One who intends to leave others better off for his having existed.

11/26/14

Wachovia CEO Robert K. Steel, Wells Fargo CEO John Stumpf and Chairman Richard Kovacevich and the Merger

On January 17, 2008, unknown to shareholders but known to Wells Fargo CEO John Stumpf and Chairman Richard Kovacevich, Wells Fargo borrowed $1.666 billion from the Federal Reserve Bank's Term Auction Faciltiy at 3.95% interest, with $47.930 billion in Unencumbered Collateral representing an undisclosed credit line with the Fed, none of which was disclosed by Wells Fargo's 2008 annual report.

On May 22 2008, unknown to shareholders but known to Wells Fargo CEO John Stumpf and Chairman Richard Kovacevich, Wells Fargo borrowed $7.5 billion from the Federal Reserve Bank's Term Auction Faciltiy at 2.1% interest, with $47.197 billion in Unencumbered Collateral representing an undisclosed credit line with the Fed, none of which was disclosed by Wells Fargo's 2008 annual report..
         
http://www.federalreserve.gov/newsevents/reform_taf.htm
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On 2008-05-15, while WFC was in possession of undisclosed Federal Reserve provided Term Auction Facility loans, Stumpf John G. purchased 1,550 of Wells Fargo stock valued at $44,841  without being arrested for Insider Trading and Securities Fraud.

On 2008-06-06, while WFC was in possession of undisclosed Federal Reserve provided Term Auction Facility loans, Kovacevich Richard M. purchased 40,398 of Wells Fargo stock valued at $1,052,367 without being arrested for Insider Trading and Securities Fraud.

http://www.insider-monitor.com/trading/cik72971-3.html  
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About six months before the merger with Wells Fargo, Wachovia’s new CEO Robert Steel, formerly the principal adviser at the U.S. Treasury Department on matters of domestic finance under Hank Paulson, purchased 1,000,000 shares of Wachovia’s stock as the company’s TAF borrowing reached an undisclosed $12.5 billion.

$42,672,115,305 of Wachovia's market capitalization disappeared between the first undisclosed TAF loan and the Wells merger.
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On October 3, 2008, Wachovia agreed to be bought by Wells Fargo for about $14.8B in an all-stock transaction.

The Federal Reserve unanimously approved the merger with Wells Fargo on October 12, 2008.

...On October 28, 2008, Wells Fargo was the recipient of $25B of the Emergency Economic Stabilization Act Federal bail-out in the form of a preferred stock purchase.

To further ensure shareholder approval, Wachovia issued Wells Fargo with preferred stock holding 39.9% of the voting power in the company [without informing Wachovia stock holders of the size of credit lines at the Federal Reserve]
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From WELLS FARGO & COMPANY FORM S-4 REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933;

"The Series M, Class A Preferred Stock was issued to Wells Fargo in connection with the entry into the merger agreement by Wells Fargo and Wachovia and represents 39.9% of the total voting power of holders of Wachovia capital stock entitled to vote at the special meeting (including on the approval of the plan of merger contained in the merger agreement). Wells Fargo is the sole holder of all shares of Series M, Class A Preferred Stock and has informed Wachovia that it intends to vote these shares in favor of approving the plan of merger contained in the merger agreement.

...In connection with entering into the merger agreement, Wachovia and Wells Fargo also entered into a share exchange agreement pursuant to which Wachovia issued, on October 20, 2008, 10 shares of its Series M, Class A Preferred Stock to Wells Fargo in exchange for the issuance by Wells Fargo to Wachovia of 1,000 shares of Wells Fargo common stock. The Series M, Class A Preferred Stock issued to Wells Fargo votes together with Wachovia common stock as a single class and represents 39.9% of the total voting power of holders of Wachovia capital stock entitled to vote at the special meeting (including on the approval of the plan of merger contained in the merger agreement).

...Share Exchange Agreement

On October 3, 2008, Wells Fargo and Wachovia, in connection with entering into the merger agreement, entered into a share exchange agreement, under which Wells Fargo agreed to purchase 10 newly issued shares of Wachovia Series M Preferred Stock, which vote together with Wachovia common stock as a single class and have voting rights equivalent to 39.9% of the total voting power of holders of Wachovia capital stock entitled to vote at the special meeting, in exchange for the issuance of 1,000 shares of Wells Fargo common stock to Wachovia.

