Main Street Lending Program Comments
Summary
A compilation headed Main Street Lending Program Comments, listing public comments in a table with columns for the question or comment, received date and ticket type. The entries read include comments received 4/9/2020 by email, such as a question about how to participate in the loan program announced on 04/09/20 and an observation that further regulation should make clear whether the mid-size business provisions of the CARES Act apply. Another comment asks that small home builders, who will not have access to capital, be considered. Commenter identifying information is withheld in the table.
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Cite this document
“Main Street Lending Program Comments.”
Original at www.federalreserve.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/federal-reserve-public-comments-1-pdf-www-federalreserve-gov-ceb531e3c-b88f406645/
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Main Street Lending Program Comments
Email Question / Comment
Received Date Ticket Type Last Name First Name Address Affiliation
Identifying Information Withheld How can we participate in the loan program that was announced on 04/09/20?
4/9/2020 12:00:00
AM PIO (Email from
Two observations- further regulation should make clear whether the mid-size business provisions contemplated in the CARES Act apply here
Identifying Information Withheld (I.e., the good faith certification requirements) and whether the employee compensation limitations of section 4004 apply.
4/9/2020 12:00:00
AM PIO (Email from
Please take care to consider Small home builders who will not have access to capital to continue projects. I in particular have 2 developments
Identifying Information Withheld in the works that can not be stopped and access to capital is imperative in keeping hundreds of blue collar workers/contractors employed
4/9/2020 12:00:00 while the market recovers. Builders need large amounts of capital to continue operations which is historically tough for small builders to obtain
AM PIO (Email from in great markets, let a lone down markets. Thank you
- Need liquidity for real estate owners. Our tenants need relief, but we need liquidity support to be able to pay our lenders while we work
through COVID.
Identifying Information Withheld - We also need some personal liquidity during COVID. We live off of rental payments we are not likely to receive near term and all available
cash + reserves are going towards servicing debt, keeping the properties in good condition, and paying our third party vendors / suppliers.
- The proposed terms of the Main Street program look like a damn near perfect solution for us, if we qualify.
- I appreciate all of the hard work and thought yall are putting into this. You have a tough job, but what you are doing is helping people and
4/9/2020 12:00:00 saving their businesses.
AM PIO (Email from
Small-scale entrepreneurs and small business owners are being left out. Identifying Information Withheld
There are hundreds of thousands
like me. I need at least $100K to get me through the next 9-months, with my credit score still intact and my family fed, paying the bills of two
businesses and my family; but, so far no resources have been designed for me. A $1,000 advance on an EIDL, if it ever arrives, isn't
going to do anything.
What I need is a cheap line of credit up to at least $100,000. Liquidity now is more important than forgivability later. Make lines of credit
available to everyone who has a business checking account that has been active over the past 12 months. Make them available asap, by
Identifying Information Withheld working directly with small business owners or through the banks that hold their checking accounts. Figure out the terms and details, the rest
of the rulemaking after. Give these entrepreneurs flexibility to make it through this period with confidence.
It is much more important to keep large banks and corporations honest on the much larger amounts of assistance they will require than it
4/9/2020 12:00:00 would be to try to keep small business owners "honest" at $100,000 or so apiece.
AM PIO (Email from
Identifying Information Withheld On the proposed Main Street lending Program, Can you clarify on the SOFR? Quotes on those today run from 30 day at 0.27 to 180 day at
4/9/2020 12:00:00 1.37. Need to know if the act states which one; 30 day, 90 day, 180 day or Index rate.
AM PIO (Email from
RE: The Main Street Lending Program - Am I correct that there is no "forgiveness" feature? We are to keep people on the payroll -
LOSING money in the process - and the federal government will loan our company the money with which to do it?? I can draw on my credit
Identifying Information Withheld lines to borrow money to fund paying employees I don't need while business activity is down - but why should I do that?? Why is there
not a forgiveness feature as in the program for companies with fewer than 500 employees?? Or am I missing something? Thanks.
Name
4/9/2020 12:00:00
AM PIO (Email from
Feedback: As a small business we have maintained our revenues at $9M/year and in 2018 we had a troubled project and had a loss of 600K.
Identifying Information Withheld We started 2019 on a good note and made a small profit but revenues went down to $7M due to not being able to get a bank small business
loan even though our projections were solid. Therefore we had to pass up business that could have doubled the size of our business. We still
4/9/2020 12:00:00 have that opportunity but I would recommend that Banks not read into the prior year losses if the follwoing year and projections show gains.
AM PIO (Email from
Identifying Information Withheld For the purpose of the "Main Street New Loan Facility" just announced this morning, what is the definition of
4/9/2020 12:00:00 "employee"? I have been looking through Federal Reserve materials and guidance, and I cannot find a bright line definition. Thank
AM PIO (Email from you.
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Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
Identifying Information Withheld Good morning, I am inquiring about how to apply for the Main Street Lending Program available for small business?
4/9/2020 12:00:00 Thank you,
AM PIO (Email from Name
For a pass-through entity (such as an S Corp), tax distributions are a necessary part of business in order to cover income taxes each year
Identifying Information Withheld that flow through to the shareholder(s). While I agree there should be restrictions on the equity distributions to protect the borrowed funds, I
believe it is more appropriate to allow certain distributions, such as based on the taxable income of the entity. This cash flow demand can
4/9/2020 12:00:00 have just as much impact on a entity's ability to stay afloat as having to pay employees for their time worked.
AM PIO (Email from
Commercial mortgage reits and business development companies are basically the banks of small and mid sized businesses. These
Identifying Information Withheld
4/9/2020 12:00:00 companies play an important role in the economy and should not be allowed to fail. Consider working with banks to prevent margin calls in the
AM PIO (Email from short term on these companies.
4/9/2020 12:00:00 Identifying Information Withheld Where do I apply, we need a $2M - 4 yr Loan to retain our 100% US Citizen Employees of 12
AM PIO (Email from Identifying Information Withheld
Following up on my recent inquiry to clarify. The "Main Street New Loan Facility" is open to eligible borrowers "with up to
10,000 employees." How is the level of employees calculated under the facility? Is there a definition of "employee" that the
Identifying Information Withheld Federal Reserve uses that draws a line between full-time employees and part-time employees, or are both categories included for the
purpose of calculating employee levels under the facility? Additionally, does the Federal Reserve utilize the Small Business
4/9/2020 12:00:00 Administration's method of including affiliates, subsidiaries, etc. in calculating employee levels? Thank you.
AM PIO (Email from
many wholesalers and retailers use Asset Based Loans (ABL) to finance operations. these often exceed the ebitda limitation particularly at
peak seasonal times. the shutdown in retail occurred at the peak of the spring retail season leaving many with high ABL balances and
inventory stalled in warehouses.
4/9/2020 12:00:00 jriedman@ph Phoenix i would ask the committee to exclude ABL balances from the ebitda limitation on the proposed term sheet. ABL facilities, by their nature are
AM PIO (Email from Riedman James xg.com Footwear Group not ebitda driven. moreover, with the trade war (tariffs) the retail sector is especially in need of liquidity / consideration.
Identifying Information Withheld Our law firm represents Identifying Information Withheld
4/9/2020 12:00:00 closed. The tribes are paying for all employees costs and maintaining the current payroll. How can these mid-size businesses apply for
AM PIO (Email from financing under the new Main Street Lending Facility? Thank you.
Dear Federal Reserve Board of Governors -
It is imperative the Main Street Lending Program be DELAYED UNITL AFTER the 100% of eligible small businesses' PPP loans have
been processed.
Banks claim to be unable to process the PPP loans due to volume and kludginess of SBA intake system. However, EIDL and PPP loan
request processing is being prioritized by bankers' self-interest in their commissions and their banks' profitability, rather than on
first-come, first-served basis and the applicant business' ability to both continue generating revenue, albeit at a lower level, and
accelerate innovation under current conditions. Please do not push the PPP loan applications further down the economic stimulus allocation
ranks.
We would like the PPP loan to fund our devoting time and effort to generate proposals in response to government RFPs as well as building
intangible assets (educational content, interactive tools). Securing PPP loan would alleviate our cash-flow concerns, so that we could invest
our savings in hiring part-time support to assist with proposal response packages, purchasing equipment from local retailers and U.S. based
manufacturers, and and outsourcing web-development to local firm.
Identifying Information Withheld
Respectfully,
4/9/2020 12:00:00
Name
AM PIO (Email from
The CARES Act appears to restrict dividends/distributions to common stock shareholders. For S Corporations and partnerships, income is
distributed to shareholders/partners on their K-1s and taxes are paid by the shareholders/partners. The companies generally distribute funds
Identifying Information Withheld to the shareholders/partners to pay the taxes on the related income. Will there be a ruling that indicates that distributions for tax payments on
4/9/2020 12:00:00 the business' income will be excluded from the restriction, so these types of distributions can be made without being precluded from
AM PIO (Email from participating in this loan program?
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Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
Is there any flexibility allowing banks to use this not just for EBITDA positive companies, but for companies that they deem financially sound
through other measures?
Many start-ups are not EBITDA positive and will not be able to benefit from this program. Many are also going through material layoffs (see
here: https : //techcrunch.com/tag/layoffs/ , and here: https : //candor.co/hiring-freezes/).
Although I don't believe the Fed should be a substitute for VC funding, I do believe that software companies with recurring revenues
should be able to benefit from this program, but currently cannot based on the EBITDA based calculation. For context, banks provide two
forms of debt to software firms. Monthly Recurring Revenue based Line of Credits that calculate availability based on a multiple of recurring
revenue and balance that by ensuring there is at least 6 months of liquidity on the balance sheet. Or term loans that have no liquidity
covenants but have rates between 10-15%. The reason why recurring revenue is measured rather than EBITDA is because acquiring a
Identifying Information Withheld
customer is expensive and it typically takes 2 years to breakeven, followed by 5-10 years of profit. As a result, most software companies
4/9/2020 12:00:00 scaling are EBITDA negative, but are generating bases of recurring revenue that act as a profitable annuity stream after the 2 year breakeven
AM PIO (Email from period. This is how great software firms like Salesforce.com began.
Identifying Information Withheld Hello, I am wondering when I can apply for the Main street lending program for my client who is in need! I would like to know where to apply.
4/9/2020 12:00:00 Thank you for your help!
AM PIO (Email from
Identifying Information Withheld
I applied for disaster assistance the first day it was available, and for over three weeks have not
Identifying Information Withheld heard a single thing. I've been trying to apply for PPP, but banks are not excepting applications. This is so frustrating, and it feels like
The biggest corporations that don't need the money I'm getting the loans in the small businesses are being hung out to dry. I hope
4/9/2020 12:00:00 this new program actually helps small businesses instead of another program we don't have access to
AM PIO (Email from
I encourage you to expand this program to cover smaller loans because small businesses need MEANINGFUL financial help beyond payroll
and benefits. The PPP and EIDL are not small business rescue packages. They are "keep you workers off unemployment"
packages.
I was expecting an EIDL loan based on the information I provided on Form 1368. A reasonable loan offer from the EIDL based on the financial
information I provided would have been around $300,000. That would have saved my business.
Instead, the SBA kneecapped the EIDL to an initial $15k maximum payout per applicant (per the MA SBA office documents). They also
changed the expected $10k advance business owners were expecting to an arbitrary amount $1000 per employee, up to a maximum of 10.
"One size fits all" is the worse solution possible to this situation, but that's the "relief" small businesses were
presented with via the EIDL.
Most buisnesses will take the PPP instead. Slightly better than the $30k max offered by the EIDL but can only be used for payroll, rent and
utilities.
These lending programs were designed to save workers, not businesses.
Personal Email Thomas None of the lending programs launched for small businesses offer sufficient funding to pay off the arrears I am with my shipping carriers,
Address
4/9/2020 12:00:00 Management suppliers and other creditors. I've no idea what happens at the end of June when my PPP loan money is exhausted and I'm
AM PIO (Email from Boswell Holly Inc. deeper in the hole with my creditors.
I would encourage that a portion of this program be designated for the community banks. Whether that would be reserving a portion of the
funding for smaller institutions or having a stream-lined process, I am not sure what would be best. I see the positive impact of the PPP loans
Identifying Information Withheld
4/9/2020 12:00:00 and think this could have a similar impact in our communities. I would encourage to take what works from the PPP program and enhance it
AM PIO (Email from for this and future programs to help our small businesses through this trying time.
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Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
There should be a special program for small bar and restaurant owners like me who don't have an option to serve food and beverages to
go. My employees are making below minimum wage as tipped employees and are literally getting screwed by the system here. Where's
your compassion? Where's your sense of humanity? Sure, I can cut them tiny checks based upon their previous wages, but it was a
pittance because they aren't getting tips. To make matters worse, most don't qualify for unemployment. You are leaving out a
whole segment of the economy by supporting these big bloated corporations and ignoring the small businesses (their people) that are an
extremely important segment of the economy. More money for the stakeholders and shareholders. Ignore the people that are really hurting.
Your stimulus will only serve to make the rich much richer. All stimulus packages should have a requirement that you must prove that you lost
business in order to qualify. Inflammatory Language
Identifying Information Withheld
4/9/2020 12:00:00
AM PIO (Email from
I understand that the Main Street Lending Program is designed to assist companies in good financial standing before the crisis. Our firm is in
the business of real estate development. Given the current crisis, we have been unable to raise sufficient debt or equity to advance our
projects. However, construction has been deemed an essential business in most jurisdictions and there is an ongoing housing shortage,
Identifying Information Withheld
which will no doubt be exacerbated by the crisis. As such, we have a series of single purpose companies that own real estate ready for
4/9/2020 12:00:00 development, but has no historical financial performance. If we got a loan through the program, we could advance the projects and be ready
AM PIO (Email from with no real estate product when the crisis subsides. Thanks for the consideration.
First, THANK YOU for all the efforts in helping America and Americans.
As I read as much as I can on the different support programs, I would like to know if a program exist to help those that are employed but are
Identifying Information Withheld compensated based on commissions alone.
Such individuals could see little to no income due to business shut down to public and unable to transact business.
If this is covered in one of the programs, would you please advise.
4/9/2020 12:00:00 Again, thank you for the Fed's tremendous support and for this consideration.
AM PIO (Email from Name
I would like to express my concerns related to the minimum loan amount and maximum term of the loan funded through this programs. As a
single location retail business we (and I assume many other businesses) seem to be stuck between the SBA lending programs and this main
street lending program. Our high overhead costs make the SBA PPP too small to provide a amount of funds needed to sustain operations
while our revenues (normally around 13-15 million annually) are artificially reduced to zero due to stay at home orders. The main street
lending program could be a solution but it seems as if it is targeted toward larger businesses with more revenue as the minimum calculated
monthly payment on the minimum borrowing amount (28,000-30,000) would be a large burden on cash flow and could easily lead to a
robbie@chris prolonged death spiral. We feel many business on the edge between these to programs are going to be left behind. Reducing the minimum
4/9/2020 12:00:00 tmasplace.co Christmas Place, borrowing amount or lengthening the term could alleviate this issue.
AM PIO (Email from Watson Robert m Inc.
Thanks for rolling out the new Federal Loan Program that can run in concurrence with the PPP program. It looks like this is being offered to
companies that had a positive EBITDA in 2019. Identifying Information Withheld
Identifying Information Withheld Our employees are considered essential employees
and assisting families, elderly and the sick through this crisis. We had net loss in 2019 because we were building the company and
infrastructure for growth to allow us to reach out and positively impact as many lives as possible. So because we are a high growth company
that invested in people and technology for future growth we are not able to take advantage of this new program. I think we need to look at it
by industry, and if a company has strong profit margins and is in an industry that is helping with the crisis, there needs to be a different
Identifying Information Withheld
program tailored for them so they do not go out of business during this critical time of need. Happy to further discuss and I appreciate you
4/9/2020 12:00:00 listening to me on this topic. Best Regards, Identifying Information Withheld
AM PIO (Email from
Are companies allowed to use EBITDA as defined in Credit Agreement covenant calculations? In other words, may we apply add-backs to our
EBITDA calculation as governed by our existing credit facility?
Identifying Information Withheld Can convertible notes be excluded from a company's Existing Debt total as it has the intent to convert to equity?
4/9/2020 12:00:00 Thank you,
AM PIO (Email from Name
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Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
Millennium Physician Group is one of the largest independent physician practices in the state of Florida, currently in the front line of the
COVID-19 Pandemic. Our organization participates in valued based payment models with CMS and maintains an Accountable Care
Organization (ACO) of which we have been #1 and #2 for 2017 and 2018, respectively in earned shared savings for the Medicare Program.
We are also eligible for the Medicare and CHIP Reauthorization Act of 2015 (MACRA) which is designed to shift Medicare physician
payments from a system based on fee for service to one based on value and quality. CMS pays and distributes the ACO earned shared
savings award and the MACRA earned payments 10 months and 12 months, respectively, after each calendar year end period. During this
period, our organization maintains a line of credit and a temporary bridge loan with a financial institution to support the organization's
finances and working capital. As such, due to our outstanding balances on the line of credit and bridge loan, we may not qualify for the Main
joseph.biscar Millennium Street Expanded Loan Facility. We ask that the staff of the Federal Reserve to consider the right of off-set to the bridge loan related to our
4/9/2020 12:00:00 di@mpgus.co Physician Group, ACO earned shared savings award and MACRA earned payments so that this loan will not count as debt in Section 5(iii) of the Main Street
AM PIO (Email from Biscardi Joseph m LLC Expanded Loan Facility guidance letter.
Identifying Information Withheld Please consider allowing companies to use 2018 or 2019 EBITDA for the loan calculation. This will allow for companies that maybe had
4/9/2020 12:00:00 anomolistic years in 2019 in the negative to still be able to apply for meaningful loans as part of the Main Street Lending Program. Thank you.
AM PIO (Email from
Identifying Information Withheld
Identifying Information Withheld
Unfortunately, that quantum of debt has a small universe of buyers, resulting in costs that will be outrageous to either amend our covenants
4/9/2020 12:00:00 (at a time when liquidity is of utmost importance) or to refi our debt (in the form of much higher interest rates). Please reevaluate the rules of
AM PIO (Email from your programs.
jsellers@yav 1. What is upsizing
4/9/2020 12:00:00 apairegionalc Yavapai 2. What is the logic of having the two facilities.
AM PIO (Email from Sellers John apital.com Regional Capital
My company needs to find a resource to answer questions about the Main Street Lending Program,specifically in relation to whether we must
use banks that hold existing debt, and whether the "uncommitted funds" calculation is different for a collateralized facility.
Additionally, we would like an understanding of the "reasonable efforts" to preserve employment.
Identifying Information Withheld Thank you
Identifying Information Withheld
4/9/2020 12:00:00
AM PIO (Email from
4/9/2020 12:00:00 dpatel@triarti the definition of EBITDA should be the definition of ebitda in credit agreements which should be adjusted for certain items.
AM PIO (Email from Patel Dishen san.com
The press release says:
Eligible banks may originate new Main Street loans or use Main Street loans to increase the size of existing loans to businesses
however, the lending term sheet says:
lee@office- New and Expanded Loans must be originated prior to April 8, 2020.
4/9/2020 12:00:00 warehouse.c
AM PIO (Email from Merritt Lee om Merritt Properties Also, please lower the $1M lower limit.
Thank you for putting together the Mainstreet Lending Program. Section 4003(c) of the CARES Act reads:
"(F) the agreement provides that, until the date 12 months after the date the loan or loan guarantee is no longer outstanding, the eligible
business shall not pay dividends or make other capital distributions with respect to
the common stock of the eligible business;"
Many of my clients are S Corporations and LLC's that distribute money solely to pay taxes. This restriction would suggest that a pass
Identifying Information Withheld through entity can not distribute for taxes. Can you please clarify? I would suggest clarifying that pass through entities may distribute an
4/9/2020 12:00:00 amount not to exceed the lesser of 50% of the entities taxable income and quarterly taxable income for estimated taxes. Thank you.
AM PIO (Email from
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Main Street Lending Program Comments
Identifying Information Withheld The facility
operates as a full time school and dormitory. Prior to Covid the school was performing according to its projections. Due to Covid there ability
to fund a critical phase two plus the new admissions have come to a stop. There projections although on target was not expected to be
profitable at this point. Therefore they do not have a positive EBITDA. Therefore are they locked out of participating in the Main Street lending
program?
thank you
Identifying Information Withheld Identifying Information
Withheld
4/9/2020 12:00:00
AM PIO (Email from
4/9/2020 12:00:00 Identifying Information Withheld Let CDFIs participate in this program. We are capital-stressed, but we are more nimble than traditional banks when assessing troubled
AM PIO (Email from businesses.
In order to stop the spread of this virus and protect society as a whole, small and medium sized business were forced to close, losing
100's of 1000's of dollars in revenue, but all of our overhead and fixed liabilities were not similarly curtailed. My rent still needs to
be paid, so do my credit cards, utility bills and interest on loans. This is, without a doubt, unfair. If can't collect revenue, than the
interests further up the food chain shouldn't be able to either. We took it on the chin to help, now the society we helped save must step
up and help us without a huge hit to us and make us whole. Burdensome "loans" with high interest rates and short payback terms
Identifying Information Withheld are not fair. The only message they send is that the next time this happens, we don't close, society be damned. If it's us or them,
4/9/2020 12:00:00 I'm going to choose myself and my family first. Do the right thing, make us whole.
AM PIO (Email from
Identifying Information Withheld This is labeled to help small businesses but why is the minimum loan 1 million. Would love a 4 year loan but the interest on a million would
4/9/2020 12:00:00 cost 25-40k a year.
AM PIO (Email from
Thank you for the Main Street Program. It is the best program I've seen so far for helping medium sized businesses. My only question
is why the Main Street Expanded Facility would penalize those companies with more conservative leverage. The restriction of "30% of
the Eligible Borrower's existing and outstanding and committed but undrawn bank debt" ultimately means a company with lower
Identifying Information Withheld leverage will be able to borrow less than a company with higher leverage. That doesn't seem to make sense. Why penalize companies
4/9/2020 12:00:00 who have historically been more measured in their use of debt and therefore have smaller debt facilities currently?
AM PIO (Email from
I am a 1099 contractor, sole proprietor started in March 2019. Identifying Information Withheld
I feel that I play an important role as a participant in the investment and growth in our economy. I do not feel going to work for someone or
Identifying Information Withheld applying for unemployment would help create value in the big picture.
4/9/2020 12:00:00 How can you create a bridge or assistance for individuals like myself whose jobs is to increase value and create investment?
AM PIO (Email from
4/9/2020 12:00:00 Identifying Information Withheld Hi, I am wondering if it is possible to look up if a company applied for/was granted a Paycheck Protection Program loan based on the
AM PIO (Email from company's tax ID. Basically, I am wondering if it is public information who applied for/was granted the loan. Thank you.
Please consider a tiered structure for The Main Street Lending Program. Meaning, going from 500 to 10,000 employees (upto $2.5B in
annual revenue) does not seem reasonable.
Identifying Information Withheld Maybe a tier of 500-2000; 2000-5000 and 5000-10,000 employees
4/9/2020 12:00:00 The lower tiers could have longer term than 4 years; better rates and a forgivable portion.
AM PIO (Email from Can't see how a business with 10,000 employees and $2.5B revenue can be considered "mid sized"
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Main Street Lending Program Comments
I appreciate the offering but have two requests i would like to make:
1) for many companies a line of credit facility would be a better choice. Yes it is true that on the lender's balance sheet it needs to
account for the full amount, even if i take less than the line, but the benefit in making sure borrowers are doing so smartly and that lenders are
not excessively lubricating the economy is in my opinion a very smart business model and one i would prefer over a lump sum that may not
need to be used all at one.
2) Facility Fee and the Origination Fee. Please don't be naive enough to think that the lender is not going to charge the borrower the
Facility Fee given you have hinted as such. On top of that the lender is also paying an Origination and Servicing Fee. Sadly the combined
amount of 2% points is way too expensive. Any company capable of getting this loan because EBITDA is strong enough should be able to
negotiate, in what otherwise would be normal loan negotiations between a lender and a borrower, with the bank an all in servicing and
origination of no more than one percent . . . even less and i can testify as such. Given the amount we are talking about, millions of dollars, the
jrc@jeffreest 2 percent is unduly pricey and really unnecessary.
4/9/2020 12:00:00 arcosmetics.c Jeffree Star
AM PIO (Email from Cohen Jeffrey om Cosmetics, Inc. Thanks for asking for our thoughts. That means a lot to me in these times.
Identifying Information Withheld I want to verify that what I read on your website was accurate. Firms that have received PPP funds can also qualify for loans in the new Main
4/9/2020 12:00:00 Street New loan facilities....not just the companies that were too big for the PPP. Thanks.
AM PIO (Email from
Sorry I may have picked to wrong area. SBA CARES Act.
My concern is for the businesses that retain and pay their workforce, however they still collect a monthly fee from their customers and apply
for government reimbursement.
Example. (Health Club that pays their employees during the stay at home order, but continue to charge the customer base a monthly fee).
There are many industries such as car washes etc. which people have paid a monthly fee, still charge you, however they apply for relief.
Identifying Information Withheld How are you going to verify that companies are NOT collecting funds from their customers during this period.
4/9/2020 12:00:00 Thank you-Name
AM PIO (Email from
Identifying Information Withheld
Identifying Information Withheld
4/9/2020 12:00:00 We can help stand-up from the an operational standpoint Main Street Lending for the Facility.
AM PIO (Email from Thank you, Name
Please make sure this program steers clear of the SBA rules on percentage of revenue from legal gambling.
Identifying Information Withheld
4/9/2020 12:00:00 4 years should be a guideline for minimum term, but the actual lender should set the actual length. The smaller the company in this program,
AM PIO (Email from the more onerous an actual 3-year repayment will be.
Many small business lenders are "non-bank" lenders who are otherwise regulated entities but are not banks, bank holding
companies or savings and loan companies and therefore cannot make Main Street Loan program loans based upon current anticipated rules.
Identifying Information Withheld
Identifying Information Withheld the small business community to allow non bank lenders - perhaps those who qualify as lenders under the Payroll Protection Program - which
program allows non bank lenders who meet certain qualification to make PPP loans - to also make Main Street Lending Program loans.
4/9/2020 12:00:00 Please consider this and incorporate into any Main Street Lending Program bill.
AM PIO (Email from
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Main Street Lending Program Comments
Identifying Information Withheld
I am writing to you in an effort to bring immediate attention to a problem regarding funding support under the COVID-19 Federal Relief plan for
our industry. The government has deemed our industry (health, wellness and beauty) as non-essential. As such, we have been ordered to
close our Identifying Information Withheld Identifying Information
Such closure directly impacts not only our Wi hheld who are, in fact, small businesses, but
also the Identifying Information Withheld salon professionals who operate within our locations. While the federal government is attempting to provide
emergency funding to the self-employed salon professionals, the relief programs offered through the SBA falls short of supporting the
businesses where those same salon professionals actually work since IdentifyingWithheld
Information
is not on the SBA franchise directory. Should
these salon suite businesses fail, you are contributing to the underlying failure of the same salon professionals you are attempting to support
through government backed programs. Unfortunately, the government's decision to support small businesses through SBA's
Identifying Information Withheld limited definition of a qualified business is directly inhibiting the ability for salon suite businesses to survive this crisis. Thank you for
understanding the need for additional resources to be provided outside the strict guidelines of the SBA. I look forward to your response.
4/9/2020 12:00:00 Sincerely yours, Name
AM PIO (Email from
To whom it may concern,
I am currently interviewing financial institutions to establish a long-term business relationship for a soon-to-be-formed acquisitions company
based in Identifying Information
Withheld
The structure of our company will be that of a holding company overseeing many acquisitions so we would want a financial institution that is
comfortable with acquisitions.
If you could provide brief answers to the following questions, I would be glad to send you a one-page Executive Summary of our business
model and brief Bios of my Board of Directors. I would then like to set up a brief interview to discuss further.
1. Do you foresee any conflicts?
2. Are you currently in a lending mode?
3. What are your basic policies on asset-based lending vs. cash flow lending?
4. We're looking for an institution that may also refer us possible acquisitions. What services could you offer?
Regards,
Identifying Information Withheld
Identifying Information Withheld
4/9/2020 12:00:00
AM PIO (Email from
These terms do not meet the needs of midsize companies that have been completely shut down at this time. We have a $45M facility
currently and unfortunately our EBITDA which historically had been $24M decreased to $12M in '19 as we invested ahead of the curve
on some revenue streams. The constraint on the EBITDA multiple adding in existing debt is insufficient. We have not furloughed anyone and
Identifying Information Withheld are projecting to lose $60M sales during the closure period. We need $25M - $35M and TRE formula doesn't work for us. We are a
4/9/2020 12:00:00 great company capable of being $1B plus while employing thousands and doing good in the community. Do not punish us for having a growth
AM PIO (Email from balance sheet that can't sustain this.
Regarding the new term sheet for the Main Street Lending Program released today (https :
//www.federalreserve.gov/newsevents/pressreleases/files/monetary20200409a6.pdf), if a business's maximum allowable loan is
negative (because it is a startup with negative EBITDA), is it still eligible for a $1M loan?
Identifying Information Withheld
4/9/2020 12:00:00 Aka, where the minimum and maximum loan amount conflict (because the maximum is below the minimum), will a business still be eligible for
AM PIO (Email from the $1M amount?
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Main Street Lending Program Comments
Good evening,
What happens to businesses like mine? PPP does not work because I have so many folks that work for me that there are independent
contractors. I have no payroll neither do I pay myself as a CEO of a company.
I'm borrowing from my home line of equity to put money in my business so I can pay workers. Please think about those companies that
don't have employees but they have a lot of independent contractors and they have great assets and they just need loans to be able to
continue operating.
Can we borrow if we can showcase assets and income to be able to pay those loans back. That's all I ask. Unfortunately banks
Identifying Information Withheld aren't receptive at this moment. Thank you for your time and consideration.
4/9/2020 8:06:00 Thank you
PM PIO (Email from Name
The terms of the Main Street Lending program do not meet the needs of midsize companies that have been completely shut down at this time.
Identifying Information Withheld
4/9/2020 12:00:00 We made the decision to retain our associates, in the spirit of the CARES Act, but the maximum loan size is insufficient incremental liquidity
AM PIO (Email from for us to survive this crisis.
We are in favor of additional lending to continue to fund and support our family business as well as those that we employ. We have had to let
go 5 staff members in this time of crisis and cut business back. We are afraid that we may not be able to reopen our doors, even though a lift
4/9/2020 12:00:00 chris@olivina on "shelter in place" may happen soon. The lasting effects of this pandemic will alter small business America for some time!
AM PIO (Email from Schobert Christopher taproom.com Olivina Taproom
Strongly opposed to the fed providing forgivable loans to private equity/venture backed companies. Private equity shops took out dividends
4/9/2020 12:00:00 Identifying Information Withheld and levered up those companies over the last decades. Their equity should be wiped out first before the fed steps in to support the
AM PIO (Email from company's workers. In any case, equity and debt investors should be wiped out first!
Identifying Information Withheld Hello. I own a Smart Home Audio Video integration firm. We have been impacted by the Covid-19 virus and we are seeking a 4 year loan.
4/9/2020 12:00:00 Unfortunately my personal credit is not good. How can I get a loan? Can someone please assist me?
AM PIO (Email from
Hello I am a Identifying Information Withheld I have a partner that helped me get started
but we were ineligible for the PPP loan as my partner informed me last week that he may have defaulted on a SBA backed loan.
Please make the Main Street funding available to anyone who qualify based on credit. My credit score is almost perfect. I have paid all my
Identifying Information Withheld bills since I had credit.
4/9/2020 12:00:00 It's unfortunate I get slapped on the wrist and am not able to take advantage of the PPP and keep my employees employed.
AM PIO (Email from
Thank you for your efforts to detail and implement the Main Street Lending program. I would like to ask for some clarifications.
1 - The announcement and term sheets seem to indicate that the MSL facility must acquire exactly 95% of a qualified loan and the lender
must retain exactly 5%. Is that the case, or can the lender retain more than 5% and sell less than 95% participations?
2 - With the lender retaining at least 5% of the loan, may the lender (a) impose additional financial covenants and (b) charge additional fees?
3 - Can you confirm, subject to the EBITDA leverage test, that borrowers may access both the MSL program and the SBA-backed Payroll
Protection Program?
4 - Under the SBA programs, there is the concept of "affiliation" to determine a borrower's size. Those rules are highly
problematic for thousands of small and mid-sized businesses that have historically raised equity capital. Can you confirm that as a Federal
Identifying Information Withheld Reserve program and not an SBA program, that the affiliation rule regime will not apply?
5 - Please confirm that lenders and borrowers are free to engage in a new loan from the MSL program on the basis of the New Loan Facility
4/10/2020 even if the lender currently has made existing debt available to the borrower?
12:00:00 AM PIO (Email from
Identifying Information Withheld Our local governments are suffering as a result of their citizens not being able to pay their water bills, sales tax revenue diminishing, hotel
4/10/2020 motel tax and alcohol excise tax diminishing all because of the coronavirus. Local governments desperately need funding at this time to keep
12:00:00 AM PIO (Email from them in the black. Please allow local governments, especially small local governments, funding opportunities too.
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Main Street Lending Program Comments
Hello, I am a health care provider working in a private practice. I have seen a lot of help come down to hospitals, insurance companies and
other government health agencies.
However, I see little is done for doctors on front line of facing this pandemic who are in private practice. The only option I see is the generic
small business options. Nothing is really done for the small fish in this tank. I would like the government to consider a special act to help
doctors who are in small private practice. Our profit of margin depends on continuation of flow of patients and steady pay by insurance
companies. Our struggle is huge and we are trying to keep serve our patients and keep our dedicated nurses and staff despite all these
challenges. I see some support from Medicare but none if any from local states for medicaid which is most of our patients. Please help us.
Identifying Information Withheld Thank you
4/10/2020 Name
12:00:00 AM PIO (Email from
4/10/2020 2:57:00 Personal Email Inflammatory Comment
AM Address
PIO (Email from love bob
Hello, my name is Ani Kamikyan and i am a private money underwriter. We do business purpose loans and use the borrower's
properties as collateral. I just came accross the Main Street New Loan Facility and was really interested in the program.
Our company has been in business for over 17 years. We would love to help the business owners by offering this new program but as i
understand, this program is for SBA lenders and Federal Banks.
What steps can we take to be eligible to offer this program to the business owners?
Please advise.
