cecil Bancorp, Inc.	$11,560,000	3/31/2009
CedarStone Bank	$3,564,000	3/31/2009
Center Bancorp, Inc.	$10,000,000	3/31/2009
Center Financial Corporation	$55,000,000	3/31/2009
Centerstate Banks of Florida Inc.	$27,875,000	3/31/2009
Centra Financial Holdings, Inc./Centra Bank, Inc.	$15,000,000	3/31/2009
Central Bancorp, Inc.	$22,500,000	3/31/2009
Central Bancorp, Inc.	$10,000,000	3/31/2009
Central Bancshares, Inc.	$5,800,000	3/31/2009
Central Community Corporation	$22,000,000	3/31/2009
Central Federal Corporation	$7,225,000	3/31/2009
Central Jersey Bancorp	$11,300,000	3/31/2009
Central Pacific Financial Corp.	$135,000,000	3/31/2009
Central Valley Community Bancorp	$7,000,000	3/31/2009
Central Virginia Bankshares, Inc.	$11,385,000	3/31/2009
Centrix Bank & Trust	$7,500,000	3/31/2009
Centrue Financial Corporation	$32,668,000	3/31/2009
CIT Group Inc.	$2,330,000,000	3/31/2009
Citigroup Inc.	$25,000,000,000	3/31/2009
Citizens & Northern Corporation	$26,440,000	3/31/2009
Citizens Bancorp	$10,400,000	3/31/2009
Citizens Bancshares Corporation	$7,462,000	3/31/2009
Citizens Bank & Trust Company	$2,400,000	3/31/2009
Citizens Commerce Bancshares, Inc.	$6,300,000	3/31/2009
Citizens Community Bank	$3,000,000	3/31/2009
Citizens First Corporation	$8,779,000	3/31/2009
Citizens Republic Bancorp, Inc.	$300,000,000	3/31/2009
Citizens South Banking Corporation	$20,500,000	3/31/2009
City National Bancshares Corporation	$9,439,000	3/31/2009
City National Corporation	$400,000,000	3/31/2009
Clover Community Bankshares, Inc.	$3,000,000	3/31/2009
Coastal Banking Company, Inc.	$9,950,000	3/31/2009
CoBiz Financial Inc.	$64,450,000	3/31/2009
Codorus Valley Bancorp, Inc.	$16,500,000	3/31/2009
ColoEast Bankshares, Inc.	$10,000,000	3/31/2009
Colonial American Bank	$574,000	3/31/2009
Colony Bankcorp, Inc.	$28,000,000	3/31/2009
Columbia Banking System, Inc.	$76,898,000	3/31/2009
Columbine Capital Corp.	$2,260,000	3/31/2009
Comerica Inc.	$2,250,000,000	3/31/2009
Commerce National Bank	$5,000,000	3/31/2009
Commonwealth Business Bank	$7,701,000	3/31/2009
Community 1st Bank	$2,550,000	3/31/2009
Community Bancshares of Kansas, Inc.	$500,000	3/31/2009
Community Bank of the Bay	$1,747,000	3/31/2009
Community Bankers Trust Corporation	$17,680,000	3/31/2009
Community Business Bank	$3,976,000	3/31/2009
Community Financial Corporation	$12,643,000	3/31/2009
Community First Bancshares Inc.	$20,000,000	3/31/2009
Community First Bancshares, Inc.	$12,725,000	3/31/2009
Community First Inc.	$17,806,000	3/31/2009
Community Holding Company of Florida, Inc.	$1,050,000	3/31/2009
Community Investors Bancorp, Inc.	$2,600,000	3/31/2009
Community Partners Bancorp	$9,000,000	3/31/2009
Community Trust Financial Corporation	$24,000,000	3/31/2009
Community West Bancshares	$15,600,000	3/31/2009
Congaree Bancshares, Inc.	$3,285,000	3/31/2009