Wells Fargo and Wachovia completed the transactions contemplated by the share exchange agreement on October 20, 2008."

http://www.sec.gov/Archives/edgar/data/72971/000095012308013965/y72243sv4.htm
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On December 23, 2014, Bloomberg's Phil Kuntz and Bob Ivry wrote "Fed’s Once-Secret Data Compiled by Bloomberg Released to Public"

http://www.bloomberg.com/news/2011-12-23/fed-s-once-secret-data-compiled-by-bloomberg-released-to-public.html

DATE......BALANCE..MARKET CAP...% CAP...TAF......DW

10/3/2008...$12,500.00...$13,406.49...93.24%...$12,500.00...$0.00
10/4/2008...$12,500.00...$13,406.49...93.24%...$12,500.00...$0.00
10/5/2008...$12,500.00...$13,406.49...93.24%...$12,500.00...$0.00
10/6/2008...$41,500.00...$12,478.18...332.58%...$12,500.00...$29,000.00
10/7/2008...$41,500.00...$11,333.99...366.16%...$12,500.00...$29,000.00
10/8/2008...$37,500.00...$10,923.81...343.29%...$12,500.00...$25,000.00
10/9/2008....$50,000.00....$7,771.88....643.35%...$25,000.00...$25,000.00...$29,396.40
10/10/2008...$50,000.00...$11,118.10...449.72%...$25,000.00...$25,000.00
10/11/2008...$50,000.00...$11,118.10...449.72%...$25,000.00...$25,000.00
10/12/2008...$50,000.00...$11,118.10...449.72%...$25,000.00...$25,000.00
10/13/2008...$50,000.00...$12,501.45...399.95%...$25,000.00...$25,000.00
10/14/2008...$50,000.00...$13,622.38...367.04%...$25,000.00...$25,000.00
10/15/2008...$50,000.00...$13,082.66...382.19%...$25,000.00...$25,000.00
10/16/2008...$50,000.00...$13,924.61...359.08%...$25,000.00...$25,000.00
10/17/2008...$50,000.00...$12,888.36...387.95%...$25,000.00...$25,000.00
10/18/2008...$50,000.00...$12,888.36...387.95%...$25,000.00...$25,000.00
10/19/2008...$50,000.00...$12,888.36...387.95%...$25,000.00...$25,000.00
10/20/2008...$50,000.00...$13,104.25...381.56%...$25,000.00...$25,000.00
10/21/2008...$50,000.00...$13,147.43...380.30%...$25,000.00...$25,000.00
10/22/2008...$50,000.00...$12,202.27...409.76%...$25,000.00...$25,000.00
10/23/2008...$50,000.00...$12,309.12...406.20%...$35,000.00...$15,000.00...$33,997.80 
10/24/2008...$50,000.00...$12,394.60...403.40%...$35,000.00...$15,000.00
10/25/2008...$50,000.00...$12,394.60...403.40%...$35,000.00...$15,000.00
10/26/2008...$50,000.00...$12,394.60...403.40%...$35,000.00...$15,000.00
10/27/2008...$50,000.00...$12,266.38...407.62%...$35,000.00...$15,000.00
10/28/2008...$50,000.00...$13,826.39...361.63%...$35,000.00...$15,000.00
10/29/2008...$50,000.00...$12,757.89...391.91%...$35,000.00...$15,000.00
10/30/2008...$50,000.00...$12,771.02...391.51%...$35,000.00...$15,000.00
10/31/2008...$50,000.00...$13,851.48...360.97%...$35,000.00...$15,000.00
11/1/2008...$50,000.00...$13,851.48...360.97%...$35,000.00...$15,000.00
11/2/2008...$50,000.00...$13,851.48...360.97%...$35,000.00...$15,000.00
11/3/2008...$50,000.00...$13,829.87...361.54%...$35,000.00...$15,000.00
11/4/2008...$47,000.00...$14,586.19...322.22%...$35,000.00...$12,000.00
11/5/2008...$47,000.00...$12,922.28...363.71%...$35,000.00...$12,000.00
11/6/2008...$47,500.00...$11,625.73...408.58%...$47,500.00...$0.00...$36,562.70
11/7/2008...$47,500.00...$12,036.31...394.64%...$47,500.00...$0.00
11/8/2008...$47,500.00...$12,036.31...394.64%...$47,500.00...$0.00
11/9/2008...$47,500.00...$12,036.31...394.64%...$47,500.00...$0.00
11/10/2008...$47,500.00...$11,841.83...401.12%...$47,500.00...$0.00
11/11/2008...$47,500.00...$11,993.09...396.06%...$47,500.00...$0.00