Thank you,
LBC Capital
4/10/2020 ani@lbccapit Income Fund, Ani Kamikyan
12:00:00 AM PIO (Email from Kamikyan Ani al.com LLC 818-299-1401
Eligible lenders for the PPP have, by many accounts, not been willing to work with many newly shuttered businesses. In the LosAngeles area,
Identifying Information Withheld
seemingly all eligible lenders either report they have reached their cap or won't offer lending to a business that does not already have an
4/10/2020 account with them. Will the MSNLF use the same eligible lenders and should they? Most small businesses are unwelcome
12:00:00 AM PIO (Email from
Can you please clarify the business eligibility requirements for the Main Street Lending Program. For instance, does this program have the
same requirements at the PPP loan program, which allows 501c3 organizations to take advantage of this program. There are a number of
Identifying Information Withheld
non-profits including specifically summer camps that are under significant financial distress due to the COVID-19 impact on operations for
4/10/2020 summer 2020. Thank you for all you are doing to help ensure the sustainability of businesses and jobs during this time.
12:00:00 AM PIO (Email from
How do we obtain an application for the Main Street Lending Program? Is it through the Fed Reserve or can we access through our banks?
Identifying Information Withheld
4/10/2020 Thanks!
12:00:00 AM PIO (Email from
How soon will this program be available? We are going to need capital in order to restart the business, retain employees and grow. Our
4/10/2020 Identifying Information Withheld manufacturing business has seen our orders drop off to almost zero and it is going to take time to restablish our base. How soon will the
12:00:00 AM PIO (Email from application process be available?
Identifying Information Withheld Hello -- Thank you for the information about the Main Street Lending Program. We are working with some lending institutions who are looking
to help borrowers participate in the program. We have two questions: (i) is there a form of participation agreement for the 95% SPV
4/10/2020 participation that we can review; and (ii) is there more information available about the process for confirming eligibility and submitting
12:00:00 AM PIO (Email from documentation to contribute a loan to the SPV? Many thanks in advance for your assistance. Name
Dear Sirs,
The automotive service industry has been severely impacted by the Covid-19 pandemic and the resulting shut down of the American
economy. As a small business owner with 24 employees, I had to make agonizing decisions to lay off some of the staff in order for the
company to survive. We absolutely applaud and encourage your intent to provide relief and stability to Main Street businesses.
Identifying Information Withheld Respectfully,
4/10/2020 Identifying Information Withheld
12:00:00 AM PIO (Email from
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Main Street Lending Program Comments
Identifying Information Withheld
Identifying Information Withheld 60 day cycle to 120 day cycle, the company would be hurt to the point of laying off employees, slowing our payments to our vendors and
4/10/2020 subcontractors. Can a participation in the Main Street Leading Program provide the cushion in these times? When will applications be
12:00:00 AM PIO (Email from available for submission?
Can you send me the forms to apply for the new federal loan that is available?
4/10/2020 Identifying Information Withheld
12:00:00 AM PIO (Email from
Identifying Information Withheld Please provide more definition for the following: "existing outstanding and committed but undrawn debt ..."
4/10/2020
12:00:00 AM PIO (Email from
I have a few questions about the Main Street Lending program that I am hoping you can answer for me.
1. How much collateral, if any, is required on these loans.
2. I know companies up to 10,000 employees are eligible but what is the minimum size a company can be? Can they be below 500
employees and be eligible?
Identifying Information Withheld
Thanks for your help.
4/10/2020
12:00:00 AM PIO (Email from Name
What option is there for restaurants who need help now paying bills because they are not allowed to be open for dine-in service? Take-out
and delivery options are great, but not sustainable when a business has always been mostly dine-in. If restrictions last through June,
restaurants can't re-hire their full staffs in 8 weeks for the PPP loan forgiveness so that doesn't help them. We need something that
offers small businesses in the restaurant industry help NOW without stipulating that they have to return to full staff capacity in 8 weeks. These
businesses need help paying rent and utilities until they can open up for full service again. It's detrimental as commercial landlords
don't care to work with businesses and still want rent no matter the state of the business. With a minimum loan amount of $1M, the Main
Identifying Information Withheld Street Lending Program doesn't help small businesses either. There's no way small businesses could afford that. There needs to
4/10/2020 be options to fit everyone and not just those who don't need truly need the help.
12:00:00 AM PIO (Email from
I see that the Fed's two new Main Street facilities - the Main Street Expanded Loan Facility and the Main Street New Loan Facility -
reference a rate of "SOFR + 250-400 bps". There is no further description of "SOFR".
Do you know if the Fed has clarified what is meant by "SOFR"? is it the 30 day average as published by the NY FEd?
Thanks,
Identifying Information Withheld
4/10/2020 Name
12:00:00 AM PIO (Email from
Please consider increasing EBITDA cap for new loans to 6x 2019 EBITDA, as you did for existing loans. This is materially hampering many
healthy mid-size companies who thoughtfully manage debt but now need additional capacity.
Identifying Information Withheld
4/10/2020 Thanks,
12:00:00 AM PIO (Email fro Name
Would like to understand how to apply for the Main Street Loan program.
Identifying Information Withheld
4/10/2020 How do you apply?
12:00:00 AM PIO (Email from
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Main Street Lending Program Comments
I have a firm that is eligible for the Main Street Relief Loan Fund. I have a bank partner interested in providing the loan to the firm. I need:
1. the application for the borrower
2. the information my banking partner needs to send the application to the Federal Reserve
3. Relevant contact (person or department) if either the borrower or institution has questions or needs guidance/assistance.
Identifying Information Withheld Thank you in advance for your prompt response.
Name
4/10/2020
10:23:00 AM PIO (Email from
1. Servicers need rules on forbearance. Mr C just gave 86000 accounts a break without having the $645,000,000. to pay investors in one
day. There is going to be prejudice and discrimination with who gets and who does not. A poor household may not have internet or a laptop to
apply. Some servicers are going to offer best deals to prime locations and balloons to those who were already limping along.
2. Secondary Market is a mess. All the non government investors pulled out and left borrowers mid stream. The only loan going forward short
term is conforming conventional - the small ones because everyone is afraid to be caught holding when their warehouse line got a haircut and
they work on tight margins. Fannie and Freddie tightened up rules like FICO must be higher, self employed income is cut 25% and rental
income ignored- for now acting as if they walk barefoot on glass is the norm.
3. we are going to see consolidation of banks, mortgage bankers, lenders, without regulation
4. County recorder offices made up their own rules- some allow erecording some are just closed, depends on the tax basis- income- $ of the
county assessor
5. Tax revenues for counties and states are going to feel stress to pay for police, fire, emergency services
I love you hard working people at the Fed. Yes I know it's not appropriate to tell strangers I love them - but I see you trying to make fixes.
Identifying Information Withheld It's all in the ashes if we don't look two steps ahead to the future
4/10/2020 Name
10:34:00 AM PIO (Email from
The language around the maximum loan size suggests that the Main Street loan is only available to borrowers who have a positive EBITDA.
In the current economic circumstances many loss making companies will fail unless they can avail of the Main Street Lending facility. These
companies need bridge financing to survive the current downtown and achieve or return to profitability. Such financing may not be available
commercially because they're currently losing money. The Main Street loan facility may be the only financing option available to them.
Please clarify or change the language. The current language is "Maximum loan size that is the lesser of (i) $150 million, (ii) 30% of the
Eligible Borrower's existing outstanding and committed but undrawn bank debt, or (iii) an amount that, when added to the Eligible
Borrower's existing outstanding and committed but undrawn debt, does not exceed six times the Eligible Borrower's 2019 earnings
before interest, taxes, depreciation, and amortization ("EBITDA");".
Thanks
-Nikhil Sinha
4/10/2020 nikhil@gsvla Chief Executive Officer, GSVlabs Inc.
12:00:00 AM PIO (Email from Sinha Nikhil bs.com GSVlabs
Identifying Information Withheld How would we apply for these loans?
4/10/2020
12:00:00 AM PIO (Email from
Identifying Information Withheld the automotive repair business has been hit hard during this outbreak. we are classified as essential and yet no one is allowed to drive their
4/10/2020 vehicles. we have furloughed more than half our employees and are hopeful and thankful for the funds coming our way. these future funds
12:00:00 AM PIO (Email from will help us come back faster and keep our people in place for a much longer time.
Please consider having a specific amount designated for community banks like mine. National and regional will take this money in a hurry
while we are still processing PPP loans for customers that need significant help.
Identifying Information Withheld
4/10/2020 Also, you will need to tighten your definition of EBITDA for the leverage test. Will it be purely based on GAAP financials, or will you allow add-
12:00:00 AM PIO (Email from backs, and just how much/many add-backs will you allow? Also consider how you will handle covenant defaults.
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Main Street Lending Program Comments
I would PLEASE ask that the Fed take into great consideration the factor of citizenship/residency requirements in the loan application process
and provide a WAIVER of these requirements for any Main Street loans under the CARES Act.
Foreign Direct Investment accounts for 7.4 MILLION jobs in the USA and supporting companies like ours, whose owners INVEST in the US
economy but are not located here, will have a major impact. The purpose of citizenship/residency is merely a tool used by banks in order to
have guarantees and/or collateral from an individual located in the United States. In the case of the CARES Act, personal guarantees or
collateral are NOT required, so please ensure that this requirement is not part of the Main Street Loans either for the purposes of the CARES
Act.
Our company, like many other FDIs, pay taxes in the USA, have tax-paying employees in the USA, are headquartered in the USA, and are an
integral part of the USA. Our owners may not reside here but they have taken their own hard earned money and committed to investing in the
USA.
PLEASE DO NOT LEAVE FDI BUSINESSES OUT OF THESE LENDING OPPORTUNITIES.
Far Horizons
Tourism, Inc / Thank you.
4/10/2020 Atlas Travel
12:00:00 AM PIO (Email from Gorin Eli eli@fht.global Solutions -Eli
Good Morning, I hope you are doing well and staying safe. I have some feedback regarding the proposed "Main Street Lending
Program". Will there be any rules within the loan program that addresses compensation for sales employees that are on a variable
compensation plan?
I noticed in the guidelines a restriction regarding anyone making over $425,000 in 2019 cannot make more than that amount for any 12 month
period the year of the loan or following year. My question is whether this will apply to the sales force on variable compensation? They all
have compensation agreements in place that are driven by sales so they have the ability to make more money but it is solely driven by them.
Question 2: What about Companies that have formal stock liquidity plans in place that are funded by a standard formula that hasn't
changed for years? It is minimum 150-200K per year but it sounds like that may not be allowed under the loan guidelines.
adamschwart LeaderOne Thanks so much and Hang Tough!
4/10/2020 z@leader1.c Financial
12:20:00 PM PIO (Email from Schwartz Adam om Corporation
Please make sure the use of funds is not restricted in same way PPP funds are and make sure the use of funds extends beyond the 8 week
period set forth in PPP package. When a hotel is completely closed due to City Ordinance in dealing w/ virus, there is no reason to bring back
employees (who are receiving more on unemployment) when there is no actual business to conduct so PPP does not work well in that
situation; however, there are still real estate taxes due, utilities, maintenance, and other operating expenses, not to be mention distributions to
owners for income taxes due, that fall outside the scope and intention of the PPP loans. 4 year term is good w/ 1st year deferred. $500K-
4/10/2020 Identifying Information Withheld $1,000,000 could be a standard loan size for applicants that are approved. Again, we need a program w/ less restrictions on use of funds.
12:36:00 PM PIO (Email from
Dear Federal Reserve,
Thank you for all your support of small businesses in this challenging time!
Question: When and how can banks start applying for the Main Street Loan Facilities?
Thank you,
4/10/2020 Identifying Information Withheld
12:00:00 AM PIO (Email from Name
Identifying Information Withheld We would like to complete several loans under the Main Street Loan program. Will you please help us?
4/10/2020 Thanks
12:00:00 AM PIO (Email from Name
Please allow help for felons. With no foodstamps available in our state fo or surrounding states for felons, this is a hard time. Imagine having
been released only to find yourself unqualified for assistance because you couldn't pay child support while in jail, and now you
can't get food stamps.
Identifying Information Withheld That's rough.
4/10/2020 Where to turn today?
12:53:00 PM PIO (Email from Back to a live of crime, or shall we finally allow America to be equal, and give EVERYONE in need help?
Page 14 of 363
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Main Street Lending Program Comments
Wholesalers and retailers use Asset Based Loans (ABL) to finance operations. These are not EBITDA based, but rather inventory and
receivable driven. The shutdown in retail occurred at the peak of the spring retail season leaving many with high ABL balances and inventory
stalled in warehouses.
Identifying Information Withheld
4/10/2020 I would ask the committee to exclude ABL balances from the EBITDA limit in your Main Street program. Wholesalers with seasonal business
12:59:00 PM PIO (Email from will otherwise not be able to participate, leaving us unable to secure fall product.
Identifying Information Withheld Will you please assist us making the Main Street Loan available to our clients. What documents do we need and applications are necessary?
4/10/2020 Also, is it available to a 501c organization?
12:00:00 AM PIO (Email from
Under the Main Street Lending Facilities (New & Expanded), does the calculation of maximum loan size require that an entity have
positive EBITDA in 2019? If it has negative EBITDA does that preclude it from obtaining a loan, or, does the minimum loan size of $1M
override the maximum loan size language?
wwright@norf Is a 501(c)(3) entity eligible to participate in these programs?
4/10/2020 olkchristian.o Norfolk Christian
12:00:00 AM PIO (Email from Wright William rg Schools Thank you.
4/10/2020 Identifying Information Withheld Can you please provide guidance on the definition of tangible net assets. Is that fair market value or book value? For a cash basis tax
12:00:00 AM PIO (Email from preparer do you take the tangible net worth from their cash basis tax return? Thank you
Hello Fed/Treasury,
Thank you for the opportunity for a feedback forum.
I believe I sadly sit in the group of 5% that are excluded from "help" from the Covid-19 crisis yet I don't know of anyone that
got hurt as bad as I did as personally as I did. If I explain my economic injury due to Covid-19 crisis perhaps that will fuel ideas on how to help
those that are getting left behind. So, please see my humble note as fuel for thought. I do appreciate what all the Fed and Treasury are
attempting to do.
Identifying Information Withheld
I am a Sole Proprietor, a born dreamer, with plans to finally launch my two small startups in earnest this year.
Identifying Information Withheld
Identifying Information Withheld
4/10/2020
12:00:00 AM PIO (Email from
Identifying Information Withheld
So, one might think. I should just apply within one of the programs. But the first question from a loan analyst will be show me LLC's CY
2019 return. Well, since I was being safe and holding back on the official launch, I have no return and no payroll. Then one may think, just
show your profits from CY2019 of your Sole Proprietorship. Well, CY2019 was a flat year for me. My entire "hit or economic injury"
took place precisely in the crazy 6-8 sigma event within 10 days in March of 2020. So, my point is none of the metrics that are being currently
Identifying Information Withheld used to capture the extent of my injury really fit. I have heard Larry Kudlow state "we need to make whole the firms that took a hit due to
this virus. the virus wasn't their fault." However, what I see in reality is the large folks (private equity/hedge fund/banks) with all the
4/10/2020 lawyers and CPA's go to the front of the line and secure the loans/grants. The big entities win again and the small guy loses.
12:00:00 AM PIO (Email from
Continued...Now, let's say I had been overly aggressive and Identifying Information Withheld got super
leveraged with a big bank loan in CY2018 or CY2019, I would have a payroll/staff and debt linked to the LLC and would easily (I think) been
able to secure a big loan given the metric that are being requested currently. Now let's say that a firm that did the aggressive super
leverage was a healthcare LLC with a similar idea as mine and they are my competition. They (a competing LLC) now get call it a $2-10
million dollar loan and can expand rapidly hire more employees and do all the things that I was patiently wanting to do organically myself. I
now can't compete and the Fed/Treasury, one can argue, just picked winners and created losers even though I know that is not the
intent. Its almost like there needs to be a Czar overseeing really looking out for the small guy to even up the playing field for the smaller
Identifying Information Withheld entities (those without the team of lawyers and CPS's on staff). All I know is I now need more funds and more latitude in the process to
4/10/2020 even hope to grow and hope to stay competitive.
12:00:00 AM PIO (Email from Thank you and I hope to hear back. Name
Identifying Information Withheld It is not clear who the SPV entity is. Can you clarify. Thank you!
4/10/2020
12:00:00 AM PIO (Email from
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Main Street Lending Program Comments
A. The Extended Main Street Facility: The language describing the facility uses the term "tranche", which appears to imply that it
is intended to be used to extend an existing credit extension. Is that correct? If so, is it permissible to extend a loan without linking it to an
existing credit extension? Was the use of the term "tranche" intentional--if so, it will seriously impede the use of the Extended
Facility. This is a significant issue.
B. Documentation--will a bank be permitted to use its current commercial loan documentation for either a Main Street or Main Street
Extended Loan? Will the FRB provide any guidance about required terms and conditions? Will the FRB provide authority similar to that
provided for the PPP SBA program for a bank to originate the loan, or will the FRB or an agent of the FRB have to first sign-off?
C. Waivers--will a bank making loan under either the Main Street or Main Street Expanded Loan programs be authorized to waive
requirements for the two programs? For example, a significant number of borrowers have already expressed that the EBITDA limitations are
not workable.
D. Registration by Banks with the Two Facilities--when will guidance be issued (and contract documents) for banks to sell participations in
loans originated under the two programs to the SPV?
lynyak.joseph Thank you in advance--we will clearly submit additional comments regarding these programs--we would appreciate it if we could receive
4/10/2020 @dorsey.co Dorsey & advice as soon as possible.
12:00:00 AM PIO (Email from Lynyak Joseph m Whitney LLP
Identifying Information Withheld Hi, I have a DI interested in contacting the Main Street Lending Facility and there was no point of contact information for me to direct him to.
4/10/2020 Could you email me and provide me with a point of contact and phone number please?
12:00:00 AM PIO (Email from
4/10/2020 Identifying Information Withheld Identifying Information Withheld Do we have to
12:00:00 AM PIO (Email from approach a bank? Does the Federal Reserve have an application for such a loan? Please advise.
The Main Street loan program excludes the practically the entire biotechnology industry by virtue of the EBITDA requirements, as most
Identifying Information Withheld
4/10/2020 biotechnology research companies are pre-revenue or at least pre-profit. Given the current situation and the industry's contributions to
12:00:00 AM PIO (Email from the COVID-19 response, that seems ill advised.
Identifying Information Withheld Our bank is interested in participating in the Main St lending program. We would like to hear/read more information on this program. Please
4/10/2020 let me know who I should speak with to go forward with this. Thanks, Name
12:00:00 AM PIO (Email from
SOFR Convention-Calculation Methodology
We have received feedback from several of our bank clients that indicates a number of operational challenges involved in using a
compounding in arrears calculation methodology for SOFR. It would be helpful to provide guidance on certain standardized coupon
conventions for these loans.
A potentially simple approach for the reference rate would be to incorporate either the SOFR Averages or SOFR Index that are published by
the New York Fed. Alternatively a simple averaging of SOFR in arrears would also be effective.
Identifying Information Withheld
4/10/2020 Thank you
12:00:00 AM PIO (Email from Confidential treatment is requested for the information included herein.
I note that the restriction on dividends and distributions to common equity holders set forth in section 4003(c)(3)(A)(ii)(II) of the CARES Act
Identifying Information Withheld does not appear to be limited in application to publicly traded securities. If all borrowers are required to abide by this restriction, then
4/10/2020 accepting Main Street Program loans may significantly restrict closely-held companies in their ability to make distributions to equity holders.
12:00:00 AM PIO (Email from
Suggestion for Main Street Lending Program eligibility: instead of using 2019 earnings as basis for loan amount, use three-year-average
(2017, 2018, 2019) earnings. Three-year average is fairer to firms that may have had a bad year in 2019. Three-year average is less risky for
Identifying Information Withheld
lenders and Federal government/taxpayers, for example, if a firm exceptionally had a single good year, 2019. Thank you!
4/10/2020 3:07:00 Name
PM PIO (Email from
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Main Street Lending Program Comments
Identifying Information Withheld As I've shared with Presidents Daly, Kaplan,
Mester, Bostic, and Barkin, hotel owners desperately need a way to refinance their existing debt. Hotels are either closed or have very little
occupancy as result of government mandated stay at home orders so there is no revenue to pay debt service. The hotels need cash to stay
afloat which is putting stress on any cash reserves owners have. A lot of hotel mortgage debt is held by non-bank lenders that aren't
under the supervision of the Fed. Lenders need to forbear on interest for a period of time, but ultimately, I think the Fed will need to backstop
a refinancing of all hotel debt. Hotel mortgages across the country either are or will soon be in default. We have proposed a solution where
the Fed backstops loans via commercial banks to refinance any hotel loan that was performing and current prior to the COVID-19 epidemic
& national emergency. The loans could have no interest for at least 24 months and have a term of 5+ years. Alternatively, the
government could institute a stay on any commercial foreclosures for a period of time or the ability to re-structure existing debt outside of
bankruptcy. I can be reached at:
Identifying Information Withheld
Identifying Information Withheld
4/10/2020 3:21:00
PM PIO (Email from Thanks. Name
For many private equity backed companies, the affiliation rules of the SBA have locked out companies such as mine from much needed
funding.
The ability for these types of companies to access these funds would eliminate the need for them to layoff or furlough their employees and
4/10/2020 3:25:00 Identifying Information Withheld
therefore avoiding more pressure on the already overwhelmed unemployment programs across the nation, and keeping these workers
PM PIO (Email from covered by much needed employer provided health insurance.
I am writing to inquire about the Federal Reserve Main Street Lending Program and how / where a company can apply.
I run an industrial services and construction company which I believe meets the Press Release criteria, but I was not certain about:
- What banks will be participating in the program / specifically which banks or institutions?
- How a business can apply for the loan (online, through forms, going directly and solely through banks, or on the Federal Reserve website,....
etc..)?
- When is the programs anticipated launch date when applications will be allowed to be processed?
- What records will need to be assembled for application to the loan?
- What are the terms of the loan?
Any feedback or assistance you could offer, especially relating to how an application can be submitted, would be greatly appreciated.
Identifying Information Withheld
4/10/2020 All the best.
12:00:00 AM PIO (Email from
The PPP will be helpful. Millions of small business owners are evaluating their reserve assets, the PPP proposed loan and evaluating
whether it is enough to make it through this downturn. In my case, I do not know. I believe we will be able to make it through. However, it is
so uncertain regarding business outlook.
I'm 62 years old and have been running businesses continually for 37 years. I encourage you to be liberal with business owners facing
shutting down, after using all personal reserves. In many cases, business owners are likely to burn through retirement savings before the
give us.
4/10/2020 3:29:00 poconnor@p
PM PIO (Email from OConnor Patrick oconnor.com OConnor Using the last of our savings, when the outlook is not clear, is very difficult.
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Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
Good afternoon,
Thank you for taking the time to read my email. I along with many others appreciate all the work that the Fed is doing, especially with the Main
Street Lending Program.
To the extent that feedback matters and can help shape additional guidance I would like to offer the following regarding EBITDA. Absent
further guidance, many banks out of concern that bank examiner's will penalize them, are already strictly interpreting EBITDA. Additional
guidance should indicate that adjustments to EBITDA that can be demonstrated and accounted for, which strengthen a borrower's
creditworthiness, should be allowed. I could write dozens of examples but let me offer two: i) a number of companies make in period
acquisitions and under the current guidelines if a company acquired a business on 12/31/19 or later you would get $0 credit for the earnings
and yet all the debt financing would be counted "against you"; ii) a number of medium size business owners "manage their
tax liability" through capitalization policies, pre-paying expenses, recognizing income because there is significant depreciation to reduce
the liability - all these actions would count "against you".
If the goal is to get liquidity to creditworthy borrowers, please consider providing additional guidance on the EBITDA definition. I am concerned
that absent more guidance good credits will be excluded and banks will ultimately be worse off.
Thank you for your consideration.
Identifying Information Withheld
Best,
Name
4/10/2020 5:27:00
PM PIO (Email from
The following relates to the Main Street Lending Program and to The Fed's 'Main Street' Mistake, WSJ, 3/10/20.
The MSLP was created to assist middle market companies weather the Covid-19 shut-down. The article describes these middle market
companies as generally as well-managed, having modest leverage and in need of bridge financing as banks won't lend to them and the
shutdown has eliminated their customers. It describes the shortcomings of the MSLP and concludes it is unlikely that funds can be distributed
fast enough to serve its purpose, which is bridge financing during an emergency.
A one sentence from the article reads: "The better solution would be no-strings loans to all-comers with good collateral and only for the
short-term"
Benefits:
1. Matches the time frame of the loan to the purpose, which is an emergency bridge
2. It is simple to administer quickly and in time to help
3. It places taxpayers at less risk
4. It protects our economy from unintended and long-term governmental overreach
While I write as a private citizen, please know I am also a director of Fixed Income for a regional bank in the Southern US and I have a good
understanding of the issues. As a concerned citizen I wanted to share constructive guidance and encourage a quick redirection of the
program. Good luck with modifying the program and helping our economy to its best and quickest recovery.
Thank you for the work you are doing.
Identifying Information Withheld Regards
4/10/2020 Name
12:00:00 AM PIO (Email from
Identifying Information Withheld Is this loan subordinated to other debt?
Is the interest that is deferred for the first year as stated or is it waived totally such that is will not be added to the back of the amount owed?
4/10/2020 6:53:00 Is the SOFR rate for the interest the daily SOFR rate or any of the other SOFR rates such as 30-day, etc?
PM PIO (Email from
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Main Street Lending Program Comments
My Question is related to #5 under Eligible Loans; Maximum loans size that is the lesser of 25M or an amount that, when added to the
Borrower's existing outstanding and committed but undrawn debt does not exceed 4x the 2018 EBITDA. We are a Mortgage Banking
Firm with warehouse lines of credit for our loan volume. The loans sit on the lines of credit short term from close date until the loans are
purchased on the Secondary Market (15-20 days). We have an asset that sits on our books for the loan amount (Loan Inventory) and a
Identifying Information Withheld
corresponding Liability for the debt on the Warehouse line of credit. The only difference between the two numbers is if the Warehouse line of
4/10/2020 7:20:00 credit does not advance the loan at 100%. How will this affect the ability to apply for this loan? It seems like consideration needs to be taken
PM PIO (Email from for this scenario. Thanks..
Identifying Information Withheld More than 80% of our company is owned by a very large private equity company. When calculating the number of employees, do we only
include the employees in our organization or are we required to include the employees of otherwise unrelated companies owned by the
4/10/2020 8:07:00 private equity company?
PM PIO (Email from
We would like to clarify whether an entity that enters into a loan under either of the two proposed Main Street Loan Facilities
("MSLFs") will also be entitled to relief under Title IV of the CARES Act (including, e.g., for a "Mid-Size Business" loan
under section 4003(c)(3)(D) of the CARES Act).
An "eligible business" for a Title IV loan under the CARES Act is defined as a US business that has not otherwise received
adequate economic relief in the form of loans or loan guarantees provided under the CARES Act. We understand that the MSLFs have been
established pursuant to section 13(3) of the Federal Reserve Act. However, a portion of the funding that comprises the $600billion for the
MSLFs is coming from Treasury out of "funds appropriated under...the CARES Act".
Identifying Information Withheld
4/10/2020 8:22:00 We would therefore be grateful for clarity in relation to whether or not an entity who has benefited from a loan under a MSLF will be taken to
PM PIO (Email from have received relief under the CARES Act for the purposes of the definition of "eligible business".
There are TWO critical elements that, if not altered, may result in the program being a failure. First, Eligible Lenders cannot be solely banks.
They are no longer the front line lenders to non-investment grade companies. That's now non-bank players: finance companies; private
funds & Business Development Companies. They are the ones with the bulk of debt capital advanced to these companies; who have
000s of specialized personnel & with institutional knowledge of the borrowers. Also delete the requirement that Eligible Borrowers must
have a max debt to EBITDA of 4x. High leverage goes to the strongest companies. The weakest borrowers have debt levels below 4x. .
According to Bloomberg, the average middle market borrower has a debt/EBITDA multiple of 4.8x. That means most companies will not
qualify. We estimate companies with an enterprise value of $3 trillion+ will be ineligible. Government - neither ethically or pragmatically -
cannot exclude huge swathes of companies from the rescue efforts. To choose this moment to adopt a misguided philosophy of turning away
the best performing non-investment grade companies is wrong headed. The solution is in the combination of our two suggestions. Recruit the
Personal
non-bank lenders who are familiar with non-investment grade companies, remove the maximum leverage requirement & the free market
Email
4/10/2020 9:16:00 Address will take care of the problem.
PM PIO (Email from Marshi Nicholas BDC Reporter
Identifying Information Withheld What is the url or where will we be able to apply for the new main street loans for small business
4/10/2020
12:00:00 AM PIO (Email from
The two most critical points relating to any future aid programs are:
1)Programs designed to benefit workers and the unemployed must not be packaged with benefits targeting corporations or financial
institutions.
2)All Congressional votes must be roll call votes. Citizens have a right to know how their representatives in Congress vote on the most
important issues facing our nation.
Not a single unemployed worker needs more debt. What is needed is unconditional aid. The US federal government issues a fiat currency.
We have seen ample evidence that the federal government is ready, willing and able to create as much new money as it wishes, when large
corporations and banks come with their hands out. That currency issuing power needs to be used to aid Main Street NOW, when it is
desperately needed.
Aid should be in the form of direct payments, with amounts calculated in proportion to reported income. Allow all US residents to file a
quarterly or yearly 2020 estimated tax statement, and pay out a "negative income tax" utilizing a simple arithmetic formula in which
Identifying Information Withheld payment is inversely proportional to income, but net income always rises as gross income rises. This simple approach will protect the financial
4/11/2020 2:34:00 safety of Americans, while maintaining minimal bureaucracy and providing a high degree of fairness.
AM PIO (Email from
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Main Street Lending Program Comments
I manage trade finance investment portfolios sourced from banks with the risk associated with financing U.S. small businesses (SME) by
purchasing trade receivables against confirmed orders from large investment grade companies. This technique is colloquially referred to as
supply chain finance. I served as advisor to Commerce https : //2014-2017.commerce.gov/tags/trade-finance-advisory-council-tfac.html under
the mandate of "expanding available financing options . .. U.S. exporters, particularly small and medium-sized businesses, to sell more .
." Please note:
Significant numbers of SMEs are not financed long term (> one year) but through working capital arrangements (< one year) through
trade finance https : //www.bis.org/publ/cgfs50.htm
Many arrangements are facilitated by uncommitted, undocumented credit facilities where product documentation is the basis for financing
Many arrangements use credit documentation of the debtor as opposed to the creditor
Bank loan documentation with individual SMEs is not standard nor is bank loan sale documentation with individual loan buyers
For the SPV to work efficiently then The Fed needs a standard borrower warranty, needs a standard bank warranty and needs a standard
bank loan sale document or management scalability is constrained
The Fed should consider mechanisms to provide working capital financing to SMEs through banks and should hire specialists to manage and
4/11/2020 adam.dener Fermat Capital review documentation for SPV
11:04:00 AM PIO (Email from Dener Adam @fcm.com Management
Whereas the proposed structure does provide liquidity to banks, it does not provide any incentive to a lender to make these loans. For the
retained portion, banks would still assume the same risks as they would have without this program. Therefore, bank have no incentive to lend
as a result of this program. In order to encourage lenders to make these loan, lenders will need to receive some incentive. Proposed
incentives are: (a) SBA style payment guarantees from the Federal Reserve to de-risk a bank lender; (b) Federal Reserve receives lower
4/11/2020 Identifying Information Withheld interest rate, allowing the bank lender to receive more economics (c) originating bank receives a senior position rather than pari-passu.
12:05:00 PM PIO (Email from
This program is not appealing to small businesses for two reasons. (1) The loan term is too short. These borrowers usually don't have
access to the capital markets, so at the end of the loan term, they will be unable to refinance the loan, and they will probably be unable to
repay it either, pushing the current financial/liquidity crisis out four years. (2) The EBITDA requirement, while it makes good sense in normal
times, does not work in these times when the intent of the CARES Act is to keep businesses afloat. The EBITDA requirement especially does
not work for a business with high revenues and high expenses (and it works too well for businesses with high revenues and very low
expenses). Imagine a company with $2 billion in revenue and $1.95 billion in expenses. It supports a huge ecosystem of employees,
independent contractors, other small businesses, raw materials suppliers, etc. A borrower like this could only get a loan to last them a few
days. These two requirements, combined with the high interest rates, mean that very few borrowers will likely take this money.
Identifying Information Withheld Instead, in order to support the legislative intent of keeping businesses afloat during these times, the loans should be for at least a ten-year
4/11/2020 1:31:00 term and use expenses from the borrower's most recent tax return as the basis for determining the loan size.
PM PIO (Email from
Few more questions and comments on the Main Street Lending Program. I recall during the 2008 crash "recovery", the Fed
provided certain banks with money that actually cost the Fed to give it to them based on negative interest rates. Then banks with their free
money were turning around and charging high interest rates or only lending to deep pocketed corporations, or even using the free (or money
that cost everyone via negative interest) money to work the stock market since repeal of Glass-Steagal. And then the same banks had a
depositor back door bailout by shafting their depositors with near zero percent interest rates.
Is the Fed going to do direct lending to small business at near zero percentage rates so banks can't turn around and use every excuse
to lend at usurious rates and formulate ridiculous lending criteria, or is the Fed going to control eligibility criteria and reasonable rates banks
can charge? Even with near perfect credit, I've had banks quote business lending rates at 8% and higher when prime was around 2%.
Identifying Information Withheld If the plan is allow banks to set their own rates and standards after the Fed hands them money, every small business and citizen is going to
4/11/2020 2:14:00 get screwed again.
PM PIO (Email from
We provide essential fuel, hangar and maintenance to Aviation. We've been profitable for 30 years. We employ 23 people. We have
always had $4 million in sales and $500,000 of ebitda. We are a subchapter S. PPP is not enough. If we can borrow 2x ebitda we can make it.
4/11/2020 3:05:00 Identifying Information Withheld This has to be recourse only to the business and not to the subchapter S shareholders. We will put this in bankruptcy or just shut it down, if
PM PIO (Email from we have to personally guarantee. It is not worth the risk to personally guarantee.
Identifying Information Withheld Where are the applications for the Main Street Lending loans? Do we get the applications through the Treasury or through our commercial
4/11/2020 3:43:00 bank?
PM PIO (Email from
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Main Street Lending Program Comments
I applied for the PPP via Chase. I have not received any information about the status of my application and am concerned.