Corning Savings and Loan Association	$638,000	3/31/2009
Country Bank Shares, Inc.	$7,525,000	3/31/2009
Crazy Woman Creek Bancorp, Inc.	$3,100,000	3/31/2009
Crescent Financial Corporation	$24,900,000	3/31/2009
Crosstown Holding Company	$10,650,000	3/31/2009
CSRA Bank Corp.	$2,400,000	3/31/2009
CVB Financial Corp.	$130,000,000	3/31/2009
D.L. Evans Bancorp	$19,891,000	3/31/2009
DeSoto County Bank	$1,173,000	3/31/2009
Dickinson Financial Corporation	$146,053,000	3/31/2009
Discover Financial Services	$1,224,558,000	3/31/2009
DNB Financial Corporation	$11,750,000	3/31/2009
Eagle Bancorp, Inc.	$38,235,000	3/31/2009
East West Bancorp	$306,546,000	3/31/2009
Eastern Virginia Bankshares, Inc.	$24,000,000	3/31/2009
ECB Bancorp, Inc./East Carolina Bank	$17,949,000	3/31/2009
Emclaire Financial Corp.	$7,500,000	3/31/2009
Encore Bancshares Inc.	$34,000,000	3/31/2009
Enterprise Financial Services Corp.	$35,000,000	3/31/2009
Equity Bancshares, Inc.	$8,750,000	3/31/2009
Exchange Bank	$43,000,000	3/31/2009
F & M Bancshares, Inc.	$4,609,000	3/31/2009
F & M Financial Corporation	$17,000,000	3/31/2009
F&M Financial Corporation	$17,243,000	3/31/2009
F.N.B. Corporation	$100,000,000	3/31/2009
Farmers & Merchants Bancshares, Inc.	$11,000,000	3/31/2009
Farmers & Merchants Financial Corporation	$442,000	3/31/2009
Farmers Bank	$8,752,000	3/31/2009
Farmers Capital Bank Corporation	$30,000,000	3/31/2009
Farmers State Bankshares, Inc.	$700,000	3/31/2009
FCB Bancorp, Inc.	$9,294,000	3/31/2009
FFW Corporation	$7,289,000	3/31/2009
Fidelity Bancorp, Inc.	$7,000,000	3/31/2009
Fidelity Financial Corporation	$36,282,000	3/31/2009
Fidelity Southern Corporation	$48,200,000	3/31/2009
Fifth Third Bancorp	$3,408,000,000	3/31/2009
Financial Institutions, Inc.	$37,515,000	3/31/2009
Financial Security Corporation	$5,000,000	3/31/2009
First American International Corp.	$17,000,000	3/31/2009
First Bancorp	$65,000,000	3/31/2009
First Bancorp	$400,000,000	3/31/2009
First BancTrust Corporation	$7,350,000	3/31/2009
First Bank of Charleston, Inc.	$3,345,000	3/31/2009
First Bankers Trustshares, Inc.	$10,000,000	3/31/2009
First Banks, Inc.	$295,400,000	3/31/2009
First Busey Corporation	$100,000,000	3/31/2009
First Business Bank, N.A.	$2,211,000	3/31/2009
First California Financial Group, Inc.	$25,000,000	3/31/2009
First Capital Bancorp, Inc.	$10,958,000	3/31/2009
First Choice Bank	$2,200,000	3/31/2009
First Citizens Banc Corp.	$23,184,000	3/31/2009
First Colebrook Bancorp, Inc.	$4,500,000	3/31/2009
First Community Bank Corporation	$10,685,000	3/31/2009
First Community Bankshares Inc.	$41,500,000	3/31/2009
First Community Corporation	$11,350,000	3/31/2009
First Defiance Financial Corp.	$37,000,000	3/31/2009
First Express of Nebraska, Inc.	$5,000,000	3/31/2009
First Federal Bancshares of Arkansas, Inc.	$16,500,000	3/31/2009
First Financial Bancorp	$80,000,000	3/31/2009