11/12/2008...$47,500.00...$11,171.94...425.17%...$47,500.00...$0.00
11/13/2008...$47,500.00...$12,187.57...389.74%...$47,500.00...$0.00
11/14/2008...$47,500.00...$11,863.43...400.39%...$47,500.00...$0.00
11/15/2008...$47,500.00...$11,863.43...400.39%...$47,500.00...$0.00
11/16/2008...$47,500.00...$11,863.43...400.39%...$47,500.00...$0.00
11/17/2008...$47,500.00...$11,388.03...417.10%...$47,500.00...$0.00
11/18/2008...$47,500.00...$11,366.42...417.90%...$47,500.00...$0.00
11/19/2008...$47,500.00...$9,875.39...480.99%...$47,500.00...$0.00
11/20/2008...$47,500.00...$8,859.76...536.13%...$47,500.00...$0.00...$47,212.70
11/21/2008...$47,500.00...$8,924.59...532.24%...$47,500.00...$0.00
11/22/2008...$47,500.00...$8,924.59...532.24%...$47,500.00...$0.00
11/23/2008...$47,500.00...$8,924.59...532.24%...$47,500.00...$0.00
11/24/2008...$47,500.00...$11,431.25...415.53%...$47,500.00...$0.00
11/25/2008...$47,500.00...$11,301.60...420.29%...$47,500.00...$0.00
11/26/2008...$47,500.00...$12,209.18...389.05%...$47,500.00...$0.00
11/27/2008...$47,500.00...$12,209.18...389.05%...$47,500.00...$0.00
11/28/2008...$47,500.00...$12,144.35...391.13%...$47,500.00...$0.00
11/29/2008...$47,500.00...$12,144.35...391.13%...$47,500.00...$0.00
11/30/2008...$47,500.00...$12,144.35...391.13%...$47,500.00...$0.00
12/1/2008....$47,500.00....$9,291.94...511.20%...$47,500.00...$0.00
12/2/2008...$47,500.00...$10,782.98...440.51%...$47,500.00...$0.00
12/3/2008...$47,500.00...$11,755.39...404.07%...$47,500.00...$0.00
12/4/2008...$45,000.00...$11,388.03...395.15%...$45,000.00...$0.00
12/5/2008...$45,000.00...$12,641.36...355.97%...$45,000.00...$0.00
12/6/2008...$45,000.00...$12,641.36...355.97%...$45,000.00...$0.00
12/7/2008...$45,000.00...$12,641.36...355.97%...$45,000.00...$0.00
12/8/2008...$45,000.00...$13,786.65...326.40%...$45,000.00...$0.00
12/9/2008...$45,000.00...$12,879.07...349.40%...$45,000.00...$0.00
12/10/2008...$45,000.00...$12,274.01...366.63%...$45,000.00...$0.00
12/11/2008...$45,000.00...$10,847.80...414.83%...$45,000.00...$0.00
12/12/2008...$45,000.00...$11,431.25...393.66%...$45,000.00...$0.00
12/13/2008...$45,000.00...$11,431.25...393.66%...$45,000.00...$0.00
12/14/2008...$45,000.00...$11,431.25...393.66%...$45,000.00...$0.00
12/15/2008...$45,000.00...$11,042.29...407.52%...$45,000.00...$0.00
12/16/2008...$45,000.00...$12,749.41...352.96%...$45,000.00...$0.00
12/17/2008...$45,000.00...$12,706.19...354.16%...$45,000.00...$0.00
12/18/2008...$30,000.00...$12,490.10...240.19%...$30,000.00...$0.00
12/19/2008...$30,000.00...$12,230.79...245.28%...$30,000.00...$0.00
12/20/2008...$30,000.00...$12,230.79...245.28%...$30,000.00...$0.00
12/21/2008...$30,000.00...$12,230.79...245.28%...$30,000.00...$0.00
12/22/2008...$40,000.00...$11,777.00...339.65%...$40,000.00...$0.00...$76,280.00 
12/23/2008...$40,000.00...$11,452.86...349.26%...$40,000.00...$0.00
12/24/2008...$40,000.00...$11,885.04...336.56%...$40,000.00...$0.00
12/25/2008...$40,000.00...$11,885.04...336.56%...$40,000.00...$0.00
12/26/2008...$40,000.00...$11,777.00...339.65%...$40,000.00...$0.00
12/27/2008...$40,000.00...$11,777.00...339.65%...$40,000.00...$0.00
12/28/2008...$40,000.00...$11,777.00...339.65%...$40,000.00...$0.00
12/29/2008...$40,000.00...$11,798.61...339.02%...$40,000.00...$0.00
12/30/2008...$40,000.00...$12,382.05...323.05%...$40,000.00...$0.00
12/31/2008...$40,000.00...$11,971.48...334.13%...$40,000.00...$0.00
1/1/2009.......$40,000.00...$11,971.48...334.13%...$40,000.00...$0.00