4/11/2020 4:59:00 Identifying Information Withheld
PM PIO (Email from
How Can I apply for a Main Street Loan. I work in San Francisco but my business address is in Marin. Thank you
Identifying Information Withheld
4/11/2020 5:17:00
PM PIO (Email from
The Main Street Program as created might not be fully utilized because of structural considerations for the new senior secured loans that the
banks view could negatively effect their existing loss given default. The senior secured (parri passu) requirement of new or incremental debt
is limited in its ability to solve both a "liquidity and solvency" crisis for middle market companies. The banks should also be
allowed as servicers to underwrite "Intermediate term cushion capital" which would be "unsecured". The banks would
receive closer to a market rate for their stub piece. I believe any costs of this program resulting from inadequate returns should be a willing
expectation (counterintuitive) of the program. Until these companies have the necessary capital the broader economy will struggle to recover
fully impacting employment levels, investment and American communities. Although Intermediate term unsecured cushion capital with
liquidity benefits is not a typical product for banks, the 95/5 split ensures that the banking industry will remain safe and sound given a total
maximum of $30bn unsecured lending exposure which is de minimus compared to the whole of the banking system. The US economic
Identifying Information Withheld system can not thrive without the strength of the companies this program is attempting to protect. Finally, I do not view or worry that there is
4/11/2020 5:19:00 any moral hazard created by enhancing the program by adopting the proposed recommendation.
PM PIO (Email from
As a start-up (technology) business, getting funding to sustain operations from traditional sources is near-impossible at this time. SBA
Identifying Information Withheld
emergency lending may be a source, but it is not clear it will be sufficient and in enough time (over next 2 months). Fine to borrow, not looking
4/11/2020 6:10:00 for handouts (grants). Main Street lending facility minimum of $1 million could be reduced in certain cases where fewer funds are needed, as
PM PIO (Email from in our case where $250,000 is sufficient to navigate this period of uncertainty.
Identifying Information Withheld Interested in applying for the Main Street Lending program. When will an application be availing to complete?
4/11/2020
12:00:00 AM PIO (Email from
Main Street New Loan Facility should be expanded to include loans to start-up businesses which can demonstrate the ability to create no
fewer than 100 jobs within the first year of operation and as many as 300 jobs by the end of the third year of operations with minimum wages
of at least $15 per hour with a hiring preference to low income workers residing in the United States. The maturity of these loans should not
exceed 10 years with one year deferral of principal and interest payments. Maximum loan cannot exceed $25 million with the actual loan
amount calculated based on a multiple of $75,000 times the number of jobs projected to be created by the end of the third year of operations.
Preferential funding of these loans shall occur for businesses which will have a substantial economic or environmental impact
Identifying Information Withheld EXPANSION LANGUAGE NEEDED BECAUSE CREDIT FACILITIES FOR START-UPS IS NON-EXISTENT TODAY DUE TO
4/11/2020 6:38:00 CORONAVIRUS.
PM PIO (Email from
Will Paycheck Protection Program borrowers be able to apply for the Main Street Lending Program, will traditional underwriting be observed,
will banks issue the loans directly, will specific applications and loan documents be used?
4/11/2020 Identifying Information Withheld Thank you for your time and consideration!
12:00:00 AM PIO (Email from Name
I had two questions on the Main Street Lending program:
1) How do you intend to calculate EBITDA which doesn't have a GAAP definition? Will you create a standard definition that all
companies must use? Companies often include numerous adjustments or pro forma estimates of benefits from actions which never
materialize in the GAAP accounting statements. Most of the adjustments are really about efficiencies which are hoped to be realized (i.e. job
cuts).
2) How will you prevent companies from using your loans to repay their other debt? Should companies need to segregate the funds? Cash
Identifying Information Withheld is fungible. How will you track that the money is used properly? Keep in mind that the lenders who are operating this program are the ones
that will be (surreptitiously) repaid from this program.
4/11/2020 9:20:00
PM PIO (Email from Thank you for your thoughts on these matters.
Not clear on the minimum a "small business" like mine can borrow? I see the minimum of $1 million and I see that it has to be 4
4/12/2020 Identifying Information Withheld times EBITDA so does a business have to make $250k? or is it gross or net? What if a company has taken a loss? Are they still eligible since
12:00:00 AM PIO (Email from we still have employees that we can pay?
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Main Street Lending Program Comments
Phealey@he WS Healey 1. A business should be given the option to use a three year average when calculating EBITA.
4/12/2020 6:07:00 aleybrothers. Chevrolet Buick 2. Debt to owners should be excluded from the calculation to determine loan size.
AM PIO (Email from Healey Paul com Inc
My businesses could really use the help of Main Street lending.
Identifying Information Withheld
4/12/2020 6:52:00
AM PIO (Email from
4/12/2020 Identifying Information Withheld ppp is under 100k and main st is for bigger business.... i see a big gap? 100k isn't that much for a self-employed or many small
10:37:00 AM PIO (Email from businesses
Identifying Information Withheld Can you provide a list of eligible lenders and application process for the Mainstreet loan program due to Covid-19.
4/12/2020
10:46:00 AM PIO (Email from
How do I go about applying for a loan?
Where do I get the proper forms.
Who do I send them to.
This loan is needed to bridge the gap between now and when things get back to normal.
I really do not want to layoff any of my employees. They are all good people.
Thank you,
Identifying Information Withheld Identifying
Information
4/12/2020 Withheld
11:45:00 AM PIO (Email from
I am guessing you are trying using existing agencies or bank to distribute. The program makes sense from the macroeconomic level. The
problem will be execution at a grass roots level. I feel the credit crisis of 2008 created a mentality for lenders to tighten credit so much, they
no longer were investors in the economy. The current environment will tighten things more.
The virus changed how we do business. Investments in assets will a better use of the stimulus money. The lender behaves as an investor
looking forward to measure value added to the economy while the Fed profits. The people that distribute the money must have a different
perspective to help the Fed and our economy to come out of this stronger. Lets change the narrative from a loan program, to investments in a
new day to recreate an economy that was distracted with a virus.
I can be of service to you. I am a "boots on the ground" person, I go from the weeds to altitude 20k feet. My most satisfying
accomplishments are when taking ideas from proposal to reality. My experience in failing and succeeding put me in a good spot to help you.
These moments are very rare where we are presented with structural change in how we do business and I am ready for the challenge.
Identifying Information Withheld Identifying Information Withheld
4/12/2020
11:46:00 AM PIO (Email from
We distribute federally approved meals and foods to school districts and children affected by school closings resulting from Corona Virus.
In order to further fulfill the basic nutritional needs of eligible children nationwide we require additional funding.
Reviewing The Main St Expanded Loan Facility we respectfully question paragraph 5 under Eligible Loans.
" An amount that when added to the eligible borrowers committed and outstanding debt does not exceed six times eligible borrowers
EBITA for 2019 .
If an Eligible borrower had negative EBITA in 2019 but positive previously and in first quarter 2020 would that qualify ?
4/12/2020 Identifying Information Withheld Thank you for your attention
12:00:00 AM PIO (Email from
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Main Street Lending Program Comments
Happy Easter Sunday,
My restaurant was ordered closed by the Govenor of Louisiana on Monday March 16, at midnight.
I have applied for the SBA's Payroll Protectiom Program and the Ecomonic Injury Disaster loan. I have not been approved for either one
at this moment. Can I apply for the Main Street Lending Program through my local bank which is Identifying Information Withheld in New
Orleans, Louisiana.
Looking forward to your reply,
Identifying Information Withheld
4/12/2020 Identifying
12:00:00 AM PIO (Email from Information Withheld
4/12/2020 Identifying Information Withheld When is the Main Street Lending Program application process starting? How do I obtain application?
12:00:00 AM PIO (Email from
Identifying Information Withheld As a small business owner for 36 years. I believe for this program to work for someone like me I would need to be able to borrow 6 to 9
4/12/2020 months of lost revenue to be able to stay in business until there is some sort of cash flow. I can expand further if you can contact me.
12:00:00 AM PIO (Email from
Main Street New Loan Facility should be expanded to include loans to start-up businesses which can demonstrate the ability to create no
fewer than 100 jobs within the first year of operation and as many as 300 jobs by the end of the third year of operations with minimum wages
of at least $15 per hour with a hiring preference to low income workers residing in the United States. The maturity of these loans should not
exceed 10 years with one-year deferral of principal and interest payments. Maximum loan cannot exceed $25 million with the actual loan
amount calculated based on a multiple of $75,000 times the number of jobs projected to be created by the end of the third year of operations.
Identifying Information Withheld Preferential funding of these loans shall occur for businesses which will have a substantial economic or environmental impact. Attestation
4/12/2020 4:02:00 relating to EBITDA language condition is not applicable to loans to start-up businesses.
PM PIO (Email from
I first want to thank the Fed team for their strong work and the bold action launching the Main Street Loan Facility (MSLF). However, with
>15 years of experience investing in SMEs in the US, I can attest that many successful, fast-growing SMEs no longer take loans from
traditional banks and S&Ls, thus I believe limiting the program to traditional lenders will delay and significantly reduce the program's
impact.
I have two key suggestions which I believe will dramatically increase the effectiveness of the MSLF:
1)Allow non-bank financial institutions, especially BDCs, to participate as lenders in the program. BDCs have taken over the role of
traditional banks in providing secured term loans to these fast-growing companies. Allowing SMEs to leverage their existing relationships with
BDCs would both expedite and magnify the impact of the MSLF.
2)Increase the leverage limit on new loans to 6x from the current 4x level. SMEs with the lowest levels of leverage are typically more cyclical
or structurally challenged (oil & gas, retailers) while there are many structurally healthy business services and software companies with
business models that allow 4.5-5.5x leverage. Expanding leverage limits on new loans would dramatically increase the program's scope
Identifying Information Withheld and save jobs.
4/12/2020 4:33:00 I applaud the bold and decisive action of the Fed in initiating the MSLF. I believe the changes above would have a dramatic effect in
PM PIO (Email from increasing the speed and efficacy of the MSLF.
It's unclear whether a company looking for the minimum loan amount ($1M) is still subject to the max EBITDA multiple requirement.
Please also allow for adjustments to EBITDA including those for excess officer compensation, one-time expenses, etc. Many small
businesses operate at a $0 EBITDA level by investing in growth, increasing compensation to officers, etc. If no EBITDA adjustments were
Identifying Information Withheld permissible, these businesses would not meet the EBITDA multiple threshold even though the businesses are healthy and able to take on the
4/12/2020 6:04:00 debt.
PM PIO (Email from
Identifying Information Withheld I would like to be notified when the Main Street loans are available for application and whatever instructions you will put together to make
4/12/2020 7:54:00 application. Our bank US Bank has given us no guidance and has no more information than I do.
PM PIO (Email from Thank you.
Who determines eligibility for loan under main street lending? What is the determining criteria?
How is maximum loan amount determined?
Identifying Information Withheld
4/12/2020 8:57:00 Thanks
Name
PM PIO (Email from
Page 25 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
With respect to the calculation of EBITDA in determining the maximum loan amount for either the Main Street New Loan Facility or the Main
Street Expanded Loan Facility, I have the following two questions: (1) How will EBITDA be calculated (including but not limited to the
expanded loan facility where the existing tranche has its own calculation of EBITDA?
Identifying Information Withheld
4/12/2020
11:23:00 PM PIO (Email from (2) Will the loan program be wholly unavailable to companies with a negative EBITDA in 2019?
With respect to the Main Street New Loan Facility and the Main Street Expanded Loan Facility, will a business satisfy the "U.S. Eligibility
requirements" if it is a wholly owned U.S. subsidiary of a foreign parent?
Identifying Information Withheld
4/12/2020 In other words, does a US subsidiary have to aggregate with the employees of its foreign parent in order to certify that a majority of its
12:00:00 AM PIO (Email from employees are based in the United States?
o"The EBITDA ratio-based limitation on loan amounts is a restrictive and overly simplistic approach to assessing both need and credit-
worthiness of potential borrowers. For example, the proposed approach does little for growth companies or companies in the midst of a turn-
around. Originating banks should be allowed to utilize a more holistic analysis, even if this involves the government taking more credit risk,
which is appropriate given the Congressionally mandated purposes of the Program and the amount of equity provided to the Federal
Reserve."
o"Given that loans under the Main Street Programs carry meaningful operating restrictions, many companies are put in a difficult
position. If they take the loans to ensure liquidity, they have subjected their businesses to operating restrictions that may well diminish
shareholder value and business-making flexibility. If they try to get by without the help of the program, but economic recovery is delayed,
there is a meaningful risk that their businesses will contract or be imperiled, leading to unnecessary contraction of the overall economy. The
Identifying Information Withheld Programs should provide more flexibility for companies to apply and qualify for a loan now, but be able to draw down on it at a later date if
4/12/2020 needed, and only upon drawing on the facility would they then become subject to the operating restrictions."
11:49:00 PM PIO (Email from
Identifying Information Withheld How does my customer apply for the MSNLF? Is there an application from the Fed?
4/13/2020 8:05:00
AM PIO (Email from Thank you
Identifying Information Withheld Restriction on paying dividends hurt shareholders that rely on dividends as their source of income. This is especially true for family owned
4/13/2020 8:27:00 businesses.
AM PIO (Email from
The federal guidelines for the CARES Act's Main Street Lending Program (MSLP) require a positive EBITDA. This means start-ups
starting to scale but not yet profitable are ineligible for this program, which will greatly limit the potential impact of the MSLP. These companies
not only employee a significant population of the workforce, but also create many new jobs. The MSLP requirements must be changed to
provide relief to a critical economic sector: successful, growing start-ups. Currently, more than 34% of the Russell 2000 companies would be
excluded due to lack of earnings. It would also exclude start-ups looking to invest in future growth, eliminating a critical source of new jobs.
Speaker Pelosi has pushed for the inclusion of start-ups in SBA relief programs, and we encourage the MSLP to also welcome start-ups.
Other countries have included start-ups in their relief packages and we encourage the US to do the same. Excluding start-ups will cause short-
term economic pain and undermine long-term growth. In the US, young firms account for 11% of employment and 27% of job creation, and
thousands have already been laid off from start-ups due to COVID-19. Start-ups also have large multipliers: for each job they create, they
indirectly create another 4-5 jobs. The repercussions of the economic hits start-ups take now will reverberate for years, and it is critical that
4/13/2020 8:39:00 Identifying Information Withheld the MSLP offer relief to EBITDA negative companies to minimize this impact and offer vital economic support.
AM PIO (Email from
dave@hoteld Hotel Can the Main Street Loan Program be used on an existing new hotel construction project? The Coronavirus has slowed our schedule
4/13/2020 9:02:00 evelopment.n Development significantly causing additional costs. In some cases increased costs from subs who are losing laborers to unemployment. Our opening date
AM PIO (Email from Wespiser David et Services, LLC has been pushed back by several months.
accounting@j Will you have a list of participating lenders available for the program?
4/13/2020 9:05:00 pceventgroup JPC Event
AM PIO (Email from Wimer Jody .com Group
Identifying Information Withheld As a non-profit organization that does not qualify for the PPP and has more that 500 employees, there should be wither a portion of the loan
4/13/2020 9:17:00 forgiveness (similar to PPP) under the Main Street Program, and fees/origination points should be waived for non-profit organizations.
AM PIO (Email from
Identifying Information Withheld As a non-profit organization that does not meet the size requirements under the Paycheck Protection Program and has more that 500
4/13/2020 9:41:00 employees as an affiliate to a larger network, it would be helpful the Main Street Loan Program to have a forgiveness provision - similar to
AM PIO (Email from PPP. Additionally, Fees/origination points should be waived for qualifying non-profit organizations. Thank you.
Page 26 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
I urge you to ensure that federally-backed mortgages can get an automatic one-year deferral just like the Main Street Lending Program where
the Fed is granting one-year deferrals for business loans. Please instruct banks to start with an automatic one-year deferral of mortgage
Identifying Information Withheld
4/13/2020 9:41:00 payments instead of the three-month increments they are currently offering and then forcing homeowners to come up with a lump sum at the
AM PIO (Email from end of three months and then apply for another three months. Thanks.
Thanks for the job you do at the Fed. I think the Main Street program needs to extend beyond the banks - they can't move fast enough
and they are too concerned about repercussions. Debt at 4x EBIDTA is likely a bad metric for this program. Bagehot said lend freely to good
Identifying Information Withheld
4/13/2020 9:45:00 credits, but this metric does not define who can service the debt and with the built in forgiveness feature it's really not applicable. Thank
AM PIO (Email from you for your consideration of my comments.
As a non-profit organization that does not meet the size requirements under the Paycheck Protection Program and has more that 500
4/13/2020 9:58:00 asoler@basic Acacia network employees, it would be helpful the Main Street Loan Program to have a forgiveness provision - similar to PPP. Additionally, Fees/origination
AM PIO (Email from Soler Amarilis sinc.org housing points should be waived for qualifying non-profit organizations. Thank you."
I operate a law firm and have two employees who I want to keep on my payroll. I'd like more info on the loans you will make or support
in the Main Street Lending program. When will the funds be available and what are the requirements for small businesses to participate? Do
you have any lenders in Identifying Information Withheld which will be working with you on it? How do I get more specific
4/13/2020 Identifying Information Withheld information about this program? Please send me anything and everything you have on this program. Thank you very much.
10:04:00 AM PIO (Email from
Will you kindly consider providing some further guidance on EBITDA calculation for purposes of the Main Street loan program? Some of my
clients are concerned about the the extent to which "add backs" - which are common in negotiating EBITDA with purchasers and
4/13/2020 Identifying Information Withheld lenders - are permitted or included. As you aware the concept of EBITDA is not a GAAP item and advice in the market (from lawyers and
12:00:00 AM PIO (Email from banks) indicates a great deal of uncertainty on the question.
I have some questions about the Main Street Loan Program that I am hoping you can assist me with .
1. Can employer with LESS than 500 employees use this AND 3P or EIDL?
2. Can it be used with ERTC and payroll tax deferral?
3. What is the process to apply?
Identifying Information Withheld 4. How much collateral and personal guarantees are required?
5. How do required dividends from COOPs comply with dividend restrictions?
4/13/2020
10:11:00 AM PIO (Email from Thank you for your help.
I am interested in the MSLP. Based on my understanding, the minimum loan amount is $1 million. This amount is too high for a company like
Identifying Information Withheld mine that is in between small and a medium size. I will end up paying interest and origination fee for a large chunk of the loan that is not
4/13/2020 needed. If the minimum loan amount can be reduced to $500,000, that would encourage more companies like mine to apply. Thank you
10:24:00 AM PIO (Email from
Identifying Information Withheld Good Morning-
4/13/2020
10:48:00 AM PIO (Email from
Identifying Information Withheld How does the Main Street Loan program handle partnerships and S Corps?
4/13/2020
10:58:00 AM PIO (Email from
Would the Main Street Lending Program be available to U.S. subsidiaries of foreign-owned companies?
Identifying Information Withheld
4/13/2020
12:00:00 AM PIO (Email from What are the affiliation rules with respect to counting employees of foreign-owned or controlled affiliates
The Main Street lending program appears to exclude businesses that did not have a positive EBIDA for 2019 irregardless of the reasons. My
Identifying Information Withheld company would not be eligible due to us losing money in 2019. Our company's loss was not due to management but due to the trade
4/13/2020 war with China and we are now struggling with the challenges brought by COVID-19. We are keeping our people employed, but have had no
12:00:00 AM PIO (Email from significant options to get help during this crisis.
4/13/2020 Identifying Information Withheld Hello, our company is a U.S.-based subsidiary of a foreign company. The subsidiary is funding by the parent company. Can the subsidiary
11:27:00 AM PIO (Email from apply into the Main Street Lending Program, with the full-backing of the parent?
Page 27 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
Hoteliers need government-mandated forbearance for 2 years. Prohibit lenders and servicers from charging "forbearance,"
"special servicing" or other predatory fees. Loan guarantees from the Fed to banks, thus enabling the banks to make mortgage
loans secured by our hotels to replace our existing loans, in an amount equal to 110% of current indebtedness - this will allow us to pay off our
current lenders at par (thus providing them with much-needed liquidity), replace depleted reserves and fund capital investment in our
properties, resulting in significant job creation The loans need to be for a term of at least 5 years. They need to be interest-free for 3 years and
bear interest at 25 to 50 bps thereafter. No origination or other fees. The loans should provide multi-year extension options to allow for an
Identifying Information Withheld orderly re-finance over time. They need to be prepayable at any time, without penalty, so we can re-finance when conditions stabilize. We
need a measured, flexible approach to any conditions imposed on CARES Act borrowers. For example, many hotels are owned by REITs that
are subject to IRS ruless governing the return of capital to shareholders. It is not feasible to prohibit REITs from paying dividends on their
common stock. We need relief from the labor union provisions. The surest way to bankrupt hotel owners is to pass laws that make it easier for
4/13/2020 workers to unionize. Simply put, we will not survive both the Covid-19 crisis and higher labor costs on top of each other!
11:31:00 AM PIO (Email from
The National Health Council urges you to prioritize nonprofit organizations within the Main Street lending program. Patient groups have been
and will be significantly harmed by reduced charitable giving, travel restrictions, fund-raising event cancellations, and reduced meeting
attendance as a result of COVID-19.
Specifically, we ask that you provide explicit funding for nonprofits through an exclusive pathway within the Mid-Size Business Loan Program.
This funding should support business loans to nonprofit employers with up to 10,000 employees, since those with over 500 employees are
barred from the CARES Act's small business lending. It is also imperative this program include loan forgiveness modeled after the
CARES Act Section 1106.
Patient advocacy organizations serve the patients and communities we represent at no-cost. They are the groups helping people most
impacted by the virus, those with underlying chronic conditions that often result in more severe cases of illness. They expect demand for their
invaluable services will increase during this public health emergency, while at the same time seeing significant reductions in revenue. In
addition, the nonprofit sector is the third largest workforce in the U.S., behind retail and manufacturing. In order to continue their valuable
4/13/2020 jdexter@nhc National Health work, it is critical that patient advocacy and community-based organizations and other nonprofits have access to loans to weather the growing
11:39:00 AM PIO (Email from Dexter Jennifer ouncil.org Council economic burden of the COVID-19 pandemic.
Good afternoon - I represent the passenger-carrier transportation and transit industry and I need to know how the Main Street Lending
Program is going to be rolled out.
Is the program going to be through banks/financial institutions, through the Federal Reserve, the SBA, or through the Department of
Treasury?
Is there going to be a full application in order for it to be evaluated? What financial and tax documentation will applicants require?
I represent a number of companies within the USDOT-regulated industry and as soon as we receive the necessary information to prepare for
the rollout then I need to brief our clients to hopefully participate in the Main Street Lending Program.
Sincerely,
Identifying Information Withheld Identifying Information Withheld
4/13/2020
12:12:00 PM PIO (Email from
Page 28 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
Hoteliers need government-mandated forbearance for 2 years. Prohibit lenders and servicers from charging "forbearance,"
"special servicing" or other predatory fees. Loan guarantees from the Fed to banks, thus enabling the banks to make mortgage
loans secured by our hotels to replace our existing loans, in an amount equal to 110% of current indebtedness - this will allow us to pay off our
current lenders at par (thus providing them with much-needed liquidity), replace depleted reserves and fund capital investment in our
properties, resulting in significant job creation The loans need to be for a term of at least 5 years. They need to be interest-free for 3 years and
bear interest at 25 to 50 bps thereafter. No origination or other fees. The loans should provide multi-year extension options to allow for an
orderly re-finance over time. They need to be prepayable at any time, without penalty, so we can re-finance when conditions stabilize. We
need a measured, flexible approach to any conditions imposed on CARES Act borrowers. For example, many hotels are owned by REITs that
are subject to IRS ruless governing the return of capital to shareholders. It is not feasible to prohibit REITs from paying dividends on their
Identifying Information Withheld common stock. We need relief from the labor union provisions. The surest way to bankrupt hotel owners is to pass laws that make it easier for
4/13/2020 workers to unionize. Simply put, we will not survive both the Covid-19 crisis and higher labor costs on top of each other!
12:20:00 PM PIO (Email from
4/13/2020 Identifying Information Withheld If the subsidiary receives the Main Street Lending Program, can the parent company issue dividends to an owner?
12:26:00 PM PIO (Email from
Applied for PPP but was denied because we are a 501(c)6 corp, even though we are the sole members of a Foundation that we oversee that
Personal Professional is a 501(c)3. Please include c6 corps in this program. Our revenues have ceased, as figure skating coaches are not working because all
4/13/2020 Email Address Skaters rinks are closed and have no income. We offer continuing education, liability insurance, safe sport education. Please help as we will have to
12:27:00 PM PIO (Email from Murphy Carol Association layoff most of our staff.
I work for owners of 130 hotels located in the U.S. As currently written, Main Street Lending does not help our hotels and will result in every
one of our hotel properties defaulting on its debt that we otherwise would have been able to adequately service pre-COVID-19. What we need
is for Main Street Lending to do 2 things: #1: we need the government to mandate that existing lenders of hotel property mortgages, including
CMBS loans, provide forbearance for borrowers for as long as it takes to complete #2. #2: Treasury / Fed must implement a program that
facilitates direct lending to hotel owners sufficient to refinance all of their existing mortgage debt. If not that, then the government needs to
provide sufficient incentives for banks to refinance current loans that were performing prior to COVID-19 under better terms to allow the hotels
to recover from the downturn. Right now, all hotels are generating negative cash flow before considering debt service. That means that
4/13/2020 jcoe@ashfor currently debt service is taking the place of payroll for our associates with the dwindling cash balances that we do currently have.
12:38:00 PM PIO (Email from Coe Justin dinc.com Ashford Inc.
The capital distribution limitation included in the Main Street New and Expanded Loan Facilities appears to preclude S corporations from
participating.
Section 4003(c)(3)(A)(ii) would prohibit distributions to S corporation shareholders, but these distributions are required under the S
corporation's ownership agreement so the owners can pay the taxes owed by the business. S corporations have to make them.
To fix this, the language should read: "The Eligible Borrower must attest that it will follow compensation, stock repurchase, and capital
distribution restrictions that apply to direct loan programs under 4003(c)(3)(D)(i)(vii) of the CARES Act. In the case of pass-through entities,
these restrictions do not apply to distributions made to pay taxes attributable to income earned by the eligible entity."
These changes could be made to the term sheets under the broad authority granted to Treasury and the Federal Reserve under Section
4003(c)(3)(D)(ii).
Thank you for your consideration.
Identifying Information Withheld
4/13/2020
12:46:00 PM PIO (Email from
I was hoping to clarify how the loan sizing in the Main Street Loan Facility works. I am reading bullet four romanette two as only applying to
Identifying Information Withheld
4/13/2020 undrawn debt and not total borrowing -- is that correct? If the idea is to just provide immediate liquidity to the market, my thought is that
12:47:00 PM PIO (Email from committed debt should not be taken into account for this program.
Our company has developed a new antimicrobial technology (compound) based on the element selenium. Additional financing is needed for
4/13/2020 kenny@selen the next 12-18 months to commercialize projects currently in progress that have been stopped due to the coronavirus. Additional funding will
12:55:00 PM PIO (Email from Gallagher Kenny bio.com SelenBio, Inc. allow revenue generation in the near future.
Identifying Information Withheld
I own a small chain of retail stores (~$5MM annual revenue 30-35 FTE equivalent) in the I am trying to figure out if
Identifying Information Withheld
4/13/2020 my business is eligible for the Main Street loan program, and if I can use my bank (USBank) to obtain one of these loans. My key contact with
12:56:00 PM PIO (Email from USBank has not heard about this program. Thank you.
Page 29 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
For the maximum loan size for the new loan program, "existing outstanding and committed but undrawn debt" is ambiguous. For
example, if I have a $100 million credit facility and I have drawn down $90 million and can still draw $10 million, do I add $100 million for the
4x EBITDA calculation, or just the undrawn amount? See below for the relevant language from the press release.
Maximum loan size that is the lesser of (i) $25 million or (ii) an amount that, when added to the Eligible Borrower's existing outstanding
Identifying Information Withheld and committed but undrawn debt, does not exceed four times the Eligible Borrower's 2019 earnings before interest, taxes, depreciation,
4/13/2020 1:00:00 and amortization ("EBITDA");
PM PIO (Email from
1. Standard sizing would be more logical-the terms sheet seems to leave open too many matters in the discretion of the issuing Bank. Other
concerns are not addressed. Such as the lending limit for loans to one borrower in 12 C.F.R. § 32.4
2. The Loans have to be processed quickly and the Banks should be prohibited from asking for a personal guarantee on the 5% of exposure
that they have.
3. The loans should be fixed rather than floating to make it attractive for the Banks to issue them
Personal
4/13/2020 1:33:00 Email Address 4. There should be uniform Notes, Loan Agreements and other ancillary documents including opinion letters so that each borrower is not
PM PIO (Email from Zafrin Mark Elliot B.Zafrin,PC negotiating a different set of documents with each bank.
Will the MSLP be open to all private nonprofits? When do you expect the MSLP application to be made available? Thank you.
Identifying Information Withheld
4/13/2020 1:43:00
PM PIO (Email from
Identifying Information Withheld As a non-profit organization that does not meet the size requirements under the Paycheck Protection Program and has more that 500
4/13/2020 1:44:00 employees, it would be helpful the Main Street Loan Program to have a forgiveness provision - similar to PPP. Additionally, Fees/origination
PM PIO (Email from points should be waived for qualifying non-profit organizations. Thank you.
Identifying Information Withheld Can a business with negative EBITDA participate in the Main Street Expanded Loan Facility program? In the calculation of the maximum loan
4/13/2020 2:00:00 amount there is a limitation of 6 times a companies EBITDA. If a company has negative EBITDA does this mean that the lowest amount
PM PIO (Email from available for the company is zero?
Commercial real estate (CRE) developments with normal debt levels would be unable to qualify for the Main St lending program based on the
EBITDA requirements as set forth in the Reserve Term Sheet. Our near airport parking portfolio (thefastpark.com) is underleveraged yet it
would not satisfy the EBITDA covenant. The Term Sheet does not give consideration to the built-up equity created in CRE. When seeking
debt financing for CRE projects, lenders look at net operating income in order to ensure that the borrower can satisfy the debt service and
look at total value of the dev (in normal times via an appraisal) in order to verify that the loan is secure. Even with the most conservative debt
service coverage ratios that banks use, our company would have no issue qualifying for traditional financing using our '19 operating
numbers. The current issue is that our business went from robust to essentially non-existent overnight
Solution
Rather than look at total debt for the liquidity test to determine max loan amount, we think the fed should specifically look at undrawn debt
(ex:lines of credit) that is already committed and accessible. This would meet the policy goal of providing the needed funds to businesses
while also recognizing that CRE devs rely on built up equity when being evaluated for loans
rob@chavez Chavez A separate solution would be to allow lenders to evaluate loan risk using previous appraisals, '19 op numbers, and their normal CRE
4/13/2020 2:02:00 properties.co Properties / Fast internal requirements/covenants
PM PIO (Email from Chavez Robert m Park
Page 30 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
Identifying Information
Withheld urges you to prioritize nonprofit organizations within the Main Street lending program. Patient groups have been and will
be significantly harmed by reduced charitable giving, travel restrictions, fund-raising event cancellations, and reduced meeting attendance as
a result of COVID-19.
Specifically, we ask that you provide explicit funding for nonprofits through an exclusive pathway within the Mid-Size Business Loan Program.
This funding should support business loans to nonprofit employers with up to 10,000 employees, since those with over 500 employees are
barred from the CARES Act's small business lending. It is also imperative this program include loan forgiveness modeled after the
CARES Act Section 1106.
Patient advocacy organizations serve the patients and communities we represent at no-cost. They are the groups helping people most
impacted by the virus, those with underlying chronic conditions that often result in more severe cases of illness. They expect demand for their
invaluable services will increase during this public health emergency, while at the same time seeing significant reductions in revenue. In
addition, the nonprofit sector is the third largest workforce in the U.S., behind retail and manufacturing. In order to continue their valuable
Identifying Information Withheld
4/13/2020 work, it is critical that patient advocacy and community-based organizations and other nonprofits have access to loans to weather the growing
12:00:00 AM PIO (Email from economic burden of the COVID-19 pandemic.
4/13/2020 Identifying Information Withheld Where do I apply for this loan. Main Street funding
12:00:00 AM PIO (Email from
As a non-profit organization that does not meet the size requirements under the Paycheck Protection Program and has more that 500
Identifying Information Withheld
4/13/2020 2:16:00 employees, it would be helpful the Main Street Loan Program to have a forgiveness provision - similar to PPP. Additionally, Fees/origination
PM PIO (Email from points should be waived for qualifying non-profit organizations. Thank you.
4/13/2020 2:21:00 TEST@TEST QA TESTING IN PROD
PM PIO (Email from test test .com test
We are positive about the MSELF program and appreciate the work to put it in place. As currently drafted, the program unintentionally
penalizes companies with low debt.
Confidential Business Information
We propose the following revisions:
1.The loan size limitation based upon previous debt and debt capacity should be waived if your post-MSELF debt/EBITDA is less than 4X
Identifying Information Withheld based upon 2019 EBITDA;
2.The definition of debt included in the 30% limitation should include all private financial institution debt;
3.Companies should be able to use MSELF to pay mandatory principal payments. With no cash inflow, we have no ability to pay debt
payments;
4/13/2020 2:22:00 4.Lenders should waive debt covenants for existing and expanded loan agreements as long as the covenant calculations include amounts
PM PIO (Email from from coronavirus impacted periods.
Regarding the two Main Street Loans eligibility loan section #5, what does the wording "Eligible Borrower's existing outstanding
and committed but undrawn debt" include? Does it include the entire debt on the balance sheet such as accounts payable and other
current debt. Does it include bank debt, financial services company debt, payments under leases? Does it just include debt owed to banks?
Identifying Information Withheld Please see Main Street New Loan Facility 5 (ii) and Main Street Expanded Loan Facility 5 (iii) from the April 9 press release for the exact
4/13/2020 citation. Thanks for your service and stay safe and healthy!!
12:00:00 AM PIO (Email from
4/13/2020 QA TEST IN PRODUCTION
12:00:00 AM PIO (Email from test test test@test.test test
KRISTIN@wil My development company Confidential Business Information will employ hundreds of people during construction and over
4/13/2020 3:05:00 dflowerfarms. Wildflower 150 people once operational. We do not have revenue today as we are about to begin construction but we have 1099 employees and detailed
PM PIO (Email from Rapoport Kristin COM Farms pro-formas. Please ensure new businesses are eligible for loans.
Page 31 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
I am the CEO of a frontline health and social services nonprofit, providing critical shelter and services to over 3,000 homeless individuals,
many with chronic health, mental health and substance use challenges, and who are highly at risk for Covid-19. Yet because we have 1,100
employees, we are not eligible for the SBA's PPP loan forgiveness program. While we are eligible for the MLSP, we request that it be
modified to include similar loan forgiveness features for frontline nonprofits who retain their workforce and are providing essential services
during the crisis. allowing us to incur expenses without putting our enterprises in jeopardy, as our work will be needed not only in the
4/13/2020 3:13:00 muzzy@brc.o immediate term, but well into the future, to help respond to the further economic dislocation that will follow the health crisis. Thank you.
