Mr Cooper Group Inc (COOP)

[marayatano]

More dilution from Claims subordinated to the level of
Equity Interests:

PDF 2 and 3.

4. As reflected in the Proposed Confirmation Order, with respect to
calculating the Pro Rata Share for holders of Claims subordinated to the level of Equity Interests,
the Seventh Amended Plan contemplated such Pro Rata Share would be determined by dividing
the amount of their Allowed Claim by the per share price of WMI common stock as of either (a)
the Petition Date, (b) the close of business on the day immediately preceding the Petition Date,
(c) December 12, 2011, or (d) such other date as determined by the Court. Although the Court
did not address this issue at the Confirmation Hearing, as drafted, the Proposed Confirmation Order provides that the Pro Rata Share of those holding Claims subordinated to the level of
Equity Interests will be calculated by dividing the amount of their Allowed Claim by the price of
WMI common stock as of the close of business on the day immediately preceding the Petition
Date. Of the options set forth in the Seventh Amended Plan, the Debtors believe that this choice
reflects the best outcome for impacted parties as this is the date that WMI common stock was
most valuable (i.e., there will be less dilution). To the extent that the Court disagrees, however,
the Debtors respectfully request that the Court interlineate whatever date it deems appropriate.

PDF page 79

34. “Pro Rata Share” for Holders of Claims Subordinated to the Level of
Equity Interests. For purposes of calculating Pro Rata Share of distributions for holders of
Claims, the share count for such holders shall be determined by dividing the amount of an
Allowed Claim by the per share price of WMI common stock as of the close of business on the
day immediately preceding the Petition Date.

http://www.kccllc.net/documents/0812229/0812229120222000000000022.pdf





Approx. $35 million from PFG Claims, et al., subordinated to equity, will dilute shares of WMI2. See PDF page 11, para 3.

http://www.kccllc.net/documents/0812229/0812229101217000000000005.pdf





In addition to DIMEq's 8.77% share of commons.

imo