Pandemic Darlings The pandemic economy, in original documents
Home Source documents Federal Reserve Lending Programs: Nearly Half of Main Street Program Loans Are Fully Repaid — GAO-25-107246

Federal Reserve Lending Programs: Nearly Half of Main Street Program Loans Are Fully Repaid — GAO-25-107246

Summary

GAO-25-107246, a December 2024 report to congressional committees from the United States Government Accountability Office, is titled Federal Reserve Lending Programs: Nearly Half of Main Street Program Loans Are Fully Repaid, but Losses Have Increased. The highlights say the Board of Governors of the Federal Reserve System authorized 13 emergency lending programs in response to the COVID-19 pandemic. They say that, of the 1,830 loans made, 850 (or almost half) had been fully repaid as of August 31, 2024, under the Main Street Lending Program. They also say that, as of the end of fiscal year 2024, four of the facilities continued to hold significant outstanding assets and loans of approximately $4.7 billion.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Issuer
Source documents
Document type
Federal Reserve Lending Programs Nearly Half Of Main Street Loans Repa
Case
Federal Reserve Lending Programs Nearly Half Of Main Street Loans Repa

Cite this document

“Federal Reserve Lending Programs: Nearly Half of Main Street Program Loans Are Fully Repaid — GAO-25-107246.” Original at www.gao.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/federal-reserve-lending-programs-nearly-half-of-main-street-loans-repa/, SHA-256 1d167ffc385f985b7b92c1a93668abf9de5eb9e10a79b3bb77107b30e258a7b2.

Full text

                United States Government Accountability Office
                Report to Congressional Committees




                FEDERAL RESERVE
December 2024




                LENDING
                PROGRAMS

                Nearly Half of Main
                Street Program Loans
                Are Fully Repaid, but
                Losses Have
                Increased




GAO-25-107246
                                             December 2024

                                             FEDERAL RESERVE LENDING PROGRAMS
                                             Nearly Half of Main Street Program Loans Are Fully
                                             Repaid, but Losses Have Increased
Highlights of GAO-25-107246, a report to
congressional committees




Why GAO Did This Study                       What GAO Found
As of the end of fiscal year 2024, four      In response to the COVID-19 pandemic, the Board of Governors of the Federal
of the Federal Reserve’s 13 lending          Reserve System authorized 13 emergency lending programs—known as
facilities, all part of the Main Street      facilities—to ensure the flow of credit across the economy. To improve oversight
Lending Program, continued to hold           of these programs, the Federal Reserve issued seven reports from December
significant outstanding assets and           2020 through June 2024 that evaluated its internal processes and controls, such
loans. These facilities had                  as for risk management and cybersecurity. These reports identified 20
approximately $4.7 billion in                opportunities to enhance internal controls. GAO found that Federal Reserve
outstanding assets and loans, which          Banks, which manage the facilities, have fully addressed 19 of the 20
will not mature until July 2025 or later.
                                             opportunities. The remaining opportunity, which relates to a facility’s evaluation
About $10.4 billion in collateral was
                                             model that monitors loans’ credit quality, is currently under review. GAO also
pledged to secure the loans. The four
facilities were among the nine that          found that the Federal Reserve’s plans for ongoing monitoring of the facilities are
received funds appropriated through          generally aligned with federal internal control standards.
the CARES Act (section 4003). The            The five facilities under the Main Street Lending Program targeted small and
Federal Reserve is required to monitor       midsize businesses and nonprofits. Of the 1,830 loans made through this
and report on the status of the facilities   program, 850 (or almost half) had been fully repaid as of August 31, 2024, the
until they no longer hold outstanding        most recent data available. Further, 138 loans (or about 8 percent) had recorded
assets or loans.
                                             a total of about $969 million in losses, a significant increase (about $781 million)
                                             year-over-year. About 46 percent (or 847 loans) remained outstanding. The
The CARES Act includes a provision
for GAO to annually report on section
                                             program had collected about $1.89 billion in interest payments.
4003 loans, loan guarantees, and             Main Street Lending Program Loans, First Quarter 2021–Third Quarter 2024
investments. This report examines (1)
the Federal Reserve’s oversight and
monitoring of the CARES Act facilities
and (2) the status and performance of
Main Street Lending Program loans.

GAO reviewed Federal Reserve
documentation, conducted loan-level
analysis of Main Street Lending
Program loan performance covering
July 2020 through August 2024, and
interviewed Federal Reserve officials.       Note: Numbers may not add to the total number of loans due to varying loan statuses.
                                             Loans to larger businesses have generally performed better than those to smaller
                                             ones. For example, businesses with annual revenues over $42.1 million at loan
                                             origination accounted for the largest share of repaid loans. In contrast, smaller
                                             businesses (annual revenues of $3.1 million or less) experienced higher rates of
                                             delinquencies and losses. Businesses in the construction sector have repaid a
                                             smaller proportion of loans and experienced higher delinquency rates compared
                                             with other sectors, such as the leisure and hospitality sector.
                                             The higher rates of delinquencies and losses partly reflect the effects of higher
                                             interest payments and the 15 percent of each loan’s principal that came due for
                                             borrowers in the second half of 2023. Interest rates higher than those at loan
                                             origination have increased borrowers’ payments, potentially creating financial
View GAO-25-107246. For more information,    strain for businesses. Another 15 percent of each loan’s principal came due
contact Michael E. Clements at (202) 512-
8678 or ClementsM@gao.gov.                   during 2024, and a balloon payment of the remaining 70 percent will come due
                                             beginning mid-2025, potentially further affecting loan performance.
                                                                                         United States Government Accountability Office
Contents


Letter                                                                                    1
              Background                                                                  3
              Federal Reserve Oversight Continues, and Reserve Banks Have
                Generally Implemented Previously Identified Enhancements                  8
              Nearly Half of Main Street Loans Have Been Fully Repaid, but
                Losses Have Increased                                                    11
              Agency Comments                                                            27

Appendix I    Objectives, Scope, and Methodology                                         30



Appendix II   GAO Contact and Staff Acknowledgments                                      33



Tables
              Table 1: Federal Reserve Facilities Established with CARES Act
                      Funding                                                             5
              Table 2: Number and Dollar Amount of Outstanding Main Street
                      Loans by Sector, as of August 2024                                 16
              Table 3: Number and Dollar Amount of Fully Repaid Main Street
                      Loans by Sector, as of August 2024                                 20
              Table 4: Number and Dollar Amount of Main Street Loan Losses
                      by Census Region, as of August 2024                                23

Figures
              Figure 1: Outstanding Assets of Federal Reserve Lending
                       Facilities Supported by CARES Act Funding, June 2020–
                       September 2024                                                     6
              Figure 2: Number of Outstanding Main Street Lending Program
                       Loans, First Quarter 2021–Third Quarter 2024                      12
              Figure 3: Percent of Outstanding Main Street Loans by Business
                       Size, as of August 2024                                           13
              Figure 4: Outstanding Main Street Loans by Census Division, as
                       of August 2024                                                    14
              Figure 5: Number of Fully Repaid Main Street Loans, First Quarter
                       2021–Third Quarter 2024                                           17
              Figure 6: Percent of Fully Repaid Main Street Loans by Business
                       Size, as of August 2024                                           18



              Page i                                 GAO-25-107246 Federal Reserve Facilities
Figure 7: Fully Repaid Main Street Loans by Census Division, as
         of August 2024                                                    19
Figure 8: Number and Dollar Amount of Main Street Loan Losses,
         Second Quarter 2021–Third Quarter 2024                            21
Figure 9: Percent of Main Street Loans with Losses by Loan Size,
         as of August 2024                                                 22
Figure 10: Percent of Main Street Loans with Losses by Business
         Size, as of August 2024                                           23
Figure 11: Number of Active Main Street Delinquencies, Fourth
         Quarter 2021–Third Quarter 2024                                   25
Figure 12: Main Street Charge-Off and Delinquency Rates, First
         Quarter 2021–Third Quarter 2024                                   26




Page ii                                GAO-25-107246 Federal Reserve Facilities
Abbreviations

NAICS             North American Industry Classification System
RBOPS             Division of Reserve Bank Operations and Payment
                  Systems




This is a work of the U.S. government and is not subject to copyright protection in the
United States. The published product may be reproduced and distributed in its entirety
without further permission from GAO. However, because this work may contain
copyrighted images or other material, permission from the copyright holder may be
necessary if you wish to reproduce this material separately.




