A new breed of transparency advocate is making itself heard this week, taking to the streets and to corporate boardrooms to demand transparency from corporations that use shareholder money to engage in political activities. These corporate transparency advocates also inundated the Securities and Exchange Commission with more than 178,000 letters in support of a rule mandating disclosure.

Protests, including one yesterday outside a 3M shareholder meeting in St. Paul and one today at Bank of America in Charlotte are scheduled to coincide with votes on resolutions to ban the corporations from making political contributions. Directors of both companies oppose the proposals, which follow on the heels of votes by shareholders of other companies to attempt to have corporations disclose their political spending.

The push for corporations to reign in or disclose their political spending stems from anger over the Supreme Court’s Citizens United case, which for the first time in a century allowed corporations (and labor unions) to funnel unlimited amounts of money from their corporate coffers to political campaigns. Although corporations are still barred from directly giving corporate funds to candidates—they have their PACs for that—the spending they are engaging in now is far more nefarious and harder to track. Money from corporations’ exceedingly deep pockets is being funneled through Super PACs and nonprofit “social welfare” organizations to pay for campaign ads and other political activities with minimal or no disclosure.

The growing discontent among shareholders may be a result of learning that corporations are spending their money on positions the shareholders disagree with. (A threatened boycott of corporate sponsors of the American Legislative Exchange Council—famous for its support of the Stand Your Ground gun laws implicated in the shooting of an unarmed Trayvon Martin—resulted in Coca-Cola, Kraft and Pepsi cutting ties to the group.) Shareholders may simply be protecting their own financial well being, as recent studies have shown companies that make political donations underperform those that stay out of the political realm.

Whatever the reason, it will be a victory for transparency if any of the disclosure resolutions pass, but it won’t be the end of the story. There must be mandatory, blanket disclosure by all corporations of their political activities to ensure a level playing field. More importantly, disclosure will ensure that shareholders feel confident that corporations are acting in their best interests and will provide the public with a better sense of who is supporting their elected officials.

That’s why it is so important for the SEC to heed the call of the 178,000 letter writers and take a stand for transparency. (The Corporate Reform Coalition, of which Sunlight is a member, spurred the letter writing campaign.) At least one SEC commissioner gets it. Luis Aguilar publicly supported mandatory disclosure stating, "Unfortunately, there is no comprehensive system of disclosure related to corporate political expenditures--and that failure results in investors being deprived of uniform, reliable, and consistent disclosure regarding the political expenditures of the companies they own. It is the commission's responsibility to rectify this gap and ensure that investors are not left in the dark while their money is used without their knowledge or consent."

The election season is not yet in full swing and yet well over $100,000,00 in dark money has been spent by Super PACs, corporations, nonprofits and labor groups. Shareholders may be the key to finally finding out where that money is coming from.

Massachusetts Attorney General Martha Coakley filed a lawsuit yesterday against five major U.S. banks for violating the state’s laws to protect consumers by conducting unfair and deceptive practices during the foreclosure crisis.

The complaint claims that Bank of America, Wells Fargo, Citi, JP Morgan Chase and Co., and Ally Financial all committed violations of the state’s laws to protect consumer rights and damaged public records through faulty and fraudulent foreclosure proceedings, failing to modify home loans and the use of a system known as the Mortgage Electronic Records System (MERS).

Much of the outrage towards these banks and others stems from the money they received during the housing and financial crisis that began in 2008. All five of these banks received billions of dollars in emergency funds through the Troubled Assets Relief Program (TARP) to ensure their stability and keep them from failing. But now, after many citizens and politicians feel the banks haven’t reciprocated the concern the public and the government had for their financial troubles, they’ve found themselves in legal and political trouble, including this lawsuit.

The violations these banks are accused of committing come after a series of programs that were intended to help the banks help the people. Regularly, before and after those programs were put into place, these banks take part in influential tactics to keep their own bottom line on the minds of lawmakers and not necessarily the financial stability of the public through campaign contributions, lobbying and other less-expected and less-expensive ways.

According to InfluenceExplorer.com, contributions to candidates across the country affiliated with these five banks totaled nearly $14 million. However, only a rather insignificant portion of that money—$173,000—went to Massachusetts politicians.

Also according to Influence Explorer, Bank of America’s political action committee and its employees and their family members gave $4.8 million to state and federal candidates during the 2009-10 election cycle. Massachusetts Democrat Barney Frank received $25,000 of that money.