First Financial Holdings Inc.	$65,000,000	3/31/2009
First Financial Service Corporation	$20,000,000	3/31/2009
First Gothenburg Bancshares, Inc.	$7,570,000	3/31/2009
First Horizon National Corporation	$866,540,000	3/31/2009
First Intercontinental Bank	$6,398,000	3/31/2009
First Litchfield Financial Corporation	$10,000,000	3/31/2009
First M&F Corporation	$30,000,000	3/31/2009
First Manitowoc Bancorp, Inc.	$12,000,000	3/31/2009
First Market Bank, FSB	$33,900,000	3/31/2009
First Menasha Bancshares, Inc.	$4,797,000	3/31/2009
First Merchants Corporation	$116,000,000	3/31/2009
First Midwest Bancorp, Inc.	$193,000,000	3/31/2009
First National Corporation	$13,900,000	3/31/2009
First NBC Bank Holding Company	$17,836,000	3/31/2009
First Niagara Financial Group	$184,011,000	3/31/2009
First Northern Community Bancorp	$17,390,000	3/31/2009
First PacTrust Bancorp, Inc.	$19,300,000	3/31/2009
First Place Financial Corp.	$72,927,000	3/31/2009
First Priority Financial Corp.	$4,579,000	3/31/2009
First Reliance Bancshares, Inc.	$15,349,000	3/31/2009
First Resource Bank	$2,600,000	3/31/2009
First Security Group, Inc.	$33,000,000	3/31/2009
First Sound Bank	$7,400,000	3/31/2009
First Southern Bancorp, Inc.	$10,900,000	3/31/2009
First Southwest Bancorporation, Inc.	$5,500,000	3/31/2009
First State Bank of Mobeetie	$731,000	3/31/2009
First Texas BHC, Inc.	$13,533,000	3/31/2009
First ULB Corp.	$4,900,000	3/31/2009
First United Corporation	$30,000,000	3/31/2009
First Western Financial, Inc.	$8,559,000	3/31/2009
Firstbank Corporation	$33,000,000	3/31/2009
FirstMerit Corporation	$125,000,000	3/31/2009
Flagstar Bancorp, Inc.	$266,657,000	3/31/2009
Florida Business BancGroup, Inc.	$9,495,000	3/31/2009
Flushing Financial Corporation	$70,000,000	3/31/2009
FNB Bancorp	$12,000,000	3/31/2009
FNB United Corp.	$51,500,000	3/31/2009
Fortune Financial Corporation	$3,100,000	3/31/2009
FPB Bancorp, Inc.	$5,800,000	3/31/2009
FPB Financial Corp.	$3,240,000	3/31/2009
Fresno First Bank	$1,968,000	3/31/2009
Fulton Financial Corporation	$376,500,000	3/31/2009
Georgia Commerce Bancshares, Inc.	$8,700,000	3/31/2009
Germantown Capital Corporation, Inc.	$4,967,000	3/31/2009
Goldwater Bank, N.A.	$2,568,000	3/31/2009
GrandSouth BanCorporation	$9,000,000	3/31/2009
Great Southern Bancorp	$58,000,000	3/31/2009
Green Bankshares, Inc.	$72,278,000	3/31/2009
Green Circle Investments, Inc.	$2,400,000	3/31/2009
Green City Bancshares, Inc.	$651,000	3/31/2009
Greer Bancshares Incorporated	$9,993,000	3/31/2009
Gregg Bancshares, Inc.	$825,000	3/31/2009
Guaranty Bancorp, Inc.	$6,920,000	3/31/2009
Guaranty Federal Bancshares, Inc.	$17,000,000	3/31/2009
Hamilton State Bancshares	$7,000,000	3/31/2009
Hampton Roads Bankshares, Inc.	$80,347,000	3/31/2009
Haviland Bancshares, Inc.	$425,000	3/31/2009
Hawthorn Bancshares, Inc.	$30,255,000	3/31/2009