PM PIO (Email from Rosenblatt Muzzy rg BRC
Hello,
We've had a number of questions about eligibility for the Main Street Loan Facilities in terms of company size. The term sheet says
"Eligible Borrowers are businesses with up to 10,000 employees or up to $2.5 billion in 2019 annual revenues." Does this mean
that a company with 15,000 employees but less than $2.5 billion of revenue is eligible?
winifred.cisar
4/13/2020 3:15:00 @wellsfargo. Thanks in advance for your help.
PM PIO (Email from Cisar Winifred com Wells fargo Winnie
Identifying Information Withheld
, our agency is fully engaged in dealing with the COVID-
19 crisis. We must ensure that our homes and services for disabled, remain as safe as possible. Because we provide essential services
during the crisis, we've incurred increased costs in staffing, PPE, and telehealth equipment costs.
Since we are not eligible for the Payroll Protection Program (PPP) due to our size and we must remain fully operational, we request that the
Mid-size Loan Program have provisions to convert to a forgivable loan for nonprofits that face losses due to COVID-19. This would grant us
the same protections as PPP.
Identifying Information Withheld
4/13/2020 Name
12:00:00 AM PIO (Email from
Identifying Information Withheld
How does our Bank obtain the applications for the Main Street Lending Programs?
ralphwiita@u Ralph Wiita
4/13/2020 3:25:00 smetrobank.c EVP/CFO
PM PIO (Email from Wiita Ralph om US Metro Bank US Metro Bank
Please consider including an alternative credit assessment metric beyond EBITDA, such as a gross or net asset test. The implicit
4/13/2020 3:42:00 dboyle@sli.c requirement of positive EBITDA will deny many early-stage, R&D heavy, and growth companies access to this capital. Thank you for
PM PIO (Email from Boyle Douglas o considering this addition to the Main Street Lending proposal.
The American Hospital Association urges the Treasury and the Federal Reserve to supplement the New Loan Facility term sheet with prompt
guidance on the following points to ensure that access to this critically-necessary loan facility will be attainable for hospitals without delay.
American Please see details here: https : //www.aha.org/lettercomment/2020-04-13-aha-requests-prompt-guidance-main-street-new-loan-facility
4/13/2020 mrock@aha. Hospital
12:00:00 AM PIO (Email from Rock Michael org Association
NetWork Sales what form is used for this MSNLF; my lender who is processing the PPP is not aware of this in any detail nor do they know or can I find what
4/13/2020 3:46:00 tony@networ and Marketing application or form to use for this. I'm apparently getting funding this week for PPP but want to apply for the additional loan support.
PM PIO (Email from lopresti anthony k-sales.com Inc
I have a firm that is eligible for the Main Street Relief Loan Fund. I have a bank partner interested in providing the loan to the firm. I need:
1. the application for the borrower
2. the information my banking partner needs to send the application to the Federal Reserve
3. Relevant contact (person or department) if either the borrower or institution has questions or needs guidance/assistance.
Thank you in advance for your prompt response.
Identifying Information Withheld
4/13/2020 Name
12:00:00 AM PIO (Email from
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Main Street Lending Program Comments
Could you please confirm whether the borrower certifications under Section 4003(c)(3)(D)(i) of the CARES Act will apply to loans issued
under the Main Street Lending Program. These borrower certifications are not referenced in the term sheets issued on April 9 nor are they
4/13/2020 nathan.tyler Grant Thornton specifically mentioned in 4003(c)(3)(D)(ii) of the CARES Act, which grants the Federal Reserve the discretion to establish the Main Street
12:00:00 AM PIO (Email from Tyler Nathan @us.gt.com LLP Lending Program.
When and where can we start applying for these loans?
gshayevitz@ Nassau Health
4/13/2020 4:20:00 mediweightlo Consultants
PM PIO (Email from Shayevitz Givon ssclinics.com Corp
We are a privately held company that has over 500 employees and does not qualify for the PPP. The Main Street program is not attractive to
us because #1 It's simply a loan #2 The loan comes with too many contingencies. #3 It's not forgivable.
It doesn't seem to be fair to allow companies below 500 employees a competitive advantage against a company that has over 500
4/13/2020 4:22:00 tflesch@gfles Gordon Flesch employees. If the Main Street program was forgivable it would be must more attractive.
PM PIO (Email from Flesch Tom ch.com Co Our business was started in 1956 by my father and is now transitioning to the 3rd generation - hopefully.
Advanced Digital How can our company apply for the Main Street Lending Program?
Personal
4/13/2020 4:25:00 Forensic
Email Address
PM PIO (Email from Wallia Jai Solutions, Inc.
4/13/2020 4:30:00 david@allovu How are loan values to be calculated for companies that are not yet profitable?
PM PIO (Email from Ally David e.com Allovue, Inc. What restrictions are there for companies that have stakeholders of 20% or more that are VC funds?
Please advise WHERE and WHEN we can obtain an application for the Main Street New Lending Program.
4/13/2020 4:30:00 msilvia@aoc
PM PIO (Email from Silvia Michelle wins.com Please advise on the interest rate for the 4 year loan.
srourk@redw HI looking to find out how to apply for the Main Street loan?
4/13/2020 4:30:00 oodresources
PM PIO (Email from rourk schenae .net
The Main Street Loan will not help businesses because the minimum loan is $1 million dollars. Small businesses like mine applied for other
loans, including the PPP loan, but most of us have still not received any funds at all. We're told that much of the PPP loan funds have
already been used up, while we filed applications immediately when the program was opened up, the federal government then changed the
application, and we filed again, putting us behind in the process.
Small businesses will close forever if the federal government doesn't act immediately to provide assistance to cover payroll costs.
4/13/2020 4:51:00 brenda@sted Please consider lowering the minimum amount for the loans under the Main Street programs. Thanks.
PM PIO (Email from Stedham Brenda hamlaw.com
4/13/2020 Identifying Information Withheld Where can I find the application for "Main Street Lending"?
12:00:00 AM PIO (Email from Thank you
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Main Street Lending Program Comments
Our guests are 90% from the U.S. Our U.S. employee base is ~457 people, which includes 193 employees working on our 4 U.S. flagged
ships (2 which were built in the U.S. for $130 million).
Lindblad is being crippled by the Coronavirus and we are not generating any revenue. Like airlines and hotels, we have a high, fixed cost
structure. Confidential Business Information .
We request the Fed assist us by amending the following in the released guidance:
1)One of the following adjustments to the 6x total leverage requirement asConfidential Business Information
a)Exclude from the calculation of total debt, construction debt related to assets that are still being constructed or are not yet generating
revenue
b)As the capital markets have provided for us, allow borrowers to add an estimated EBITDA for any asset that is not yet in service (our new
ship was 90%+ booked for 2020)
c)View the 6x total leverage in the context of relative priority. The Fed could take the view that a 6x total debt ratio applies solely to first
priority debt
jessica@mille 2)Remove from the Maximum Loan Amount formula "(ii) 30% of the Eligible Borrower's existing outstanding and committed but
4/13/2020 4:54:00 rstrategies.co Lindblad undrawn bank debt." Including this clause in the definition effectively blocks many companies that most need additional liquidity
PM PIO (Email from Lindblad Sven-Olof m Expeditions, LLC
While appreciative of the Fed's leadership to assist Main Street, I'm concerned about the parameters of the program that seem to
favor mid-market rather than Main Street. The biggest concern is the minimum loan amount of $1 million. The PPP loans are assisting in
meeting some needs of small businesses; however, more help is needed to ensure that the 30 million small businesses in America do not
meet their end as a result of COVID-19. Our average PPP loan was $80,000 with a minimum of $2,000. These businesses, with economic
uncertainty, will be unable to find credit alternatives. Additionally, the guidelines imply that existing bank debt is subordinate to Main Street
debt. Clarification is needed to ensure that if the entity sells collateral pledge to a participating entity's non-Main Street loan, proceeds
can be applied to the existing bank loan. The attestation that the lender will not reduce lines of credit although economic conditions, guarantor
strength or available collateral may call for such is also excessively limiting. Finally, the restriction to not use these proceeds to pay other
debts diminishes the program's effectiveness. Many banks, including mine, have deferred principal and interest payments to assist
jcastilla@citiz borrowers during this time. Expanding the program to include debt absorption would dramatically impact the economy and the small
4/13/2020 4:57:00 ensedmond.c The Citizens businesses that support it. I'm grateful for this bold action and appreciate the opportunity to comment.
PM PIO (Email from Castilla Jill om Bank of Edmond
The CARES Act-Tile IV (A)(c)(3)(D)(i)(VII], says "the recipient will not pay dividends with respect to the common stock of the eligible
business, or repurchase an equity security that is listed on a national securities exchange of the recipient or any parent company of the
recipient while the direct loan is outstanding, except to the extent required under a contractual obligation that is in effect as of the date of
enactment of this Act"
So in terms of the Main Street Loan Program-
What does this mean for patronage dividends of cooperatives.these are not based on common stock and would have potential negative
impact on cooperatives?
What does this mean for partnerships.they do not have common stock (rather they have partnership units) and they make distributions the
brad.mohrma partners need to receive to enable them to pay taxes on their share of the income.
4/13/2020 5:09:00 nn@kcoe.co Where do S-corporations fit into these limitations.they do have common stock but do not pay dividends, rather they pay distributions for the
PM PIO (Email from Mohrmann Brad m same reason as partnerships.
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Main Street Lending Program Comments
1. Would the restrictions on capital distributions under the Main Street Lending Program prevent a member-owner of a cooperative
from leaving the cooperative? That is, if a member exits the cooperative (perhaps due to retiring from farming, or due to death), the
cooperative must currently repurchase that member's share.
2. Would the restrictions on capital distributions under the Main Street Lending Program prevent a cooperative from paying out the
federally mandated 20% dividend (for tax purposes) to its members when the cooperative realizes a profit?
3. Would the restrictions on capital distributions under the Main Street Lending Program prevent a borrower that is organized as a
cooperative from paying out previously deferred patronage refunds/equities?
luke.greiner 4. Would the a borrower that is organized as a supply cooperative be prohibited from paying, inclusive of premiums, a maximum figure
4/13/2020 5:15:00 @lathropgpm for commodities (e.g, milk) to their patrons? (I.e., could a dairy cooperative who is a borrower use funds from the loan to subsidize
PM PIO (Email from Greiner Luke .com members' milk price or would this be considered an implied/inappropriate shareholder distribution?)
How can we apply for the Main Street Loan?
4/13/2020 5:18:00 floorsbyadria Adrian Flooring
PM PIO (Email from Ungureanu Camelia n@gmail.com Inc.
Essential health care nonprofits under 500 employees were covered in the PPP, but were completely left out in the Mainstreet Lending
Program. Nonprofits of all sizes have the same pressures of being restricted from making a profit and forgivable loan programs recognize
that restriction. Even low interest loans are difficult if not impossible for nonprofit businesses to repay who do not have large or any cash
reserves. Our agency, Momentum for Mental Health, provides essential mental health and substance use disorder services to almost an
entirely Medicaid population. We are included in the Federal definition of essential health benefits and yet do not receive the same type of
dmineta@mo support as other nonprofit essential health service providers. With an expected wave of new mental health and substance use disorder needs
4/13/2020 5:24:00 mentummh.o Momentum for on the way, the nonprofit providers need some specific stimulus to keep our doors open for when existing and new clients are identified for
PM PIO (Email from Mineta David rg Mental Health services.
There are caps on leverage multiples of 2019 EBITDA of 4 or 6x, depending on the product. Expanded is 6x and New is 4x. In calculating
EBITDA is there a cap on adjustments?
Is there an ability to repay test performed on 2019 EBITDA that needs to be met to qualify for this program?
After the one-year deferral period is the amortization 3 years? Are longer amortizations possible for properly secured credit? Why is there no
secured option for the New Loan Program?
Are any industries excluded? If so which ones?
What does "reasonable efforts to maintain its payroll and retrain its employees during the term of the loan" mean and what is the
impact of the Borrower failing in that regard?
Are there quantifications on capital distribution restrictions?
What covenants or default provisions can (or can't) be included in the Loan Agreements?
What are the reporting requirements during the loan term (from bank and borrower) to the SPV?
kevin.rafferty For companies with operating lines of credit that function on a daily basis, how does the bank insure the cash proceeds are not used to pay
4/13/2020 5:30:00 @hancockwh Hancock down the revolver? Cash is fungible.
PM PIO (Email from Rafferty Kevin itney.com Whitney Bank Why limit the New Loan facility as unsecured only?
Can the Expanded Loan Facility be second lien? Are loans risk rated adversely and loans on non-accrual automatically excluded from
consideration? Will any exception to the dividend prohibition be available for tax distributions to the owners of pass-through entities? Are US-
chartered subsidiaries of foreign corporations' eligible borrowers? What authorization does the Eligible Lender receive from the FED or
SPV prior to closing/funding of each loan? Do we get a funding commitment from Fed to eliminate warehousing risk? How often will FED
SPVs entertain purchases? At closing, Weekly, Monthly? What happens when the allocation is spoken for? Will a bank have a specific
allocation of capacity defined up front? What is recourse to bank for underwriting or servicing flaw? Will the Fed SPV require a standard
chris.pennewi documentation package? How will voting rights be handled with the SPV should there be a modification needed during the loan term? What
4/13/2020 5:32:00 ll@hancockw Hancock documentation requirements will there be: i.e. Inter-creditor Agreement, participation agreement etc.
PM PIO (Email from Pennewill Jr Christopher hitney.com Whitney Bank
Identifying Information Withheld I would like to apply for The Main Street Lending Program.
4/13/2020 Thank you
12:00:00 AM PIO (Email from
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Main Street Lending Program Comments
Will the affiliation rules applied by the SBA with respect to the PPP program also be applied to the mid-sized lending program.
When you count employees of an applicant, does that include all of its employees, or only employees who reside in the United States.
Is SOFR the only index possible? Can the bank place a floor on the SOFR index?
Can these be swapped? Should there be a fixed rate option?
The two different types of facilities seem to treat the split of the upfront fee differently? Was this intended and if so what is the rational?
Please verify that the maximum fee eligible to be charges to Borrower is 00 bps, of which 95 bps is remitted to SPV
Identifying Information Withheld Please specify annual monitoring requirements
Is the Bank responsible for verification and due diligence of Borrower's attestation?
4/13/2020
12:00:00 AM PIO (Email from
What is the definition of "Eligible Borrower's existing outstanding and committed but undrawn debt"? Is this only Bank debt?
Other non-bank financial institutions? Individuals/insiders/affiliate notes payable? What about discretionary revolving credit facilities where a
Lender can choose to advance or not advance for any reason? (such as factoring, inventory, or trade finance facilities) Lastly, does it include
trade debt (A/P)
4/13/2020 5:56:00 jbarney@celti Can a Lender refinance (under its own authority) existing lines of credit or other debt of the Eligible Borrower before, at, or around the same
PM PIO (Email from Barney Jake cbank.com Celtic Bank time of closing the new Eligible Loan? And if so, can those facilities be secured while the Main Street loan is unsecured?
4/13/2020 5:58:00 Rbudway@h Are non profits eligible for the Main Street Lending Facility? I'm on the Board of a private school which had an endowment and valuable
PM PIO (Email from Budway Robert pa.edu HPA property but may have short term cash needs.
The proposed Main Street New Loan Facility sounds good.
If the banks are "on the hook" for 5%, while not a lot, this may increase the due diligence period a bank may require. Perhaps, 0%
in Years 1 and 2 and then 2.5% and then 5%...if the goes "bad" fast, they won't be on the hook as much...just thinking this
might encourage a faster process.
Also, the term sheet does not specify the loan closing fees. You may want to do that to prevent fee gouging. A perhaps some guidance on
how the interest spread pricing range may be enacted...you might have to pick an interest spread and stick to it, or provide some simple
guidance on leverage ratios?
And, like the new PPP Liquidity fund, you may want to consider rolling this program out at the same time as rolling out a liquidity option for
Personal smaller / regional banks to get access to more funds for these loans.
4/13/2020 6:06:00 Email Address Sweat Energy
PM PIO (Email from White Andrew Services, LLC Thank you!
grosado@ac For a non-profit organization that does not meet the size requirements under the Paycheck Protection Program and has more that 500
4/13/2020 6:07:00 acianetwork. employees, it would be helpful for the Main Street Loan Program to have a forgiveness provision - similar to PPP. Additionally,
PM PIO (Email from Rosado Giamara org Fees/origination points should be waived for qualifying non-profit organizations. Thank you.
Identifying Information Withheld As a non-profit organization that does not meet the size requirements under the Paycheck Protection Program and has more that 500
4/13/2020 employees, it would be helpful the Main Street Loan Program to have a forgiveness provision - similar to PPP. Additionally, Fees/origination
12:00:00 AM PIO (Email from points should be waived for qualifying non-profit organizations. Thank you."
Identifying Information Withheld As a non-profit organization that does not meet the size requirements under the Paycheck Protection Program and has more than 500
4/13/2020 employees, it would be helpful the Main Street Loan Program to have a forgiveness provision - similar to PPP. Additionally, Fees/origination
12:00:00 AM PIO (Email from points should be waived for qualifying non-profit organizations. Thank you.
Page 36 of 363
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Main Street Lending Program Comments
A few questions regarding the Main Street Lending Program:
1. Are loan term details such as construction loan "draws" determined between lender and borrower or does the Fed have input?
2. Is the 1st year's amortized Interest & Principal that is deferred, a balloon payment at the end of year 4 or tacked on as a year 5?
3. If the borrower is doing 2 separate "projects" under its business, will the bank just classify them internally as two different
"sub-loan numbers" under a "Master Loan" from the Main Street Lending program or does the borrower apply for
multiple loans for each "project"?
4. Do the borrower and lender determine the interest rate on the loan, as the Main Street Lending program's term sheet only states
"SOFR plus 250-400 BPS"?
5. Is the loan AMORTIZED over 4 years, or is that just the TERM of the loan. Basically, can the loan be amortized over 25 years, with a
maturity/balloon upon year 4?
Personal 6. Does the Bank/Lender handle all the underwriting, or is the Fed via the Main Street Lending Program involved also?
4/13/2020 6:33:00 Email Hillside Home
PM PIO (Email from Sahakian Armen Address Builders LLC
The MSLP terms seem to preclude loans to biotech firms in pre-clinical and clinical development stages by reason of the leverage limits
related to EBITDA. Though it is true that the MSLP and PPP loans are intended to preserve employment, the reality is that both private
david.meredit Strathspey markets and public markets are very difficult to access now, and companies in pre-clinical and clinical development stages (1) employ people
4/13/2020 6:35:00 h@strathspe Crown Holdings and (2) are undertaking R&D that underpins future earnings for the nation's economy in high value products.
PM PIO (Email from Meredith David ycrown.com Group, LLC
As a non-profit organization that does not meet the size requirements under the Paycheck Protection Program and has more that 500
Personal
4/13/2020 6:56:00 employees, it would be helpful the Main Street Loan Program to have a forgiveness provision - similar to PPP. Additionally, Fees/origination
Email Address
PM PIO (Email from Mamelka Angela Acacia Network points should be waived for qualifying non-profit organizations. Thank you
We have interest in participating but would like clarity on the following:
1.We are an eligible bank, but how does a bank "enroll" to participate?
2.Will FRB form one SPV for all banks, or a single SPV for each bank?
3.Will FRB take our existing loan documents or, like SBA, require us to use special loan documents?
4.All participations require a participation agreement among parties to the agreement. Will FRB supply their version or do we use our own?
robert.edstro Thanks in advance,
4/13/2020 6:57:00 m@opbc.co Oregon Pacific REE
PM PIO (Email from Edstrom Robert m Bank
As a non-profit organization that does not meet the size requirements under the Paycheck Protection Program and has more that 500
4/13/2020 7:00:00 mmatics@pr employees, it would be helpful the Main Street Loan Program to have a forgiveness provision - similar to PPP. Additionally, Fees/origination
PM PIO (Email from Matics Michelle omesa.org Acacia Network points should be waived for qualifying non-profit organizations. Thank you."
Identifying Information Withheld I own a retail store and I do wholesale. my yearly gross income is between one to two millions dollar yearly. i just want to know how if I am
4/13/2020 eligible to apply for main street loan also if i am eligible to do so how do i apply for the main street loan? is there a link? i need your help
12:00:00 AM PIO (Email from please
As a non-profit organization that does not meet the size requirements under the Paycheck Protection Program and has more that 500
4/13/2020 7:03:00 canegron@pr La Casa de employees, it would be helpful the Main Street Loan Program to have a forgiveness provision - similar to PPP. Additionally, Fees/origination
PM PIO (Email from Negron Catherine omesa.org Salud, Inc points should be waived for qualifying non-profit organizations. Thank you
Hi,
When would the MSL program start and how can we apply?
frodriguez@k Thanks,
4/13/2020 7:22:00 andeofund.co
PM PIO (Email from Rodriguez Felipe m Eduardo
Page 37 of 363
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Main Street Lending Program Comments
As a non-profit organization that does not meet the size requirements under the Paycheck Protection Program and has more that 500
employees, it would be helpful the Main Street Loan Program to have a forgiveness provision - similar to PPP. Additionally, Fees/origination
4/13/2020 7:27:00 bakhere@pro points should be waived for qualifying non-profit organizations.
PM PIO (Email from Akhere Bright mesa.org Acacia Network Thank you
Dear Board of Governors,
I would like to provide some comments on the Main Street Lending Programs you are initiating to help struggling business recover during this
COVID-19 Crisis. First, I'd like to extend my thanks for your unseen efforts each and every day. Your focus and leadership likely go
unnoticed to many millions, but is evident during a time like this.
Secondly, as a privately-owned business, I'd ask your consideration to ensure access to the program is not hindered for private
businesses like ours as you prepare regulations for these programs. Hotel groups, restaurant groups, and other privately-owned small to mid-
size businesses may not have existing banking relationships to help facilitate this program effectively. And we need the access to these
Programs to save jobs.
Also, I'd ask that the option to consolidate existing loans & mortgages, be a permitted use of Program funds (in addition to the
currently stated funds). In this way, it will ensure our business's continuity in this crisis, thru recovery, and onto greater success once
again!
Confidential Business Information
Thank you and please know I am available for any clarifications needed.
Best Regards,
Rex Jariwala
Rex@hammo COO
4/13/2020 7:37:00 ckworldwide. Hammock Hotels Hammock Hotels & Resorts
PM PIO (Email from Jariwala Rex com & Resorts
As a non-profit organization that does not meet the size requirements under the Paycheck Protection Program and has more that 500
4/13/2020 7:43:00 jsiddall@pro employees, it would be helpful the Main Street Loan Program to have a forgiveness provision - similar to PPP. Additionally, Fees/origination
PM PIO (Email from Siddall John mesa.org Acacia Network points should be waived for qualifying non-profit organizations. Thank you.
As a non-profit organization that does not meet the size requirements under the Paycheck Protection Program and has more that 500
4/13/2020 8:00:00 skadin@acac employees, it would be helpful the Main Street Loan Program to have a forgiveness provision - similar to PPP. Additionally, Fees/origination
PM PIO (Email from Kadin Steve ianetwork.org points should be waived for qualifying non-profit organizations. Thank you
Page 38 of 363
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Main Street Lending Program Comments
Thumbtack respectfully submits the following comments on the Federal Reserve's Main Street Loan program. We deeply appreciate the
Federal Reserve's attention to the needs of businesses of all sizes during this challenging time.
2019 EBITDA Requirements
Eligibility for Main Street loans is currently tied to EBITDA having been positive in 2019. We ask that you consider removing this requirement
to participate in this program. Otherwise, the program will leave out many credit-worthy businesses that are in need of support, including the
following examples:
A company that had been profitable from 2015-2018 but decided to expand into new work in 2019 and was intentionally EBITDA negative in
2019.
A new business that required significant investment at the start of 2019 but grew to profitability by the end may not have been EBITDA
positive for all of 2019.
An investor-backed start-up that decided that 2019 was a year to invest in growth and may not have been EBITDA positive in 2019.
How to Size Loans
For companies that were not EBITDA positive in 2019, something would need to replace the loan maximum that is currently a multiple of 2019
EBITDA. We recommend that loans be set at a fraction of 2019 gross profit. Gross profit reflects a company's profit before operating
4/13/2020 8:00:00 kellyn@thum expenses, such as salaries and rent, and it therefore reasonably reflects the amount of a loan that would be helpful to cover exactly those
PM PIO (Email from Blossom Kellyn btack.com Thumbtack operating expenses during this challenging time.
To Whom It May Concern:
On behalf of MyPath's board of directors, staff and participants, we thank you for including nonprofits in the CARES Act relief package,
as nonprofits are truly on the front lines of the crisis facing this country. We urge you to include nonprofits in the second phase of relief, Main
Street Lending, as we need additional forms of relief. As both large scale employers and front line service providers assisting families to meet
their basic needs in the face of this crisis, all while our philanthropic funds slow down, nonprofits must receive access to the second phase of
federal relief.
Sincerely,
4/13/2020 8:02:00 Margaret@m Margaret Libby, CEO & Founder
PM PIO (Email from Libby Margaret ypathus.org MyPath MyPath
As a non-profit organization that does not meet the size requirements under the Paycheck Protection Program and has more that 500
4/13/2020 9:36:00 snieto@ubpin employees, it would be helpful the Main Street Loan Program to have a forgiveness provision - similar to PPP. Additionally, Fees/origination
PM PIO (Email from Nieto Stephanie V. c.org Acacia Network points should be waived for qualifying non-profit organizations. Thank you.
Very interested in this loan. We have two catamarans on Waikiki Beach. Confidential Business Information
Personal Email
4/13/2020 9:42:00 Address We have been in this business for over 50 years and believe that we are leaders in this profession. Mahalo
PM PIO (Email from Savio Fariyal Tour Operator
dcollymore@ As a non-profit organization that does not meet the size requirements under the Paycheck Protection Program and has more that 500
4/13/2020 9:43:00 acacianetwor employees, it would be helpful for the Main Street Loan Program to have a forgiveness provision - similar to PPP. Additionally,
PM PIO (Email from Collymore David k.org Acacia Network Fees/origination points should be waived for qualifying non-profit organizations. Thank you.
Page 39 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
This is a comment about the EBITDA requirements for the Main Street facility.
The purpose of the EBITDA requirements seems to be to ensure that the Main Street facility is used by financially viable businesses, and that
is entirely understandable. However, if GAAP measures of EBITDA are strictly enforced, many businesses will be excluded from this facility
due simply to the manner in which they have chosen to operate their business in the preceding year.
Many businesses pay out end of year bonuses to employees, or have one-off or discretionary expenditures specifically intended to make the
business itself operate at or close to breakeven; these businesses, most of them extremely solvent, would be disqualified under a strict GAAP
interpretation of EBITDA required for this facility.
Guidance regarding whether or not a strict GAAP interpretation will be used is absolutely required, and if there is a desire to actually help
many of these businesses that otherwise would fail to qualify for the Main Street facility due simply to the manner in which they chose to
4/13/2020 sidney@onca operate the business so as to target a near breakeven state, then there should be guidance issued related to how companies, lenders, and
10:22:00 PM PIO (Email from VanNess Sidney llcentral.com On Call Central accountants should consider the effects of certain add-backs and adjustments to EBITDA.
As a non-profit organization that does not meet the size requirements under the Paycheck Protection Program and has more that 500
4/13/2020 esmith@hub Acacia Network - employees, it would be helpful the Main Street Loan Program to have a forgiveness provision - similar to PPP. Additionally, Fees/origination
11:08:00 PM PIO (Email from Smith Elizabeth wny.org PROMESA points should be waived for qualifying non-profit organizations. Thank you.
4/13/2020 mcrichton@c Please advise on the use of SOFR as a reference rate and whether it will be calculated in arrears or forward looking. Additionally, will it be
11:22:00 PM PIO (Email from Crichton McLean ooley.com Cooley calculated based on a 30/90/180 day interest period?
Re: the Mainstreet Lending Program, I would ask that you strongly consider including a provision to support equity backed entities who have
steven.hamilt yet to report earnings but employ many individuals. This is particularly important for new media and technology companies that employ 50-
4/14/2020 on@bancofc 500+ employees who did not qualify for the PPP program due to VC/PE interests but require capital to support continued operations and
12:14:00 AM PIO (Email from Schwartz Steven al.com development. Many would also be willing to provide personal guarantees for majority owners.
Confidential Business Information My resort is closed -state mandate -and my staff (65 in
summer in a town of 700) is laid off. We had a projected record year on the books at the end of Feb. Confidential Business Information
. The Resort - golf 18 holes, 34 lodging units, RV Park,
Thunder Bay Restaurant, Elk Viewing Preserve, homesites. Confidential Business Information
jack@thunde Golf Course, Inc Confidential Business Information
Next year would be my families 50th anniversary since opening.
4/14/2020 rbayresort.co DBA Thunder Confidential Business Information ThunderBayResort.com Need help!
12:16:00 AM PIO (Email from Matthias Jack m Bay Resort
Personal Email
Address
BEZO Information on Main Street Lending
4/14/2020 7:00:00 ENTERPRISES,
AM PIO (Email from Labriola Laura LLC
Expanded Loan Facility ("MSELF"):
Suppliers to GM sustained a major hit to 2019 earnings due to the UAW strike. To mitigate this impact on the calculation of EBITDA, a
Borrower should be allowed to normalize 2019 results, or allow a borrower to use its 2018 actual results or its pre-coronavirus 2020 budget for
purposes of establishing the EBITDA base.
The interest rate should be limited to not more than 25 bp greater than the existing term loan, not to exceed SOFR + 400 basis points. A
Lender should not use this as an opportunity to greatly increase rates.
The maximum loan size should be the greater of (i) 50% of existing as well as committed but undrawn senior secured debt; or (ii) an amount
that when added to all existing and committed but undrawn debt, does not exceed 8 times Applicable EBITDA, but not to exceed $150 million.
Increasing the potential loan while maintaining the overall cap will allow companies with higher debt burdens due to one-time events or due to
the nature of its business to participate in the program.
ihessel@bear
4/14/2020 7:31:00 diversified.co Bear Diversified Although the loan cannot be used to prepay existing term loans, it should be available to repay bridge loans or over advances that were
AM PIO (Email from Hessel Ian m Inc provided by senior lenders as a coronavirus accommodation.
Acacia Network- "As a non-profit organization that does not meet the size requirements under the Paycheck Protection Program and has more that 500
4/14/2020 8:06:00 jecollazo@pr La Casa De employees, it would be helpful the Main Street Loan Program to have a forgiveness provision - similar to PPP. Additionally, Fees/origination
AM PIO (Email from Collazo Jennifer omesa.org Salud Inc points should be waived for qualifying non-profit organizations. Thank you."
Page 40 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
Main Street New Loan Facility should be expanded to include loans to start-up businesses which can demonstrate the ability to create no
fewer than 100 jobs within the first year of operation and as many as 300 jobs by the end of the third year of operations with minimum wages
of at least $15 per hour with a hiring preference to low income workers residing in the United States. The maturity of these loans should not
exceed 10 years with one-year deferral of principal and interest payments. Maximum loan cannot exceed $25 million with the actual loan
amount calculated based on a multiple of $75,000 times the number of jobs projected to be created by the end of the third year of operations.
Personal Preferential funding of these loans shall occur for businesses which will have a substantial economic or environmental impact. Attestation
4/14/2020 8:54:00 Email Address relating to EBITDA language condition is not applicable to loans to start-up businesses.
AM PIO (Email from DeRemer Stewart CadizLane LLC.
rpalmer@aca As a non-profit organization that does not meet the size requirements under the Paycheck Protection Program and has more that 500
4/14/2020 8:54:00 cianetwork.or Acacia Network, employees, it would be helpful the Main Street Loan Program to have a forgiveness provision - similar to PPP. Additionally, Fees/origination
AM PIO (Email from Palmer Russell g Inc. points should be waived for qualifying non-profit organizations. Thank you
Volunteers of America - Greater New York, Inc. is a social services agency. We serve over 38,000 clients in Manhattan boroughs and
northern NJ. Average staff compensation is $40,000 a year. We hire recovering staff who live in the poorest neighborhoods and our clients:
people who are conquering, with our help, issues stemming from domestic violence, mental illness, substance abuse, veterans'
concerns, and poverty in general. While we have over 1,000 staff, we are not a rich charity: 95% of our funding is mostly cost reimbursement
based from government contracts. Our cash flow is typically challenged due to slow payments from several agencies. COVID-19 has made
things even worse: city agencies, in particular, must be facing their own COVID-19 challenges. The majority of our staff are social workers,
cooks, maintenance workers and client care workers: good, working class people who support their families through the dignity of work.
Volunteers of Please consider the same forgiveness relief for not for profit organizations. We have been hit hard with extra costs that are so far not yet
America - funded. VOA-GNY would use loan proceeds, or forgiveness amounts, toward staff payroll and benefits costs. This will, in turn, be a step
4/14/2020 8:58:00 joliver@voa- Greater New toward protection of the local economy once businesses are allowed to reopen.
AM PIO (Email from Oliver Julia gny.org York, Inc.
4/14/2020 9:01:00 plee@konda When will there be more guidance on MSLP? When can we apply for the loan?
AM PIO (Email from Lee Patty ur.com
Personal Can you paydown your debt prior to applying for a loan from the Main Street New Loan Facility? My thought is you cannot reduce debt
4/14/2020 Email Address capacity prior to applying for the loan correct? Thank you.
12:00:00 AM PIO (Email from Gmeinder Ben
mcompres@ As a non-profit organization that does not meet the size requirements under the Paycheck Protection Program and has more than 500
4/14/2020 9:37:00 acacianetwor Acacia Puerto employees, it would be helpful for the Main Street Loan Program to have a forgiveness provision - similar to PPP. Additionally,
AM PIO (Email from Russi Raul k.org Rico Inc Fees/origination points should be waived for qualifying non-profit organizations. Thank you.
I would encourage you to lower the minimum loan amount from $1 million to $500,000. As a small business with 65 employees and about $5
million in revenue, $1 million is more than I need or can afford to finance.
Paycheck Protection Program funds provide limited flexibility outside of funding payroll for a short period of time during 2020. There are other
intermediate-to-longer term business needs that require financing due to the cash flow challenges brought on by COVID19. For example:
capital improvement projects that have been agreed to, scheduled equipment that must be replaced, marketing expenditures to build back
business, recruiting and training new employees, paying back deferred expenses, etc. There is no other avenue to address these non-PPP
related cash concerns. I suspect a loan floor of $1 million eliminates many businesses that are in need of capital from eligibility.