BofA also lobbied heavily on a variety of bills related to finance and other issues, spending $7.4 million during those same two years. BofA frequently disclosed lobbying on the Dodd-Frank bill—officially known as H.R. 4173, The Wall Street Transparency and Accountability Act of 2010. Presumably, the banking giant spent a great deal of that money to influence the formation and implementation of this bill, which was intended to regulate many banking practices that had no formal regulation before and threatened to significantly lower the profits a bank could rake in. The goal of that bill, according to lawmakers, was to make sure the country would never see a financial crisis like the one recently experienced again.

According to Federal Advisory Committee Act data also displayed on Influence Explorer, as of 2011, Bank of America has five employees sitting on federal advisory committees. Those employees are in the position to advise various agencies on how to implement regulations and do business, usually doing so on issues that affect their own business matters. Walter Muller, the bank’s Chief Investment Officer, sits on the Department of Treasury’s Advisory Committee of the Securities Industry and Financial Markets Association.

JP Morgan is a big spender in Washington as well. During the 2009-10 election cycle, there were $3.4 million campaign contributions affiliated with financial company. There were also $13.4 million in lobbying expenditures reported. Like BofA, JP Morgan reported lobbying heavily on the Dodd-Frank Financial Reform bill.

JP Morgan doesn’t currently have any employees on any federal advisory committees, but did in 2010 when the company’s Executive Director of Environmental Affairs sat on an advisory committee with the Department of Commerce.

If you’d like more influence data about these two companies, or the remaining three being sued by Massachusetts—Well Fargo, Ally Financial (formerly GMAC) and Citi—you can visit InfluenceExplorer.com and TransparencyData.com.

Part of the lawsuit has been brought about because the attorney general Martha Coakley doesn’t believe the banks have adequately satisfied promises to modify mortgages and slowdown the rampant foreclosures happening in the state. For information on that issue, see the report we did on the Home Affordable Modification Program (HAMP), which is a funded through TARP.

On Sunday, Bloomberg News reported on an estimated $13 billion worth of income that banks gained by taking advantage of the Federal Reserve’s below-market interest rates, which were sometimes as low as 0.01 percent.

The six banks that benefited the most from this “subsidy” – Bank of America, Citigroup, Goldman Sachs, JP Morgan, Morgan Stanley, and Wells Fargo – reaped a combined $4.8 billion of estimated extra income from the below-market loans.

It’s worth pointing out that all six of these banks were major political players.

All six have also averaged at least $2.7 million in lobbying a year for the period 2008-2010. And all six have averaged at least $2 million in campaign contributions for the last two electoral cycles. Four of the six banks rank among the top 100 political contributor organizations for the last two cycles. Two of the six were in the top 100 political lobbying organizations for the period 2008-2010. (We focus on 2008-2010 because although the bulk of the lending took place in late 2008 and early 2009, continued lobbying by the banks may have contributed to keeping these deals undisclosed until now.)

 

Bank	Contributions 2007-008 & 2009-2010 (Average Per Cycle)	Lobbying 2008-2010 (Average Per Year)	In-house lobbyists 2008-2010 (Average Per Year)	Firms hired 2008-2010 (Average Per Year)
Bank of America	$3,233,745 (rank: 57)	$4,085,333 (rank: 160)	5.0	7.7
Citigroup	$3,746,536 (rank: 70)	$5,846,666 (rank:37)	9.0	13.7
Goldman Sachs	$5,315,836 (rank: 51)	$3,584,333 (rank: 179)	7.7	14.0
JP Morgan	$4,274,232 (rank: 56)	$6,323,333 (rank: 70)	9.3	12
Morgan Stanley	$3,072,767 (rank: 108)	$2,710,000 (rank: 237)	4.0	4.3
Wells Fargo	$2,000,573 (rank: 126)	$3,518,580 (rank: 197)	3.7	3.3

While it’s difficult to infer causality from these numbers, it is fair to say that these companies were no strangers to Washington. And this probably didn’t hurt them when it came to negotiating bail-out deals with the Federal Reserve and keeping these deals undisclosed.

It’s well known by now that the Occupy Wall Street protesters are occupying Zuccotti park – a park just a couple blocks away from Wall Street in lower Manhattan. That occupation was almost ended when the owner of the park asked that the park be cleared so it can be cleaned last week.