HCSB Financial Corporation	$12,895,000	3/31/2009
Heartland Financial USA, Inc.	$81,698,000	3/31/2009
Heritage Commerce Corp.	$40,000,000	3/31/2009
Heritage Financial Corporation	$24,000,000	3/31/2009
Heritage Oaks Bancorp	$21,000,000	3/31/2009
HF Financial Corp.	$25,000,000	3/31/2009
Highlands Independent Bancshares, Inc.	$6,700,000	3/31/2009
Hilltop Community Bancorp, Inc.	$4,000,000	3/31/2009
HMN Financial, Inc.	$26,000,000	3/31/2009
Home Bancshares, Inc.	$50,000,000	3/31/2009
Hometown Bancorp of Alabama, Inc.	$3,250,000	3/31/2009
Hometown Bancshares, Inc.	$1,900,000	3/31/2009
HopFed Bancorp	$18,400,000	3/31/2009
Horizon Bancorp	$25,000,000	3/31/2009
Howard Bancorp, Inc.	$5,983,000	3/31/2009
Huntington Bancshares	$1,398,071,000	3/31/2009
Hyperion Bank	$1,552,000	3/31/2009
Iberiabank Corporation	$90,000,000	3/31/2009
IBT Bancorp, Inc.	$2,295,000	3/31/2009
IBW Financial Corporation	$6,000,000	3/31/2009
ICB Financial	$6,000,000	3/31/2009
Idaho Bancorp	$6,900,000	3/31/2009
Independence Bank	$1,065,000	3/31/2009
Independent Bank Corp.	$78,158,000	3/31/2009
Independent Bank Corporation	$72,000,000	3/31/2009
Indiana Community Bancorp	$21,500,000	3/31/2009
Integra Bank Corporation	$83,586,000	3/31/2009
Intermountain Community Bancorp	$27,000,000	3/31/2009
International Bancshares Corporation	$216,000,000	3/31/2009
Intervest Bancshares Corporation	$25,000,000	3/31/2009
JPMorgan Chase & Co.	$25,000,000,000	3/31/2009
Katahdin Bankshares Corp.	$10,449,000	3/31/2009
KeyCorp	$2,500,000,000	3/31/2009
Kirksville Bancorp, Inc.	$470,000	3/31/2009
Lafayette Bancorp, Inc.	$1,998,000	3/31/2009
Lakeland Bancorp, Inc.	$59,000,000	3/31/2009
Lakeland Financial Corporation	$56,044,000	3/31/2009
LCNB Corp.	$13,400,000	3/31/2009
Leader Bancorp, Inc.	$5,830,000	3/31/2009
Legacy Bancorp, Inc.	$5,498,000	3/31/2009
Liberty Bancshares, Inc.	$57,500,000	3/31/2009
Liberty Bancshares, Inc.	$21,900,000	3/31/2009
Liberty Financial Services, Inc.	$5,645,000	3/31/2009
Liberty Shares, Inc.	$17,280,000	3/31/2009
LNB Bancorp Inc.	$25,223,000	3/31/2009
Lone Star Bank	$3,072,000	3/31/2009
LSB Corporation	$15,000,000	3/31/2009
M&T Bank Corporation	$600,000,000	3/31/2009
Madison Financial Corporation	$3,370,000	3/31/2009
Magna Bank	$13,795,000	3/31/2009
MainSource Financial Group, Inc.	$57,000,000	3/31/2009
Manhattan Bancorp	$1,700,000	3/31/2009
Marine Bank & Trust Company	$3,000,000	3/31/2009
Market Bancorporation, Inc.	$2,060,000	3/31/2009
Marquette National Corporation	$35,500,000	3/31/2009
Marshall & Ilsley Corporation	$1,715,000,000	3/31/2009
Maryland Financial Bank	$1,700,000	3/31/2009
MB Financial Inc.	$196,000,000	3/31/2009
Medallion Bank	$11,800,000	3/31/2009
Mercantile Capital Corp.	$3,500,000	3/31/2009
Merchants and Planters Bancshares, Inc.	$1,881,000	3/31/2009
Meridian Bank	$6,200,000	3/31/2009
