If the Ec were going to propose a new POR soon, it would have answers to what makes A>L and what makes this plan more approvable than Rosey's POS.
So I would expect to see the inclusion of the obvious things like the NOL's, $4b in cash, etetc., but there is also the debated financial worth of litigation that JMfW poo poo'd in her opinion.
Hopefully if enough pressure is applied, some third parties like Bank of America might want to submit their settlemtent contribution to the POR just like we want JPM/FDIC to feel the hell fires of SG to contribute $ to the POR as well for releases, etc.