Page iii                                          GAO-25-107246 Federal Reserve Facilities
                       Letter




441 G St. N.W.
Washington, DC 20548




                       December 19, 2024

                       Congressional Committees

                       In response to the economic effects of the COVID-19 pandemic, in 2020,
                       the Board of Governors of the Federal Reserve System authorized 13
                       emergency lending programs, known as facilities. These facilities were
                       intended to support the flow of credit to employers, consumers, small and
                       midsize businesses, state and local governments, and nonprofit
                       organizations. 1 Nine of the 13 facilities received funds appropriated by the
                       CARES Act. 2

                       The CARES Act facilities ceased purchasing assets or extending credit by
                       January 8, 2021. Only the facilities under the Main Street Lending
                       Program, which targeted small and midsize businesses and nonprofits,
                       continue to hold substantial outstanding assets and loans. 3 As of
                       September 30, 2024, the program held about $4.7 billion in outstanding
                       assets and loans. 4 Main Street loans have a 5-year maturity, meaning
                       any currently outstanding loans will not mature until July 2025 or later.

                       Section 4026(f) of the CARES Act includes a provision for us to report
                       annually on the loans, loan guarantees, and other investments provided




                       1The facilities are authorized under section 13(3) of the Federal Reserve Act and
                       approved by the Secretary of the Treasury. Section 13(3) of the Federal Reserve Act
                       permits the Federal Reserve to provide emergency lending.
                       2To provide economic relief, section 4003(b)(4) of the CARES Act made available at least
                       $454 billion for the Department of the Treasury to support the Board of Governors of the
                       Federal Reserve System in establishing facilities. Pub. L. No. 116-136, § 4003(b)(4), 134
                       Stat. 281, 470 (2020). We refer to these facilities as CARES Act facilities.
                       3The Federal Reserve also established four emergency lending facilities that did not
                       receive CARES Act appropriations, which we refer to as non–CARES Act facilities,
                       intended to serve various markets and credit needs. On July 30, 2021, the last of the non–
                       CARES Act facilities stopped purchasing assets or extending credit.
                       4This amount includes Main Street loan participations at face value, net of an allowance
                       for credit losses updated as of September 30, 2024. As of September 30, 2024, about
                       $10.4 billion was held in collateral to secure the loans.



                       Page 1                                            GAO-25-107246 Federal Reserve Facilities
under section 4003 of the CARES Act. 5 This report examines (1) the
Federal Reserve’s oversight and monitoring of the CARES Act facilities
and (2) the status of Main Street loans and characteristics and trends in
loan performance.

To address the first objective, we analyzed documentation from the
Federal Reserve’s Division of Reserve Bank Operations and Payment
Systems (RBOPS). This included its procedures for CARES Act facilities,
planning documents, and summaries of its completed reviews. We also
compared RBOPS’s monitoring plans against selected federal internal
control standards. 6 Additionally, we reviewed the Federal Reserve’s
periodic reports and financial statements for updates on potential and
actual losses incurred by the facilities, and we received written responses
from Federal Reserve officials.

For the second objective, we conducted loan-level analysis of Main Street
Lending Program data as of the end of August 2024, the most recent data
available from the Federal Reserve Bank of Boston. To assess the
reliability of these data, we reviewed documentation, including the data
dictionary, for Main Street loan data and performed electronic testing on-
site for outliers, missing data, and erroneous values. We also gathered
information from Federal Reserve Bank of Boston officials about the
collection methodology. We determined the data were sufficiently reliable
for the purpose of describing the status and characteristics of Main Street
loans and their performance. A more detailed description of our
objectives, scope, and methodology can be found in appendix I.



5Specifically, we are to report no later than 9 months after the date of enactment of the
act, and annually thereafter through the year succeeding the last year for which loans,
loan guarantees, or other investments made under section 4003 are outstanding. Our
previous reports were GAO, Federal Reserve Lending Programs: Status of Monitoring and
Main Street Lending Program, GAO-24-106482 (Washington, D.C.: Dec. 22, 2023);
Federal Reserve Lending Programs: Risks Remain Low in Related Credit Markets, and
Main Street Loans Have Generally Performed Well, GAO-23-105629 (Washington, D.C.:
Dec. 19, 2022); Federal Reserve Lending Programs: Credit Markets Served by the
Programs Have Stabilized, but Vulnerabilities Remain, GAO-22-104640 (Washington,
D.C.: Oct. 19, 2021); and Federal Reserve Lending Programs: Use of CARES Act-
Supported Programs Has Been Limited and Flow of Credit Has Generally Improved,
GAO-21-180 (Washington, D.C.: Dec. 10, 2020). Additionally, we regularly issue
government-wide reports on the federal response to COVID-19, available at
https://www.gao.gov/coronavirus.
6GAO, Standards for Internal Control in the Federal Government, GAO-14-704G
(Washington, D.C.: September 2014).




Page 2                                             GAO-25-107246 Federal Reserve Facilities
                       We conducted this performance audit from December 2023 to December
                       2024 in accordance with generally accepted government auditing
                       standards. Those standards require that we plan and perform the audit to
                       obtain sufficient, appropriate evidence to provide a reasonable basis for
                       our findings and conclusions based on our audit objectives. We believe
                       that the evidence obtained provides a reasonable basis for our findings
                       and conclusions based on our audit objectives.


Background
The Federal Reserve    The Federal Reserve Act established the Federal Reserve System as the
System and Emergency   country’s central bank. 7 The system consists of three parts: the Federal
Lending Authority      Reserve Board, Reserve Banks, and the Federal Open Market
                       Committee. 8 The Federal Reserve Board is a federal agency located in
                       Washington, D.C., that oversees the operations of the Reserve Banks
                       and shares with them the responsibility for supervising and regulating
                       certain financial institutions and activities. The Federal Reserve System is
                       divided into 12 districts, and each district is served by a regional Reserve
                       Bank.

                       The Federal Reserve Board has the authority to authorize the Reserve
                       Banks to extend credit more broadly than usual during emergencies. 9
                       Specifically, under section 13(3) of the Federal Reserve Act, during
                       unusual and exigent circumstances, the Federal Reserve can authorize
                       Reserve Banks to extend credit to a broader range of borrowers. 10




                       7Federal Reserve Act, Pub. L. No. 63-43, 38 Stat. 251 (1913).

                       8The Federal Open Market Committee consists of the seven members of the Board of
                       Governors, the President of the Federal Reserve Bank of New York, and four other
                       Reserve Bank presidents who serve on a rotating basis. The committee is responsible for
                       directing open market operations to influence the total amount of money and credit
                       available in the economy.
                       9Reserve Banks typically lend to banks through discount window programs based on
                       established statutory criteria. 12 U.S.C. § 347b(a). The discount window is a Federal
                       Reserve Board lending program that allows eligible institutions to borrow money, usually
                       on a short-term basis, at an above-market rate to meet temporary liquidity shortages.
                       1012 U.S.C. § 343(3). During the 2007–2009 financial crisis, the Federal Reserve invoked
                       its section 13(3) authority to create emergency programs to stabilize financial markets and
                       avert the failures of a few individual institutions.




                       Page 3                                            GAO-25-107246 Federal Reserve Facilities
Emergency Lending           In response to the economic disruptions caused by the COVID-19
Facilities in Response to   pandemic, the CARES Act authorized at least $454 billion for the
                            Department of the Treasury to support the Federal Reserve in
COVID-19
                            establishing facilities to provide liquidity to the financial system. With the
                            Secretary of the Treasury’s approval, the Federal Reserve used its
                            authority under section 13(3) to authorize nine facilities using funds
                            appropriated by the CARES Act. 11 The Federal Reserve cited a number
                            of factors in determining that unusual and exigent circumstances existed.
                            These factors included disruption in the financial markets, reduced
                            availability of credit, a heightened need for credit, and an increase in
                            business expenditures.