Metro City Bank	$7,700,000	3/31/2009
MetroCorp Bancshares, Inc.	$45,000,000	3/31/2009
Metropolitan Capital Bancorp, Inc.	$2,040,000	3/31/2009
Mid Penn Bancorp, Inc.	$10,000,000	3/31/2009
Mid-Wisconsin Financial Services, Inc.	$10,000,000	3/31/2009
Middleburg Financial Corporation	$22,000,000	3/31/2009
Midland States Bancorp, Inc.	$10,189,000	3/31/2009
MidSouth Bancorp, Inc.	$20,000,000	3/31/2009
Midtown Bank & Trust Company	$5,222,000	3/31/2009
Midwest Banc Holdings, Inc.	$84,784,000	3/31/2009
Midwest Regional Bancorp, Inc.	$700,000	3/31/2009
MidWestOne Financial Group, Inc.	$16,000,000	3/31/2009
Millennium Bancorp, Inc.	$7,260,000	3/31/2009
Mission Community Bancorp	$5,116,000	3/31/2009
Mission Valley Bancorp	$5,500,000	3/31/2009
Monadnock Bancorp, Inc.	$1,834,000	3/31/2009
Monarch Community Bancorp, Inc.	$6,785,000	3/31/2009
Monarch Financial Holdings, Inc.	$14,700,000	3/31/2009
Moneytree Corporation	$9,516,000	3/31/2009
Monument Bank	$4,734,000	3/31/2009
Morgan Stanley	$10,000,000,000	3/31/2009
Morrill Bancshares, Inc.	$13,000,000	3/31/2009
Moscow Bancshares, Inc.	$6,216,000	3/31/2009
MS Financial, Inc.	$7,723,000	3/31/2009
MutualFirst Financial, Inc.	$32,382,000	3/31/2009
Naples Bancorp, Inc.	$4,000,000	3/31/2009
Nara Bancorp, Inc.	$67,000,000	3/31/2009
National Bancshares, Inc.	$24,664,000	3/31/2009
National Penn Bancshares, Inc.	$150,000,000	3/31/2009
NCAL Bancorp	$10,000,000	3/31/2009
New Hampshire Thrift Bancshares, Inc.	$10,000,000	3/31/2009
New York Private Bank & Trust Corporation	$267,274,000	3/31/2009
NewBridge Bancorp	$52,372,000	3/31/2009
Nicolet Bankshares, Inc.	$14,964,000	3/31/2009
North Central Bancshares, Inc.	$10,200,000	3/31/2009
Northeast Bancorp	$4,227,000	3/31/2009
Northern States Financial Corporation	$17,211,000	3/31/2009
Northern Trust Corporation	$1,576,000,000	3/31/2009
Northway Financial, Inc.	$10,000,000	3/31/2009
Northwest Bancorporation, Inc.	$10,500,000	3/31/2009
Northwest Commercial Bank	$1,992,000	3/31/2009
Oak Ridge Financial Services, Inc.	$7,700,000	3/31/2009
Oak Valley Bancorp	$13,500,000	3/31/2009
OceanFirst Financial Corp.	$38,263,000	3/31/2009
Ojai Community Bank	$2,080,000	3/31/2009
Old Line Bancshares, Inc.	$7,000,000	3/31/2009
Old National Bancorp	$100,000,000	3/31/2009
Old Second Bancorp, Inc.	$73,000,000	3/31/2009
Omega Capital Corp.	$2,816,000	3/31/2009
OneUnited Bank	$12,063,000	3/31/2009
Pacific Capital Bancorp	$180,634,000	3/31/2009
Pacific City Financial Corporation	$16,200,000	3/31/2009
Pacific Coast Bankers’ Bancshares	$11,600,000	3/31/2009
Pacific Coast National Bancorp	$4,120,000	3/31/2009
Pacific Commerce Bank	$4,060,000	3/31/2009
Pacific International Bancorp	$6,500,000	3/31/2009
Park Bancorporation, Inc.	$23,200,000	3/31/2009
Park National Corporation	$100,000,000	3/31/2009
Parke Bancorp, Inc.	$16,288,000	3/31/2009
