Treasury Secretary Timothy Geithner. (Andrew Harrer/Bloomberg)

Three Washington area banks are among the 380 institutions to receive notice from the Treasury Department about its new effort to wind down the Troubled Asset Relief Program.

Arlington-based Virginia Commerce Bank, Severn Savings of Annapolis and Annapolis Bank are part of the remaining group of financial institutions that have yet to repurchase the preferred stock they issued to Treasury under TARP’s Capital Purchase Program. They are part of a group that collectively owes more than $17 billion to the government.

Sloan Deerin, director of the Capital Purchase Program, sent a letter on Nov. 30 to the institutions saying Treasury hired investment advisory firm Houlihan Lokey Capital “to explore options for the management and ultimate recovery of our remaining CPP investments.”

“In the coming weeks, Treasury will be contacting you ... to discuss the options we are considering and any thoughts you might have,” he wrote.

Treasury cannot require banks to repay their TARP investments, especially since regulators have to first give the okay. Considering these banks are under no deadline to settle their tabs, analysts wondered if the action is not a response to a recent quarterly report by TARP’s special inspector general.

The special inspector general criticized Treasury for not having a exit path for small and medium-size banks, which comprise the majority of the institutions still in the program.

“Despite the dramatic efforts to expedite the exit of the largest banks from TARP, there appears to be no corresponding concrete plan for community banks,” said the report. These banks need a strategy “put into action well before a scheduled rise in the TARP dividend.”

Starting in the fall of 2013, the current 5 percent dividend rate will soar to 9 percent. Nearly half of the community banks in the program are not paying their TARP dividend now, according to the report.

Officials at the Treasury said the inspector general’s report had nothing to do with the decision to send the letter. “It’s our goal to replace government capital with private capital and we are now three years into the program,” said agency spokesman Matthew Anderson.

Treasury, he noted, has recovered $258 billion, out of the $245 billion it originally awarded, meaning the agency has turned a profit.

Easing out of TARP is no cake walk for community banks. Many still are contending with troubled commercial real estate loans and simply do not have the same access to capital as their larger counterparts.

A number of community banks to exit TARP, such as EagleBank of Bethesda, used another government source, the Small Business Lending Fund, to convert the prior investment to the new program at a lower dividend rate. Not everyone that applied to SBLF received approval.

Virginia Commerce was one of the 601 banks, representing 64 percent of applicants, rejected from the program.

“While we felt that participation in the program would have been beneficial, non-participation in no way affects our inclination to earn our way out of TARP,” Virginia Commerce chief executive Peter Converse told analysts in a third quarter earnings call.

“We do not anticipate pursuing a capital raise for the foreseeable future. The repayment process is ... not likely to start until the end of the second quarter of 2012 at the earliest.”

A Virginia Commerce official said Converse was traveling and declined further comment. Virginia Commerce reported profits of $5.2 million, or 17 cents a share, in the most recent quarter, down 8.6 percent from the same period a year ago. The bank took $71 million in TARP funds and has been paying dividends on the investment.

Officials from Severn and Annapolis Bank did not return repeated calls for comment on their TARP payment plans.

To date, 11 banks in the Washington area have repaid their TARP bills, including Sandy Spring Bank of Olney, Waldorf-based Tri County Bank and Howard Bank of Columbia.