 Above in Bold = Billions in Unencumbered Collateral held at the Federal Reserve
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In negotiations and litigation before, during and after the closing of the merger deal, both Wachovia and Wells Fargo failed to disclose massive credit lines with the Federal Reserve via the Term Auction Facility, which could have affected the merger's negotiated terms.

Some Wachovia shareholders initiated litigation within which Wachovia and Wells Fargo didn't disclose the Federal Reserve Term Auction Facility credit lines.
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"North Carolina State Treasurer Richard Moore slammed Wells Fargo & Co.’s proposed purchase of Wachovia Corp., calling the deal “highway robbery.”

In a Wednesday morning appearance on CNBC’s Squawk Box, Moore said it didn’t make sense for the federal government to have engineered a buyout of Wachovia.

...it’s not a fair deal, he says, in light of the number of banks the government is propping up with its “troubled asset relief program.” Under TARP, banks are getting cash infusions by selling preferred stock directly to the government.

All of the nation’s big banks, Moore told CNBC, are participating in the program, and he thinks Wachovia should have been kept alive until it received the same opportunity.

...“We’re going to be cashed out of our Wachovia stock at around $6 or $7 when I can’t find anyone who tells me that given time, under the TARP, it’s a $25 stock,” Moore says.

...As of Oct. 31, CNBC says, the state pension fund owned 3.22 million shares of Wachovia (NYSE: WB).

Moore also expressed consternation at a controversial provision of the Wells-Wachovia deal that essentially guaranteed the sale would go through over any shareholder objection. In October, Wachovia issued preferred stock to Wells that gave Wells 40 percent of the ballots to be cast in the shareholder vote on the deal.

http://www.bizjournals.com/sanfrancisco/stories/2008/11/10/daily64.html?page=all
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"North Carolina's Attorney General And State Treasurer Duke It Out"

"One of the unusual things about the litigation over the Wachovia-Wells Fargo merger ...was the flood of letters and emails written to the Court.  Judge Diaz received over 200 pieces of correspondence about the case.

The most high profile of those communications was the one from State Treasurer Richard Moore...  Ever since Moore wrote his letter, I've been wondering why he didn't move to intervene in the case.  That would have let him speak directly on behalf of the North Carolina Retirement System (the NCRS), which has lost nearly $20 million on its investment in Wachovia.

...In filings in the Southern District, the North Carolina Attorney General and the State Treasurer had gone to war over the authority of the State Treasurer to initiate the litigation and to retain outside counsel to represent the NCRS.

This is a thorny and interesting issue of the power of the State Treasurer versus that of the Attorney General.  Maybe it will be resolved one day in a court closer to home."

http://www.ncbusinesslitigationreport.com/2008/11/articles/class-actions/north-carolinas-attorney-general-and-state-treasurer-duke-it-out/
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WFC's 2008 annual report cites the words "Term Auction" zero times, "TAF" zero times and "Discount Window" zero times, with no mention of the overall size of Wachovia or Wells Fargo's Federal Reserve Term Auction Facility  and Discount Window credit lines, interest rates and maturities, all of which were material inside information known to Wachovia CEO Robert K. Steel, Wells Fargo CEO John Stumpf and Chairman Richard Kovacevich but not Wachovia or Wells Fargo shareholders, Congress, or the public, before, during or after the two company's merged.