Parkvale Financial Corporation	$31,762,000	3/31/2009
Pascack Community Bank	$3,756,000	3/31/2009
Patapsco Bancorp, Inc.	$6,000,000	3/31/2009
Pathway Bancorp	$3,727,000	3/31/2009
Patriot Bancshares, Inc.	$26,038,000	3/31/2009
Patterson Bancshares, Inc.	$3,690,000	3/31/2009
Peapack-Gladstone Financial Corporation	$28,685,000	3/31/2009
Peninsula Bank Holding Co.	$6,000,000	3/31/2009
Penn Liberty Financial Corp.	$9,960,000	3/31/2009
Peoples Bancorp	$18,000,000	3/31/2009
Peoples Bancorp Inc.	$39,000,000	3/31/2009
Peoples Bancorp of North Carolina, Inc.	$25,054,000	3/31/2009
Peoples Bancshares of TN, Inc.	$3,900,000	3/31/2009
PeoplesSouth Bancshares, Inc.	$12,325,000	3/31/2009
PGB Holdings, Inc.	$3,000,000	3/31/2009
Pierce County Bancorp	$6,800,000	3/31/2009
Pinnacle Bank Holding Company, Inc.	$4,389,000	3/31/2009
Pinnacle Financial Partners, Inc.	$95,000,000	3/31/2009
Plains Capital Corporation	$87,631,000	3/31/2009
Plumas Bancorp	$11,949,000	3/31/2009
Popular, Inc.	$935,000,000	3/31/2009
Porter Bancorp Inc.	$35,000,000	3/31/2009
Prairie Star Bancshares, Inc.	$2,800,000	3/31/2009
Premier Bank Holding Company	$9,500,000	3/31/2009
Premier Service Bank	$4,000,000	3/31/2009
PremierWest Bancorp	$41,400,000	3/31/2009
Princeton National Bancorp, Inc.	$25,083,000	3/31/2009
Private Bancorporation, Inc.	$4,960,000	3/31/2009
PrivateBancorp, Inc.	$243,815,000	3/31/2009
Provident Bancshares Corp.	$151,500,000	3/31/2009
Provident Community Bancshares, Inc.	$9,266,000	3/31/2009
PSB Financial Corporation	$9,270,000	3/31/2009
Puget Sound Bank	$4,500,000	3/31/2009
Pulaski Financial Corp	$32,538,000	3/31/2009
QCR Holdings, Inc.	$38,237,000	3/31/2009
Redwood Capital Bancorp	$3,800,000	3/31/2009
Redwood Financial Inc.	$2,995,000	3/31/2009
Regent Bancorp, Inc.	$9,982,000	3/31/2009
Regent Capital Corporation	$2,655,000	3/31/2009
Regional Bankshares, Inc.	$1,500,000	3/31/2009
Regions Financial Corp.	$3,500,000,000	3/31/2009
Reliance Bancshares, Inc.	$40,000,000	3/31/2009
Ridgestone Financial Services, Inc.	$10,900,000	3/31/2009
Rising Sun Bancorp	$5,983,000	3/31/2009
Rogers Bancshares, Inc.	$25,000,000	3/31/2009
Royal Bancshares of Pennsylvania, Inc.	$30,407,000	3/31/2009
S&T Bancorp	$108,676,000	3/31/2009
Saigon National Bank	$1,549,000	3/31/2009
Salisbury Bancorp, Inc.	$8,816,000	3/31/2009
Sandy Spring Bancorp, Inc.	$83,094,000	3/31/2009
Santa Clara Valley Bank, N.A.	$2,900,000	3/31/2009
Santa Lucia Bancorp	$4,000,000	3/31/2009
SBT Bancorp, Inc.	$4,000,000	3/31/2009
SCBT Financial Corporation	$64,779,000	3/31/2009
Seacoast Banking Corporation	$50,000,000	3/31/2009
Seacoast Commerce Bank	$1,800,000	3/31/2009
Seaside National Bank & Trust	$5,677,000	3/31/2009
Security Bancshares of Pulaski County, Inc.	$2,152,000	3/31/2009
Security Business Bancorp	$5,803,000	3/31/2009
Security California Bancorp	$6,815,000	3/31/2009