                            In general, the CARES Act facilities were designed to address broad
                            sectors of the economy, such as large corporations, small and midsize
                            businesses, and state and local governments. Overall, the CARES Act
                            facilities could support up to $1.95 trillion in transaction volume, and
                            Treasury disbursed $102.5 billion in CARES Act funds to the support the
                            facilities. Of this total, as of September 30, 2024, the Federal Reserve
                            had returned about $97.5 billion to Treasury, leaving about $5 billion
                            available to cover any potential losses the facilities incur. In accordance
                            with the Consolidated Appropriations Act, 2021, all nine facilities stopped
                            purchasing assets or extending credit by January 2021. They conducted
                            a total of about $41 billion in transactions (see table 1). 12




                            11The Federal Reserve established 13 emergency lending facilities in response to the
                            COVID-19 pandemic. Four emergency lending facilities—the Commercial Paper Funding
                            Facility, Money Market Mutual Fund Liquidity Facility, Paycheck Protection Program
                            Liquidity Facility, and Primary Dealer Credit Facility—were non–CARES Act facilities,
                            which all stopped purchasing assets or extending credit by July 30, 2021. In March 2023,
                            the Federal Reserve established another emergency lending facility to boost operating
                            banks’ liquidity and minimize contagion after Silicon Valley Bank and Signature Bank
                            failed. The Bank Term Funding Program was established on March 12, 2023, and ceased
                            extending loans on March 11, 2024.
                            12For the Main Street Lending Program, the transaction amount refers to the Federal
                            Reserve’s participation in the Main Street loans, which is the purchase of 95 percent of
                            lenders’ authorized loan amount to eligible borrowers.




                            Page 4                                            GAO-25-107246 Federal Reserve Facilities
Table 1: Federal Reserve Facilities Established with CARES Act Funding

CARES Act–supported facilities                         Number Facility activity                                             Termination date        Transaction
                                                              of                                                                                     amount (in
                                                      facilities                                                                                       billions)
Primary Market Corporate Credit                                  2 Support large businesses by purchasing                   Dec. 31, 2020                  $14.3a
Facility and Secondary Market                                      qualifying corporate bonds and other eligible
Corporate Credit Facility                                          assets
Main Street Lending Program                                     5b Support small and midsize for-profit businesses Jan. 8, 2021                            $16.5c
                                                                   and nonprofit organizations by purchasing
                                                                   participations in eligible loans
Municipal Liquidity Facility                                     1 Support states, certain counties, municipalities, Dec. 31, 2020                           $6.4
                                                                   multistate entities, and revenue bond issuers
                                                                   by purchasing eligible notes that these entities
                                                                   issued
Term Asset-Backed Securities                                     1 Support consumers and businesses by           Dec. 31, 2020                               $3.7
Loan Facility                                                      providing nonrecourse loans to U.S. companies
                                                                   secured by qualifying asset-backed securities
                                                                   generally backed by recently originated
                                                                   consumer and business loans
Source: GAO analysis of documents and data from the Board of Governors of the Federal Reserve System. | GAO-25-107246
                                                              aThe Primary Market Corporate Credit Facility did not conduct any transactions.
                                                              bThe Main Street Lending Program comprised five facilities: the Main Street New Loan Facility, Main
                                                              Street Priority Loan Facility, Main Street Expanded Loan Facility, Nonprofit Organization New Loan
                                                              Facility, and Nonprofit Organization Expanded Loan Facility.
                                                              cThe transaction amount refers to the Federal Reserve’s participation in Main Street Lending
                                                              Program loans, which is the purchase of 95 percent of lenders’ authorized loan amount to eligible
                                                              borrowers. The Nonprofit Organization Expanded Loan Facility did not conduct any transactions.


                                                              For the facilities that received CARES Act funds, outstanding assets
                                                              peaked between November 2020 and January 2021 (see fig. 1). As of
                                                              September 2024, only four of the Main Street Lending Program facilities
                                                              continued to hold assets. 13




                                                              13The Main Street Lending Program’s Nonprofit Organization Expanded Loan Facility did
                                                              not conduct any transactions.




                                                              Page 5                                                    GAO-25-107246 Federal Reserve Facilities
Figure 1: Outstanding Assets of Federal Reserve Lending Facilities Supported by CARES Act Funding, June 2020–September
2024




Note: Since Feb. 24, 2021, the Main Street Lending Program’s outstanding assets have been reported net of an allowance for credit losses, which is
updated quarterly. The Main Street lending facilities purchased a participation interest in newly issued eligible loans that eligible lenders made to eligible
small and midsize for-profit borrowers and nonprofit organizations.


Federal Reserve                                      The Federal Reserve’s Division of Reserve Bank Operations and
Oversight of the Facilities                          Payment Systems (RBOPS), which oversees the policies and operations
                                                     of the Reserve Banks, is primarily responsible for the oversight of the
                                                     facilities. RBOPS’s general framework for oversight consists of three
                                                     phases:

                                                     •    Phase one. During its initial phase of oversight, RBOPS, through
                                                          communication with Reserve Bank staff, focused on providing
                                                          assistance in setting up the various facilities quickly.
                                                     •    Phase two. As the facilities became operational, RBOPS reviewed
                                                          the facilities’ established governance structures, process workflows,
                                                          and internal control design. RBOPS conducted these reviews to assist
                                                          Reserve Banks in identifying any enhancements at an early point in
                                                          the life of the facilities and to obtain reasonable assurance that the
                                                          design of controls and processes was adequate to ensure the




                                                     Page 6                                                    GAO-25-107246 Federal Reserve Facilities
    facilities’ effective operation. RBOPS completed phase two reviews
    for all facilities by December 2020.
•   Phase three. The third phase consists of ongoing monitoring
    activities. These include continued communication with Reserve Bank
    management and periodic reviews of facility operations and controls
    to obtain reasonable assurance that controls are present and are
    functioning in a manner that addresses identified risks. According to
    RBOPS documentation, phase three oversight activities will continue
    throughout the life of the facilities, until they no longer hold
    outstanding assets or loans.
As part of phase three, RBOPS prepares interim reports at 6-month
intervals, unless a change in timing is approved by the credit facilities’
oversight steering group and advisers. 14 These reports summarize the
scope of oversight activities and any enhancement opportunities related
to facility processes and controls. As of October 2024, RBOPS had
issued seven interim reports to Reserve Bank management
communicating the results of phase three reviews, cumulatively covering
December 2020 to June 2024.

As we previously reported, RBOPS has a process for determining
whether enhancement opportunities have been addressed. 15 RBOPS
officials said Reserve Bank staff notify RBOPS when they have
completed steps to address an enhancement opportunity. RBOPS then
analyzes the actions taken and determines whether the enhancement
opportunity has been addressed. According to RBOPS officials, this
analysis may include discussions with a Reserve Bank’s internal audit
team and management, walk-throughs with Reserve Bank staff to
understand new or updated processes, and reviews of documentation,
such as process flows and procedures.

As of February 2024, all of the CARES Act facilities, except those under
the Main Street Lending Program, had wound down all processes and
terminated operations.




14RBOPS’s organizational structure for phase three credit facility oversight consists of a
steering group and an adviser group that oversee the teams responsible for phase three
focus areas.
15GAO-24-106482.