4/14/2020 9:38:00 Personal Email Thank you for reconsidering.
AM PIO (Email from Raval Mitesh Address SUBWAY
As a non-profit organization that does not meet the size requirements under the Paycheck Protection Program and has more that 500
4/14/2020 9:39:00 rrussi@acaci employees, it would be helpful for the Main Street Loan Program to have a forgiveness provision - similar to PPP. Additionally,
AM PIO (Email from Russi Raul anetwork.org Acacia Network Fees/origination points should be waived for qualifying non-profit organizations. Thank you.
As a non-profit organization that does not meet the size requirements under the Paycheck Protection Program and has more that 500
4/14/2020 9:40:00 lalbors@acac employees, it would be helpful for the Main Street Loan Program to have a forgiveness provision - similar to PPP. Additionally,
AM PIO (Email from Albors Lymaris ianetwork.org Acacia Network Fees/origination points should be waived for qualifying non-profit organizations. Thank you.
Due to the composition of the hotel industry and how fragmented we are, this loan needs to have the same profile eligibility as PPP so it can
lily.hu@cresc be available to individual hotel owners, who are NOT the Employer. This provision was not written into the Employee Retention Credit
4/14/2020 9:45:00 enthotels.co program, and therefore no one in the industry with the Owner-Employer relation could take advantage of that program.
AM PIO (Email from Hu Lily m
ggonzalez@a As a non-profit organization that does not meet the size requirements under the Paycheck Protection Program and has more that 500
4/14/2020 9:50:00 cacianetwork. employees, it would be helpful the Main Street Loan Program to have a forgiveness provision - similar to PPP. Additionally, Fees/origination
AM PIO (Email from Gonzalez Gabriela org Acacia Network points should be waived for qualifying non-profit organizations. Thank you.
Page 41 of 363
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Main Street Lending Program Comments
Personal Please don't forget the really small rural businesses like ours that have 1 to 10 employees and are the heart of our historic
Email Address downtowns' commercial and social lives. The owners are unable to take on more debt for shops and restaurants that already operate on
4/14/2020 9:51:00 Main Street a thin margin. Especially hard hit are the sole proprietors who are being inadvertently omitted from the major programs and need forgivable
AM PIO (Email from MacIntosh Kay Chestertown loans or small grants to be able to reopen when the virus cloud finally lifts. Thanks for listening!
As a non-profit organization that does not meet the size requirements under the Paycheck Protection Program and has more that 500
employees, it would be helpful the Main Street Loan Program to have a forgiveness provision - similar to PPP. Additionally, Fees/origination
4/14/2020 9:56:00 mrowe@hub Hispanos Unidos points should be waived for qualifying non-profit organizations.
AM PIO (Email from Russi Eugenio wny.org De Buffalo Thank you
If the purposes of the Main Street Lending Program (MSLP) are to "promote maximum payroll," ensure economic recovery and
provide "relief and stability," it is imperative that the Federal Reserve allows proceeds of these loans to repay pre-existing debt
where such repayments preserve payroll, long-term viability and reduce or eliminate principal payments, preserving cash flow. Maximum
flexibility to employ business judgment is necessary where the effects of the pandemic may be more longitudinal for critical infrastructure
companies such as small and mid-sized satellite, terrestrial and other telecommunications resellers serving the energy sector. The Federal
Reserve must focus on net debt, excluding the Paycheck Protection Program, which will largely be forgiven. A decline in overall financial
performance due to coronavirus can put businesses, even with moderate debt, in a potential default position, risking jobs. Allowing proceeds
from federal programs to pay down existing debt provides longer term job protection by helping companies remain solvent during the crisis
4/14/2020 9:58:00 jamie.barnett and during the aftermath of the crisis until business levels return to pre-crisis levels.
AM PIO (Email from Barnett James @rig.net RigNet, Inc.
Questions re: Main Street Loan Program:
(a) is a personal guaranty required?
(b) Must the borrower have employees in order to qualify for this loan (our business has no employees but contracts with other companies for
use of contractors to perform most business functions (i.e., acctg, marketing, sales. etc/) ?
(c) Under loan term sheet, borrower cannot issue dividends or distributions to owners during the term of the loan plus 12 months, but what
about distributions to owners to pay tax liabilities that flow thru from the borrower to the owners (i.e., where the borrower is an LLC)?
(d) Loan Fees - Is the borrower liable for up to 2% of loan as a fee to the lender (i.e., 1% for the loan charged by the lender, and 1% that the
lender may bill the borrower to reimburse the lender for the fee that the lender pays to the Fed)?
bradberish@ (e) After the initial year of the loan, what payments are due to the lender (i.e., interest only, or is it principal and interest based on some form
4/14/2020 sovereignbra of amortization schedule) ?
10:13:00 AM PIO (Email from Berish Brad nds.com Luc Belaire LLC
gmarinescu As a non-profit organization that does not meet the size requirements under the Paycheck Protection Program and has more that 500
4/14/2020 @promesa.or employees, it would be helpful the Main Street Loan Program to have a forgiveness provision - similar to PPP. Additionally, Fees/origination
10:20:00 AM PIO (Email from Marinescu-CruGabriela g Acacia Network points should be waived for qualifying non-profit organizations. Thank you
We are interested in obtaining information on how to access/start the process for the Main Street Expanded Loan Program. Do you anticipate
4/14/2020 lpistilli@kram publishing information as to process - and if so - would you please advise as to when and how to access?
10:22:00 AM PIO (Email from Pistilli Lia erlevin.com Kramer Levin
The Main Street New Loan Facility should be expanded to include loans to start-up businesses which can reasonably demonstrate the ability
to create no fewer than 100 jobs within the first year of operation, and as many as 300 jobs by the end of the third year of operations, with
minimum wages of at least $15 per hour and with a hiring preference to low-income workers residing in the United States. The maturity of
these loans would not exceed 10 years, with a one-year deferral of principal and interest payments. The maximum loan would not exceed
$25 million, with the actual loan amount calculated based on a multiple of $75,000 times the number of jobs reasonably projected to be
Personal created by the end of the third year of operations. Preferential funding of these loans would be for businesses which would have a projected
4/14/2020 Email Address substantial economic or environmental impact. The attestation relating to EBITDA would not be applicable to loans to start-up businesses.
10:32:00 AM PIO (Email from Loumiet Carlos
What is the definition of "majority" in Eligible Borrowers paragraph? Does it mean more than 50% of its employees must be based
in the United States?
Can a Borrower use its convertible notes instead of a term loan as an eligibility requirement?
Do convertible notes have to be included as debt?
Please provide clearer definitions of EBITDA & Debt.
daniel.maran
4/14/2020 gola@kodak. Eastman Kodak Thanks,
10:33:00 AM PIO (Email from Marangola Daniel com Company Dan
Page 42 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
I understand the Main Street Lending Program is referenced in Section 4003(c)(3)(D)(ii) of the CARES Act, which is separate and in addition
to the Mid-Size Business Program to be implemented by the Treasury Secretary under Section 4003(c)(3)(D)(i) of the Act. Is this correct?
4/14/2020 parksb@balla Will there by separate Mid-Size Business Program as provided in Section 4003(c)(3)(D)(i) of the CARES Act? If so, what is the anticipated
10:34:00 AM PIO (Email from Park Steve rdspahr.com timing on these two programs?
1. For purposes of the 6x leverage ratio, EBITDA should be calculated as defined in the underlying credit agreement at the time the loan is
funded.
2. For purposes of the 6x leverage ratio, debt should be defined as indebtedness for money borrowed.
3. There is uncertainty in the loan markets as to SOFR interest rate conventions - do you mean backward looking SOFR or SOFR based on a
Kramer Levin futures market (is it robust enough) ? The loan market is still basing interest on LIBOR with replacement mechanisms punting the migration
4/14/2020 Refarley@kra Naftalis & to SOFR when these conventions become clear. You should provide for that in this program to eliminate the need for significant amendments
10:41:00 AM PIO (Email from Farley Richard merlevin.com Frankel LLP to the payment and interest calculation mechanics in existing credit agreements.
I am a partner with a public accounting firm in Iowa. One of our clients is looking into applying for a loan under the Main Street Lending
Program, however; we have a question (concern) regarding the language that limits the payment of dividends. Our client is an S Corporation
for income tax purposes. As an S Corporation the corporation itself does not pay income tax on its earnings but rather passes through the
income to the shareholders of the corporation and all taxes are paid by the individual on the shareholders individual 1040. Due to this pass-
through treatment of income and deductions the shareholders need to receive distributions from the company in order to pay federal and state
income taxes on the earnings. The current language limiting dividends appears to apply only to public companies, however; this point is not
4/14/2020 khabel@honk Honkamp clear. Could the Reserve please clarify whether or not an S Corporation could make reasonable distributions to shareholders for the payment
10:50:00 AM PIO (Email from Habel Keith amp.com Krueger of income taxes.
4/14/2020 carli@nimahu Please send me information about how to apply for a Main Street Lending Program loan.
10:51:00 AM PIO (Email from Carli Donald nter.com Nima Hunter Inc.
It is imperative that non profit organizations be included as entities eligible for the Main Street Lending program. Many non-profit organizations
have more than 500 employees were thus ineligible for the Paycheck Protection Program under the SBA. Cutting those organizations out of
the MSL program will severely impair their ability to survive the COVID crisis. It is also true that while larger non profit organizations tend to
jefferyfox@a have greater revenues than those with under 500 employees, they are still mission driven and maintain a goal for zero net income at the end
4/14/2020 bilitiesfirstny. Abilities First, of the fiscal year. For these reasons, eligibility for assistance programs should not distinguish between non profits based on number of
10:54:00 AM PIO (Email from Fox Jeffery org Inc. employees.
I believe we can rebuild America stronger than ever .Much like the growth of the Industrial Revolution, programs like MSL will allow
businesses to get access to capital and grow America even stronger after suffering the devastating losses of Covid-19. I would like to
participate in this program and Confidential Business Information , adding a school on sit, more locations, while creating many
new jobs. Please send application details at your earliest convenience.
Personal
4/14/2020 Email Myra P and Sincerely
10:55:00 AM PIO (Email from Porter Myra Address Company, Inc Myra Porter, Esq.
I have been informed that the the Trump Administration is trying to exclude nonprofits, many institutions of higher learning and Minority-
Serving Institutions from critical loans in the CARES Act. This would be extremely damaging to the recovery of our communities and to the
4/14/2020 peifer@unc.e University of recovery of higher education, as these institutions play a key role at the local and state level. Please ensure that they retain eligibility.
11:00:00 AM PIO (Email from Peifer Mark du North Carolina
US Olympic Please consider adding non-profits to be eligible for the Main Street Lending facility.
bobbi.mcpher &
4/14/2020 son@usopc.o Paralympic
11:12:00 AM PIO (Email from McPherson Bobbi rg Committee
tokiwa.smith As an entrepreneur and nonprofit owner I would like to be included and receive information about funding
4/14/2020 @semsucces
11:14:00 AM PIO (Email from Smith Tokiwa s.org SEM Link
Eligibility for REITs: As drafted, the Main Street Loan Program would prohibit REITs, who are required to distribute at least 90% of its taxable
income to shareholders annually in the form of dividends, from participating in the program. Commercial Real Estate REITs are suffering
staggering losses as a result of tenants not paying rent and have no avenue for relief under the existing stimulus programs. The PPP will only
april.dendy@ cover payroll expenses, but will not be enough for loan payments and other expenses. Is it possible for REITs to borrow at the taxable REIT
4/14/2020 bccompany.c Burroughs subsidiary level and not make distributions up to its parent (in essence walling off the TRS), but allow the parent to still distribute taxable
11:16:00 AM PIO (Email from Dendy April om & Chapin income to shareholders as required?
Personal Excluding loans to the groups that most need our support and provide invaluable services/functions, is beyond my comprehension!!!! On
4/14/2020 Email Address multiple occasions I have witnessed, volunteered and/or worked for nonprofit so I have seen firsthand the dire need for their support and the
11:30:00 AM PIO (Email from Lodestro Cynthia impact they have! For God's sake, practice what you preach and what is preached in our multiple faiths.
Page 43 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
Hello,
4/14/2020 GSANTIAGO RSM PUERTO
11:56:00 AM PIO (Email from SANTIAGO GERARDO @RSM.PR RICO Is there any intention of including Puerto Rico in the Main Street Lending Program?
Good afternoon,
Will the new Main Street Lending program allow non-profits to borrow money in addition to companies?
Greater Thank you in advance,
Personal
4/14/2020 Cleveland Film
Email Address
12:00:00 AM PIO (Email from Wagner Jon Commission Jon
The CIA is a 501(c)3 Educational Institution and also is a major economic driver - our main campus in Hyde Park, NY, and our branch
campuses in The City of Napa, CA, and St. Helena, CA, as well as The CIA San Antonio. In each of its regions with food and hospitality
programs that support the restaurant industry and tourism. These programs are a major source of revenue which include public restaurants,
special events, and other consumer operations in NY, CA, and TX; all of our operations, including these, fall under one 501(c)3. With those
business lines shuttered, the lost revenue will impact the CIA's ability to maintain student affordability. In addition, like any food,
beverage, and hospitality business there are fixed costs related to those operations that we have had to sustain, even while suspending
operations. The affect the restaurant and hospitality industry is feeling due to COVID-19 is being felt by the CIA as well. Right now, despite
restaurant and hospitality revenue being central to our revenue model, the CIA is unable to qualify for SBA funds because we are a nonprofit
educational institution with these businesses falling under our one tax ID. As of today CARES funding will not address these components of
Rick.Tietjen The Culinary our operation as were not able to access funds coming through the SBA. As a nonprofit organization the CIA should not be excluded from
4/14/2020 @Culinary.ed Institute of accessing funds through the Main Street funding opportunity which are intended to support business like ours.
12:06:00 PM PIO (Email from Tietjen Rick u America
Personal My bank, TDBank does not have any information to apply for the Main Street funding Program nor does American Express, Paypal... how do
4/14/2020 Email aPear Creative we apply?
12:23:00 PM PIO (Email from Poirier Christie Address Corp.
Rescue Air Would we apply for this through our bank, or is there another avenue?
4/14/2020 mhirsh@resc Heating and Thank you
12:33:00 PM PIO (Email from Hirsh Michael ueairtx.com Cooling Michael
God bless you all in these hard times.
i have been trying to access who i possibly talk to about the Main Street Lending plan announced last week?
banks do not know anything and frankly no one does.
paul@paulfle when will they be available and how to i apply
4/14/2020 mingrestaura fleming thanks very much
12:39:00 PM PIO (Email from fleming paul nts.com restaurants paul fleming
Please reconsider the Maximum loan size that is the lesser of (i) $25 million or (ii) an amount that, when added to the Eligible Borrower's
existing outstanding and committed but undrawn debt, does not exceed four times the Eligible Borrower's 2019 earnings before interest,
taxes, depreciation, and amortization("EBITDA");- The multiple needs to be higher for especially for certain industries or another
metric needs to be used.
jonathan@coi
4/14/2020 company.co Please also reconsider the use of the fund to refinance/pay down other debt since the COVID crisis will likely negatively effect debt covenants.
12:50:00 PM PIO (Email from Samek Jon m COI Company
Page 44 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
Please include loans to new non-speculative businesses that show they would have a generally sound financial condition. Significant
employment and business destruction is taking place that will inevitably damage the safety, flexibility and stability of our monetary and
financial system.
Absent MSNLF expansion, new businesses that would acquire, re-start or launch operations of businesses shuttered, due to demand loss,
owner death or retirement, etc., or whose business models have been impaired will be unlikely to secure debt financing timely or at all, except
possibly from private equity, resulting in further resource concentration in a small group and increasing our economic fragility.
Please allow (i) new businesses to obtain loans if they show ability to create jobs (say 25 low and middle income jobs in the first year), to
acquire or create material assets (say FMV of at least 50% of the loan drawn) and to become profitable with sufficient cash flow (based on
projected EBITDA) to timely repay the loan, (ii) a longer maturity of these loans (say 5 years, up to 10 years for asset heavy businesses) and
a longer deferral of amortization where assets cannot be placed in service quickly and (iii) authorize loan amounts based on the number of
jobs to be created (say a multiple of $75,000 times the number of jobs to be created) and to provide for preferential funding in areas which
mr.barker@w have been hardest hit or are historically underserved by the banking and investment community.
4/14/2020 ithersworldwi Withersworldwid
12:50:00 PM PIO (Email from Barker M Ridgway de.com e
For starters, I think the Main Street Lending Program is outstanding. That said, I would appreciate if you would consider companies like mine
Confidential Business Information
Beyond the PPP, the Main Street Lending program caps the lending at 4x 2019 EBDITA. We were close to profitability in 2019 (assuming you
will use GAAP), but still operated at a loss, so we would be excluded from this program.
The only other source of funding is the SBA's Disaster Loan Program. However, what the NYT reported last week is consistent with our
experience.
In total, the programs are set up to benefit established companies and not start-ups. I worry that a generation of innovative companies will be
washed away.
I do have a policy idea that I hope you will consider. In short, use the current framework but also include a max loan that is tied to employee
count. For instance, $20k per FTE. You could go further and only make that open to companies that increased their 940 headcounts in 2019
by 200%.
kyle.weatherl In this scenario, the Fed would not only help established companies but also rapidly expanding companies where a disproportionate
4/14/2020 y@stayfrontd percentage of the job growth and innovation occurs.
12:54:00 PM PIO (Email from Weatherly Kyle esk.com Frontdesk
The Puerto As a non-profit organization that does not meet the size requirements under the Paycheck Protection Program and has more that 500
Rican employees, it would be helpful the Main Street Loan Program to have a forgiveness provision - similar to PPP. Additionally, Fees/origination
Organization to points should be waived for qualifying non-profit organizations. Thank you.
Motivate,
adgarcia@ac Enlighten and
4/14/2020 acianetwork. Serve Addicts,
12:00:00 AM PIO (Email from GARCIA ARIEL org Inc.
I am contacting you regarding your "Main Street Lending" Program. I ask that you permit nonprofits and universities to participate
in it. Most universities have more than 500 employees so they cannot qualify for the SBA program in the CARES Act. More than 5 million
people are employed by universities and colleges in the United States. Many of these institutions, besides being a main employer in their
communities are also an economic engine. From sponsored research to corporate partnerships, universities are invested in the business
community. Many medical facilities are part of a university system.
During this pandemic, universities have rapidly adjusted by going completely online and having their staff/faculty telecommute. There have
been costs involved in this transition and all institutions are weighing decisions around essential and non-essential staff.
4/14/2020 Jlaudisio@st St. Thomas We ask that you include universities in the "Main Street Lending" program so that once the pandemic passes these institutions are
12:00:00 AM PIO (Email from Laudisio Janine u.edu University positioned to continue to serve and educate the19.9 million students enrolled in college.
Page 45 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
Please consider expanding the Main Street Lending program to nonprofits. Institutions of higher education, along with other nonprofits such
as hospitals, serve as major employers in their communities and, like most businesses, are struggling to maintain operations as we facew
4/14/2020 chapdelaine significant revenue shortfalls for the foreseeable future. We have had to furlough 25% of our staff, with more anticipated. Access to this loan
12:57:00 PM PIO (Email from Chapdelaine Andrea @hood.edu Hood College would help us maintain current employees and meet student financial needs.
4/14/2020 1:04:00 Lee.willard@ Absolutely nonprofits, minority serving institutions, and institutions of higher learning MUST be included in the CARES funding. This money is
PM PIO (Email from Willard Lee duke.edu absolutely critical to our national interest in their success.
In The Name Of GRACE (Giving Recovering Addicts a Chance to Evolve) is a not-for-profit that gives hope to recovering addicts and
alcoholics by helping to support Oxford Houses and provide safe, sober, living homes.
GRACE has opened 15 houses since August of 2016 where previously there were none. Our 2020 goal was to have 20 houses open but we
are struggling to attain any of our fundraising objectives with COVID-19 safe restrictions. We are 100% donation and sponsorship funded.
To compound difficulties, our residents (134 men, women, and parents with children), are 60% employed by hourly positions that are now
closed due to the pandemic. Employment and rent payment on time are 2 of the foundations for our 91% long term recovery over 5 years.
They desperately need assitance.
Personal Email
4/14/2020 1:04:00 In The Name Of
Address
PM PIO (Email from Boyer Karen GRACE
To whom it may concern:
As I review the guidance of the Main Street New Loan Facility Program, I'd like to offer feedback on the Eligible Loan types. The
restriction of maximum loan about to not exceed an Eligible Borrower's 2019 EBITDA (#5) puts smaller businesses who experienced an
investment year at a disadvantage. Our business, Sigora Solar, was one of these businesses. Confidential Business Information
Based on our interpretation of the guidance, this would not allow us to borrow under this program. If this restriction on the maximum borrowing
amount could be revised, we think it would greatly benefit those businesses that were on an upward trajectory and have been significantly
impacted by the current crisis.
mary.mowrer Thank you,
4/14/2020 1:06:00 @sigorasolar Mary Mowrer
PM PIO (Email from Mowrer Mary .com Sigora Solar Controller, Sigora Solar
I am a small business owner looking to apply for a Main Street Expanded Loan. How do I go about that?
Personal Thanks You,
Email PAM Inc dba Holly Udy-Meekin
4/14/2020 Arthur Murray Personal Email Address
Address
12:00:00 AM PIO (Email from Udy-Meekin Holly Dance 602-677-8126
4/14/2020 1:18:00 w.schlesinger Are non-profits, universities and minority-serving institutions excluded from the Main Street Lending Program, and if so, on what basis?
PM PIO (Email from Schlesinger Bill @pvida.net Project Vida These are critical entities, not only in themselves, but in providing jobs and economic stability in their communities.
DBLK&S Music Management is a for-profit small ranch that has been in business since 1996. We live, love, and find time each day to
enjoy music, horses, and students of all ages and from all walks of life.
We are professional musicians with multiple secondary degrees who entertain, teach, and compose. We have 42 years of music
performance, business, and teaching experience with 8 years of that on the road with performances in 22 states and in Germany from clubs
to cafes and halls to stadiums. We have to our credit, multiple professional recordings with radio airplay and live television performances
performing at the Grand Old Opry in Nashville, TN.
As part of the DBL K&S charter, and blending Music Therapy and Equine Therapy since 1996, we depend on students and
Personal performances to support our work and longevity. The COVID-19 pandemic has taken a serious toll on our operations. Therefore, we are
Email DBL K&S looking for assistance to sustain us through this time as well as to build-out facilities while there is time to do so.
4/14/2020 1:20:00 Address Music
PM PIO (Email from Boyer Karen Management Thank you for consideration.
4/14/2020 1:22:00 joberstadt@q Erwin Quarder, I hope you will give priority to firms which have been unable to obtain a PPP loan/grant. We applied for a PPP loan/grant but it appears that
PM PIO (Email from Oberstadt Jim uarder.com Inc. we were too late to the trough, and will not receive any funds.
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Main Street Lending Program Comments
As the CFO of a nonprofit organization that is providing essential services to the community for over 126 years, our agency is dealing with the
impact of the COVID virus on this community with dedicated response and expenses. We provided essential services and have stepped up
services to our clients especially in homeless shelters, meal delivery and mental health programs. We are incurring additional expenses at
an alarming rate and must respond with immediate services and supplies, without being able to think about how to fund all of these necessary
costs. We need to keep our facilities clean and safe for staff and clients and are incurring alarming amounts of cleaning and protection costs.
Our staff are also impacted by school closures, program closures and childcare costs. Since we have more than 500 employees, we are
unable to qualify for the PPP and therefore cannot receive loans/grant assistance through the CARES act provisions. We request that the
forgivable loan provisions be extended to larger Nonprofit agencies such as HSS. We are doing the same essential work as a small nonprofit,
only in larger volumes and at greater cost, but we should be extended the same federal subsidy opportunities. With much appreciation in
4/14/2020 1:31:00 jlume@henry Henry Street advance, respectfully Josephine Lume and the Henry Street Settlement team.
PM PIO (Email from Lume Josephine street.org Settlement
Hello, I would kindly need your assistance to apply for this loan. Can you send me a list of approved lenders or if there is an application so I
HGEORGE@ ST GEORGE can apply by myself.
4/14/2020 1:38:00 STGAUTOG AUTO SALES
PM PIO (Email from George Hany ROUP.COM INC
In support of the 4,000 employees of a regional non-profit health and human services agency that provides programs and services to nearly
10,000 people with intellectual and developmental disabilities, special needs, their families and older adults throughout numerous counties in
Western New York and the Greater Rochester region, I am writing today to inform you that People Inc. is fully engaged in dealing with the
COVID-19 crisis. They must ensure that more than 150 community-based homes and services for people with disabilities remain as safe as
possible and are staffed 24/7. The vulnerable people that depend on People Inc. deserve no less. However, because they are providing
essential services during the crisis, People Inc. has incurred highly unusual increased costs in staffing, PPE, and cleaning services.
Since People Inc. is not eligible for the Payroll Protection Program (PPP) due to their size and the fact that they must remain fully operational,
we request that the Mid-Size Loan Program have provisions to convert to a forgivable loan for nonprofits that face staggering losses due to
COVID-19. This would grant them the same protections as PPP.
abuchwald@
4/14/2020 1:45:00 people- Thank you in advance for your support of direct care staff, the people they support and People Inc.
PM PIO (Email from Buchwald Alyssa inc.org People Inc.
4/14/2020 1:45:00 cfoster@front Frontwave Credit How can Frontwave Credit Union participate in this program? Will you call or email me details please?
PM PIO (Email from Foster Carrie wavecu.com Union
I urge you to consider including nonprofits in the new main street lending program. I work for Aliviane, Inc, a nonprofit organization with over
50 years of experience providing substance use prevention and treatment services to the most marginalized populations in West Texas. We
4/14/2020 1:47:00 gvalenzuela employ 148 employees. Excluding nonprofits is a significant blow, especially since we are also ineligible for the Paycheck Protection
PM PIO (Email from VALENZUELAGUILLERMO @aliviane.org Aliviane Program.
I am looking to inquire about the Main Street Lending program to find out if a list of banks that are partaking in the program is avaiable. All of
4/14/2020 kirby@midso the local banks we deal with has said they do not know about the program.
12:00:00 AM PIO (Email from Wilson Kirby uthaudio.com Mid South Audio
Personal Email Please be far and help us continue to help other who need us.
4/14/2020 1:53:00 Address
PM PIO (Email from Adams Tiffany People Inc
Please consider allowing higher education to participate in the Main Street Lending program. Participation will provide many schools with
4/14/2020 2:07:00 macur@med some debt relief. We do not have a Chapter 11 option for debt restructuring. Participating in the Main Street Lending program would give us
PM PIO (Email from Macur Dr. Kenneth aille.edu Medaille College an opportunity to restructure the debt during the critical rebuilding academic year of 2020-21.
Are there guidelines for where in the range of interest rates a borrower falls?
Repayment schedule?
4/14/2020 2:08:00 jcornett@360 Guidelines for "it will make reasonable efforts to maintain its payroll and retain its employees"?
PM PIO (Email from Cornett John care.com Other than the restrictions already specifically stated, any other guidance on the use of loan proceeds?
As a non-profit organization that does not meet the size requirements under the Paycheck Protection Program and has more that 500
4/14/2020 2:09:00 plucien@pro employees, it would be helpful the Main Street Loan Program to have a forgiveness provision - similar to PPP. Additionally, Fees/origination
PM PIO (Email from Lucien Phillip mesa.org Acacia Network points should be waived for qualifying non-profit organizations. Thank you.
4/14/2020 2:12:00 Personal We are a small nonprofit in SF. We are trying to get the PPP forgivable loan because we are not able to operate during the SIP, so it's
PM PIO (Email from Keston Vicky Email Address Renegade Girls hard to think of repaying a loan when we will never make up that revenue.
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Main Street Lending Program Comments
The nonprofits are the glue that keep our communities together. They are the boots on the ground, and often - for some people - the only
resource these people have. If anyone, they are impacted sometimes even greater than for profit businesses. Please think twice before
Personal omitting them from funding. Think about your own life - and when you were growing up and first starting out. All the non profits that touched
4/14/2020 2:13:00 Email Address your own life personally. Would you want that taken away from the next generation. We live in extraordinary times and they require
PM PIO (Email from Katsaros Robin extraordinary leadership. Do the right thing. Be proud of your decisions.
In support of the 4,000 employees of a regional non-profit health and human services agency that provides programs and services to nearly
10,000 people with intellectual and developmental disabilities, special needs, their families and older adults throughout numerous counties in
Western New York and the Greater Rochester region, I am writing today to inform you that People Inc. is fully engaged in dealing with the
COVID-19 crisis. They must ensure that more than 150 community-based homes and services for people with disabilities remain as safe as
possible and are staffed 24/7. The vulnerable people that depend on People Inc. deserve no less. However, because they are providing
essential services during the crisis, People Inc. has incurred highly unusual increased costs in staffing, PPE, and cleaning services.
Since People Inc. is not eligible for the Payroll Protection Program (PPP) due to their size and the fact that they must remain fully operational,
we request that the Mid-Size Loan Program have provisions to convert to a forgivable loan for nonprofits that face staggering losses due to
COVID-19. This would grant them the same protections as PPP.
4/14/2020 2:16:00 Sparadisi@p Thank you in advance for your support of direct care staff, the people they support and People Inc.
PM PIO (Email from Paradisi-Clark Savina eople-inc.org People Inc
The terms of the Main Street New Loan Facility require borrowers to agree to restrictions that apply to direct loan programs under section
4003(C)(3)(A)(ii) of the CARES Act. This provision prohibits the borrower from paying dividends and capital distributions until 12 months after
the loan is paid off. This poses a huge barrier for businesses solely owned by federally recognized Indian tribes. Tribes do not have tax
bases, and thus must fund basic services like healthcare, education, public works, assisted living units, etc. from business revenues. Tribally
owned businesses could agree to forgo payment of dividends and capital distributions while the loan is outstanding, as expressed in section
4003(C)(3)(D)(i)(VII), but they must be able to distribute revenues to their sole owners once the loan is repaid. The restrictions on paying
dividends and capital distributions were included in the CARES Act to prevent borrowers from using credit facilities to amass more wealth for
their shareholders at the expense of job security for their employees. They were not included to stymie the essential government and social
zatherton- Mille Lacs services that are funded by tribally owned businesses. For entities wholly owned by tribes, please consider the less restrictive conditions
4/14/2020 2:18:00 ely@mlcv.co Corporate articulated in the CARES Act regarding paying dividends and capital distributions.
PM PIO (Email from Atherton-Ely Zachary m Ventures
Please include loans to new non-speculative businesses that show they would have a generally sound financial condition. Significant
employment and business destruction is taking place that will inevitably damage the safety, flexibility and stability of our monetary and
financial system.
Absent MSNLF expansion, new businesses that would acquire, re-start or launch operations of businesses shuttered, due to demand loss,
owner death or retirement, etc., or whose business models have been impaired will be unlikely to secure debt financing timely or at all, except
possibly from private equity, resulting in further resource concentration in a small group and increasing our economic fragility.
Please allow (i) new businesses to obtain loans if they show ability to create jobs (say 25 low and middle income jobs in the first year), to
acquire or create material assets (say FMV of at least 50% of the loan drawn) and to become profitable with sufficient cash flow (based on
projected EBITDA) to timely repay the loan, (ii) a longer maturity of these loans (say 5 years, up to 10 years for asset heavy businesses) and
a longer deferral of amortization where assets cannot be placed in service quickly and (iii) authorize loan amounts based on the number of
jobs to be created (say a multiple of $75,000 times the number of jobs to be created) and to provide for preferential funding in areas which
have been hardest hit or are historically underserved by the banking and investment community.
4/14/2020 2:28:00 jtabak@miller Miller Tabak +
PM PIO (Email from Tabak Jeffrey tabak.com Co., LLC
The Federal Reserve's new Main Street lending program should be expanded to include nonprofit organizations. Nonprofits are an
economic powerhouse in the U.S., providing 12.3 million jobs, 1.4 million in Texas alone. $110 billion of Texas' GDP is due to the
nonprofit sector. Lending programs need to take into account nonprofits' enormous contribution to the economic health of the community
as well as the welfare of its residents. They are being tasked more than ever before due to this crisis and it is critical that they have options to
4/14/2020 bsenger@ep El Paso Center expand and remain sustainable. To understand more about our impact and why the Federal Reserve should expand this lending opportunity,
12:00:00 AM PIO (Email from Senger Beth ccinc.org for Children, Inc. please visit www.councilofnonprofits.org.
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Main Street Lending Program Comments
It is my understanding that the Main Street lending program will support up to $600 billion in bank lending to small and mid-sized businesses,
including two lending options: new loans of $1 million to $25 million, or expansion of a business's existing loan with a bank to up to $150
million. It is also my understanding that the Main Street Lending Program excludes nonprofits, many institutions of higher learning and
Minority-Serving Institutions. I strongly urge that the Federal Reserve make eligibility changes to this initiative to include nonprofits. It is
4/14/2020 2:30:00 itapia@alivia crucial to include nonprofits to continue operating and providing vital services like ours, providing substance use and mental health disorder
PM PIO (Email from Tapia Ivonne ne.org Aliviane treatment.
Main Street New Lending Program
1.Change 4-yr maturity to 5-yr
2.Max loan: 5(i) change to $50 million; 5(ii) change to 5x EBITDA
3.Attestations
a.Why not provide incentives to Borrowers that INCREASE their employment during each year of loan by offering loan forgiveness of
1% for each % increase in average employment each year. Example: Increase employment 10%; forgive 10% of loan
b.Clarify that Borrower need NOT maintain the leverage requirement in 5(ii)
c.Remove restriction on compensation referred to in CARES Act section 4003(c)(3)(A)(ii)
4.Facility Fee too high at 100bps - reduce to 10bps with min of $15k or cap at $25k.
4/14/2020 2:49:00 rcolucci@coll Collette Travel 5.Loan Origination fee too high at 100bps-reduce to 10bps with min of $15k or cap at $25k
PM PIO (Email from Colucci Robert ette.com Service Inc 6. Make loan interest free for at least year 1
My company provides emergency repair of transportation infrastructure. We're working hard to keep roadways open so first responders
and critical supplies can continue to move. However, state DOTs and federally backed companies are delaying/cancelling projects, which
extends the impact of this crisis for us past 24 months.
