23-10367-mg Doc 1379 Filed 08/02/24 Entered
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2.1.201 Subordinated Note Trustee Expenses means the reasonable and
documented compensation, fees, expenses, disbursements, and claims for indemnity, subrogation, and contribution incurred or owed to the Subordinated Note Indenture Trustees and their professionals, recoverable in accordance with the Subordinated
Note Indenture Trustees charging liens, whether prior to or after the Petition Date and whether prior to or after the Effective Date, and reasonable fees and expenses incurred in connection with distributions made pursuant to the Plan or the
cancellation and discharge of the Subordinated Note Indentures, in each case to the extent payable or reimbursable under the Subordinated Note Indentures, including the reasonable and documented fees and expenses of Pryor Cashman LLP, as counsel to
the Subordinated Note Indenture Trustees.
2.1.202 Subordinated Notes means the BP Trust I Preferred Securities and the
BP Trust II Capital Securities.
2.1.203 SVB Capital Sale means the sale of the SVB Capital business, subject to the
terms and conditions provided in the Interest Purchase Agreement, dated as of May 2, 2024, by and between the Debtor and Pinegrove Sierra HoldCo LLC.
2.1.204 SVBFG has the meaning set forth in the Introduction hereto.
2.1.205 SVBFG Common Stock means the common stock of SVBFG.
2.1.206 Tax Authority means a federal, state, local or foreign government, or agency, instrumentality, or employee thereof,
court, or other body (if any) charged with the administration of any law relating to Taxes.
2.1.207 Tax Return means a
return, declaration, form, election letter, report, statement, estimate, information return, or other information filed or required to be filed with respect to any Taxes, including any schedule or attachment thereto or amendment thereof.
2.1.208 Taxes means all (i) federal, state, local, or foreign taxes, including all net income, net worth or gross
receipts, capital, value added, franchise, profits, employment, estimated, excise, severance, stamp, occupation, premium, windfall profits, environmental, custom duties, property, sales, use, license, transfer, registration, payroll, withholding,
social security, unemployment, disability, alternative or add-on minimum or other taxes, and (ii) interest, penalties, fines, additions to tax or additional amounts imposed by any Tax Authority or paid in
connection with any item described in clause (i) hereof.
2.1.209 Third-Party Release means the third-party
release contained in Section 12.9 hereof.
2.1.210 Third-Party Release Election Form means an election form
annexed to the non-voting notices to Holders of Claims and Interests in Classes 1, 2, 6, 7 and 8 to permit such Holders to opt in to the Third-Party Release.
2.1.211 Treasury Regulations means the United States Department of Treasury regulations promulgated under the IRC.
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