Page 7                                            GAO-25-107246 Federal Reserve Facilities
Federal Reserve
Oversight Continues,
and Reserve Banks
Have Generally
Implemented
Previously Identified
Enhancements
Federal Reserve Identified   RBOPS’s two most recent interim reports identified no additional
No Additional                opportunities to enhance facilities’ processes and controls. These reports,
                             which were issued to the applicable Reserve Banks, covered 6-month
Opportunities to Enhance
                             periods from July 2023 to June 2024.
Processes and Controls
                             Consistent with our previous reporting, we found that RBOPS’s ongoing
                             monitoring of the facilities generally aligns with federal internal control
                             standards for monitoring of an entity’s internal control system. 16 According
                             to the standards, management should establish and operate monitoring
                             activities to monitor the internal control system and evaluate the results.
                             This includes ongoing monitoring of the design and operating
                             effectiveness of the internal control system as part of the normal course
                             of operations. Further, management should remediate identified internal
                             control deficiencies on a timely basis.

                             From July 2023 to June 2024, RBOPS continued to monitor facilities with
                             outstanding loans and to review progress toward implementing a
                             previously identified enhancement opportunity, discussed further below.
                             RBOPS communicated the results of its ongoing monitoring to facility
                             management teams at relevant Reserve Banks and the Federal Reserve
                             Board. As part of its phase three reviews, RBOPS conducts ongoing
                             follow-up and periodic reporting on facilities’ progress in incorporating the
                             remaining enhancement.

                             RBOPS last updated its overall monitoring approach in fiscal year 2023
                             and made no changes for fiscal year 2024. In early 2023, RBOPS
                             reassessed operation and risk factors to calibrate its oversight activities
                             for the year. RBOPS identified three overall focus areas for 2023: (1)

                             16See GAO-14-704G and GAO-24-106482.




                             Page 8                                    GAO-25-107246 Federal Reserve Facilities
collateral and asset management; (2) operations and controls; and (3)
cybersecurity, resiliency, and data management. The operations and
controls area was further divided into four subfocus areas: risk
management; vendor management; internal controls; and resources,
roles, and responsibilities.

RBOPS noted the following for each focus area:

•   Collateral and asset management. RBOPS will continue to monitor
    underlying collateral, such as by reviewing activities to understand
    and evaluate whether the Reserve Banks’ approach ensures that the
    emergency loans remain adequately collateralized and whether asset
    management procedures are consistent with sound risk management
    practices.
•   Operations and controls. RBOPS will use the components of the
    operations and controls function to obtain reasonable assurance that
    controls are present and are functioning in a manner that addresses
    evolving risks.
•   Cybersecurity, resiliency, and data management. To strengthen
    risk management practices, reduce cyber risks, and maintain
    resiliency for the facilities, RBOPS will continue to oversee ongoing
    operations and improvements to the cybersecurity programs through
    various oversight activities. These oversight activities include regular
    reviews, continuous monitoring, and other efforts to reduce risk and
    improve the efficiency and effectiveness of information technology
    operations.
According to RBOPS’s 2023 planning documentation, phase three
oversight will continue to take an adaptive approach, given the maturity of
the underlying assets and ongoing investments. Board staff are to consult
and coordinate ongoing oversight activities with Reserve Bank control
functions, such as risk management and internal audit, and with external
auditors. Additionally, RBOPS is to perform a risk assessment each year
to inform its planned oversight activities. Based on its ongoing
assessments, RBOPS determined that no changes were needed to its
monitoring approach for 2024.




Page 9                                    GAO-25-107246 Federal Reserve Facilities
RBOPS Completed Its         As we previously reported, Reserve Banks have implemented processes
Review of Almost All        to address all 20 opportunities for enhancing processes and controls
                            identified by RBOPS. 17 Of the 20 enhancement opportunities, RBOPS
Reserve Bank Actions to
                            has completed its review of 19. The remaining opportunity, which relates
Enhance Processes and       to the validation of one facility’s credit evaluation model, is currently under
Controls                    review. 18

                            During 2023, RBOPS balanced its ongoing oversight of the CARES Act
                            facilities with other activities, including the Federal Reserve’s response to
                            2023 banking stress and the announcement and implementation of the
                            Bank Term Funding Program. According to RBOPS, review of the
                            remaining opportunity resumed in December 2023.

Actual and Expected         As of September 30, 2024, the Main Street Lending Program facilities
Losses Are Limited to the   were the only ones that had experienced losses. As of that date, the Main
                            Street facilities had recognized approximately $1.2 billion in actual credit
Main Street Lending
                            losses, net of subsequent recoveries, which we discuss in more detail
Program                     later in the report. This accounts for about 7 percent of the total
                            transaction amount the program conducted.

                            The Federal Reserve analyzes all of the outstanding CARES Act facilities
                            on a quarterly basis to determine if it is necessary to set aside an
                            allowance for potential losses. The evaluation of loan participations
                            purchased by the Main Street Lending Program, including those in
                            nonaccrual status, resulted in recording a credit loss allowance for the
                            Main Street Lending Program of $923 million as of June 30, 2024 (down
                            from $1.1 billion reported for the prior quarter). According to RBOPS, the
                            open opportunity for enhancement related to the credit valuation model is
                            unlikely to have any effect on the Main Street Lending Program’s portfolio
                            valuation, credit loss reserve calculation, or other processes.




                            17GAO-24-106482. The 20 opportunities identified include those related to the Paycheck
                            Protection Program Liquidity Facility, which is a non–CARES Act facility.
                            18The credit evaluation model is used to monitor the credit quality of loans purchased by
                            the facility.




                            Page 10                                           GAO-25-107246 Federal Reserve Facilities
                          As of the end of August 2024, about 46 percent of Main Street loans were
Nearly Half of Main       outstanding, and about 46 percent had been fully repaid. However, about
Street Loans Have         8 percent of loans had been charged off (either partially or fully) by that
                          date, which may reflect borrowers’ first and second principal payments
Been Fully Repaid,        coming due starting in July 2023 and July 2024, respectively. 19
but Losses Have           Delinquencies have fluctuated over time, rising throughout most of the
                          program’s life cycle but falling in recent quarters as many delinquent
Increased                 loans were charged off.

Outstanding Main Street
Loans Declined as More
Borrowers Made Full
Repayments

Outstanding Loans         Since the Main Street Lending Program terminated in January 2021, Main
                          Street borrowers generally have made regular and early (unscheduled)
                          payments, resulting in fewer outstanding loans than expected at this point
                          compared with the program’s repayment schedule. 20 As of August 31,
                          2024, 847 loans (or about 46 percent) of the 1,830 Main Street Lending
                          Program loans remained outstanding. This accounted for about $7.5
                          billion (or about 43 percent) of the total authorized loan amount. 21 The
                          number of outstanding loans has decreased steadily over time, as the
                          number of loans that have been fully repaid or charged off has increased
                          (see fig. 2). Across all loans, including those currently outstanding, the
                          program has collected $1.89 billion in interest payments. 22




                          19Banks charge off debts when they do not believe that a borrower will pay the amount
                          owed. That is, charge-offs are the value of loans that are removed from the books and
                          charged against loss reserves. However, because Main Street loans are recourse loans,
                          borrowers are still responsible for repaying that debt.
                          20Loans issued under the Main Street Lending Program are recourse loans and have a 5-
                          year maturity, meaning they are expected to be fully repaid 5 years after the date of
                          origination. As recourse loans, lenders can pursue the borrower’s assets in the event of
                          default.
                          21The total authorized amount is defined as the total amount eligible lenders have
                          extended to eligible borrowers.
                          22The amount of interest payments collected by the Main Street Lending Program relative
                          to losses cannot be used as a measure of the program’s profitability, as it does not
                          account for other program costs, such as those incurred for establishing and maintaining
                          the program throughout its life cycle.




                          Page 11                                           GAO-25-107246 Federal Reserve Facilities
Figure 2: Number of Outstanding Main Street Lending Program Loans, First Quarter 2021–Third Quarter 2024




Note: This figure reflects data through the end of August 2024, which only partially represents the third quarter of 2024. In addition, these counts reflect
the final count of outstanding Main Street loans at the end of a given quarter.


