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Blind Pools, Split Banks and the Further Evolution of Bank Investing



by David L. Ansell
Fried, Frank, Harris, Shriver & Jacobson LLP - Washington Office

Robert H. Ledig
Fried, Frank, Harris, Shriver & Jacobson LLP - Washington Office

Gordon L. Miller
Fried, Frank, Harris, Shriver & Jacobson LLP - Washington Office

Thomas P. Vartanian
Fried, Frank, Harris, Shriver & Jacobson LLP - Washington Office

November 13, 2009

Previously published on November 6, 2009

Recently, blind pool bank investment funds have become the latest structure to attract interest among investors looking for investment opportunities in financial institutions. The NBH Holdings* transaction is the first recent example of this kind of a structure, which can be used to recapitalize or purchase open banks, or bid on failed banks from the Federal Deposit Insurance Corporation (FDIC) once a shelf charter is obtained. However, this structure comes with its own set of challenging issues for organizers and investors.


 

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