Due to technicalities in determining 500 employees between FFCRA and CARES we are eligible to provide leave payments to employees but
are not eligible to receive SBA loans. Main Street Lending has offered opportunities to obtain relief funding, however, as a investment backed
company the covenants severely limit the funding we are eligible to receive. Additionally, the restrictions on use of the funds eliminates our
ability to protect our employees against the impact of COVID.
It was likely not the intention that a business would receive FFCRA and not CARES. Nor was it the intention of Main Street Lending that a
business could not protect against the impact of COVID-19. This disharmony creates negative results for companies like ours and does not
help mitigate potential job losses. This can be rectified by modifying the covenant restrictions on Main Street Lending and allow us to use the
funds to replace existing debt with lower rate Federal backed debt. The longer nature of the debt savings would allow us to match government
4/14/2020 2:53:00 DANIEL.LINE help with our likely reduction in demand over time, which should allow us to retain employees during a delayed return to normal.
PM PIO (Email from Lines Daniel S@GSI.US Geostabilization
Which banks are lending the MSNLF? My local bank said they are not participating.
4/14/2020 2:56:00 alex@sulliva
PM PIO (Email from Cistone Alex nhauling.com Sullivan Hauling
director@culi Please send information on the Main Street Lending Program, as a seasonal small business, we lost all income as of March 13, 2020. It has
4/14/2020 3:02:00 narykidsns.co Confidential Business Information 29 employees have lost hours and we are in the process of navigating loan applications, etc,
PM PIO (Email from Hansen Sherri m Culinary Kids but time has gotten short. Please send any material to educate us on options. Thank you!
I would strongly encourage this initiative to include non-profit organizations as we are suffering tremendous losses during the COVID-19
American pandemic. We bridge the gap between the government and private sector and our society as a whole would truly suffer if the majority of non-
4/14/2020 3:02:00 lrosenbaum Council of Young profits had to shutter after this. Please provide us an additional avenue to access funds to pay our teams and keep us whole-- especially
PM PIO (Email from Rosenbaum Libby @acypl.org Political Leaders when nonprofit fundraising is also suffering.
"I am affiliated with a non-profit behavioral health organization in California, and I am writing to advocate for the inclusion of non-profits
as part of the Main Street Lending Program. Non-profit behavioral health agencies provide critical services (mental health therapy and drug
Tessie counseling) to hundreds of thousands of Californians, yet have been left out of the Main Street Lending Program. Without the vital supports
Cleveland provided by the programs, these agencies will have to make cuts to staff and services which impacts their ability to serve some of the most
4/14/2020 3:29:00 carolyn@tccs Community vulnerable clients in California. PLEASE INCLUDE THESE NON-PROFIT BUSINESSES AND IN TURN INCREASE THE CAPACITY OF THE
PM PIO (Email from Chadwick Carolyn c.org Services SAFETY NET SYSTEM."
Page 49 of 363
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Main Street Lending Program Comments
I am affiliated with a non-profit behavioral health organization in California, and I am writing to advocate for the inclusion of non-profits as part
of the Main Street Lending Program. Non-profit behavioral health agencies provide critical services to hundreds of thousands of Californians,
yet have been left out of the Main Street Lending Program. Without the vital aid provided by the program, these agencies will have to make
cuts to staff and services which impacts their ability to serve some of the most vulnerable clients in California. This will result in increased
kellyv@redw Redwood mental health crisis, homelessness related issues, child abuse and neglect, and domestic violence. PLEASE INCLUDE THESE NON-PROFIT
4/14/2020 3:30:00 oodcommunit Community BUSINESSES AND IN TURN INCREASE THE CAPACITY OF THE SAFETY NET SYSTEM.
PM PIO (Email from Kelly Victoria yservices.org Services
I am the Executive Director of a non-profit providing behavioral health and child care services in a very rural area of northern California, and I
am writing to advocate for the inclusion of non-profits as part of the Main Street Lending Program. Non-profit behavioral health and family
services agencies provide critical services to hundreds of thousands of Californians, yet have been left out of the Main Street Lending
Program. Without the vital aid provided by the program, these agencies will have to make cuts to staff and services which impacts their ability
kvenegas@c to serve some of the most vulnerable clients in California, especially up here in Humboldt County where we are geographically remote and
4/14/2020 3:34:00 hangingtidesf Changing Tides cover a very large area. PLEASE INCLUDE THESE NON-PROFIT BUSINESSES AND IN TURN INCREASE THE CAPACITY OF THE
PM PIO (Email from Venegas Kerry s.org Family Services SAFETY NET SYSTEM."
The Main Street lending program will support up to $600 billion in bank lending to small and mid-sized businesses, including two lending
options: new loans of $1 million to $25 million, or expansion of a business's existing loan with a bank to up to $150 million.
Unfortunately, the Administration and the Federal Reserve, as of today, are excluding nonprofits, many institutions of higher learning and
Minority-Serving Institutions. This is a significant blow in particular to entities that are also ineligible for the Paycheck Protection Program.
Personal
Email Address All of us in small business, and especially those in higher education or nonprofits, need help at this time to keep the businesses afloat. This is
4/14/2020 3:37:00 Healthy Days an important lending program but needs to include ALL businesses.
PM PIO (Email from Days Alison Pediatrics, PA
"I am affiliated with a non-profit behavioral health organization in California, and I am writing to advocate for the inclusion of non-profits
as part of the Main Street Lending Program. Non-profit behavioral health agencies provide critical services to hundreds of thousands of
Californians, yet have been left out of the Main Street Lending Program. Without the vital aid provided by the program, these agencies will
Alum Rock have to make cuts to staff and services which impacts their ability to serve some of the most vulnerable clients in California. PLEASE
4/14/2020 seckert@alu Counseling INCLUDE THESE NON-PROFIT BUSINESSES AND IN TURN INCREASE THE CAPACITY OF THE SAFETY NET SYSTEM."
12:00:00 AM PIO (Email from Eckert Steve mrockcc.org Center
I work for a non-profit behavioral health organization in California, and I am writing to advocate for the inclusion of non-profits as part of the
Main Street Lending Program. Since we have 529 employees we have been left out of the SBA PPP. We provide critical services to
Personal thousands of Californians, and it now appears we may also be left out of the Main Street Lending Program. Without the vital aid provided by
Email Address the program, we will have to make cuts to staff and services which impacts our ability to serve some of the most vulnerable clients in
4/14/2020 3:39:00 Momentum for California. PLEASE INCLUDE NON-PROFIT BUSINESSES LIKE US AND IN TURN INCREASE THE CAPACITY OF THE SAFETY NET
PM PIO (Email from Golden Melinda Mental Health SYSTEM.
As a non-profit technology company that provides rent assistance payments in the social services sector, access to enhanced lending is
critical to our ability to rapidly scale to prevent homelessness for the millions of families across the state and nation who are unable to meet
their rental obligations due to CV-19. Due to reimbursable contracts, cash flow limitations impede the efficiency and timeline of scaling our
platform, unnecessarily putting lives at risk.
brian.basinge
4/14/2020 3:39:00 r@theQfound We strongly encourage you to include the nonprofit sector in all financial relief efforts. Our strength in times of crisis is directly linked to the
PM PIO (Email from Basinger Brian ation.org Q Foundation strength and health of our nation.
Hi Under the Main Street Lending Prgogram -
1 - what is the definition of EBITDA?
2 - For Executive compensation (Highly Compensated Execs "HCS").
In calculating the 2019 $425k threshold for HCE's, is this total compensation PAID OUT in 2019?
Is there a specific makeup of the $425k such as base pay, base plus bonus, base plus, total W2 earnings or something similar...? 
Are profit interests and stock grants not yet exercised included in the $425k baseline amount?  
Does the program prohibit issuing additional profit interest or stock grants during the term of the loan?
Personal 2019 Bonuses are paid in 2020, does the threshold include 2019 amounts earned but not yet paid? 
Email Address If increases to executives were supposed to incur in 2020 but those are on hold pending reopening back up and there is an obligation to pay
4/14/2020 3:40:00 once re-opening would the loan program affect the retro payment of the increases?
PM PIO (Email from Smith Patrick
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Main Street Lending Program Comments
The National Multiple Sclerosis Society urges you to prioritize nonprofit organizations within the Main Street lending program. We already
have and will continue to be impacted by reduced charitable giving, travel restrictions, and fund-raising event cancellations as a result of
COVID-19. Specifically, we ask that you provide explicit funding for nonprofits through an exclusive pathway within the Mid-Size Business
Loan Program. This funding should support business loans to nonprofit employers with up to 10,000 employees, as those with over 500
employees are barred from the CARES Act's small business lending. It is also imperative this program include loan forgiveness modeled
after the CARES Act Section 1106. During this challenging period, the Society views itself as a strategic partner to the federal government.
Through the Society's MS Navigator service, every person affected by MS can access a partner to navigate the problems and
challenges of MS. We are a trusted source of information for both people with MS and healthcare providers, offering weekly live Q&A
sessions for people with MS and bi-weekly session for healthcare providers. We expect the demand for our services will increase in the
coming months and we also anticipate a significant reduction in revenue. For our community to continue its work, it is critical that we have
4/14/2020 Leslie.Ritter National Mulitple access to loans to weather the growing economic burden of the COVID-19 pandemic.
12:00:00 AM PIO (Email from Ritter Leslie @nmss.org Sclerosis Society
In support of the 4,000 employees of a regional non-profit health and human services agency that provides programs and services to nearly
10,000 people with intellectual and developmental disabilities, special needs, their families and older adults throughout numerous counties in
Western New York and the Greater Rochester region, I am writing today to inform you that People Inc. is fully engaged in dealing with the
COVID-19 crisis. They must ensure that more than 150 community-based homes and services for people with disabilities remain as safe as
possible and are staffed 24/7. The vulnerable people that depend on People Inc. deserve no less. However, because they are providing
essential services during the crisis, People Inc. has incurred highly unusual increased costs in staffing, PPE, and cleaning services.
Since People Inc. is not eligible for the Payroll Protection Program (PPP) due to their size and the fact that they must remain fully operational,
we request that the Mid-Size Loan Program have provisions to convert to a forgivable loan for nonprofits that face staggering losses due to
Personal COVID-19. This would grant them the same protections as PPP.
Email
4/14/2020 3:49:00 Address Thank you in advance for your support of direct care staff, the people they support and People Inc.
PM PIO (Email from SantaLucia Roslyn People Inc.
Good Afternoon.
Personal Could you please advise on how to apply for the Main Street Lending loans?
Email Address
4/14/2020 THE Thank you and advice would be helpful,
12:00:00 AM PIO (Email from Myers John PARSONAGE Chef John Myers
I'm a CFO in the biofuels industry and am struggling to find an Eligible Lender that is willing to engage on the Main Street Lending
Program. They see their 5% participation as an unsecured position at very low interest rate (especially considering the lack of collateral).
The following changes to the program would help:
-For Eligible Lenders, include Farm Credit System institutions. Most biofuel companies' primary lending relationship is with a Farm
Credit System institution.
-For Eligible Loans, allow them to be either unsecured or secured. The Eligible Lenders I am talking to do not want to hold 5% of the loan
without at least a second lien. Or perhaps another solution would be: The Federal Reserve Bank's 95% tranche cannot have a secured
position but the Eligible Lender's 5% tranche can have a secured position.
-For the Federal Reserve Bank's 95% tranche, keep the interest rates at the proposed levels. But allow Eligible Lenders to charge a
higher interest rate on their 5% tranche. Eligible Lenders are not sufficiently motivated to provide these unsecured loans at the proposed low
jcosby@eene rate. Eligible Lenders need to have the ability to increase the rate to a level that is more reflective of a return that would be expected on an
4/14/2020 3:56:00 rgyadams.co E Energy unsecured or second lien loan.
PM PIO (Email from Cosby Jonathan m Adams, LLC
Page 51 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
As one of 4,000 employees of a regional non-profit health and human services agency that provides programs and services to nearly 10,000
people with intellectual and developmental disabilities, special needs, their families and older adults throughout numerous counties in Western
New York and the Greater Rochester region, I am writing today to inform you that our agency, People Inc., is fully engaged in dealing with the
COVID-19 crisis. We must ensure that our homes and services for people with disabilities remain as safe as possible and are staffed 24/7.
The vulnerable people that depend on us deserve no less. However, because we are providing essential services during the crisis, People
Inc. has incurred highly unusual increased costs in staffing, PPE, and cleaning services.
Since we are not eligible for the Payroll Protection Program (PPP) due to our size and we must remain fully operational, we request that the
Mid-Size Loan Program have provisions to convert to a forgivable loan for nonprofits that face staggering losses due to COVID-19. This would
grant us the same protections as PPP.
4/14/2020 4:06:00 charvey@pe Thank you in advance for your support of direct care staff, the people we support and our agency, People Inc.
PM PIO (Email from Harvey Cynthia ople-inc.org People Inc.
I am affiliated with a non-profit behavioral health organization in Long Beach, California, and I am writing to advocate for the inclusion of non-
profits as part of the Main Street Lending Program. Non-profit behavioral health agencies provide critical services to hundreds of thousands of
Californians, yet have been left out of the Main Street Lending Program. Without the vital aid provided by the program, these agencies will
Mental Health have to make cuts to staff and services which impacts their ability to serve some of the most vulnerable clients in California. PLEASE
4/14/2020 4:09:00 ccostello@m America of Los INCLUDE THESE NON-PROFIT BUSINESSES AND IN TURN INCREASE THE CAPACITY OF THE SAFETY NET SYSTEM."
PM PIO (Email from Costello Chad hala.org Angeles
As one of 4,000 employees of a regional non-profit health and human services agency that provides programs and services to nearly 10,000
people with intellectual and developmental disabilities, special needs, their families and older adults throughout numerous counties in Western
New York and the Greater Rochester region, I am writing today to inform you that our agency, People Inc., is fully engaged in dealing with the
COVID-19 crisis. We must ensure that our homes and services for people with disabilities remain as safe as possible and are staffed 24/7.
The vulnerable people that depend on us deserve no less. However, because we are providing essential services during the crisis, People
Inc. has incurred highly unusual increased costs in staffing, PPE, and cleaning services.
Since we are not eligible for the Payroll Protection Program (PPP) due to our size and we must remain fully operational, we request that the
Mid-Size Loan Program have provisions to convert to a forgivable loan for nonprofits that face staggering losses due to COVID-19. This would
grant us the same protections as PPP.
4/14/2020 4:09:00 cferriter@peo Thank you in advance for your support of direct care staff, the people we support and our agency, People Inc.
PM PIO (Email from Ferriter Christy ple-inc.org People Inc.
As one of 4,000 employees of a regional non-profit health and human services agency that provides programs and services to nearly 10,000
people with intellectual and developmental disabilities, special needs, their families and older adults throughout numerous counties in Western
New York and the Greater Rochester region, I am writing today to inform you that our agency, People Inc., is fully engaged in dealing with the
COVID-19 crisis. We must ensure that our homes and services for people with disabilities remain as safe as possible and are staffed 24/7.
The vulnerable people that depend on us deserve no less. However, because we are providing essential services during the crisis, People
Inc. has incurred highly unusual increased costs in staffing, PPE, and cleaning services.
Since we are not eligible for the Payroll Protection Program (PPP) due to our size and we must remain fully operational, we request that the
Mid-Size Loan Program have provisions to convert to a forgivable loan for nonprofits that face staggering losses due to COVID-19. This would
grant us the same protections as PPP.
4/14/2020 4:12:00 joswald@peo Thank you in advance for your support of direct care staff, the people we support and our agency, People Inc.
PM PIO (Email from Oswald James ple-inc.org People Inc.
On behalf of the National Council for Behavioral Health (NCBH), a nonprofit association composed of more than 3,450 Community Mental
Health Centers and community behavioral health organizations serving more than 10 million low-income Americans with serious mental
health and substance use disorders, thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by
the Federal Reserve Act. Without increased access to lending programs intended to sustain payroll and retain employees, many mental
health and substance use service providers are at risk, a circumstance that could leave hundreds of thousands without access to appropriate
The National and desperately needed treatment and care. A lack of access to adequate mental and substance use care will lead many Americans to
stephaniek@t Council for utilization of emergency services, over-crowding community hospital emergency departments and drastically increasing health care costs. As
4/14/2020 4:13:00 henationalco Behavioral such, it is imperative that the Main Street New Loan Facility eligibility include nonprofit organizations employing up to 10,000 employees or
PM PIO (Email from Ingoglia Chuck uncil.org Health with 2019 annual revenue up to $2.5 billion.
Page 52 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
As one of 4,000 employees of a regional non-profit health and human services agency that provides programs and services to nearly 10,000
people with intellectual and developmental disabilities, special needs, their families and older adults throughout numerous counties in Western
New York and the Greater Rochester region, I am writing today to inform you that our agency, People Inc., is fully engaged in dealing with the
COVID-19 crisis. We must ensure that our homes and services for people with disabilities remain as safe as possible and are staffed 24/7.
The vulnerable people that depend on us deserves no less. However, because we are providing essential services during the crisis, People
Inc. has incurred highly unusual increased costs in staffing, PPE, and cleaning services.
Since we are not eligible for the Payroll Protection Program (PPP) due to our size and we must remain fully operational, we request that the
Mid-Size Loan Program have provisions to convert to a forgivable loan for nonprofits that face staggering losses due to COVID-19. This would
grant us the same protections as PPP.
4/14/2020 4:13:00 Scurl@peopl Thank you in advance for your support of direct care staff, the people we support and our agency, People Inc.
PM PIO (Email from Curl Shelley e-inc.org People Inc.
As one of 4,000 employees of a regional non-profit health and human services agency that provides programs and services to nearly 10,000
people with intellectual and developmental disabilities, special needs, their families and older adults throughout numerous counties in Western
New York and the Greater Rochester region, I am writing today to inform you that our agency, People Inc., is fully engaged in dealing with the
COVID-19 crisis. We must ensure that our homes and services for people with disabilities remain as safe as possible and are staffed 24/7.
The vulnerable people that depend on us deserve no less. However, because we are providing essential services during the crisis, People
Inc. has incurred highly unusual increased costs in staffing, PPE, and cleaning services.
Since we are not eligible for the Payroll Protection Program (PPP) due to our size and we must remain fully operational, we request that the
Mid-Size Loan Program have provisions to convert to a forgivable loan for nonprofits that face staggering losses due to COVID-19. This would
grant us the same protections as PPP.
4/14/2020 4:15:00 eschultz@pe Thank you in advance for your support of direct care staff, the people we support and our agency, People Inc.
PM PIO (Email from Schultz Edmond ople-inc.org People Inc
Please consider other loan requirements for eligibility outside of EBITDA. We are a company that is growing but does not have a positive
EBITDA. We have assets like real estate and equipment as collateral and forward earnings but if the program only lends off EBITDA then it
jonathan.rauc wont help real businesses like mine. There are plenty of companies that are not profitable due to growth expenses but need the Main St
4/14/2020 4:15:00 h@wsdevelo Moon Tide Lending Program more than ever to stay solvent and continue operations. Are you considering loans with real collateral in lieu of EBITDA?
PM PIO (Email from Rauch Jonathan pment.com Springs Thank you
As the owner of eligible business that would qualify under the MSNLF, I would like to propose the option of allowing EBITDA to be calculated
using the trailing twelve months preceding the loan origination. For some of us, this provides a more accurate representation of quality of
mprovine@m earnings. Your consideration into this matter is greatly appreciated.
4/14/2020 4:15:00 akooilfield.co Mako Oilfield
PM PIO (Email from Provine Mark m Services, LLC Thank you,
As one of 4,000 employees of a regional non-profit health and human services agency that provides programs and services to nearly 10,000
people with intellectual and developmental disabilities, special needs, their families and older adults throughout numerous counties in Western
New York and the Greater Rochester region, I am writing today to inform you that our agency, People Inc., is fully engaged in dealing with the
COVID-19 crisis. We must ensure that our homes and services for people with disabilities remain as safe as possible and are staffed 24/7.
The vulnerable people that depend on us deserve no less. However, because we are providing essential services during the crisis, People
Inc. has incurred highly unusual increased costs in staffing, PPE, and cleaning services.
Since we are not eligible for the Payroll Protection Program (PPP) due to our size and we must remain fully operational, we request that the
Personal Mid-Size Loan Program have provisions to convert to a forgivable loan for nonprofits that face staggering losses due to COVID-19. This would
Email grant us the same protections as PPP.
Address
4/14/2020 4:15:00 Thank you in advance for your support of direct care staff, the people we support and our agency, People Inc.
PM PIO (Email from Iwanski-Jacks Matthew
It is VITAL that nonprofits be included in the Main Street Lending Program. We provide essential services to underserved individuals. We
help prevent the escalation of child mental health problems into larger issues that cost our society more money, and that are more difficult for
4/14/2020 4:17:00 cgaytan@epc El Paso Child children to recover from. Nonprofits provide employment to hundreds of thousands of Americans, and deserve to be included in the major
PM PIO (Email from Gaytan Cathy gc.org Guidance Center lending program.
Page 53 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
As one of 4,000 employees of a regional non-profit health and human services agency that provides programs and services to nearly 10,000
people with intellectual and developmental disabilities, special needs, their families and older adults throughout numerous counties in Western
New York and the Greater Rochester region, I am writing today to inform you that our agency, People Inc., is fully engaged in dealing with the
COVID-19 crisis. We must ensure that our homes and services for people with disabilities remain as safe as possible and are staffed 24/7.
The vulnerable people that depend on us deserve no less. However, because we are providing essential services during the crisis, People
Inc. has incurred highly unusual increased costs in staffing, PPE, and cleaning services.
Since we are not eligible for the Payroll Protection Program (PPP) due to our size and we must remain fully operational, we request that the
Mid-Size Loan Program have provisions to convert to a forgivable loan for nonprofits that face staggering losses due to COVID-19. This would
grant us the same protections as PPP.
4/14/2020 4:17:00 cflorio@peopl Thank you in advance for your support of direct care staff, the people we support and our agency, People Inc.
PM PIO (Email from Florio Casey e-inc.org People Inc.
We seek clarification on the term Eligible Borrower in Main Street Loan program ("MSLP"). First, some background. When the first
loan application for PPP Loans was issued, it provided that a business with 20% or more foreign ownership did not qualify for a PPP Loan.
This restriction was not in the CARES Act. This eligibility restriction was later eliminated. However, many forms the banks use for PPP loans
still require US citizenship by an individual owner. Thus, foreign owned U.S. businesses cannot access PPP Loans. The MSLP may be their
only option. To avoid the issues with the PPP Loans, please: (1) confirm that the MSLP term "Eligible Borrower" includes entities
organized under the laws of the U.S. that are foreign owned so long as such entities satisfy all of the other requirements of an "Eligible
Borrower"; and (2) clarify that the affiliation rules do not apply. Or, if that is not correct, please clarify:
Can foreign owned entities apply for MSLP loans?
For the employee count, do you count:
oonly employees of the business; or
oemployees of the business and its affiliates residing in the US; or
odo you count affiliated employees around the world?
For revenue target, of $2.5 billion in 2019 annual revenues, do you count the revenue of:
oThe business applying for the loan; or
jwatson@ma Masuda, Funai, oThe businesses in the affiliated group in the US; or
4/14/2020 4:23:00 sudafunai.co Eifert & oThe businesses in the affiliated group throughout the world?
PM PIO (Email from Watson Jennifer m Mitchell, Ltd.
Please do not exclude non-profits from eligibility for lending programs under the CARES act. We are working hard during this time of crisis to
Support for provide essential services to the families in our community so that they in turn can contribute to the overall success of the economy. Excluding
finance@sup Families of non-profits would mean excluding all the people we serve.
4/14/2020 4:25:00 portforfamilie Children with Respectfully yours,
PM PIO (Email from Bernazzani Paola s.org Disabilities Paola Bernazzani
Hello,
We are interested in the Main street loan how can we obtain it? and with which bank?
also got a previous email saying below and not sure what is it mean
"As the Federal Reserve has established several funding facilities, we are unable to determine the funding facility you're
mibrahim@pr referencing. Please write back to our office, via the "contact us" form and provide additional information."
4/14/2020 ecisionmdca. Mahmoud
12:00:00 AM PIO (Email from Khattab mahmoud com Khattab MD Inc Thanks
Please consider enterprises that are in aggressive start-up mode, entrepreneurial and unique structures, with limited past financials and
unique payroll situations. Confidential Business Information
Personal Restructure beyond what banks are currently considering
4/14/2020 4:31:00 Email would be the only hope for small businesses like ours with only handfuls of employees, limited reserves, and truly Main Street businesses that
PM PIO (Email from Kaufmann Juli Address Fix Development serve as primarily hospitality businesses and landlords.
Page 54 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments I
I request that the Federal Reserve allow non-profits to apply for CARES Act financial support, whether the low-interest loans or grants.
It's not at all clear why non-profit organizations were left off the list of organizations that could apply. They employ people, just like for-
Personal profit entities. They need our support, as they are providing services or programming that benefits many people in their communities and
Email Address
4/14/2020 4:32:00 Resilient Noe across the country.
PM PIO (Email from Closson Jessica Valley
Rrampersaud As a non-profit organization that does not meet the size requirements under the Paycheck Protection Program and has more that 500
4/14/2020 4:34:00 @basicsinc.o Acacia network employees, it would be helpful the Main Street Loan Program to have a forgiveness provision - similar to PPP. Additionally, Fees/origination
PM PIO (Email from Rampersaud Ravi rg housing points should be waived for qualifying non-profit organizations. Thank you.
As a non-profit organization that does not meet the size requirements under the Paycheck Protection Program and has more that 500
4/14/2020 4:37:00 Jarroyo@bas Acacia Network, employees, it would be helpful the Main Street Loan Program to have a forgiveness provision - similar to PPP. Additionally, Fees/origination
PM PIO (Email from Arroyp Jahayra icsinc.org Inc points should be waived for qualifying non-profit organizations. Thank you.
elliott@invest I have red about the Main Street Loan program as announced, but there is no information on who to apply to, and application forms! Who are
4/14/2020 4:38:00 orsamerica.c Elliot Dental the participating banks?
PM PIO (Email from Elliott William om Corp
4/14/2020 4:39:00 yoonjae.lee@ Eligible Banks list for the Main Street Lending
PM PIO (Email from LEE YOON JAE bbva.com BBVA
Dear Federal Reserve,
We are a multi-state Ambulance company treating/transporting COVID patients in hot spots like NYC and CA. We have pulled out all stops to
help, including moving vehicles and EMTs from around the country to NYC.
To date we have been hurt and excluded from many of the key stimulus programs, and now it looks like we won't be eligible for the main
street either if one of the drafted requirements are not adjusted to account for companies like ours.
As a fairly new company that has invested heavily in footprint expansion, equipment, ambulances and technology, Confidential Business
Information
; and
We respectfully recommend consideration for Companies that are less than 5 years old to have a waiver from this requirement, as most
healthy startups will not meet this requirement.
Without this consideration we will not be eligible, and we have already been excluded from the SBA PPP as we have too many EMTs - over
Personal the 500 limit.
4/14/2020 Email Address
12:00:00 AM PIO (Email from Blech Eli It's ironic that our ability to help treat COVID patients is what is hurting us from getting the desperately needed funding
"As a non-profit organization that does not meet the size requirements under the Paycheck Protection Program and has more that 500
4/14/2020 mthornhill@b Acacia Housing employees, it would be helpful the Main Street Loan Program to have a forgiveness provision - similar to PPP. Additionally, Fees/origination
12:00:00 AM PIO (Email from Thornhill Maureen asicsinc.org Network points should be waived for qualifying non-profit organizations. Thank you."
As someone affiliated with a California nonprofit behavioral health organization, I strongly encourage the inclusion of nonprofits in the Main
Street Lending Program. Nonprofit behavioral health organizations provide essential services to the community, supporting thousands of
Californians who are in critical need of support - now, more than ever. Their exclusion from the Main Street Lending Program, and the aid it
Erin.O'Brien provides, will result in cuts to services and staffing, leaving the most vulnerable Californians even more vulnerable during this crisis. Please
4/14/2020 4:45:00 @community Community include nonprofit businesses in this assistance program, thereby strengthening the safety net system that is essential to our residents and
PM PIO (Email from O'Brien Erin solutions.org Solutions community.
The Survey of Entrepreneurs, as cited in Hope over Hate: State of Black Business, 17th edition, indicates that only 10,000 of 700,000 bank
loans go to African-Americans, however 60 percent of those are originated by the 20 black-owned banks. There is an urgent need ror $300
million in capital to those banks in order to provide credit access in black communities as Liberty Bank did after Katrina and the Great
Recession. This is the fastest way to bring back economic activity. Addiitonally, HBCUs, which have a $14.3 billion impact, are hemorrhaging
because their students are unable to pay for the spring semester. They need an emergency lending facility to stay in business, particularly for
johnwtemplet the small towns where they are the primary economic engine. Finally, community development corporations such as Central Brooklyn EDC
4/14/2020 4:49:00 on@blackmo National Black need access to capital to build the affordable housing which can address the health disparities in their community.
PM PIO (Email from Templeton John ney.com Business Month
Page 55 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
The term sheets, dated April 9, 2020, for the MSNLF and MSELF state that "[e]ach Eligible Borrower must be a business that is created
or organized in the United States or under the laws of the United States with significant operations in and a majority of its employees based in
valdamier.coll the United States." Does the term "United States" include businesses created, organized and/or domiciled in the United
4/14/2020 4:52:00 ens@firstban States Virgin Islands with significant operations in and a majority of its employees based in the United States Virgin Islands?
PM PIO (Email from Collens Valdamier kvi.com FirstBank
In support of the 4,000 employees of a regional non-profit health and human services agency that provides programs and services to nearly
10,000 people with intellectual and developmental disabilities, special needs, their families and older adults throughout numerous counties in
Western New York and the Greater Rochester region, I am writing today to inform you that People Inc. is fully engaged in dealing with the
COVID-19 crisis. They must ensure that more than 150 community-based homes and services for people with disabilities remain as safe as
possible and are staffed 24/7. The vulnerable people that depend on People Inc. deserve no less. However, because they are providing
essential services during the crisis, People Inc. has incurred highly unusual increased costs in staffing, PPE, and cleaning services.
Since People Inc. is not eligible for the Payroll Protection Program (PPP) due to their size and the fact that they must remain fully operational,
we request that the Mid-Size Loan Program have provisions to convert to a forgivable loan for nonprofits that face staggering losses due to
COVID-19. This would grant them the same protections as PPP.
Personal
4/14/2020 5:10:00 Email Address Thank you in advance for your support of direct care staff, the people they support and People Inc.
PM PIO (Email from Shields Nicole
On behalf of Children's Institute, a behavioral health organization in Los Angeles, California, I am writing to advocate for the inclusion of
non-profit organizations as part of the Main Street Lending Program. Essential service organizations like Children's Institute provide
critical services to hundreds of thousands of Californians, yet have been left out of the Main Street Lending Program. During this crisis, we
continue to provide critical mental health services via phone and video conferencing, support our school partners as they transition to distance
tkim@childre learning, and respond to emergencies when they occur. Without the vital aid provided by the Main Street Lending Program, non-profits like
4/14/2020 5:10:00 nsinstitute.or Children's ours will have to make cuts to staff and services. It is imperative that non-profit organizations are included and resourced to be a safety net for
PM PIO (Email from Kim Terry g Institute our most vulnerable and impacted communities during this crisis.
llliguichuzhca As a non-profit organization that does not meet the size requirements under the Paycheck Protection Program and has more that 500
4/14/2020 5:17:00 @basicsinc.o Acacia network employees, it would be helpful the Main Street Loan Program to have a forgiveness provision - similar to PPP. Additionally, Fees/origination
PM PIO (Email from LLIGUICHUZHLOURDES rg housing points should be waived for qualifying non-profit organizations. Thank you
As a non-profit organization that does not meet the size requirements under the Paycheck Protection Program and has more that 500
4/14/2020 5:17:00 ygomez@bas Acacia network employees, it would be helpful the Main Street Loan Program to have a forgiveness provision - similar to PPP. Additionally, Fees/origination
PM PIO (Email from Gomez Yudelqui icsinc.org housing points should be waived for qualifying non-profit organizations. Thank you
shemi.hart@ Can you please provide a list of participating lenders for the "Main Street Lending."
4/14/2020 5:19:00 wetdesign.co Thanks.
PM PIO (Email from Hart Shemi m WET
The Main Street Lending program should be explicitly available to nonprofits over 500 employees since they have been excluded from PPP.
These nonprofits deliver much of the social safety net in this country (homeless shelters, homes for the developmentally disabled, primary
health care) and are major employers. (Nonprofits are corporations they just don't have shareholders. The Main Street program is to
help employees and customers, not bail out shareholders, so this is irrelevant.) Since EBITDA is not a sensible metric for nonprofit borrowing
capacity they should be able to borrow the greater of (i) 4x EBITDA or (ii) two months of expenses but these loans by 5% of revenue until
jmacintosh@ repaid (like a revenue bond). There should be CRA-type incentive for banks to lend to nonprofits. Third-parties-board members, foundations,
4/14/2020 5:22:00 seachangeca SeaChange state or local government-should be able to guarantee the 5% risk position otherwise held by the bank.
PM PIO (Email from MacIntosh John p.org Capital Partners
Page 56 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
I hope you will reconsider the decision to exclude private higher education institutions from applying for Main Street program loans.
Indiana's 30 private colleges are the anchors of their communities, often the largest employer. The colleges collectively are the 7th
largest employer in the state with more than 22,000 employees. They are struggling to keep them on their payrolls and to provide healthcare
for them and their families.
Twelve of the colleges were able to receive SBA loans due to their size. Seventeen, however, are not eligible, being sometimes just over the
500 employee threshold. However, they have the same urgent concerns as their smaller counterparts.
The Main Street loans are to help sustain the economies of local communities. It is a mistake, therefore, to eliminate significant drivers of that
economy from this opportunity.
The Indiana private colleges contribute $5.3B to Indiana's economy and account for more than $979M in tax reveune. They credit worthy
and will pay off their loans. Moreover, Indiana's private colleges produce doctors, nurses, engineers, social workers, police officers,
teachers, and business leaders. They are key to the intellectual supply chain. We need colleges to be able to keep doing what they do.
Indepedent
4/14/2020 5:23:00 dwantz@icin Colleges of In sum, we are businesses too. Please give us the same opportunities to survive as are given to other for-profit employers.
PM PIO (Email from Wantz Dr. David diana.org Indiana
As one of 4,000 employees of a regional non-profit health and human services agency that provides programs and services to nearly 10,000
people with intellectual and developmental disabilities, special needs, their families and older adults throughout numerous counties in Western
New York and the Greater Rochester region, I am writing today to inform you that our agency, People Inc., is fully engaged in dealing with the
COVID-19 crisis. We must ensure that our homes and services for people with disabilities remain as safe as possible and are staffed 24/7.