                                                    Distribution of outstanding loans by loan size. Since the Main Street
                                                    Lending Program terminated in January 2021, the distribution of
                                                    outstanding loans by loan size has generally aligned with the overall
                                                    distribution of Main Street loans made under the program. However, since
                                                    the fourth quarter of 2022, the smallest loans (valued at $1.2 million or
                                                    less) have constituted a slightly larger share of outstanding loans. As of
                                                    the end of August 2024, these smaller loans accounted for about 22
                                                    percent of outstanding loans, although they account for 20 percent of all
                                                    originated Main Street loans.

                                                    Distribution of outstanding loans by business size. As of the end of
                                                    August 2024, the distribution of outstanding loans had shifted slightly
                                                    toward smaller businesses, compared with the distribution of all Main
                                                    Street loans. Businesses with annual revenues of $7.7 million or less at
                                                    loan origination accounted for about 46 percent of outstanding loans,
                                                    whereas these businesses represented about 40 percent of all Main
                                                    Street borrowers.




                                                    Page 12                                                   GAO-25-107246 Federal Reserve Facilities
In contrast, businesses with annual revenues exceeding $7.7 million
accounted for about 54 percent of outstanding loans but 60 percent of all
Main Street borrowers (see fig. 3). This distribution generally aligns with
our findings in 2023. 23 It may reflect the varying abilities of businesses of
different sizes to fully repay their loans in advance, which we discuss
further below.

Figure 3: Percent of Outstanding Main Street Loans by Business Size, as of August
2024




Note: Percentages may not sum to 100 percent due to rounding. In this figure, percentages are
rounded individually for graphical presentation.
aThis subtotal percentage does not equal the sum of the two percentages it represents due to
rounding of the individual categories.


Regional distribution of outstanding loans. The regional distribution of
outstanding loans generally aligned with the overall distribution of all Main
Street loans. As of the end of August 2024, most of the program’s
outstanding loans were in the southern United States, particularly in
census divisions 5 and 7 (South Atlantic and West South Central) (see
fig. 4). 24 This concentration is consistent with our findings in 2023. 25



23GAO-24-106482, 31.

24The Census Bureau divides the United States into a variety of geographies for analytical
purposes. Regions are the largest geographic unit, dividing the country into four major
areas, with U.S. territories (other than the District of Columbia) not represented in a formal
region. Divisions are the second largest geographic unit, dividing the country into nine
major areas. As with regions, U.S. territories (other than the District of Columbia) are not
represented in a formal division.
25GAO-24-106482, 27.




Page 13                                                GAO-25-107246 Federal Reserve Facilities
When comparing the proportion of outstanding loans across census
divisions, both the number and dollar amount of outstanding loans varied
considerably across different regions of the United States. Across all
census divisions, census division 4 (West North Central) had the highest
percentage of loans outstanding by number and dollar amount in a
division. In this division, 59 percent of loans remain outstanding by both
number and dollar amount. Conversely, division 1 (New England) had the
lowest percentage of loans outstanding by both number and dollar
amount.

Figure 4: Outstanding Main Street Loans by Census Division, as of August 2024




Page 14                                     GAO-25-107246 Federal Reserve Facilities
Sectoral distribution of outstanding loans. The sectoral distribution of
outstanding loans also generally aligned with the sectoral distribution of
all Main Street loans. About 73 percent of outstanding loans were in
service-providing sectors, while about 27 percent were in goods-
producing sectors. This distribution is consistent with our findings in
2023. 26

Businesses in service-providing sectors accounted for the largest share of
outstanding loans, both by number and dollar value. The top sectors were
(1) leisure and hospitality and (2) trade, transportation, and utilities.
However, the percentage of loans outstanding within each sector varied.
Businesses in construction—a goods-producing sector—had the greatest
percentage of loans outstanding by both number and dollar amount, with
58 percent outstanding by number and 62 percent outstanding by dollar
amount (see table 2). In contrast, loans to businesses in leisure and
hospitality had the smallest share outstanding based on the number of
loans. The “other services” sector had the smallest share based on dollar
amount. This sector includes industries not classified within the defined
service-providing sectors, such as personal and laundry services and
repair and maintenance.




26GAO-24-106482, 27–28.




Page 15                                  GAO-25-107246 Federal Reserve Facilities
Table 2: Number and Dollar Amount of Outstanding Main Street Loans by Sector, as of August 2024

Sector                                                               Number of outstanding loans     Dollar amount outstanding, dollars in millions
                                                                        (% of all loans in sector)              (% of total loan amount in sector)
Service-providing sectors                                                             621 (44.5%)                                    $5,225 (40.0%)
      Leisure and Hospitality                                                         153 (39.7%)                                    $1,262 (36.8%)
      Trade, Transportation, and                                                      146 (45.8%)                                    $1,290 (40.8%)
      Utilities
      Professional and Business                                                       121 (48.6%)                                     $815 (37.3%)
      Services
      Financial Activities                                                             93 (48.9%)                                     $876 (46.2%)
      Education and Health Services                                                    43 (44.3%)                                     $506 (44.2%)
      Information                                                                      37 (40.2%)                                     $360 (39.7%)
      Other Services                                                                   28 (43.8%)                                     $117 (33.2%)
      (except Public Administration)
Goods-producing sectors                                                               225 (52.0%)                                    $2,263 (51.6%)
      Construction                                                                     97 (58.4%)                                     $696 (61.5%)
      Manufacturing                                                                    76 (45.0%)                                     $684 (40.0%)
      Natural Resources and Mining                                                     52 (53.1%)                                     $883 (57.2%)
Source: GAO analysis of Federal Reserve Bank of Boston data. | GAO-25-107246




Fully Repaid Loans                                           As of the end of August 2024, 850 loans (about 46 percent of all Main
                                                             Street loans) had been fully repaid. These loans accounted for about $8.8
                                                             billion (or about 51 percent) of the total authorized loan amount. These
                                                             totals reflect a year-over-year increase of 238 loans and about $2.8 billion
                                                             repaid since August 2023 (see fig. 5).




                                                             Page 16                                         GAO-25-107246 Federal Reserve Facilities
Figure 5: Number of Fully Repaid Main Street Loans, First Quarter 2021–Third Quarter 2024




Note: This figure reflects data through the end of August 2024, which only partially represents the third quarter of 2024.


                                                    Distribution of fully repaid loans by loan size. The distribution of fully
                                                    repaid loans by loan size generally aligned with the overall distribution of
                                                    loans made, as of the end of August 2024. The smallest loans (valued at
                                                    $1.2 million or less) accounted for about 18 percent of fully repaid loans,
                                                    while representing 20 percent of all Main Street loans. In contrast, the
                                                    largest loans (valued at more than $14.3 million) accounted for 22 percent
                                                    of fully repaid loans, while representing 20 percent of all Main Street
                                                    loans.

                                                    Distribution of fully repaid loans by business size. As of the end of
                                                    August 2024, loans to larger businesses constituted a slightly larger share
                                                    of fully repaid loans than those made to smaller businesses (see fig. 6).
                                                    Specifically, loans to larger businesses (those with annual revenues
                                                    exceeding $42.1 million) represented 20 percent of all loans but
                                                    accounted for nearly 25 percent of fully repaid loans. In contrast, loans to
                                                    smaller businesses (those with annual revenue of about $3.1 million or
                                                    less) accounted for 20 percent of all borrowers but about 16 percent of
                                                    fully repaid loans.




                                                    Page 17                                                  GAO-25-107246 Federal Reserve Facilities
Figure 6: Percent of Fully Repaid Main Street Loans by Business Size, as of August
2024




Note: Percentages may not sum to 100 percent due to rounding.


Regional distribution of fully repaid loans. As of the end of August
2024, fully repaid loans were concentrated in the southern United States,
consistent with our findings from 2023. 27 Borrowers in census divisions 5
(South Atlantic) and 7 (West South Central) fully repaid more loans, both
by number and dollar amount, than borrowers in other areas of the United
States. Fully repaid loans in Florida and Texas together accounted for
almost one-third of all fully repaid loans.