That owner, Brookfield Properties, has not only become the unhappy landlord of a movement that has spread across the country, but also takes part in the some of the practices #occupy protesters appear to have an issue with: using money to push corporate interests through Congress and influence the political process. It should be noted that Brookfield’s involvement in politics through contributions and lobbying and the presence of Occupy Wall Street protestors in their park is purely coincidental and neither Brookfield nor people emailed with the OWS movement have said otherwise. It is, however, an interesting coincidence.

Zuccotti park operates as a public space and is open 24 hours a day. It is privately owned by Canada-based Brookfield Properties. Brookfield is a publicly traded real estate company with land and buildings in some of the most prestigious areas of the United States. They also happen to lease properties to Bank of America and Wells Fargo, both banks given TARP money during the financial bailout in 2008 and an issue that helped spark the OWS movement.

Brookfield employees have been active in political giving on the federal level for the last decade. Brookfield CEO Richard Clark and Chariman John Zuccotti—the man the park is named after—are both donors to various politicians in New York and other states and donors to an influential real estate trade political action committee. In the 1970’s, Zuccotti was the chairman of the New York Planning Commission and following that position was deputy mayor of New York.

Between 2000 and 2010, Richard Clark made at least $169,950 in contributions to PACS and committees such as Democratic Senatorial Campaign Committee and the National Association of Real Estate Trusts and various politicians such as Kristen Gillibrand(D-NY) and Chuck Schumer (D-NY). Records also show that Clark has given to Super Committee Member Chris Van Hollen (D-MD).

John Zuccotti’s contributions between the years 2002 and 2010 were $195,300 to many of the same committees, PACs and politicians as Clark, according to TransparencyData.

Brookfield Asset Management—a company listed on Brookfield Properties’ website as having a controlling stake in the company—has reported spending just over $500,000 lobbying the federal government on energy, financial and tax issues since 2009, according to the Center for Responsive Politics.

The Occupy Wall Street movement has been protesting what participants consider corporate greed for 34 days now. The protest has been replicated across the country in Washington DC, Denver and San Diego, to name just a few places. The movement cites the Arab Spring at Tahrir Square in Egypt and protests also inspired by poor economic conditions that took place in Spain earlier this year as inspiration for the occupations.

A roundup of what we're noticing in the Reporting Group as we dig into government data and disclosures:

By the numbers: Outside groups have disclosed spending some $347 million, of which $302 million directly advocates defeat or election of a federal candidate. Biggest chunk of that latter portion: Outside, non-party groups (including Super PACs and non-profits) opposing Democratic candidates ($73.5 million) followed by Democratic Party committees opposing Republican candidates ($66.4 million). Get the latest numbers right here.

Running out of cash? National Republican Congressional Committee reported spending $10 million over the last five days. Democratic Congressional Campaign Committee, over the same period, spent $1.2 million. Super PAC American Crossroads spent $1.9 million over the same period.

Discl-$0-sure: Ending Spending Fund, a Super PAC that's disclosed spending $1.1 million--the biggest chunk on opposing Sen. Harry Reid, D-Nev.--has filed its pre-general election report with the Federal Election Commission. Starting cash: $0. Total receipts: $0. Total spent: $0. They don't disclose donors either.

New Super PACs: Kinde Durkee, who runs a firm that specializes in helping political organizations comply with filing requirements (and was fined $110,000 by the California Fair Political Practices Commission for financial reporting violations), filed a form with the FEC for No 2 Sides PAC. The initial filing for the Super PAC lists the Liar Alert PAC as an affiliated committee; the latter discloses no receipts or disbursements in its October quarterly report. Matthew Garrington registered the Environment Colorado Action Committee. Garrington's linkedin profile is here. Neither group has disclosed spending any money, though Liar Alert PAC has a website featuring issue ads.

Be sure to check out our Follow the Unlimited Money tool--updated hourly!--to get all the latest info on outside groups.

PhRMA & 527s: Citizens for Strength and Security filed its 527 pre-election report with the Internal Revenue Service. Biggest donors: Pharmaceutical Research and Manufacturers of America, Democratic Governors Association and labor union SEIU. My colleague wrote about CSS Action Fund, which may or may not be an affiliated committee, here.

From Sunlight CAM: Democratic National Committee supporting Todd Young in Indiana? Might mean the DCCC.

The Daily Poligraft: Weekend edition: GOP Mega Donors look toward 2012, from Politico.

Subcontractors: USASpending.gov announces on its home page that it will track sub award data starting Dec. 1st.

Today's Politiwidget: Bank of America acknowledged errors in its handling of foreclosures, the Wall Street Journal reports. We've been keeping an eye on the foreclosure crisis and Bank of America; the top House recipient of contributions from them is...