https://www08.wellsfargomedia.com/downloads/pdf/invest_relations/wf2008annualreport.pdf
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From 2006 through 2008, SEC Chair Mary Jo White's husband John served as Director of the Division of Corporation Finance at the U.S. Securities and Exchange Commission, which oversees disclosure and reporting by public companies in the United States.was head of the SEC division which oversees disclosure and reporting by public companies. Mr. White played an integral role in the SEC’s response to market turmoil throughout 2008, ensuring that the Division acted swiftly and appropriately to facilitate strategic transactions and access to capital for public companies.
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Bloomberg's Bob Ivry, Bradley Keoun, Phil Kuntz, Alison Fitzgerald, Fabio Benedetti-Valentini, Noah Bhahayar, Dakin Campbell, Christopher Condon, Gavin Finch, Andrew Frye, Donal Griffin, Christine Harper, Takashiko Hyuga, Aaron Kirchfeld, Dawn Kopecki, Rachel Layne, Elena Logutenkova, John Martens, Michael J. Moore, Howard Mustoe, Hugh Son, James Sterngold, Robert Friedman, John Voskuhl and Otis Bilodeau didn't follow up on the legality of the loan reporting, to the benefit of Bloomberg companies, whose profit is derived from services rendered to many of the same financial institutions.

http://www.bloomberg.com/news/2011-11-28/secret-fed-loans-undisclosed-to-congress-gave-banks-13-billion-in-income.html
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On December 21, 2011, Stephanie L. Hunsaker, Senior Assistant Chief Accountant Division of Corporation Finance at the Securities and Exchange Commission asked Wells Fargo & Company; "We have become aware through various news reports that you may have accessed various Federal Reserve ...sponsored funding programs during 2008 and 2009, including the Term Auction Facility (TAF)... We note from your disclosures during these periods that ...you do not appear to have provided any discussion about certain other programs that were in existence at this time, such as the TAF...

Wells Fargo responded by stating for the first time "Wells Fargo did not participate in the Commercial Paper Funding Facility (CPFF), Primary Dealer Credit Facility (PDCF) or Term Securities Lending Facility (TSLF). Moreover, we did not participate in the Term Asset-Backed Securities Loan Facility (TALF), nor did we access the Federal Reserve’s discount window for liquidity purposes during 2008 and 2009.

[Wachovia did access the Federal Reserve’s discount window for liquidity purposes during 2008 after the merger was announced between 10/6/2008 and 11/5/2008, switching much of the lending the undisclosed TAF.]  

We did participate in the Term Auction Facility (TAF) during 2008 through August 2009.  TAF was established by the Federal Reserve in December 2007, and represented one of several sources of competitive, low-cost short term funding available to us.  ...At December 31, 2008, our short-term borrowings under TAF totaled $72.5 billion, which included $40 billion of TAF borrowings by Wachovia Corporation at the time of acquisition

[approved by the Federal Reserve Board which issued the loans, with no mention of the size of the credit lines or Discount Window borrowings by Wachovia in the lead up to the merger]

However, the TAF borrowings were classified differently in the legacy Wells Fargo and Wachovia accounting systems (which had not been integrated as of the time the 2008 Form 10-K was prepared), which resulted in our reporting of $32.5 billion of the TAF borrowings in the “Commercial paper and other short-term borrowings” line item, and the $40 billion of Wachovia TAF borrowings reported in the “Federal funds purchased and securities sold under agreements to repurchase” line item...

...our management did not distinguish TAF from other sources of short-term borrowings, such as federal funds purchased, commercial paper or securities sold under repurchase agreements...

...We believe FRC 501.06.c does not apply to us because we have not entered into any federally assisted acquisitions or restructurings; in fact, our acquisition of Wachovia was specifically structured not to receive federal financial assistance. In addition, we do not believe that participation in the referenced programs constituted a form of federal financial assistance within the scope of FRC 501.06.c. Our participation in these federal programs was not “intended to make the surviving financial institution a viable entity.”  We were a viable entity regardless of whether we participated in the programs.  Further, our participation in the programs did not ...provide ...arrangements designed to insulate us from the economic effects of problem assets. ...our participation in the referenced programs did not materially affect, and was not reasonably likely to have a material future effect upon our financial condition or results of operations...

http://www.sec.gov/Archives/edgar/data/72971/000119312511349117/filename1.htm
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The SEC didn't ask about Sarbanes Oxley related certification issues.
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On September 1, 2010, Scott G. Alvarez, General Counsel of the Federal Reserve, testified "Before the Financial Crisis Inquiry Commission", on "The Acquisition of Wachovia Corporation by Wells Fargo & Company"

"...I am pleased to appear today to provide the Commission with information on the events leading up to the acquisition of Wachovia Corporation and its banking and nonbanking subsidiaries by Wells Fargo & Company in the fall of 2008. The purpose of my testimony is to summarize the events, with a focus on the Federal Reserve's involvement. I will also address the lending and supervisory questions raised in the Commission's invitation letter.