The percentage of loans that had been fully repaid varied across different
regions. Compared with other census divisions, division 6 (East South
Central) had the highest percentage of fully repaid loans by number (59
percent repaid), while division 1 (New England) had the highest
percentage by dollar amount (74 percent repaid). In contrast, division 4
(West North Central) had the lowest percentage of fully repaid loans,
measured by both number and dollar amount (see fig. 7).




27GAO-24-106482, 36.




Page 18                                              GAO-25-107246 Federal Reserve Facilities
Figure 7: Fully Repaid Main Street Loans by Census Division, as of August 2024




Sectoral distribution of fully repaid loans. As of the end of August
2024, about 80 percent of fully repaid loans were in service-providing
sectors, while about 20 percent were in goods-producing sectors. This
distribution generally aligns with our findings in 2023. 28 Across all sectors,
the percentage of fully repaid loans varied by both number and dollar
amount. The information sector and the leisure and hospitality sector had
the highest percentages of fully repaid loans, at about 59 and 56 percent,
respectively, by number of loans repaid. In contrast, the construction


28GAO-24-106482, 36–37.




Page 19                                      GAO-25-107246 Federal Reserve Facilities
                                                             sector had the lowest percentage of fully repaid loans, at about 32
                                                             percent (see table 3).

Table 3: Number and Dollar Amount of Fully Repaid Main Street Loans by Sector, as of August 2024

Sector                                                               Number of fully repaid loans     Dollar amount fully repaid, dollars in millions
                                                                        (% of all loans in sector)               (% of total loan amount in sector)
Service-providing sectors                                                             682 (48.9%)                                      $7,031 (53.8%)
 Leisure and Hospitality                                                              217 (56.4%)                                      $2,008 (58.6%)
 Trade, Transportation, and                                                           144 (45.1%)                                      $1,648 (52.1%)
 Utilities
 Professional and Business                                                            110 (44.2%)                                      $1,253 (57.3%)
 Services
 Financial Activities                                                                  80 (42.1%)                                        $810 (42.7%)
 Information                                                                           54 (58.7%)                                        $544 (60.0%)
 Education and Health Services                                                         47 (48.5%)                                        $597 (52.2%)
 Other Services                                                                        30 (46.9%)                                        $171 (48.7%)
 (except Public Administration)
Goods-producing sectors                                                               168 (38.8%)                                      $1,802 (41.1%)
 Manufacturing                                                                         76 (45.0%)                                        $952 (55.6%)
 Construction                                                                          53 (31.9%)                                        $330 (29.2%)
 Natural Resources and Mining                                                          39 (39.8%)                                        $521 (33.7%)
Source: GAO analysis of Federal Reserve Bank of Boston data. | GAO-25-107246



Losses Have Increased,                                       As of the end of August 2024, 138 loans (or about 8 percent of all Main
Particularly among                                           Street loans) had been partially or fully charged off, totaling about $969
                                                             million in recorded losses, a significant increase year-over-year (about
Smaller Businesses                                           $781 million). 29 Losses increased sharply during the fourth quarter of
                                                             2023, with that trend continuing through the second quarter of 2024 (see
                                                             fig. 8).




                                                             29Recorded losses reflect losses on the principal amount of Main Street loans.




                                                             Page 20                                          GAO-25-107246 Federal Reserve Facilities
Figure 8: Number and Dollar Amount of Main Street Loan Losses, Second Quarter 2021–Third Quarter 2024




Note: This figure reflects data through the end of August 2024, which only partially represents the third quarter of 2024. The dollar amount of losses
reflects losses on the principal amount of Main Street loans.


                                                   This significant increase in the number and dollar amount of losses may
                                                   reflect the effects of increased interest payments and the first of three
                                                   required principal payments coming due for Main Street loans. As we
                                                   reported in 2023, higher interest rates have led to increased interest
                                                   payments on outstanding loans for borrowers, potentially imposing
                                                   financial burdens on businesses. 30 The first principal payments, which
                                                   began in July 2023 and continued through early 2024, required borrowers
                                                   to pay 15 percent of their loan’s principal. The second principal payment
                                                   of an additional 15 percent came due for most borrowers during the
                                                   second half of 2024, which could lead to further losses. A balloon
                                                   payment of 70 percent of the loan’s principal will come due for the earliest
                                                   program participants in the second half of 2025.

                                                   Distribution of losses by loan size. Of the approximately 8 percent of
                                                   Main Street loans that have experienced losses to date, losses by loan

                                                   30GAO-24-106482, 33. Main Street loans are subject to adjustable interest rates based on
                                                   a benchmark rate (generally, the Secured Overnight Financing Rate). Interest rates have
                                                   generally stabilized since our 2023 report, but they may still be higher than borrowers
                                                   initially anticipated.




                                                   Page 21                                                  GAO-25-107246 Federal Reserve Facilities
size generally aligned with the distribution of Main Street loans at
origination. For example, loans valued at $1.2 million or less represent 20
percent of all loans and accounted for about 21 percent of charge-offs. In
addition, the largest loans (valued at more than $14.3 million), which also
represent 20 percent of all loans, accounted for about 18 percent of
charge-offs (see fig. 9). The largest loans represented 2 percent of all
losses when we last reported on losses in the Main Street program in
2023, which reflects the changing spread of losses year-over-year. 31

Figure 9: Percent of Main Street Loans with Losses by Loan Size, as of August 2024




Note: Percentages may not sum to 100 percent due to rounding.


Distribution of losses by business size. Loans to smaller businesses
accounted for a greater share of losses than loans to larger businesses,
as of the end of August 2024. Specifically, loans to Main Street borrowers
with annual revenue of about $3.1 million or less at the time of program
entry—the program’s smallest businesses—represent 20 percent of all
Main Street loans but about 28 percent of loans with losses to date. In
comparison, the program’s largest businesses, those with annual
revenues exceeding $42.1 million, also account for 20 percent of all loans
but about 14 percent of loans with losses (see fig. 10). These largest
businesses accounted for a smaller share of losses when we last
reported on Main Street loans, at about 2 percent. 32




31GAO-24-106482, 57.

32GAO-24-106482, 58.




Page 22                                              GAO-25-107246 Federal Reserve Facilities
                                                             Figure 10: Percent of Main Street Loans with Losses by Business Size, as of August
                                                             2024




                                                             Note: Percentages may not sum to 100 percent due to rounding.


                                                             Regional distribution of losses. As of the end of August 2024, census
                                                             region 3 (the South) accounted for the highest number and dollar amount
                                                             of losses in the Main Street program. 33 In this region, 81 loans
                                                             experienced about $581 million in losses, resulting in a charge-off rate
                                                             (that is, the number or dollar amount of loans charged off as a percentage
                                                             of total loans in a region) of about 9 percent by number of loans and
                                                             about 7 percent by dollar amount of loans. (See table 4.)




Table 4: Number and Dollar Amount of Main Street Loan Losses by Census Region, as of August 2024

Region                          Number of loans with losses                       Percent (%) of all   Dollar amount of losses, in Percent of total loan
                                   (number of loans made)                      loans in region that                         millions  amount in region
                                                                                have been charged           (total dollar amount of      that has been
                                                                                                off                    loans made)         charged off
1 (Northeast)                                                  17 (225)                       7.6%                  $115 ($2,419)                   4.8%
2 (Midwest)                                                    10 (290)                       3.4%                   $32 ($2,972)                   1.1%
3 (South)                                                      81 (927)                       8.7%                  $581 ($8,378)                   6.9%
4 (West)                                                       29 (382)                       7.6%                  $235 ($3,615)                   6.5%
Source: GAO analysis of Federal Reserve Bank of Boston data. | GAO-25-107246




                                                             33As noted earlier, the Census Bureau divides the United States into various geographies
                                                             for analytical purposes. We report losses by Census region rather than Census division
                                                             due to the smaller percentage of loans that have incurred losses, compared with
                                                             outstanding and fully repaid loans.