They received billions in help from the federal government to stay afloat during the worst days of the financial crisis and they've--mostly--paid it all back since. Now the top six biggest recipients of money from the Troubled Asset Relief Program--the Treasury Department program adopted in 2008 to shore up troubled banks--are contributing to the campaigns of congressional office seekers across the political spectrum.

Of the top fifteen recipients of campaign contributions from employees and political action committees of Bank of America, Citigroup, Goldman Sachs, JPMorgan Chase, Morgan Stanley and Wells Fargo, five are running for office in New York state, Wall Street's home base, and five are Republican candidates seeking election to the Senate. This is based on data collected from the Center for Responsive Politics.

These six banks were the biggest recipients of money from the bailout fund created by the Emergency Economic Stabilization Act of 2008. Bank of America and Citigroup each received $45 billion, JPMorgan Chase and Wells Fargo received $25 billion each and Goldman Sachs and Morgan Stanley both received $10 billion. Only Citigroup has failed to fully repay the money to the Treasury Department. Citigroup still owes $14 billion.

While the high number of contributions sent to New York pols and key individual lawmakers may be predictable, the presence of a number of Republican candidates seeking to become freshmen senators in the 112th Congress is not. Republicans have successfully used public anger against the bank bailouts to their advantage during the run-up to this fall's midterm elections.

Rob Portman, a former congressman, U.S. Trade Representative and director of the Office of Management and Budget in the George W. Bush administration running for the Senate in Ohio, is the leading recipient of big bailout bank money among GOP Senate aspirants, having raised $97,592 from the six banks.

Portman, who stated he would have voted for the bailout bill, has not run directly against the bailouts, but has taken a position that the bailout money that has been paid back to Treasury should be used to pay down the deficit.

Other GOP Senate aspirants among the top fifteen recipients of big bailout bank contributions include California's Carly Fiorina ($94,850), Illinois' Mark Kirk ($81,275), Delaware's Mike Castle ($66,000) and Missouri's Roy Blunt ($65,642).

Blunt, Castle and Kirk currently serve in the House of Representatives and all three voted in support of the bailout on October 3, 2008. They also all voted against the financial reform bill in 2010.

Fiorina, as a top advisor in the 2008 presidential campaign of Sen. John McCain, defended McCain's support of the bailout bill, but is now running against the bailout. In a recent debate Fiorina attacked her opponent, Sen. Barbara Boxer, for voting for the bailout and receiving campaign contributions from banking executives. The latter attack came despite the fact that Fiorina received more in contributions over the course of 2009-2010 from the six big bailout banks than Boxer.

The top recipient of contributions from the six big banks is Sen. Kirsten Gillibrand with $241,000. Gillibrand is running in her first Senate election after being appointed to take the seat of Secretary of State Hillary Clinton. Gillibrand has long relied on these big banks to provide funds for her campaigns. All of the banks, save for Bank of America, rank as top career donors to Gillibrand's campaign efforts.

The second-biggest recipient of contributions from these six banks is Sen. Richard Shelby, the ranking member on the Senate Committee on Banking, House and Urban Affairs. Over the 2010 election cycle Shelby received $127,050 from the big bailout banks.

While Shelby voted against the bailout legislation in 2008, he played an instrumental role in opposing the financial regulatory bill advocated for by President Obama, Senate Banking Committee chairman Chris Dodd and House Financial Services Committee chair Barney Frank. Many in the financial sector, particularly the six big banks, opposed pieces of, if not the entirety of, the financial regulatory bill and worked to strip it of as many provisions as possible.

Shelby focused sharply on a provision designed to liquidate firms that were no longer solvent instead of bailing them out with Treasury funds. Shelby declared the liquidation fund to be a proposal for bailout forever and won concessions from the Democrats in the debate over the provision.

The other candidates hailing from New York state include freshman congressmen Scott Murphy ($105,050) and Mike McMahon ($103,350), senior senator and long-time Wall Street booster Chuck Schumer ($99,100) and Reshma Saujani ($88,200), the Democratic primary challenger to Rep. Carolyn Maloney.

Murphy, who won a 2009 special election to the upstate seat formerly occupied by Gillibrand, has long ties to the financial industry having worked for Bankers Trust and Advantage Capital Partners, a venture capital firm. McMahon, whose Staten Island district houses many employees in the financial sector, fought hard for the bank's positions on derivatives during the debate over the Dodd-Frank financial reform bill.