The vulnerable people that depend on us deserve no less. However, because we are providing essential services during the crisis, People
Inc. has incurred highly unusual increased costs in staffing, PPE, and cleaning services.
Since we are not eligible for the Payroll Protection Program (PPP) due to our size and we must remain fully operational, we request that the
Mid-Size Loan Program have provisions to convert to a forgivable loan for nonprofits that face staggering losses due to COVID-19. This would
grant us the same protections as PPP.
Personal
4/14/2020 5:29:00 Email Address Thank you in advance for your support of direct care staff, the people we support and our agency, People Inc.
PM PIO (Email from Banner Richard People Inc
PKilgore@mc We would like to learn more about the program as quickly as possible. Will you be releasing information through the Banks or through a FED
4/14/2020 5:30:00 rinvestors.co release again?
PM PIO (Email from Kilgore Phillip m MCR Investors
Page 57 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
As one of 4,000 employees of a regional non-profit health and human services agency that provides programs and services to nearly 10,000
people with intellectual and developmental disabilities, special needs, their families and older adults throughout numerous counties in Western
New York and the Greater Rochester region, I am writing today to inform you that our agency, People Inc., is fully engaged in dealing with the
COVID-19 crisis. We must ensure that our homes and services for people with disabilities remain as safe as possible and are staffed 24/7.
The vulnerable people that depend on us deserve no less. However, because we are providing essential services during the crisis, People
Inc. has incurred highly unusual increased costs in staffing, PPE, and cleaning services.
Since we are not eligible for the Payroll Protection Program (PPP) due to our size and we must remain fully operational, we request that the
Mid-Size Loan Program have provisions to convert to a forgivable loan for nonprofits that face staggering losses due to COVID-19. This would
grant us the same protections as PPP.
Thank you in advance for your support of direct care staff, the people we support and our agency, People Inc.
Thank you in advance for your help
Susan Muscarella
Personal Residential Director
4/14/2020 5:32:00 Email People Inc
PM PIO (Email from Muscarella Susan Address People Inc
aramirez@ac As a non-profit organization that does not meet the size requirements under the Paycheck Protection Program and has more that 500
4/14/2020 5:33:00 acianetwork. employees, it would be helpful the Main Street Loan Program to have a forgiveness provision - similar to PPP. Additionally, Fees/origination
PM PIO (Email from Ramirez Anthony org Acacia Network points should be waived for qualifying non-profit organizations. Thank you."
I am President of Lead Bank, Missouri State Chartered Bank. I have a commercial customer that would like to apply for a Main Street New
Loan Facility loan. Can you direct me to someone that can help me with the process?
4/14/2020 5:36:00 gbynum@lea Thank you,
PM PIO (Email from Bynum Greg d.bank Lead Bank Greg Bynum
jarodriguez@ For a non-profit organization that does not meet the size requirements under the Paycheck Protection Program and has more that 500
4/14/2020 5:38:00 acacianetwor Acacia Network, employees, it would be helpful for the Main Street Loan Program to have a forgiveness provision - similar to the Paycheck Protection
PM PIO (Email from Rodriguez Jose k.org Inc. Program. Additionally, fees/origination points should be waived for qualifying non-profit organizations. Thank you.
Comment: "As a non-profit organization that does not meet the size requirements under the Paycheck Protection Program and has
4/14/2020 5:43:00 yperez@pro more that 500 employees, it would be helpful the Main Street Loan Program to have a forgiveness provision - similar to PPP. Additionally,
PM PIO (Email from Perez cubillan Yaberci mesa.org Acacia Network Fees/origination points should be waived for qualifying non-profit organizations. Thank you."
asantini@aca As a non-profit organization that does not meet the size requirements under the Paycheck Protection Program and has more that 500
4/14/2020 5:45:00 cianetwork.or employees, it would be helpful the Main Street Loan Program to have a forgiveness provision - similar to PPP. Additionally, Fees/origination
PM PIO (Email from Santini Angel g Acacia Network points should be waived for qualifying non-profit organizations.
As a non-profit organization that does not meet the size requirements under the Paycheck Protection Program and has more that 500
4/14/2020 5:47:00 vgatell@acac Acacia Network employees, it would be helpful the Main Street Loan Program to have a forgiveness provision - similar to PPP. Additionally, Fees/origination
PM PIO (Email from Gatell Vicky ianetwork.org Inc points should be waived for qualifying non-profit organizations. Thank you."
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. The enabling legislation (CARES Act,
Section 4003) expressly included nonprofit organizations between 500 and 10,000 employees, but it now appears the Federal Reserve's
initial guidance for the Main Street Lending Program excludes nonprofits for eligibility. These critical providers of the nation's safety net
are not eligible for the Paycheck Protections Program (PPP) (Sections, 1102, 1106) or the Economic Injury Disaster Loans (EIDL) (Section
1110) or other federal relief. This proposed action threatens the viability of larger nonprofits who provide aid to hundreds of thousands of
children and families. Please include non-profits that employ over 500 employees in the Main Street Program to protect the critical safety net.
sleshin@mo
4/14/2020 5:50:00 mentummh.o Momentum for Sydney Hoff
PM PIO (Email from Hoff Sydney rg Mental Health
Page 58 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
arodriguez@ hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/14/2020 5:50:00 momentumm eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
PM PIO (Email from Rodriguez Ashley h.org
As a non-profit organization that does not meet the size requirements under the Paycheck Protection Program and has more that 500
4/14/2020 5:50:00 jmcghee@ba employees, it would be helpful the Main Street Loan Program to have a forgiveness provision - similar to PPP. Additionally, Fees/origination
PM PIO (Email from McGhee Jessica sicsinc.org Acacia Network points should be waived for qualifying non-profit organizations. Thank you.
Constituent (Staff)
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees.
Without increased access to lending programs intended to sustain payroll and retain employees, many mental health and substance use
service providers are at risk, a circumstance that could leave hundreds of thousands without access to appropriate and desperately needed
treatment and care. A lack of access to adequate mental and substance use care will lead many Americans to utilization of emergency
services, over-crowding community hospital emergency departments and drastically increasing health care costs.
Smorales@m As such, it is imperative that the Main Street New Loan Facility eligibility include nonprofit organizations employing up to 10,000 employees or
4/14/2020 5:51:00 omentummh. with 2019 annual revenue up to $2.5 billion.
PM PIO (Email from Morales Sara org Momentum
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
Personal Email access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
Address hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/14/2020 5:51:00 Momentum for eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
PM PIO (Email from Shwarzstein Alexandra Mental Health
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
RMarcial- hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/14/2020 5:53:00 Cruz@mome eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
PM PIO (Email from M R ntummh.org
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/14/2020 5:54:00 sruiz@mome Momentum for eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
PM PIO (Email from Ruiz Sarah ntummh.org Mental Health
Page 59 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
ecovotta@m hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/14/2020 5:56:00 omentummh. Momentum for eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
PM PIO (Email from Covotta Eric org Health
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
Personal access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
Email Address hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/14/2020 5:57:00 eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
PM PIO (Email from Amsden Claire
Hello,
I have a question on affiliate debt. I have borrowers that would borrow at a parent level but the parent company owns many SPVs which own
and operate one or several utility scale solar projects. The debt is typically non recourse to the parent company and is supported in excess by
each of the solar assets. However, all of the income and EBITDA rolls up to the parent. Would I need to count the non-recourse project level
debt for each of their SPVs in my debt sizing calculation?
4/14/2020 6:01:00 jfuller@celtic Thanks,
PM PIO (Email from Fuller Justin bank.com Celtic Bank Justin
Don't exclude medium and large size nonprofits from your lending.
4/14/2020 6:02:00 chorton@hop
PM PIO (Email from HORTON CARLLA esdoorny.org Ms.
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
sserrano@m hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/14/2020 6:02:00 omentummh. Momentum for eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion. Please take us
PM PIO (Email from Serrano Stefani org Mental Health into consideration.
Businesses can't possibly determine amount of financing needed for an undetermined amount of time and so many variables in
economic conditions. A loan program that would establish a ceiling for a loan arrangement acting more like a line of credit would work better.
Additionally, 2 years is far too short for a loan term for companies with high running overhead costs to recover from. 5-10 year terms, and/or
4/14/2020 6:03:00 HOYT@WIS Washington incentives to private lenders to refinance after economic recovery signals occur.
PM PIO (Email from Purinton Hoyt FERRY.COM Island Ferry Line
Juan@olivebr Blackhawk Would like to start the process of filling out application for the Main Street lending program for small businesses
4/14/2020 6:08:00 anchpropertyt Investment
PM PIO (Email from Zayas Juan rust.com groups
Page 60 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
I am the owner of a winery/farming group in El Dorado County, CA call Fairplay Enterprises. I have 45 employees and are the fastest
growing winery group in El Dorado County. Our largest customers are airlines and distributors who service restaurants. We also generate
some revenue through our tasting rooms. Our largest contracts were put on hold with United Airlines in the beginning of March, and the
Governor of CA shut down all wineries March 15. Confidential Business Information
Thank you for your consideration and
4/14/2020 6:09:00 jill@impact2s Fairplay your action to change this to support employees of small businesses.
PM PIO (Email from Osur Jill olutions.com Enterprises LLC
Questions:
1) Please define: "Eligible Borrower's existing outstanding and committed but undrawn debt". Is this only bank debt? Other
non-bank institutions? Individuals/insiders/affiliate notes? Discretionary revolving facilities (like factoring, inventory, or trade finance facilities)
where lender has discretion to fund/not fund? Does it include Trade debt (A/P)?
2) Can a lender refinance (under its own authority) existing lines of credit or other debt of the Eligible Borrower before, at, or around the same
of closing the new Eligible Loan? And if so, can those facilities be secured while the Main Street facility is unsecured?
3) Are non-bank Lenders/Financial Institutions considered Eligible Borrowers? (Factors, Asset-Based Lending institutions, Equipment
Financiers/Leasing Companies, etc.)
4/14/2020 6:10:00 dgodfrey@ce Celtic Bank 4) Does unsecured mean literally no security or collateral (even a junior UCC-1 financing statement filing) or does it imply a sometimes used
PM PIO (Email from Godfrey Daniel lticbank.com Corporation regulatory definition of unsecured (i.e., not secured by real estate or cash)
As the Treasury works to create a program as directed under section 4003(c)(3)(D) providing financing to banks and other lenders to make
loans to nonprofits and other mid-size business of between 500-10,000 employees, we request that the program:
Include a 0.50% interest rate (50 basis points) for 501(c)(3) charitable nonprofits at a 5-year amortization
Provide priority to 501(c)(3) charitable nonprofits responding to COVID-19 relief efforts
Payments shall not be due until two years after a direct loan is made
It is of the utmost importance that nonprofits are eligible for a new lending facility because they are uniquely situated to address the gaps in
services outside of the responsibility of the government. Nonprofits rely on donations from individuals, grants, and government contracts,
leaving them especially vulnerable during a financial crisis.
Failing to protect nonprofits during a global pandemic and a financial crisis will threaten tens of thousands of nonprofit sector jobs and the
vulnerable communities they serve. At Bethany, we've already had to reduce our staff by 100 full-time equivalents since this crisis
Bethany began. Hundreds of other nonprofits have made similar cuts. Access to a new lending facility is crucial for organizations to continue serving
4/14/2020 6:10:00 nbult@betha Christian Americans both during this crisis and long into the future, especially as more find themselves in a dire situation due to the extensive physical,
PM PIO (Email from Bult Nathan ny.org Services emotional, and economic damage of COVID-19.
Please help secure some grant funding for 501c6 organizations! As our member businesses are fighting to keep their doors open, we are
doing our best to support them, but we need to have some financial aid to help weather this temporary shutdown! We do not have direct
melissa@na employees as we hire our service providers, but we have contracts in place and limited revenue coming in to pay our bills. Please don't
4/14/2020 6:12:00 wbochicago.o NAWBO forget about all of the chambers of commerce and other membership based organizations so we can continue to support the small businesses
PM PIO (Email from Lagowski Melissa rg Chicago of America during this pandemic!
Personal As I understand the Administration and the Federal Reserve, as of today, are considering the exclusion of nonprofits, many institutions of
4/14/2020 6:12:00 Email higher learning and Minority-Serving Institutions. This is a significant negative blow in particular to entities that are also ineligible for the
PM PIO (Email from Moore Bob Address ACOFP Paycheck Protection Program. I request these groups be included. Thanks!
Page 61 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
In support of the 4,000 employees of a regional non-profit health and human services agency that provides programs and services to nearly
10,000 people with intellectual and developmental disabilities, special needs, their families and older adults throughout numerous counties in
Western New York and the Greater Rochester region, I am writing today to inform you that People Inc. is fully engaged in dealing with the
COVID-19 crisis. They must ensure that more than 150 community-based homes and services for people with disabilities remain as safe as
possible and are staffed 24/7. The vulnerable people that depend on People Inc. deserve no less. However, because they are providing
essential services during the crisis, People Inc. has incurred highly unusual increased costs in staffing, PPE, and cleaning services.
Since People Inc. is not eligible for the Payroll Protection Program (PPP) due to their size and the fact that they must remain fully operational,
we request that the Mid-Size Loan Program have provisions to convert to a forgivable loan for nonprofits that face staggering losses due to
4/14/2020 6:14:00 Dnowak@pe COVID-19. This would grant them the same protections as PPP.
PM PIO (Email from Nowak DaraLeigh ople-inc.org People Inc
501c6's continue to be left behind in all stimulus and relief packages. We are the lifeblood of support for businesses and the
mmueller@e communities we serve. As largely convening organizations, we have been hit tremendously hard by this pandemic. We collectively employ 1.3
4/14/2020 6:14:00 xecutivesclub Executives' Club million workers and are struggling to maintain staff and operations. I implore you to include our class of non-profit and not limit funds to
PM PIO (Email from Mueller Margaret .org of Chicago 501c3's. Thank you.
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. The enabling legislation (CARES Act,
Section 4003) expressly included nonprofit organizations between 500 and 10,000 employees, but it now appears the Federal Reserve's
initial guidance for the Main Street Lending Program excludes nonprofits for eligibility. These critical providers of the nation's safety net
are not eligible for the Paycheck Protections Program (PPP) (Sections, 1102, 1106) or the Economic Injury Disaster Loans (EIDL) (Section
kdewitt@mo 1110) or other federal relief. This proposed action threatens the viability of larger nonprofits who provide aid to hundreds of thousands of
4/14/2020 6:15:00 mentummh.o Momentum for children and families. Please include non-profits that employ over 500 employees in the Main Street Program to protect the critical safety net.
PM PIO (Email from DeWitt Dee rg Mental Health
douglasdvora Nonprofits including 501 C5's and C6's, many institutions of higher learning and Minority-Serving Institutions should be included in
4/14/2020 6:16:00 k@fortworth. the bipartisan CARES Act to receive aid as well as small and mid-sized businesses.
PM PIO (Email from Dvorak Douglas com Visit Fort Worth
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
czubach@mo hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/14/2020 6:18:00 mentummh.o Momentum for eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
PM PIO (Email from Zubach Christina rg Mental Health
JRSamples@ Please include non-for-profit organizations in being eligible for PPP and/or CARES.
4/14/2020 6:21:00 adagetech.co Adage
PM PIO (Email from Samples James m Technology
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
aramirez@m hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/14/2020 6:21:00 omentummh. Momentum for eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
PM PIO (Email from Ramirez Alithia org Mental Health
Page 62 of 363
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Main Street Lending Program Comments
I am shocked that the Administration and Federal Reserve have decided to exclude nonprofits in the "Main Street" lending
program. This program was presented to nonprofits as an alternate loan program for organizations with 500 or more staff members. Large
nonprofits do the job of serving the neediest and most vulnerable of our communities. They do the hard work of caring for members of society
that the government has abandoned. I find the omission of nonprofits from the Main Street lending program not only unconscionable, but
economically disastrous for municipal, rural, and state governments alike who will be burdened with the work done by these nonprofits. The
cost to society will be much greater in the long run than the cost to support these organizations with loans.
4/14/2020 6:21:00 lgold@aaarts Asian American I am deeply disappointed in this decision.
PM PIO (Email from Gold Lisa alliance.org Arts Alliance
I am affiliated with a non-profit behavioral health organization in California, and I am writing to advocate for the inclusion of non-profits as part
of the Main Street Lending Program. Non-profit behavioral health agencies provide critical services to hundreds of thousands of Californians,
yet have been left out of the Main Street Lending Program. Without the vital aid provided by the program, these agencies will have to make
Didi Hirach cuts to staff and services which impacts their ability to serve some of the most vulnerable clients in California. PLEASE INCLUDE THESE
4/14/2020 6:23:00 hgoldman@d Mental Health NON-PROFIT BUSINESSES AND IN TURN INCREASE THE CAPACITY OF THE SAFETY NET SYSTEM."
PM PIO (Email from Goldman Howard idihirsch.org Services
4/14/2020 6:24:00 Personal Email Are the Main Street programs available to nonprofit organizations?
PM PIO (Email from Murray- BrownDonna Address
Can I please obtain more information on the "Main Street Lending Program to enhance support for small and mid-sized businesses that
were in good financial standing before the crisis by offering 4-year loans to companies employing up to 10,000 workers or with revenues of
4/14/2020 brenda@pqs less than $2.5 billion"?
12:00:00 AM PIO (Email from Maas Brenda wim.com PILYQ LLC Where can I apply?
It was encouraging to learn of the new "Main Street" lending facility. Unfortunately, this facility currently does not include access
for nonprofits, many institutions of higher learning, and Minority-Serving Institutions. This is a significant negative blow in particular to entities
that are also ineligible for the Paycheck Protection Program.
4/14/2020 6:27:00 george1@illin Please extend access to this lending facility to serve these worthy and valuable institutions.
PM PIO (Email from Gogola George oisalumni.org Thank you.
megan@river Please ensure that nonprofits, institutions of higher learning and minority-serving institutions are included in this program. Why would they be
4/14/2020 6:27:00 otterecology. River Otter left out, when they are among the most important and least able to weather this catastrophe? Enough for the 1%, how about giving a thought
PM PIO (Email from Isadore Megan org Ecology Project to the rest of us.
I am asking the Federal Reserve to reconsider the exclusion of nonprofit organizations from the new Main Street lending program. The
coronavirus pandemic has had an especially devastating impact on minority and low-income communities. Minorities make up a
disproportionate number of the Covid-19 casualties, and low-wage jobs are nearly twice as likely than higher paying positions to be cut during
this crisis. Nonprofits are providing vital support including meals, housing for the homeless, academic services and mentoring for low-income
youth and mental health counseling. These organizations deserve the support of the Federal Reserve. But without access to financial
assistance such as the Main Street lending program, many nonprofit organizations might not survive. Although many parts of the nation may
experience a rapid recovery, those communities that are hardest hit will undoubtedly take the longest time to rebound. If nonprofits are not
Boys & there to help, the economic and social devastation left in the wake of the pandemic will be even more catastrophic. Please support the
4/14/2020 6:28:00 wsmith@bgc Girls Clubs of El nonprofit sector and allow nonprofits to be eligible for this financial support that is so desperately needed. Thank you.
PM PIO (Email from Smith Whit elpaso.org Paso
Dear Federal Reserve,
Some nonprofits will not be able to survive this pandemic if lending opportunities are not made available. These nonprofits offer higher
learning and opportunities people don't have.
4/14/2020 6:30:00 mstanley@aa
PM PIO (Email from Stanley Myria pmr.org 1976 Please reconsider this stance.
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
rnelson@mo hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/14/2020 6:32:00 mentummh.o Momentum for eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
PM PIO (Email from Nelson Robert rg Mental Health
Page 63 of 363
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Main Street Lending Program Comments
"I am the President and CEO of Hillsides, a non-profit behavioral health organization in California, and I am writing to advocate for the
inclusion of non-profits as part of the Main Street Lending Program. Non-profit behavioral health agencies provide critical services to hundreds
of thousands of Californians, yet have been left out of the Main Street Lending Program. Without the vital aid provided by the program, our
agencies will potentially have to make cuts to staff and services which impacts our ability to serve some of the most vulnerable clients in
4/14/2020 6:35:00 jcosta@hillsid California. PLEASE INCLUDE THESE NON-PROFIT BUSINESSES AND IN TURN INCREASE THE CAPACITY OF THE SAFETY NET
PM PIO (Email from Costa Joe es.org Hillsides SYSTEM."
On behalf of the Association of Community Human Service Agencies, which represents more than 85 non-profit mental health, child welfare,
and juvenile justice agencies in Los Angeles County, we strongly advocate for including non-profits in the Main Street Lending Program. Non-
Association of profit behavioral health agencies provide critical services to hundreds of thousands of Californians, yet have been left out of the Main Street
Community Lending Program. Without the vital aid provided by the program, these agencies will have to make cuts to staff and services which impact
4/14/2020 6:37:00 bdewveall@a Human Service their ability to serve some of the most vulnerable clients in California. PLEASE INCLUDE THESE NON-PROFIT BUSINESSES AND IN TURN
PM PIO (Email from Dewveall Blake chsa.net Agencies INCREASE THE CAPACITY OF THE SAFETY NET SYSTEM.
Seneca is the largest children's behavioral health provider in California, serving thousands of children and families across 18 counties.
We work across the behavioral health, child welfare, juvenile justice, and education systems to support children with the most profound
needs. During this pandemic, we are seeing mental health symptoms grow more acute in the children and families in our programs.
Distressingly, we are also facing a financial crisis that threatens our ability to keep providing the services these families depend on. I am
writing to advocate for the inclusion of non-profits as part of the Main Street Lending Program. Non-profit behavioral health agencies provide
critical services to hundreds of thousands of Californians, but we have been left out of the Main Street Lending Program. Without the vital aid
hope_kamer provided by the program, we will have to make cuts to staff and services which impacts our ability to serve some of the most vulnerable clients
4/14/2020 6:47:00 @senecacent Seneca Family in California. Please make MSLP viable for providers like us, and in turn, strengthen the safety net for behavioral health care in this country.
PM PIO (Email from Berrick Ken er.org of Agencies
"I am affiliated with a non-profit behavioral health organization in California, and I am writing to advocate for the inclusion of non-profits
as part of the Main Street Lending Program. Non-profit behavioral health agencies provide critical services to hundreds of thousands of
Californians, yet have been left out of the Main Street Lending Program. Without the vital aid provided by the program, these agencies will
bphillips@mo have to make cuts to staff and services which impacts their ability to serve some of the most vulnerable clients in California. PLEASE
4/14/2020 6:51:00 mentummh.o Momentum for INCLUDE THESE NON-PROFIT BUSINESSES AND IN TURN INCREASE THE CAPACITY OF THE SAFETY NET SYSTEM."
PM PIO (Email from Phillips Brenda rg Mental Health
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am a
Board Member affiliated with Momentum for Mental Health nonprofit behavioral health organization serving children and families in California
and I am writing to advocate for restoration of the applicability of the Main Street Lending Program to nonprofits with more than 500
employees.
Without increased access to lending programs intended to sustain payroll and retain employees, many mental health and substance use
service providers are at risk, a circumstance that could leave hundreds of thousands without access to appropriate and desperately needed
treatment and care. A lack of access to adequate mental and substance use care will lead many Americans to utilization of emergency
Personal
services, over-crowding community hospital emergency departments and drastically increasing health care costs. As such, it is imperative
Email Address
4/14/2020 6:52:00 that the Main Street New Loan Facility eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual
PM PIO (Email from Baca Georgina revenue up to $2.5 billion.
Pleasanton We respectfully request you include 501c6 non-profit organizations in the main street lending program. Chambers of Commerce, Downtown
4/14/2020 6:53:00 steve@pleas Chamber of Associations and other non-profits provide valuable services to their respective business communities. They are struggling financially just as
PM PIO (Email from Van Dorn Steve anton.org Commerce many small businesses are and should be supported in the same way. Thank you!
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. The enabling legislation (CARES Act,
Section 4003) expressly included nonprofit organizations between 500 and 10,000 employees, but it now appears the Federal Reserve's
initial guidance for the Main Street Lending Program excludes nonprofits for eligibility. These critical providers of the nation's safety net
are not eligible for the Paycheck Protections Program (PPP) (Sections, 1102, 1106) or the Economic Injury Disaster Loans (EIDL) (Section
Personal 1110) or other federal relief. This proposed action threatens the viability of larger nonprofits who provide aid to hundreds of thousands of
4/14/2020 6:54:00 Email Momentum for children and families. Please include non-profits that employ over 500 employees in the Main Street Program to protect the critical safety net.
PM PIO (Email from Tondreau Patrick Address Mental Health
Page 64 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/14/2020 6:56:00 smiller@mom Momentum for eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
PM PIO (Email from Miller Shefali entummh.org Mental Health
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
bkham@mo hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/14/2020 6:57:00 mentummh.o Momentum for eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
PM PIO (Email from Kham Bory rg Health
Please include nonprofits in your initiatives. I urge the Federal Reserve to Include Nonprofits and Universities in CARES Act Lending
Facilities. We are vulnerable.
admin@alab Alabama Waldorf
4/14/2020 6:58:00 amawaldorf.o Association The
PM PIO (Email from Grupe Lisa rg Redmont School
Association for Please consider 501c6 entities for financial assistance related current crisis.
Supply Chain
4/14/2020 7:00:00 jzettek@asc Management
PM PIO (Email from Zettek Jeff m.org (ASCM)
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
mary.rotunno hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/14/2020 7:03:00 @elcamiohea El Camino eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
PM PIO (Email from Rotunno Mary lth.org Health
Personal Please extend this lending program to non-profit organizations. These provide greatly needed employment and services to very large parts of
4/14/2020 7:05:00 Email Address our society and economy and are also impacted by the economic activity stoppages related to the Covid19 health orders.
PM PIO (Email from Rauschelbach Paul
"I am affiliated with a non-profit behavioral health organization in California, and I am writing to advocate for the inclusion of non-profits
as part of the Main Street Lending Program. Non-profit behavioral health agencies provide critical services to hundreds of thousands of
Californians, yet have been left out of the Main Street Lending Program. Without the vital aid provided by the program, these agencies will
cecilynguyen Mekong have to make cuts to staff and services which impacts their ability to serve some of the most vulnerable clients in California. PLEASE
4/14/2020 7:05:00 @mekongco Community INCLUDE THESE NON-PROFIT BUSINESSES AND IN TURN INCREASE THE CAPACITY OF THE SAFETY NET SYSTEM."
PM PIO (Email from Nguyen Cecily mmunity.org Center
Personal Please restore non-profits to participation in the Main Street Lending program. 1) Non-profits are the backbone of our communities, providing
4/14/2020 7:06:00 Email Finance essential services (many of which used to be provided by local and state government,) and 2) non-profit spending has a big multiplier effect in
PM PIO (Email from Kernan Susanne Address manager the local economy, as much as 6 times. Please restore
Page 65 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
In response to new Main Street Lending plan:
The failure to include nonprofits in the new "Main Street" lending facility is a failure to fully consider the impact this pandemic has
on the organizations that are known for their benefit to society and care of our country's most vulnerable populations. Nonprofits that
offer essential services are stepping forward to meet pressing community needs at a time when social distancing is a safety mandate and
resources are especially limited.
On the other hand, some nonprofits are either operating remotely or have temporarily closed shop. Whether you provide additional lending
facilities to nonprofits affects whether some of these nonprofits will survive this temporary closure. For those that do not re-open, the loss will
be felt most acutely in the most rural parts of our country, like we see in Montana, where the closure of any business or resource ripples
through the entire community.
Nonprofits are needed now more than ever as we face this crisis and will be needed as we come out of it. Access to additional resources,
such as the lending options provided through this new lending facility, helps ensure nonprofits can continue the good work they are doing
across our country.
The decision you make now will help reduce the harm of the pandemic on nonprofits and businesses alike. Please consider an amendment to
Montana the proposed lending plan to include nonprofits.
4/14/2020 7:07:00 teal@mtcf.or Community
PM PIO (Email from Whitaker Teal g Foundation Thank you for your consideration.
As COVID-19 continues to spread, my dance service organization, Dance/NYC, and its constituents of over 5,000 individual dance artists,
1,200 dance-making entities, and 500 nonprofit dance companies are facing tremendous financial loss and uncertainty. Dance/NYC's
Coronavirus Impact Survey that we have been disseminating since March, has revealed total revenue loss for dance organizations exceeds
$17M. Simply put, the need is dire.As Executive Director I live in one of the most impacted areas of COVID-19 in Queens, NY. The last few
weeks have included long working days to ensure the survival of my staff, many of who are freelance workers whose other jobs have
disappeared as a result of this crisis. We are not only concerned for our workforces' financial well-being, but also the emotional and
mental health toll this crisis is having on those still working in relief efforts or those unsure of how they will pay their rent. In light of the recent
CARES Act, I ask that the Federal Reserve reconsider their decision and include nonprofits in the Main Street lending facility. It is imperative
Dance Service non-profits have access to funds to ameliorate the situation. Failure to do so will come as a significant hit to non-profits that are also ineligible
New York City, for the Paycheck Protection Program. Dance/NYC works in alliance with Dance/USA and together are committed to serving the public as the
4/14/2020 7:07:00 aduque@dan Inc. DBA impact of COVID-19 deepens. It is essential that non-profits be included in the Main Street Lending program.
PM PIO (Email from Duque Cifuen Alejandra ce.nyc Dance/NYC
The Federal Reserve recently announced its new "Main Street" lending facility and is soliciting comments. This facility will support
up to $600 billion in bank lending to small and mid-sized businesses. Unfortunately, excluded from the provision are nonprofits, many
institutions of higher learning and Minority-Serving Institutions. This is a particular challenge for those entities that are also ineligible for the
Paycheck Protection Program. The way the current legislation is written, it creates challenges for our most vulnerable small businesses and
does not provide aid for struggling hospitals and state and local governments. Congress has clearly signaled their intention to treat non-profits
as they do small businesses in the CARE initiatives - as critical service providers, necessary to their communities, and as significant
beths@caha employers and generators of economic activity. Please be sure to include non-profits in this new initiative. Please also give special assistance
4/14/2020 7:11:00 bariversociet Cahaba River to minority-serving institutions, health care facilities, and our state and local governments. Thank you.
PM PIO (Email from Stewart Beth y.org Society
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
Jcrittenden@ hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/14/2020 7:14:00 momentumm Momentum for eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
PM PIO (Email from CRITTENDEN Justin h.org Health
Page 66 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
I am writing to advocate for the inclusion of non-profits as eligible entities for the Main Street Lending Program. Non-profits, and especially
behavioral health agencies, provide critical services to hundreds of thousands of Californians, yet have been left out of the Main Street
Lending Program. Without the vital aid provided by the lending program, many agencies will have to make cuts, both staff and service levels,
which will, in turn, diminish their ability to help some of the most vulnerable people. As the Executive Director of a non-profit behavioral health
4/14/2020 7:19:00 jfarber@hyci Helpline Youth organization in California I respectfully request that non-profits be included in the loan program
PM PIO (Email from Farber Jeff nc.org Counseling
As one of 4,000 employees of a regional non-profit health and human services agency that provides programs and services to nearly 10,000
people with intellectual and developmental disabilities, special needs, their families and older adults throughout numerous counties in Western
New York and the Greater Rochester region, I am writing today to inform you that our agency, People Inc., is fully engaged in dealing with the
COVID-19 crisis. We must ensure that our homes and services for people with disabilities remain as safe as possible and are staffed 24/7. In
addition, we are providing essential communication access for Deaf and Hard of Hearing individuals in numerous settings and with local
government officials to ensure that the COVID-19 information is accessible. The vulnerable people that depend on us deserve no less.
However, because we are providing essential services during the crisis, People Inc. has incurred highly unusual increased costs in staffing,
PPE, and cleaning services.
Since we are not eligible for the Payroll Protection Program (PPP) due to our size and we must remain fully operational, we request that the
Deaf Access Mid-Size Loan Program have provisions to convert to a forgivable loan for nonprofits that face staggering losses due to COVID-19. This would
Services, an grant us the same protections as PPP.
4/14/2020 7:19:00 JChibi@wnyd Affiliate of
PM PIO (Email from Chibi Jodie as.org People Inc. Thank you in advance for your support of direct care staff, the people we support and our agency, People Inc.
I am writing to advocate for the inclusion of non-profits as eligible entities for the Main Street Lending Program. Non-profits, and especially
behavioral health agencies, provide critical services to hundreds of thousands of Californians, yet have been left out of the Main Street
Lending Program. Without the vital aid provided by the lending program, many agencies will have to make cuts, both staff and service levels,
4/14/2020 7:19:00 mhering@cpi Center Point, which will, in turn, diminish their ability to help some of the most vulnerable people. As a representative of a non-profit behavioral health
PM PIO (Email from Hering Marc nc.org Inc. organization in California I respectfully request that non-profits be included in the loan program
I'm writing today to express my concern for the exclusion of nonprofits, many institutions of higher learning and Minority-Serving
Institutions from being eligible for loans through the "Main Street" lending facility. I would especially like to voice my concern on
behalf of the nonprofits in our country as we are all battling to make it through the COVID-19 pandemic. Donations and other funding have
halted due to the pandemic leaving us searching for ways to keep our doors open until we can restart our programs and funding streams. The
Paycheck Protection Program will only give us funding to sustain our essential expenses through June 30th. Many nonprofits are forced to
design cash flow models that go beyond June 30th until we can restart funding streams that were interrupted by the various social restrictions
implemented by the federal and state government in response to COVID-19. We are in need of lending options provided by the "Main
Youth 2 Leaders Street" facility. Please consider including nonprofits as well as institutions of higher learning as eligible entities for these loan programs.
4/14/2020 7:22:00 framirez@y2l Education Thank you,
PM PIO (Email from Ramirez Frank ef.org Foundatio
Regarding the Main Street Lending Program (MSLP), where can interested companies apply? How are eligibility and maximum loan amount
determined?
adrian.stewar
4/14/2020 7:23:00 t@dentons.c Furthermore, does the MSLP overlap with the CARES Act Section 4003 Mid Sized Business Relief? Why are some but not all of the
PM PIO (Email from Stewart Adrian om Dentons certifications similar?
Please make this lending facility either direct through the Federal Government or open to all financial institutions without regard to existing
loans or prior existing account relationship.
The reason: we have an established banking, non-debt relationship with JP Morgan Chase bank, who in all honest is already overwhelmed
just by the PPP. Additionally, large institutions have an direct beneficial incentive to steer lending toward currently indebted borrows in hopes
to getting paid on previous debts, while unfairly not selecting firms, such as ours, that have been financial sound and resisted until now to
borrow.