                                                             Page 23                                              GAO-25-107246 Federal Reserve Facilities
                          Sectoral distribution of losses. Loans with losses were concentrated in
                          service-providing sectors, which generally reflects the overall distribution
                          of Main Street loans. In particular, loans to the trade, transportation, and
                          utilities sector accounted for the most losses by number (28), while loans
                          to financial activities companies accounted for the highest losses by dollar
                          amount (about $213 million).

                          Certain sectors have experienced higher charge-off rates than others. For
                          example, based on dollar value, about 12 percent of loans made to
                          construction businesses have been charged off. The financial activities
                          sector had the second highest charge-off rate, about 11 percent by dollar
                          value. In comparison, most sectors have experienced lower charge-off
                          rates, ranging from about 3 to 6 percent.

Delinquencies Have        Delinquencies have generally increased over the course of the Main
Fluctuated as Principal   Street Lending Program’s life cycle, but they began to decline after the
                          fourth quarter of 2023 (see fig. 11). 34
Payments Have Come
Due and More Loans
Have Been Charged Off




                          34The Federal Reserve Bank of Boston defines delinquent payments as any interest or
                          principal payment that is 30 or more days late. We calculate the delinquency rate as the
                          ratio of delinquent loans to outstanding loans at a given time. Generally, our delinquency
                          rate refers to active Main Street loans only. It excludes charged-off loans, which are no
                          longer considered active despite remaining in the Main Street portfolio for potential
                          recovery during the 5-year term of the loan.




                          Page 24                                           GAO-25-107246 Federal Reserve Facilities
Figure 11: Number of Active Main Street Delinquencies, Fourth Quarter 2021–Third Quarter 2024




Note: This figure reflects data through the end of August 2024, which only partially represents the third quarter of 2024. Delinquency counts include all
instances as of each quarter, meaning individual loans may be represented multiple times.


                                                   Federal Reserve Bank of Boston staff told us they attribute this decline to
                                                   the fact that many delinquent loans were fully charged off, removing them
                                                   from the count of active delinquencies. Our analysis of charge-offs and
                                                   delinquencies shows that the charge-off rate in the second and third
                                                   quarters of 2024 exceeded the delinquency rate among active loans (see
                                                   fig. 12). This suggests that many delinquent loans were charged off and
                                                   recorded as losses. The losses in the first two quarters of 2024 occurred
                                                   after initial principal payments (15 percent of loan principal) came due for
                                                   most borrowers in the second half of 2023. Some loans may have been
                                                   charged off because borrowers were unable to make this initial principal
                                                   payment.




                                                   Page 25                                                   GAO-25-107246 Federal Reserve Facilities
Figure 12: Main Street Charge-Off and Delinquency Rates, First Quarter 2021–Third Quarter 2024




Note: This figure reflects data through the end of August 2024, which only partially represents the third quarter of 2024.

                                                    Distribution of delinquencies by loan size. Smaller loans accounted for
                                                    more delinquencies than larger loans as of the end of August 2024. The
                                                    smallest loans (valued at $1.2 million or less), which represent 20 percent
                                                    of all loans, accounted for about 22.4 percent of delinquent active loans.
                                                    In contrast, the largest loans (valued at more than $14.3 million), which
                                                    also represent 20 percent of all loans, accounted for about 14 percent of
                                                    delinquent loans.

                                                    Distribution of delinquencies by business size. Loans made to smaller
                                                    businesses accounted for more delinquencies than those made to larger
                                                    businesses. Specifically, loans to borrowers with annual revenue of $3.1
                                                    million or less represent 20 percent of all loans but accounted for about
                                                    30 percent delinquent active loans. Conversely, loans to larger
                                                    businesses, which also represent 20 percent of all loans, accounted for
                                                    about 11 percent of delinquent loans.

                                                    Regional distribution of delinquencies. The number of delinquent
                                                    active loans varied across U.S. regions. Census region 3 (the South) had
                                                    the highest number of delinquent active loans, with 66 loans (about 7
                                                    percent of the region’s loans). Although census region 1 (the Northeast)


                                                    Page 26                                                  GAO-25-107246 Federal Reserve Facilities
                  had fewer delinquent loans, at 16, its delinquency rate was equal to that
                  of region 3.

                  Sectoral distribution of delinquencies. More delinquencies occurred in
                  service-providing sectors than in goods-producing sectors, reflecting the
                  distribution of loans at origination. The trade, transportation, and utilities
                  sector had the most delinquent loans, with 27 active loans delinquent.

                  In contrast, other sectors had higher delinquency rates despite having
                  fewer delinquent loans. For example, while the construction sector had 15
                  active delinquent loans—tied for third highest of all sectors—it had a
                  delinquency rate of about 9 percent, which is higher than any other
                  sector.

                  We provided a draft of this report to the Federal Reserve and Treasury for
Agency Comments   review and comment. The Federal Reserve provided technical comments,
                  which we incorporated as appropriate. Treasury informed us it had no
                  comments.

                  We are sending copies of this report to the appropriate congressional
                  committees, the Chair of the Board of Governors of the Federal Reserve
                  System, and the Secretary of the Treasury. This report will also be
                  available at no charge on GAO’s website at https://www.gao.gov.

                  If you or your staff have any questions about this report, please contact
                  me at (202) 512-8678 or clementsm@gao.gov. Contact points for our
                  Offices of Congressional Relations and Public Affairs may be found on
                  the last page of this report. GAO staff who made key contributions to this
                  report are listed in appendix II.




                  Michael E. Clements
                  Director, Financial Markets and Community Investment




                  Page 27                                    GAO-25-107246 Federal Reserve Facilities
List of Committees

The Honorable Patty Murray
Chair
The Honorable Susan Collins
Vice Chair
Committee on Appropriations
United States Senate

The Honorable Sherrod Brown
Chairman
The Honorable Tim Scott
Ranking Member
Committee on Banking, Housing, and Urban Affairs
United States Senate

The Honorable Sheldon Whitehouse
Chairman
The Honorable Chuck Grassley
Ranking Member
Committee on the Budget
United States Senate

The Honorable Maria Cantwell
Chair
The Honorable Ted Cruz
Ranking Member
Committee on Commerce, Science, and Transportation
United States Senate

The Honorable Kyrsten Sinema
Chair
The Honorable James Lankford
Ranking Member
Subcommittee on Government Operations and Border Management
Committee on Homeland Security and Governmental Affairs
United States Senate




Page 28                               GAO-25-107246 Federal Reserve Facilities
The Honorable Tom Cole
Chairman
The Honorable Rosa DeLauro
Ranking Member
Committee on Appropriations
House of Representatives

The Honorable Jodey Arrington
Chairman
The Honorable Brendan Boyle
Ranking Member
Committee on the Budget
House of Representatives

The Honorable Patrick McHenry
Chairman
The Honorable Maxine Waters
Ranking Member
Committee on Financial Services
House of Representatives

The Honorable Sam Graves
Chairman
The Honorable Rick Larsen
Ranking Member
Committee on Transportation and Infrastructure
House of Representatives




Page 29                                GAO-25-107246 Federal Reserve Facilities
Appendix I: Objectives, Scope, and
              Appendix I: Objectives, Scope, and
              Methodology


Methodology

              The objectives of this report were to examine (1) the Board of Governors
              of the Federal Reserve System’s oversight and monitoring of the CARES
              Act facilities and (2) the status of Main Street loans and their
              characteristics and trends in loan performance.

              To address the first objective, we analyzed documentation from the
              Federal Reserve’s Division of Reserve Bank Operations and Payment
              Systems (RBOPS). This included its policies and procedures pertaining to
              the monitoring and controls of the CARES Act facilities. We reviewed
              planning documents and summaries of completed reviews of the facilities.
              We also obtained written responses from Federal Reserve officials on
              RBOPS’s framework and approach for ongoing monitoring of the facilities
              and results of RBOPS’s oversight reviews.