Saujani is the only non-incumbent candidate for the House ranked in the top fifteen recipients of big bailout bank contributions. Earlier this year Saujani, a Wall Street banker, touted her Street cred by stating that she was, "running on my Wall Street record, not from it.” Saujani, in defending Wall Street, said, "Instead of browbeating Wall Street, I want to invite them to help create jobs."

Despite the in flux of contributions from the financial sector that have buoyed her campaign, Saujani suddenly backtracked on her statement that she would not browbeat Wall Street. In a recent debate with Maloney, Saujani attacked the congresswoman for failing to make the financial reform bill tougher and for hosting fundraisers with Wall Street lobbyists during the crafting of the reform bill.

The other four candidates ranking in the top fifteen recipients of big bailout bank contributions include Senate Majority Leader Harry Reid ($74,250), Connecticut congressman and former Goldman Sachs banker Jim Himes ($69,320), Senator Richard Burr ($67,680) and Republican Minority Whip Eric Cantor ($66,100).

Burr, Cantor and Reid voted for the 2008 bailout. Himes was elected to Congress in 2008 after the vote had taken place. Both Reid and Himes supported the financial reform bill, while Burr and Cantor did not.

Concerned about seeing their huge profits cut, six big banks are leading the charge to weaken or block new financial regulations being considered in the United States Senate. To push their cause these banks have hired 145 former government officials--congressmen, staffers and executive branch officials--to lobby on Capitol Hill and in the executive branch.

The top six bank holding companies engaged in lobbying on financial regulation include Bank of America, JPMorgan Chase, Citigroup, Wells Fargo, Goldman Sachs and Morgan Stanley. According to the Center for Responsive Politics, these banks spent a combined total of $23.8 million lobbying Washington in 2009.

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Former government officials accounted for seventy-one percent of all lobbyists hired in 2009 by these six banking companies. The company with the highest percentage of former government officials working as lobbyists is Goldman Sachs. Eighty-two percent of the lobbyists hired by Goldman Sachs previously worked in government.

Fifty-five of the 145 former government employees previously worked in the Senate, the current point of lobbying in the financial regulation debate. Fourteen of these former staffers turned lobbyists previously worked for the Senate Committee on Banking, Housing and Urban Affairs or members of the committee. The senator with the most former staffers working as lobbyists for these big banks is Sen. Max Baucus with four former staffers who have gone through the revolving door.

One chief concern of the major bank holding companies is the derivatives language introduced by Sen. Blanche Lincoln and passed out of the Senate Agriculture Committee. Lincoln's legislation would require these banks to spin off their derivatives trading desks into separate entities. This would slash the profits that these companies currently make from derivatives trading.

According to the Office of the Comptroller or the Currency, five of these big banks -- JPMorgan, Bank of America, Citigroup, Merrill Lynch and Goldman Sachs -- account for 97% of the derivatives holdings of United States commercial banks. The investment of millions of dollars in lobbying could save the companies billions of dollars in lost revenue.

Jamie Dimon, JPMorgan's chief executive, stated earlier that derivatives reform could cost his company "$700 million or a couple billion dollars," depending on how tough the regulations were. This calculation likely excludes the possibility that banks would spin off their derivatives trading desks, which could, according to some analysts, lead to the banks getting out of derivatives trading entirely.

The former staffers turned big bank lobbyists worked in other parts of government aside from the Senate. Sixty-five of the 145 previously worked in the House of Representatives. Forty-two worked previously in the executive branch in some capacity and of those with executive experience eight previously worked for either the Treasury Department or the Securities and Exchange Commission.

Today, the Center for Political Accountability (CPA), a non-partisan group working to create transparency and accountability with corporate political spending, announced that they are leading a nationwide shareholder initiative to address the lack of disclosure of certain kinds of political giving by banks receiving TARP money.

The initiative, supported by 23 shareholder advocates, is calling on 19  companies that received more than $1 billion in TARP funds to disclose and require board oversight of their political spending with corporate funds. Only three financial groups -- Prudential Financial Services, American Express and Capital One -- have agreed to do so. Bruce Freed, CPA’s executive director, said that, as a matter of course, banks should be open and above board with their political spending. This is especially true now that they have received huge amounts of bailout funds from the government. Unfortunately, many have resisted. “A safe and sound financial system must be based on transparency and accountability,” he said.