Security Federal Corporation	$18,000,000	3/31/2009
Security State Bancshares, Inc.	$12,500,000	3/31/2009
Severn Bancorp, Inc.	$23,393,000	3/31/2009
Shore Bancshares, Inc.	$25,000,000	4/15/2009
Signature Bank	$120,000,000	3/31/2009
Somerset Hills Bancorp	$7,414,000	3/31/2009
Sonoma Valley Bancorp	$8,653,000	3/31/2009
Sound Banking Company	$3,070,000	3/31/2009
South Financial Group, Inc.	$347,000,000	3/31/2009
Southern Bancorp, Inc.	$11,000,000	3/31/2009
Southern Community Financial Corp.	$42,750,000	3/31/2009
Southern First Bancshares, Inc.	$17,299,000	3/31/2009
Southern Illinois Bancorp, Inc.	$5,000,000	3/31/2009
Southern Missouri Bancorp, Inc.	$9,550,000	3/31/2009
Southwest Bancorp, Inc.	$70,000,000	3/31/2009
Sovereign Bancshares, Inc.	$18,215,000	3/31/2009
Spirit BankCorp, Inc.	$30,000,000	3/31/2009
St. Johns Bancshares, Inc.	$3,000,000	3/31/2009
State Bancorp, Inc.	$36,842,000	3/31/2009
State Bankshares, Inc.	$50,000,000	3/31/2009
State Capital Corporation	$15,000,000	3/31/2009
State Street Corporation	$2,000,000,000	3/31/2009
StellarOne Corporation	$30,000,000	3/31/2009
Sterling Bancorp	$42,000,000	3/31/2009
Sterling Bancshares, Inc.	$125,198,000	3/31/2009
Sterling Financial Corporation	$303,000,000	3/31/2009
Stewardship Financial Corporation	$10,000,000	3/31/2009
Stockmens Financial Corporation	$15,568,000	3/31/2009
Stonebridge Financial Corp.	$10,973,000	3/31/2009
Summit State Bank	$8,500,000	3/31/2009
Sun Bancorp, Inc.	$89,310,000	4/8/2009
SunTrust Banks, Inc.	$3,500,000,000	3/31/2009
SunTrust Banks, Inc.	$1,350,000,000	3/31/2009
Superior Bancorp Inc.	$69,000,000	3/31/2009
Surrey Bancorp	$2,000,000	3/31/2009
Susquehanna Bancshares, Inc.	$300,000,000	3/31/2009
SV Financial, Inc.	$4,000,000	3/31/2009
SVB Financial Group	$235,000,000	3/31/2009
Synovus Financial Corp.	$967,870,000	3/31/2009
Syringa Bancorp	$8,000,000	3/31/2009
Taylor Capital Group	$104,823,000	3/31/2009
TCB Holding Company, Texas Community Bank	$11,730,000	3/31/2009
TCF Financial Corporation	$361,172,000	3/31/2009
TCNB Financial Corp.	$2,000,000	3/31/2009
Tennessee Commerce Bancorp, Inc.	$30,000,000	3/31/2009
Tennessee Valley Financial Holdings, Inc.	$3,000,000	3/31/2009
Texas Capital Bancshares, Inc.	$75,000,000	3/31/2009
Texas National BanCorporation	$3,981,000	3/31/2009
The Bancorp, Inc.	$45,220,000	3/31/2009
The Bank of Currituck	$4,021,000	3/31/2009
The Bank of Kentucky Financial Corporation	$34,000,000	3/31/2009
The Baraboo BanCorporation	$20,749,000	3/31/2009
The Connecticut Bank and Trust Company	$5,448,000	3/31/2009
The Elmira Savings Bank, FSB	$9,090,000	3/31/2009
The First Bancorp, Inc.	$25,000,000	3/31/2009
The First Bancshares, Inc.	$5,000,000	3/31/2009
The Freeport State Bank	$301,000	3/31/2009
The Goldman Sachs Group, Inc.	$10,000,000,000	3/31/2009
The Little Bank, Inc.	$7,500,000	3/31/2009