              We compared RBOPS’s monitoring plans against selected federal
              internal control standards, including the principles that management
              should establish and operate monitoring activities to monitor the internal
              control system and evaluate the results, and that management should
              remediate identified internal control deficiencies on a timely basis. 1
              Additionally, we reviewed the Federal Reserve’s periodic reports covering
              6-month periods from July 2023 to June 2024 and quarterly and annual
              financial statements for updates on potential and actual losses incurred
              by the Federal Reserve facilities. We also received written responses to
              discussion questions from RBOPS officials on their lending facility
              oversight and monitoring activities.

              To address the second objective, we conducted on-site reviews of Main
              Street Lending Program data at the Federal Reserve Bank of Boston. To
              assess the status and characteristics of and trends in Main Street
              Lending Program loans, we retrieved information from two data sources:
              (1) a compendium from the Reserve Bank of borrower information
              collected in the lender registration and participation review processes and
              (2) Main Street accounting records that are generated by a third-party
              contractor. The compendium included borrower information at loan
              origination, as well as borrower-reported payment information. The
              accounting records included information on loan positions, loan
              transactions from inception, and loan delinquencies. We reviewed and




              1GAO, Standards for Internal Control in the Federal Government, GAO-14-704G
              (Washington, D.C.: September 2014).




              Page 30                                       GAO-25-107246 Federal Reserve Facilities
Appendix I: Objectives, Scope, and
Methodology




analyzed participation data and loan-level payment data as of the end of
August 2024, the most recent data available.

We analyzed data from the program’s July 2020 inception through August
2024 to determine:

•   the number and dollar amount of Main Street loan payments,
    including interest and principal payments due and made;
•   the number and dollar amount of outstanding, fully repaid, and
    charged-off loans;
•   the number of delinquent loans; and
•   the distribution of outstanding, fully repaid, charged-off, and
    delinquent loans by their loan and business sizes.
In addition, we analyzed geographic and sectoral information for
outstanding, fully repaid, charged-off, and delinquent loans. For our
geographic analysis, we used Main Street program data to match loan
payment information as of August 2024 to geographic identifiers collected
from borrowers at intake. To avoid revealing borrower-specific
information, we aggregated geographic data at the census division level
for outstanding and fully repaid loans and at the census region level for
charged-off and delinquent loans. We reported the number of loans for
each status category and analyzed dollar amounts for outstanding, fully
repaid, and charged-off loans.

For our sectoral analysis, we used program data to match loan payment
information to North American Industry Classification System (NAICS)
codes collected from borrowers at intake. To avoid revealing borrower-
specific information, we aggregated Main Street borrowers’ designated
NAICS codes into sectors defined by the Bureau of Labor Statistics. We
further aggregated sectors into super-sectors. 2 We reported the number
of loans for each loan status (outstanding, fully repaid, charged off, and
delinquent) by sector and super-sector. We also analyzed and reported
dollar amounts for outstanding, fully repaid, and charged-off loans.



2According to the Bureau of Labor Statistics, NAICS codes can be grouped into 10
sectors: construction; education and health services; financial activities; information;
leisure and hospitality; manufacturing; natural resources and mining; professional and
business services; trade, transportation, and utilities; and other services. These sectors
can be further aggregated into super-sectors, which include a goods-producing super-
sector and a service-providing super-sector.




Page 31                                            GAO-25-107246 Federal Reserve Facilities
Appendix I: Objectives, Scope, and
Methodology




To understand the relationship between delinquent and charged-off loans,
we used Main Street loan performance data to calculate delinquency and
charge-off rates on a quarterly basis. We first identified the number of
outstanding, delinquent, and charged-off loans for each quarter from April
2021 to August 2024. We then generated the delinquency and loss rates
by dividing the number of delinquent or charged-off loans by the number
of outstanding loans for each quarter.

We assessed the reliability of the Main Street data we used by reviewing
agency documentation, including a data dictionary, and conducting
electronic testing for outliers, missing data, and erroneous values. We
also interviewed staff of the Federal Reserve Bank of Boston to discuss
the interpretation and reliability of various data fields and how data are
collected, stored, and maintained. We determined that the data were
sufficiently reliable for describing selected characteristics of Main Street
loans and payment performance.

We conducted this performance audit from December 2023 to December
2024 in accordance with generally accepted government auditing
standards. Those standards require that we plan and perform the audit to
obtain sufficient, appropriate evidence to provide a reasonable basis for
our findings and conclusions based on our audit objectives. We believe
that the evidence obtained provides a reasonable basis for our findings
and conclusions based on our audit objectives.




Page 32                                   GAO-25-107246 Federal Reserve Facilities
Appendix II: GAO Contact and Staff
                  Appendix II: GAO Contact and Staff
                  Acknowledgments


Acknowledgments

                  Michael E. Clements, clementsm@gao.gov, (202) 512-8678
GAO Contact
                  In addition to the contact named above, Tarek Mahmassani (Assistant
Staff             Director), Zamir Ruli (Analyst in Charge), Blake Faucher, Daniel Flavin,
Acknowledgments   John Karikari, Christopher Klemmer, Marc Molino, Jessica Sandler,
                  Jennifer Schwartz, and Farrah Stone made key contributions to this
                  report.




                  Page 33                                  GAO-25-107246 Federal Reserve Facilities
                         The Government Accountability Office, the audit, evaluation, and investigative
GAO’s Mission            arm of Congress, exists to support Congress in meeting its constitutional
                         responsibilities and to help improve the performance and accountability of the
                         federal government for the American people. GAO examines the use of public
                         funds; evaluates federal programs and policies; and provides analyses,
                         recommendations, and other assistance to help Congress make informed
                         oversight, policy, and funding decisions. GAO’s commitment to good government
                         is reflected in its core values of accountability, integrity, and reliability.

                         The fastest and easiest way to obtain copies of GAO documents at no cost is
Obtaining Copies of      through our website. Each weekday afternoon, GAO posts on its website newly
GAO Reports and          released reports, testimony, and correspondence. You can also subscribe to
                         GAO’s email updates to receive notification of newly posted products.
Testimony
Order by Phone           The price of each GAO publication reflects GAO’s actual cost of production and
                         distribution and depends on the number of pages in the publication and whether
                         the publication is printed in color or black and white. Pricing and ordering
                         information is posted on GAO’s website, https://www.gao.gov/ordering.htm.
                         Place orders by calling (202) 512-6000, toll free (866) 801-7077, or
                         TDD (202) 512-2537.
                         Orders may be paid for using American Express, Discover Card, MasterCard,
                         Visa, check, or money order. Call for additional information.

                         Connect with GAO on Facebook, Flickr, X, and YouTube.
Connect with GAO         Subscribe to our RSS Feeds or Email Updates. Listen to our Podcasts.
                         Visit GAO on the web at https://www.gao.gov.

                         Contact FraudNet:
To Report Fraud,
                         Website: https://www.gao.gov/about/what-gao-does/fraudnet
Waste, and Abuse in
                         Automated answering system: (800) 424-5454 or (202) 512-7700
Federal Programs
                         A. Nicole Clowers, Managing Director, ClowersA@gao.gov, (202) 512-4400, U.S.
Congressional            Government Accountability Office, 441 G Street NW, Room 7125, Washington,
Relations                DC 20548

                         Sarah Kaczmarek, Managing Director, KaczmarekS@gao.gov, (202) 512-4800,
Public Affairs           U.S. Government Accountability Office, 441 G Street NW, Room 7149
                         Washington, DC 20548

                         Stephen J. Sanford, Managing Director, spel@gao.gov, (202) 512-4707
Strategic Planning and   U.S. Government Accountability Office, 441 G Street NW, Room 7814,
External Liaison         Washington, DC 20548




                            Please Print on Recycled Paper.


File and source

File
federal-reserve-lending-programs-nearly-half-of-main-street-loans-repa.pdf
Size
1,220,196 bytes
SHA-256
1d167ffc385f985b7b92c1a93668abf9de5eb9e10a79b3bb77107b30e258a7b2
Our copy
federal-reserve-lending-programs-nearly-half-of-main-street-loans-repa.pdf
Original
www.gao.gov
Back to top