The CPA-lead initiative sent each bank a letter calling for disclosure of political spending (including soft money contributions and payments to trade associations and other tax exempt groups used for political purposes) to help rebuild shareholder and public trust in financial services institutions. Unfortunately, the banking industry has lagged behind other industries in adopting disclosure. As of mid February, CPA reports, more than 52 leading U.S. public companies, including more than one-third in the S&P 100, have disclosed political giving, including Merck, Dell, General Electric, Pfizer, Hewlett Packard, FirstEnergy, Procter & Gamble and Aetna.

The initiative sent letters to the following institutions: Bank of America, Citigroup, JPMorgan Chase, Wells Fargo, Goldman Sachs, PNC Financial Services, Regions Financial Corp, SunTrust Banks, Fifth Third Bancorp, BB&T, Bank of New York Mellon, KeyCorp, CIT Group, Comerica, State Street, Marshall & Ilsley, Northern Trust, Zions Bancorporation and Huntington Bancshares.

It’s outrageous that the Congress didn’t include a provision in the Emergency Economic Stabilization Act passed last fall that would require disclosure of this type of political spending. And it’s doubly outrageous that the banks are refusing to disclose as due course of receiving public funds.

From October 1, 2008 through the end of the year, eighteen companies that had received, or would receive, bailout funds spent money lobbying the government. As the bailout is set to move onto round two, there have been concerns that recipients of funds are improperly lobbying the government after receiving the funds. In the past week there has been an effort by Treasury Secretary Timothy Geithner to restrict lobbying of his department by bailout recipients and a bill introduced by Sens. Dianne Feinstein and Olympia Snowe to ban the use of bailout funds for political influence. Some good government groups are objecting to bailout recipient Bank of America's involvement in organizing opposition to the Employee Free Choice Act.

In total, the eighteen bailout recipients that continued to spend money on lobbying spent $14,810,259 over the three month period of October to December. Of course, many of these companies were lobbying on a variety of issues and did not necessarily spend the full amount listed on their disclosure to lobby on the bailout. All but two of the bailout contracts received by these companies came during the period of which this lobbying spending is the subject. Lobbying on the bailout was determined by whether the lobbyist disclosure forms listed one of the following in the Issue Area provided on the form: H.R. 1424, Emergency Economic Stabilization Act, TARP, and Troubled Asset Relief Program. One bailout recipient that continued to list lobbying expenses, American Internation Group (AIG), has publicly stated that they are no longer lobbying government. The report AIG filed indicates that the expenses were for:

In response to requests and to correct misinformation, AIG provided information about AIG to federal officials in connection with government efforts to address instability and liquidity in the financial markets and congressional oversight of federal programs including the Troubled Asset Relief Program.

Topping the list is the General Motors Corporation with lobbying expenses totalling $3,550,000. The financial arm of the General Motors family, GMAC, a bailout recipient, also spent $,1540,000 on lobbying expenses. Both of these bailout recipients obtained funds at the end of the lobbying disclosure quarter, after Congress rejected a bill granting non-TARP funds for them, suggesting that the majority of the lobbying was done in pursuit of the funds themselves. Four more companies also obtained their bailout funds in the waning days of the year (the end of the disclosure quarter) or in the new year. Those companies are American Express, Chrysler, CIT Group, and PNC Financial Services Group.

Below is the full table of bailout recipients, their lobbying expenses for the 4th quarter, and the first date upon which they were issued bailout funds.

Oct.-Dec. 2008 Lobbying by Bailout Recipients

Bailout Recipient	Lobbying Expenses (Oct.-Dec. 2008)	First receipt of bailout funds
American Express Company	$1,080,000	1/9/09
American International Group	$1,080,000	10/28/08
Bank of America	$880,000	10/28/08
Chrysler LLC	$1,356,589	1/2/09
CIT Group, Inc.	$80,000	12/31/08
Citigroup	$1,480,000	10/28/08
General Motors Corporation	$3,550,000	12/29/08
GMAC LLC	$1,540,000	12/29/08
Goldman Sachs & Co.	$720,000	10/28/08
Huntington Bancshares, Inc.	$43,670	11/14/08
J.P. Morgan Chase Bank	$1,100,000	10/28/08
Morgan Stanley	$610,000	10/28/08
PNC Financial Services Group	$10,000	12/31/08
State Street Corporation	$210,000	10/28/08
The Bank of New York Mellon	$330,000	10/28/08
U.S. Bancorp	$160,000	11/14/08
Wells Fargo & Co.	$580,000	10/28/08