...On September 25, 2008, the Federal Deposit Insurance Corporation (FDIC) seized and sold Washington Mutual Bank (WaMu), then the largest thrift in the United States.

...The day after the failure of WaMu, Wachovia Bank depositors accelerated the withdrawal of significant amounts from their accounts. In addition, wholesale funds providers withdrew liquidity support from Wachovia.  It appeared likely that Wachovia would soon become unable to fund its operations. ...On September 27 and 28, both Citigroup and Wells Fargo, the second and fifth largest banking organizations in the United States, respectively, conducted due diligence investigations of Wachovia.  Both Citigroup and Wells Fargo also contacted federal regulators indicating that government assistance would be needed in connection with each of their proposed bids to acquire Wachovia.

...At the time, U.S. banking organizations were extremely vulnerable to a loss of confidence by wholesale suppliers of funds. Markets were already under considerable strain after the events involving Lehman Brothers, AIG, and WaMu.  Investors were becoming increasingly concerned about the outlook for a number of U.S. banking organizations, putting downward pressure on their stock prices and upward pressure on their credit default swap spreads.

At the time, Wachovia was considered "well capitalized" by regulatory standards and until very recently had not generally been thought to be in danger of failure, so there were fears that the failure of Wachovia would lead investors to doubt the financial strength of other organizations in similar situations, making it harder for those institutions to raise capital and other funding.

For these reasons, on September 28, 2008, the Board by unanimous vote determined that compliance by the FDIC with the least-cost requirements of the FDI Act with respect to Wachovia Bank and its insured depository institution affiliates would have serious adverse effects on economic conditions and financial stability, and that action or assistance by the FDIC permitted under the systemic risk exception within the act would avoid or mitigate these adverse effects.

Similar determinations were made by the board of directors of the FDIC and the Secretary of the Treasury, in consultation with the President, which allowed the FDIC to consider measures outside the least-cost resolution requirement to resolve Wachovia, including the provision of so-called "open bank" assistance.

...On October 2, during the period Citigroup and Wachovia were negotiating a final merger agreement, the board of directors of Wachovia received a communication from Wells Fargo that included an offer from Wells Fargo to acquire all of Wachovia's stock by merger.  Contrary to its original communication days before that FDIC assistance would be needed as part of a Wells Fargo bid, the new Wells Fargo proposal did not involve any direct financial assistance from the FDIC. 

Based on an IRS notice issued September 30, Wells Fargo had determined that certain U.S. federal income tax benefits resulting from the proposed Wachovia transaction would allow it to acquire Wachovia without FDIC assistance.

On October 3, 2008, Wachovia's board of directors voted to accept the Wells Fargo offer, and the parties signed a binding merger agreement...

...In light of the emergency affecting the financial markets, and as permitted by the BHC Act and Federal Reserve regulations, the Board waived public notice of the proposal and shortened the notice period to the primary regulators of the banks and thrifts involved.  These agencies, and the Department of Justice, indicated that they had no objection to approval of the proposal.

...On December 23, 2008, Wachovia announced that its shareholders had approved the Wells Fargo merger proposal.  On January 1, 2009, Wells Fargo announced that the merger had been completed effective December 31, 2008.

Federal Reserve Assistance

The Federal Reserve did not provide any emergency financial assistance in connection with the Wells Fargo-Wachovia merger...

...While emergency credit was not sought or given in connection with the Wachovia transaction, Wachovia's depository institutions accessed the Federal Reserve's discount window at various times throughout 2008. The discount window comprises several credit facilities open to insured depository institutions on a regular basis and is not limited to emergency credit like section 13(3).

The Wachovia depository institutions accessed these facilities on the same terms and conditions applicable to other depository institutions, including the completion of required documentation and the pledging of collateral to the Federal Reserve. Many other depository institutions accessed the discount window during this period as well."

http://www.federalreserve.gov/newsevents/testimony/alvarez20100901a.htm

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