The PNC Financial Services Group Inc.	$7,579,200,000	3/31/2009
The Private Bank of California	$5,450,000	3/31/2009
The Queensborough Company	$12,000,000	3/31/2009
The Victory Bank	$541,000	3/31/2009
TIB Financial Corp.	$37,000,000	3/31/2009
Tidelands Bancshares, Inc.	$14,448,000	3/31/2009
Tifton Banking Company	$3,800,000	3/31/2009
Timberland Bancorp, Inc.	$16,641,000	3/31/2009
Titonka Bancshares, Inc.	$2,117,000	3/31/2009
Todd Bancshares, Inc.	$4,000,000	3/31/2009
TowneBank	$76,458,000	3/31/2009
Treaty Oak Bancorp, Inc.	$3,268,000	3/31/2009
Tri-County Financial Corporation	$15,540,000	3/31/2009
Tri-State Bank of Memphis	$2,795,000	3/31/2009
Triad Bancorp, Inc.	$3,700,000	3/31/2009
Trinity Capital Corporation	$35,539,000	3/31/2009
TriState Capital Holdings, Inc.	$23,000,000	3/31/2009
TriSummit Bank	$2,765,000	3/31/2009
Trustmark Corporation	$215,000,000	3/31/2009
U.S. Bancorp	$6,599,000,000	3/31/2009
UBT Bancshares, Inc.	$8,950,000	3/31/2009
UCBH Holdings, Inc.	$298,737,000	3/31/2009
Umpqua Holdings Corp.	$214,181,000	3/31/2009
Union Bankshares Corporation	$59,000,000	3/31/2009
United American Bank	$8,700,000	3/31/2009
United Bancorp, Inc.	$20,600,000	3/31/2009
United BanCorporation	$10,300,000	3/31/2009
United Community Banks, Inc.	$180,000,000	3/31/2009
United Financial Banking Companies, Inc.	$5,658,000	3/31/2009
Unity Bancorp, Inc.	$20,649,000	3/31/2009
US Metro Bank	$2,861,000	3/31/2009
Uwharrie Capital Corp	$10,000,000	3/31/2009
Valley Commerce Bancorp	$7,700,000	3/31/2009
Valley Community Bank	$5,500,000	3/31/2009
Valley Financial Corporation	$16,019,000	3/31/2009
Valley National Bancorp	$300,000,000	3/31/2009
Virginia Commerce Bancorp	$71,000,000	3/31/2009
VIST Financial Corp.	$25,000,000	3/31/2009
W.T.B. Financial Corporation	$110,000,000	3/31/2009
Wainwright Bank & Trust Company	$22,000,000	3/31/2009
Washington Banking Company/Whidbey Island Bank	$26,380,000	3/31/2009
Washington Federal Inc.	$200,000,000	3/31/2009
WashingtonFirst Bank	$6,633,000	3/31/2009
Webster Financial Corporation	$400,000,000	3/31/2009
Wells Fargo & Company	$25,000,000,000	3/31/2009
Wesbanco Bank Inc.	$75,000,000	3/31/2009
West Bancorporation, Inc.	$36,000,000	3/31/2009
Westamerica BanCorporation	$83,726,000	3/31/2009
Western Alliance BanCorporation	$140,000,000	3/31/2009
Western Community Bancshares, Inc.	$7,290,000	3/31/2009
Western Illinois Bancshares Inc.	$6,855,000	3/31/2009
White River Bancshares Company	$16,800,000	3/31/2009
Whitney Holding Corporation	$300,000,000	3/31/2009
Wilmington Trust Corporation	$330,000,000	3/31/2009
Wilshire Bancorp, Inc.	$62,158,000	3/31/2009
Wintrust Financial Corporation	$250,000,000	3/31/2009
WSFS Financial Corporation	$52,625,000	3/31/2009
Yadkin Valley Financial Corporation	$36,000,000	3/31/2009
Zions BanCorporation	$1,400,000,000	3/31/2009
Total: $198,888,248,000 Firms Participating: 555