4/14/2020 7:29:00 finance@nan
PM PIO (Email from MORGAN SCOTT ome.ai NANOME Thank you.
Page 67 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
Personal hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/14/2020 7:34:00 Email Momentum eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
PM PIO (Email from Edwards Delphia Address Mental Health
As a non-profit organization that does not meet the size requirements under the Paycheck Protection Program and has more that 500
4/14/2020 7:34:00 hbrito@prom employees, it would be helpful the Main Street Loan Program to have a forgiveness provision - similar to PPP. Additionally, Fees/origination
PM PIO (Email from Brito Honey esa.org Acacia Network points should be waived for qualifying non-profit organizations. Thank you."
Personal It is imperative that the Main Street Lending be available to nonprofits, institutions of higher learning, and minority-serving institutions. Please
4/14/2020 7:40:00 Email Address make this funding available to all businesses.
PM PIO (Email from Smith Laura
Greater Memphis Media, Inc, provides critical community based information to the underserved African American Community, on vital issues
for the lifeblood of the majority of the African American Community in the Greater Memphis Community...
In addition Greater Memphis Media, Inc., has a critical component to its business plan where we work closely with Undergraduates @
LeMoyne Owen College (a HBCU in Memphis) & its underserved student population, through Scholarships.& Communication
Internships
Personal
Greater Grrater Memphis Media, Inc. also sponsors "The I Love Reading Initiative", were.Greater Memphis Media, Inc provides
Email
4/14/2020 7:42:00 Memphis Media, "Culturally Sensitive Books" to K-3rd graders.@ underserved Elementary's in Memphis, in our ongoing fight against
Address
PM PIO (Email from Clay Brian Inc. illeteracy...
I am President and Chief Executive Officer of Tarzana Treatment Centers a non-profit substance use treatment center and behavioral health
organization in California, and I am writing to advocate for the inclusion of non-profits as part of the Main Street Lending Program. Non-profit
behavioral health agencies provide critical services to hundreds of thousands of Californians, yet have been left out of the Main Street
Tarzana Lending Program. Without the vital aid provided by the program, these agencies will have to make cuts to staff and services which impacts
4/14/2020 7:43:00 asenella@tar Treatment their ability to serve some of the most vulnerable clients in California. PLEASE INCLUDE THESE NON-PROFIT BUSINESSES AND IN TURN
PM PIO (Email from Senella Albert zanatc.org Centers INCREASE THE CAPACITY OF THE SAFETY NET SYSTEM. Thank you.
To whom it may concern and regarding the Main Street program addressing COVID-19 responses,
Thank you for the care and concern that you have put in to responding tot this health and economic crisis. Please know that you and the work
you are doing on our behalf are greatly appreciated!
I understand that the Main Stree program, as it is currently conceived, will not be open to non-profit organizations. I ask that this oversight be
re-considered.
Non-profits, such as the Y (and many other impactful organizations) are making a difference in communities around our country. We are
feeding the poor, providing shelter and showers for the homeless, providing childcare for families in need and the essential workers, providing
connection and community for seniors and healthy options for youth. All of this work requires staff and resources. Like any business, our non-
profits are significantly impacted by facility closures, stay at home orders and the economic shutdown. Still, we work to serve our
communities.
Please consider allowing these great non-profit organizations to access the Main Street Lending program. We exist with the stated mission to
serve our communities. By allowing non-profits to access these resources you allow us to protect our communities most vulnerable.
Thank you for your consideration.
Dean Snider
CEO- Skagit Valley Family YMCA
4/14/2020 7:44:00 d.snider@ska Skagit Valley Mount Vernon, WA 98273
PM PIO (Email from Snider Dean gitymca.org Family YMCA
Page 68 of 363
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Main Street Lending Program Comments
To Whom it may concern I have been working with the mental health population for many years.Our clients rely on us for their daily basic
needs. They rely on us to help link them to their doctor appointments, court hearings , assist them with getting their medication refilled ,
helping them with their housing, and food. My company Momentum (non profit) caters to a very large mental health population in Santa Clara
County and if we ran out of money or couldn't apply for a loan because we are to big of a non profit it would be absolutely devastating to
4/14/2020 7:49:00 lvelez@mom Momentum for our community our clients would be so lost and sick with no help. Most of our clients only have us health care workers in their life's we
PM PIO (Email from velez Lisa entummh.org Mental Health are all they have left. Thank you for your time.
4/14/2020 7:51:00 Personal testing my comments
PM PIO (Email from test laura Email Address
cretan@speci Nonprofit businesses are an essential part of the community's economy, and they should have access to the Main Street loans.
4/14/2020 7:52:00 alkindofcarin
PM PIO (Email from Retan Chris g.org
4/14/2020 7:55:00 Personal Email test test test
PM PIO (Email from test test Address
In support of the 4,000 employees of a regional non-profit health and human services agency that provides programs and services to nearly
10,000 people with intellectual and developmental disabilities, special needs, their families and older adults throughout numerous counties in
Western New York and the Greater Rochester region, I am writing today to inform you that People Inc. is fully engaged in dealing with the
COVID-19 crisis. They must ensure that more than 150 community-based homes and services for people with disabilities remain as safe as
possible and are staffed 24/7. The vulnerable people that depend on People Inc. deserve no less. However, because they are providing
essential services during the crisis, People Inc. has incurred highly unusual increased costs in staffing, PPE, and cleaning services.
Since People Inc. is not eligible for the Payroll Protection Program (PPP) due to their size and the fact that they must remain fully operational,
Personal we request that the Mid-Size Loan Program have provisions to convert to a forgivable loan for nonprofits that face staggering losses due to
4/14/2020 8:05:00 Email Address COVID-19. This would grant them the same protections as PPP.
PM PIO (Email from Kremer Michele Peope Inc
Personal Please consider changing the initiative so that non profits may be eligible to receive support through the CARES act. To exclude us from this
4/14/2020 8:09:00 Email Address would be a blow to our budget and could result in us needing to cut critical programs to the families within our communities during a time
PM PIO (Email from Hammond Melissa Encompass NW when they need us the most!
Personal Cabinet When can we apply? Where can I go?
4/14/2020 8:11:00 Email Address Solutions USA
PM PIO (Email from Robinson James Inc Thank you
"I am affiliated with a non-profit behavioral health organization in California, and I am writing to advocate for the inclusion of non-profits
as part of the Main Street Lending Program. Non-profit behavioral health agencies provide critical services to hundreds of thousands of
Californians, yet have been left out of the Main Street Lending Program. Without the vital aid provided by the program, these agencies will
Tarzana have to make cuts to staff and services which impacts their ability to serve some of the most vulnerable clients in California. PLEASE
4/14/2020 8:11:00 kbachrach@t Treatment INCLUDE THESE NON-PROFIT BUSINESSES AND IN TURN INCREASE THE CAPACITY OF THE SAFETY NET SYSTEM."
PM PIO (Email from Bachrach Kenneth arzanatc.org Centers, Inc.
"I am affiliated with a non-profit behavioral health organization in California, and I am writing to advocate for the inclusion of non-profits
as part of the Main Street Lending Program. Non-profit behavioral health agencies provide critical services to hundreds of thousands of
Californians, yet have been left out of the Main Street Lending Program. Without the vital aid provided by the program, these agencies will
have to make cuts to staff and services which impacts their ability to serve some of the most vulnerable clients in California. PLEASE
4/14/2020 8:14:00 ldibbs@tarza Tarzana Tx INCLUDE THESE NON-PROFIT BUSINESSES AND IN TURN INCREASE THE CAPACITY OF THE SAFETY NET SYSTEM."
PM PIO (Email from Dibbs Lauren natc.org Centers
My business is a 501c6 not for profit association that does zero lobbying. We provide education and support to the structural engineering
profession. They need our education to be licensed by their states. Without education, they can't practice. Without structural
engineers, our nation can not perform most construction.
Confidential Business Information
National Council
4/14/2020 8:18:00 aspada@ncs of Structural Please help the 501c6 organizations that don't do lobbying.
PM PIO (Email from Spada Alfred ea.com Engineere
Page 69 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
The Fed's Main Street Lending program seems to be an attempt to serve medium-sized businesses that couldn't take advantage of
the SBA programs in the CARES act due to size. Unfortunately, the programs where we might qualify do not include any loan forgiveness
options.
We're looking for similar programs made available to NPO's under 500 employees to be expanded to those that are slightly above
that threshold, that perhaps meets some other criteria (i.e. serving vulnerable populations, etc.).
We are a social services organization that serves 1100+ children and adults with intellectual and developmental disabilities and are
considered an essential agency and have 250 residents that live with us fulltime. At 550 employees, we were unable to benefit from any of
4/14/2020 8:18:00 Jdrew@littlec Little City the CARES opportunities for small businesses, but similar agencies wtih 495 employees were able to receive $4 million in aid. There needs
PM PIO (Email from Drew Jayne ity.org Foundation to be some flexibility. Thank you.
As a non-profit organization that does not meet the size requirements under the Paycheck Protection Program and has more that 500
4/14/2020 8:21:00 dsusana@ba Acacia network employees, it would be helpful the Main Street Loan Program to have a forgiveness provision - similar to PPP. Additionally, Fees/origination
PM PIO (Email from Susana Desiree sicsinc.org housing points should be waived for qualifying non-profit organizations. Thank you.
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/14/2020 8:27:00 joanna.leung Uplift Family eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
PM PIO (Email from Leung Joanna @upliftfs.org Services
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
Personal hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/14/2020 8:27:00 Email Address Uplift Family eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
PM PIO (Email from Cyrluk Laurel Services
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
Personal hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/14/2020 8:27:00 Email Uplift Family eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
PM PIO (Email from Toh Mun Keong Joshu Address Services
Please do not exclude nonprofits, institutions of higher learning and Minority-Serving Institutions from lending opportunities from this program.
Personal
4/14/2020 8:28:00
Email Address
PM PIO (Email from Cumming Maria
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
christopher.b hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/14/2020 8:28:00 oyer@upliftfs. Uplift Family eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
PM PIO (Email from Boyer Christopher org Services
Page 70 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/14/2020 8:28:00 eva.rodriguez Uplift Family eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
PM PIO (Email from Rodriguez Eva @upliftfs.org Services
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/14/2020 8:28:00 anh.tran@upl Uplift Family eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
PM PIO (Email from Tran Anh iftfs.org Services
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
Thank you so much for all of your advocacy efforts during the past few weeks as we navigate the many challenges occurring in our funding
sources at all levels of government. We appreciate all that you do for the agency and for the children and families that we serve. You are all
champions!
With gratitude,
sahar.ebrahi
4/14/2020 8:29:00 mi@upliftfs.or Sahar
PM PIO (Email from sahar ebrahimi g
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
Thank you so much for all of your advocacy efforts during the past few weeks as we navigate the many challenges occurring in our funding
samantha.riv sources at all levels of government. We appreciate all that you do for the agency and for the children and families that we serve. You are all
4/14/2020 8:29:00 era@upliftfs. Uplift Family champions!
PM PIO (Email from Rivera Samantha org Services
Page 71 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
Personal hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/14/2020 8:30:00 Email Address Uplift Family eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
PM PIO (Email from Danganan Agape John Services
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
dominique.m hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/14/2020 8:30:00 atthews@upli Uplift Family eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
PM PIO (Email from Matthews Dominique ftfs.org Services
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
jennifer.chan hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/14/2020 8:30:00 dler@upliftfs. Uplift Family eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
PM PIO (Email from Chandler Jennifer org Services
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/14/2020 8:30:00 susie.pham@ Uplift Family eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
PM PIO (Email from Pham Susie upliftfs.org Services
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/14/2020 8:30:00 mdhillon@upl Uplift Family eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
PM PIO (Email from Dhillon Parmvir iftfs.org Services
Page 72 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
In support of the 4,000 employees of a regional non-profit health and human services agency that provides programs and services to nearly
10,000 people with intellectual and developmental disabilities, special needs, their families and older adults throughout numerous counties in
Western New York and the Greater Rochester region, I am writing today to inform you that People Inc. is fully engaged in dealing with the
COVID-19 crisis. They must ensure that more than 150 community-based homes and services for people with disabilities remain as safe as
possible and are staffed 24/7. The vulnerable people that depend on People Inc. deserve no less. However, because they are providing
essential services during the crisis, People Inc. has incurred highly unusual increased costs in staffing, PPE, and cleaning services.
Since People Inc. is not eligible for the Payroll Protection Program (PPP) due to their size and the fact that they must remain fully operational,
we request that the Mid-Size Loan Program have provisions to convert to a forgivable loan for nonprofits that face staggering losses due to
COVID-19. This would grant them the same protections as PPP.
Personal
4/14/2020 8:31:00 Email Address Thank you in advance for your support of direct care staff, the people they support and People Inc.
PM PIO (Email from Beuzenburg Jackie People Inc
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
Thank you so much for all of your advocacy efforts during the past few weeks as we navigate the many challenges occurring in our funding
sources at all levels of government. We appreciate all that you do for the agency and for the children and families that we serve. You are all
champions!
With gratitude,
4/14/2020 8:31:00 darryl.prince Darryl Prince
PM PIO (Email from Prince Darryl @upliftfs.org
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/14/2020 8:31:00 dtaylor@uplift Uplift Family eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
PM PIO (Email from Taylor Don fs.org Services
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
lory.dangana hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/14/2020 8:32:00 n@upliftfs.or Uplift Family eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
PM PIO (Email from Danganan Lory g Services
Page 73 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
yesenia.cam hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/14/2020 8:32:00 pos@upliftfs. Uplift Family eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
PM PIO (Email from Campos Yesenia org Services
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/14/2020 8:32:00 cniedhamer Uplift Family eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
PM PIO (Email from Niedhamer Courtney @upliftfs.org Services
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
nicolette.hart hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/14/2020 8:32:00 er@upliftfs.or Uplift Family eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
PM PIO (Email from Vang Nicolette g Services
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/14/2020 8:32:00 mnunez@upli Uplift Family eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
PM PIO (Email from Nunez Maria ftfs.org Services
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
Personal Email
hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
Address
4/14/2020 Uplift Family eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
12:00:00 AM PIO (Email from Clausen Rachael Services
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for
restoration of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased
access to lending programs intended to sustain payroll and retain employees, many mental health and substance use service providers
are at risk, a circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment
and care. A lack of access to adequate mental and substance use care will lead many Americans to utilization of emergency services,
Monique.Enri over-crowding community hospital emergency departments and drastically increasing health care costs. As such, it is imperative that
4/14/2020 quez@uplifte Uplift Family the Main Street New Loan Facility eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue
12:00:00 AM PIO (Email from Enriquez Monique d.org Services up to $2.5 billion.
Page 74 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
sidya.espinoz hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/14/2020 8:36:00 a@upliftfs.or eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
PM PIO (Email from Espinoza Sidya g
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I have
worked for the same nonprofit behavioral health organization serving children and families in California for the past 5 years and I am writing
to advocate for restoration of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without
increased access to lending programs intended to sustain payroll and retain employees, many mental health and substance use service
providers are at risk, a circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment
and care that will further exacerbate the problems overwhelm the already over-crowded community hospital emergency departments and
drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility eligibility include nonprofit
organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
Thank you so much for all of your advocacy efforts during the past few weeks as we navigate the many challenges occurring in our funding
sources at all levels of government. We appreciate all that you do for the agency and for the children and families that we serve. We are
literally depending on you to help us so we can continue to help others far less fortunate.
With gratitude,
patrick.nedde
4/14/2020 8:36:00 rsen@UpliftF Uplift Family Patrick Neddersen
PM PIO (Email from Neddersen Patrick S.org Services
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/14/2020 8:36:00 sbittner@uplif Uplift Family eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
PM PIO (Email from Bittner Scott tfs.org Services
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
leticia.rodrigu hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/14/2020 8:37:00 ez@upliftfs.or Uplift Family eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
PM PIO (Email from Rodriguez Leticia g Services
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
Personal
4/14/2020 8:38:00 eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
Email Address
PM PIO (Email from Abbott Cassandra
Page 75 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
4/14/2020 8:38:00 shaun@epaz interested in the main street lending program for my company
PM PIO (Email from Passley Shaun z.net Epazz Inc
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
Personal Email
hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
Address
4/14/2020 8:39:00 Uplift Family eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
PM PIO (Email from Yamat Jacqueline Services
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
Personal hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/14/2020 8:39:00 Email Address Uplift Famliy eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
PM PIO (Email from Refo Jacqueline Services
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/14/2020 8:40:00 cherie.yeung Uplift Family eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
PM PIO (Email from Yeung Cherie @upliftfs.org Services
Personal Please help the non-profits.
4/14/2020 8:41:00 Email Address Christian's Place
PM PIO (Email from Newman Carole Mission
As part of the Coronavirus Aid, Relief, and Economic Security (CARES) Act that Congress passed into law on March 27, 2020, the Federal
Reserve was required to provide lending to "Main Street." Unfortunately, the Administration and the Fed, as of today, are excluding
nonprofits, many institutions of higher learning and Minority-Serving Institutions. This is a significant blow in particular to entities that are also
rochelle.clayt ineligible for the Paycheck Protection Program.
onstrunk@en
4/14/2020 compassnw.o Please include nonprofit organizations, institutions of higher learning and Minority Serving Institutions. These organizations are vital to our
12:00:00 AM PIO (Email from Clayton StrunkRochelle rg Encompass NW communities. Support is critical in sustaining important programs and services.
My nonprofit organization provide services throughout the state of California. There are a range of programs that provide important services to
vulnerable individuals such as foster youth, individuals with autism, and substance abuse. These programs prevent higher burdens on our
society such as crime and negative impacts on loved ones. Due to the number of employees in our organization (1000+), our organization will
not qualify for the loan program. Already our organization is impacted by current realities, with those that make the less impacted the most. I
Personal hope that there can be understanding regarding the importance of the work we do and those that provide that work.
Email Address
4/14/2020 8:43:00 Uplift Family Thank you
PM PIO (Email from Ko Jeffrey Services
Page 76 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
In support of the 4,000 employees of a regional non-profit health and human services agency that provides programs and services to nearly
10,000 people with intellectual and developmental disabilities, special needs, their families and older adults throughout numerous counties in
Western New York and the Greater Rochester region, I am writing today to inform you that People Inc. is fully engaged in dealing with the
COVID-19 crisis. They must ensure that more than 150 community-based homes and services for people with disabilities remain as safe as
possible and are staffed 24/7. The vulnerable people that depend on People Inc. deserve no less. However, because they are providing
essential services during the crisis, People Inc. has incurred highly unusual increased costs in staffing, PPE, and cleaning services.
Since People Inc. is not eligible for the Payroll Protection Program (PPP) due to their size and the fact that they must remain fully operational,
we request that the Mid-Size Loan Program have provisions to convert to a forgivable loan for nonprofits that face staggering losses due to
COVID-19. This would grant them the same protections as PPP.
Personal
4/14/2020 8:44:00 Email Thank you in advance for your support of direct care staff, the people they support and People Inc.
PM PIO (Email from Shiesley Leah Address
$1m min will exclude a lot of smaller businesses. PPP is great but will not help us reset and get back to full operation. $500k would open to a
4/14/2020 8:45:00 Ed@dark- Dark Storm lot of companies that could use this. Or give us a separate program. We are excluded from EIDL because of PPP and loans for companies
PM PIO (Email from Newman Edward storm.com Industries LLC our size are tough to get in good times.
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/14/2020 8:45:00 latina.gutierre Uplift Family eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
PM PIO (Email from Gutierrez Latina z@upliftfs.org Services
I am affiliated with a non-profit behavioral health organization in California, and I am writing to advocate for the inclusion of non-profits as part
of the Main Street Lending Program. Non-profit behavioral health agencies provide critical services to hundreds of thousands of Californians,
yet have been left out of the Main Street Lending Program. Without the vital aid provided by the program, these agencies will have to make
apingdifiore Tarzana cuts to staff and services which impacts their ability to serve some of the most vulnerable clients in California. PLEASE INCLUDE THESE
4/14/2020 8:47:00 @tarzanatc.o Treatment NON-PROFIT BUSINESSES AND IN TURN INCREASE THE CAPACITY OF THE SAFETY NET SYSTEM.
PM PIO (Email from Ping-DiFiore Alesia rg Centers, Inc.
Dear Board of Governors of the Federal Reserve:
I am the CEO of a Seattle-based nonprofit organization, The Mountaineers. We employ more than 50 full-time employees, have an annual
budget of more than $9 million, and are recognized as one of the top outdoor education and conservation nonprofits in the country. I am
writing today to urge you to allow 501(c)(3) nonprofit organizations to access the $600B Main Street credit facility created by the CARES Act
of 2020.
Excluding nonprofit organizations from this credit during this unprecedented crisis is patently unfair and further, is economically a poor
decision. Nonprofits are no less worthy of relief support to protect jobs and sustain our contributions to the GDP than are small and medium
businesses. Further, many employees working for nonprofits such as The Mountaineers accept below market wages to work in a mission-
driven organization. We are in a desperately difficult situation and should have the same access to lending facilities such as Main Street as do
for-profit businesses.
The Mountaineers was founded in 1906 and I can say with little doubt that the coronavirus crisis is one of the most significant threats to our
existence since the Great Depression and the world wars. I urge you to reconsider your policy proposal on Main Street Lending and include
501(c)(3) nonprofit organizations alongside businesses.
Best regards,
4/14/2020 8:48:00 tomv@mount The
PM PIO (Email from Vogl Tom aineers.org Mountaineers Tom Vogl, CEO - The Mountaineers
Nonprofits should be treated like all
4/14/2020 8:53:00 Jphaydon@s Other businesses to benefit from the CARES Act. In many cases, nonprofits have a bigger economic and social impact in their communities
PM PIO (Email from Haydon Jeff bcglobal.net than for profit businesses. Please do not exclude them from this program.
Page 77 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
"I am affiliated with a non-profit behavioral health organization in California, and I am writing to advocate for the inclusion of non-profits
as part of the Main Street Lending Program. Non-profit behavioral health agencies provide critical services to hundreds of thousands of
Californians, yet have been left out of the Main Street Lending Program. Without the vital aid provided by the program, these agencies will
have to make cuts to staff and services which impacts their ability to serve some of the most vulnerable clients in California. PLEASE
4/14/2020 9:01:00 aurton@hom HomeFirst INCLUDE THESE NON-PROFIT BUSINESSES AND IN TURN INCREASE THE CAPACITY OF THE SAFETY NET SYSTEM."
PM PIO (Email from urton andrea efirstscc.org Services
A broader window of EBITDA used for the loan maximum would be appropriate for certain businesses, especially in the training and defense
arenas. For example, our organization has undergone a product transition, starting from mid-2017. This was entirely self funded, and our
Personal institution maintained payroll and headcount. Our return to market was mid-2019, so using only 2019 EBITDA comes nowhere near
4/14/2020 9:04:00 Email accurately reflecting historical revenue potential and ability to repay the loan. I respectfully request allowing use of the highest EBITDA in the
PM PIO (Email from Bailey Eric Address Acuitus last 3 to 5 years for the maximum loan calculation.
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
Be well,
4/14/2020 9:04:00 Sdexter@upli Uplift Family Suzanne
PM PIO (Email from Dexter Suzanne ftfs.org Services
hank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am affiliated
with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration of the
applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending programs
intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a circumstance that
could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of access to adequate
mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community hospital emergency
departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility eligibility include
4/14/2020 nicole.bennet Uplift Family nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
12:00:00 AM PIO (Email from Bennett Nicole t@upliftfs.org Services
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/14/2020 9:13:00 vivian.aizpuru Uplift Family eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
PM PIO (Email from Aizpuru Vivian @upliftfs.org Services
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
Please, we are forced to cut jobs of Social Workers who care for our Foster kids and teens. Please do not exclude non-profit agencies like
4/14/2020 9:15:00 rjones@upliftf ours.
PM PIO (Email from Jones Rylle s.org Uplift Family Svs
Page 78 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
Personal Please, please include nonprofits eligible for this program. Nonprofits--especially small ones like our agency barely meet our budget in a
4/14/2020 9:17:00 Email Address Community Grief good year; we will suffer a great deal this year and may have to close if we don't get assistance. We provide 3,000-plus bereaved adults
PM PIO (Email from Harrison Lisa Support in the Greater Birmingham with free grief counseling, support groups, and community education.
Federal Reserve:
Our company has been negatively impacted by the current health crisis. We are a relatively new company (18 months) which we know is a
priority in the effort to help small businesses. Our company has received partial assistance using the PPP; however, this is not enough to
allow us to fully resume business operations. We turned to the Main Street Lending Program as outlined in the CARES ACT, but the
requirements for this loan necessitate a loan calculation based on EBITDA. Unfortunately, this gives no option for companies that are pre-
vincent@sols revenue. In order to best help new companies (we employed over 400 people in the U.S. in the last year) stay in business and prosper, an
4/14/2020 9:23:00 tice- option to obtain a MSLP loan needs to be available for companies that have not yet had a chance to record revenue/profit. We ask that the
PM PIO (Email from Bruzzese Vincent studios.com guidance to the banks be adjusted to allow for this.
lmendenhall As a non-profit organization that does not meet the size requirements under the Paycheck Protection Program and has more that 500
4/14/2020 @acacianetw employees, it would be helpful the Main Street Loan Program to have a forgiveness provision - similar to PPP. Additionally, Fees/origination
12:00:00 AM PIO (Email from Mendenhall Lauren rok.org Acacia Network points should be waived for qualifying non-profit organizations. Thank you.
As a nonprofit Community Health Center, Cahaba Medical Care Foundation has been greatly affected by COVID-19. We have lost 40% of our
incoming revenue. Seven of our medical clinics and one dental clinic have closed. Yet, we are still at the forefront providing services to the
Personal vulnerable populations we serve in Central Alabama. Without Federal assistance we will not be able to continue to do what we do on a daily
4/14/2020 9:28:00 Email Cahaba Medical basis. We need the same benefits as other small businesses. We have 354 employees. We are the 5th largest employer in Bibb County.
PM PIO (Email from Cade Patricia Address Care Foundation Nonprofits are businesses, too. Help us to help others.
It is totally ridiculous that the Fed is ignoring major places of need during this pandemic for lending them money to cover staff paychecks and
for operations of these businesses. A non-profit business is a business of serving people while employing millions of people to help others to
gain a foothold to a better financial time. Excluding non profits, educational institutions and minority serving institutions is not only
discriminatory as a civil and human right, but is bad economics since these populations are the future of this country and can contribute to its
Montgomery growth and wealth. Also, the populations most affected by the coronavirus are these populations where the need is greatest. Do your job for
County the good of ALL the Nation and not just the well-off. Include non profits, large educational institutions and minority serving institutions as
Personal Executive's Latin eligible for receiving funds for lending to main street.. Do the right thing for the right reason to get the right result. Thank you.
4/14/2020 9:32:00 Email Address American Henry Montes
PM PIO (Email from Montes J. Henry Advisory Group
Non-profit organizations are the lifeblood of our country, often stepping in to fill the gaps where government doesn't provide. They
operate lean organizations generally on a shoe-string budget, but effect tremendous impact in communities all over our country. Non-profits
have been devastated financially as a result of Covid-19. Yet, as we emerge from this public health emergency, non-profits will be more
brookek@my important than ever. A simple look at the miles long lines of cars trying to secure food from food pantries is just one illustration. The federal
4/14/2020 9:42:00 northshore.or Northshore government should be prioritizing support for non-profits as their will be tremendous economic and social impact when non-profits are left to
PM PIO (Email from Knight Brooke g Senior Center fail.
St. David's Center is a secular nonprofit 501c3 serving the Twin Cities, Minnesota seven-county metropolitan area, meeting the needs
for early education, early intervention, and disability support of over 4,300 children and families annually. We provide roughly 63% of our
services at four campus locations and another 13% in place-based partnerships with 30 different schools, childcare centers, and community
organizations, all dramatically affected by this public health crisis, community fear, and executive orders to limit group contact and, most
recently, shelter in place. Emergency funding is necessary to 1) offset essential expenses as we execute new service models, 2) transition
staff and families to virtual service delivery, and 3) retain the right workforce to nimbly manage growth in demand. All provisions for the
nonprofit sector included in the previous coronavirus relief packages have been aimed at nonprofits with employee counts of 500 and less.
There are over 100 social service safety net nonprofits in the state of Minnesota alone with more than 500 employees. The Main Street
mwalsh@std Lending Program could be a useful tool for all of us, if there are two inclusions: 1) loans for nonprofits are structured over 15-30 years, given
4/14/2020 9:54:00 avidscenter.o St. David's our sector operates with very thin margins and loan repayment will be challenging and 2) loans are forgivable if criteria are met.
PM PIO (Email from Walsh Maureen rg Center
Hello, I am interested in applying for your Main
barbara.bisho Street Lending program. Is there an application I could have?
4/14/2020 9:58:00 p@bbprinc.in
PM PIO (Email from Bishop Barbara c BBPR, Inc. Thanks. Barbara Bishop
Page 79 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
I am writing to advocate for the inclusion of non-profits as eligible entities for the Main Street Lending Program. Non-profits, and especially
behavioral health agencies, provide critical services to hundreds of thousands of Californians, yet have been left out of the Main Street
Lending Program. Without the vital aid provided by the lending program, many agencies will have to make cuts, both staff and service levels,
4/14/2020 9:58:00 jchoothesa@ Amity which will, in turn, diminish their ability to help some of the most vulnerable people. As a representative of a non-profit behavioral health
PM PIO (Email from Bond Doug amityfdn.org Foundation organization in California I respectfully request that non-profits be included in the loan program
Ccabral@iron When will the full information for the Main Street loans be available?
4/14/2020 horsefunding. Ironhorse
12:00:00 AM PIO (Email from Cabral Cheryl com Funding LLC
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
yaminah.hen hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/14/2020 drix@emq.or Uplift Family eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
10:13:00 PM PIO (Email from Hendrix-Parso Yaminah g Services
4/14/2020 fjmitch@iland Hello. I was inquiring about a loan. I'm not sure if this is thus is how I do it? Please let me know what I need to do.
10:53:00 PM PIO (Email from MITCHELL JANET .net Thanks for your assistance.
Personal Jalayah Our organization is currently looking for funding in order to keep our non-profit in business. All of our funding and fundraisers have been
4/14/2020 Email Address Hackman canceled due to Covid-19. We are struggling in keeping the doors open. We are needing rental assistance as well as utilities.
10:56:00 PM PIO (Email from Fluker Sherae Foundation
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
Personal hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/14/2020 Email Address Uplift Family eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
10:57:00 PM PIO (Email from Antonioli Stephanie Services
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
Thank you so much for all of your advocacy efforts during the past few weeks as we navigate the many challenges occurring in our funding
sources at all levels of government. We appreciate all that you do for the agency and for the children and families that we serve. You are all
champions!
christina.arce With gratitude,
4/14/2020 ga@upliftfs.o Uplift Family Christina Arcega
11:03:00 PM PIO (Email from Arcega Christina rg Services
Page 80 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
In support of the 4,000 employees of a regional non-profit health and human services agency that provides programs and services to nearly
10,000 people with intellectual and developmental disabilities, special needs, their families and older adults throughout numerous counties in
Western New York and the Greater Rochester region, I am writing today to inform you that People Inc. is fully engaged in dealing with the
COVID-19 crisis. They must ensure that more than 150 community-based homes and services for people with disabilities remain as safe as
possible and are staffed 24/7. The vulnerable people that depend on People Inc. deserve no less. However, because they are providing
essential services during the crisis, People Inc. has incurred highly unusual increased costs in staffing, PPE, and cleaning services.
Since People Inc. is not eligible for the Payroll Protection Program (PPP) due to their size and the fact that they must remain fully operational,
we request that the Mid-Size Loan Program have provisions to convert to a forgivable loan for nonprofits that face staggering losses due to
Personal COVID-19. This would grant them the same protections as PPP.
Email
4/14/2020 Address Thank you in advance for your support of direct care staff, the people they support and People Inc.
11:05:00 PM PIO (Email from Harle-Mould Jessica People Inc
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
Melissa.new hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/14/2020 man@upliftfs. Uplift Family eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
11:22:00 PM PIO (Email from Newman Melissa org Services
Personal As a pastor in the United Church of Christ, and with a daughter who is a house manager for People Inc. for Main Street Lending, please
4/14/2020 Email change the loan program for this non-profit to make it forgivable. They are courageously caring for many disabled adults. Please recognize
11:31:00 PM PIO (Email from Harle-Mould Hope Address their sacrifice.
Please ensure nonprofits are explicitly named as eligible recipients of the Main Street Lending program
Please also ensure that nonprofit employers with between 500 and 10,000 employees are able to access the loans.
Please also consider loan forgiveness for nonprofits, similar to the Paycheck Protection Program, to eliminate the burden of repayment in
these uncertain times.
Without additional resources, many nonprofit organizations will be lost to their communities, including YMCAs.
The YMCA of Greater Cincinnati employed 1,700 staff prior to the COVID-19 pandemic and have had to lay-off 85% of our staff.
We were not able to apply for the Paycheck Protection Program because of our size.
Without access to support, our Y will not be able to resume operations as we knew it or retain our staff.
Including larger organizations would ensure that we can continue to provide urgently needed services for their neighbors.
Despite our facilities being closed, our Y is providing childcare to Healthcare families, distributing thousands of meals, checking in on our
isolated seniors, and providing academic support to low-income youth.
jperez@cinci Our Y, along with others, are committed to serving our communities throughout this pandemic and beyond.
4/14/2020 nnatiymca.or YMCA of Greater
12:00:00 AM PIO (Email from Perez Jorge g Cincinnati Please help us ensure that we have the resources necessary to supporting our neighbors and our staff.
Personal Please make this facility available to nonprofit organizations, colleges, and universities. Thank you.
4/14/2020 Email Address
11:43:00 PM PIO (Email from Schaefer Bart iPost
Page 81 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
Personal hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/14/2020 Email Uplift Family eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
11:45:00 PM PIO (Email from Salinas Belinda Address Services
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/14/2020 mpost@mom Momentum for eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
11:49:00 PM PIO (Email from Post Marina entummh.org Mental Health
I have worked for decades as a case manager at Momentum for Mental Health, an essential part of the system of care for those with mental
health disorders in our county. Our agency has slightly over 500 employees. I have learned that the Main Street Lending program would
mmartin@mo exclude non-profit agencies with more than 500 employees from obtaining assistance from that program. Agencies like ours are crucial to
4/14/2020 mentummh.o Momentum for meeting the needs of the county's mental health population. Therefore, I am writing to ask that non-profit agencies with over 500
11:49:00 PM PIO (Email from Martin Marilyn rg Mental Health employees be included in the Main Street Lending program. Thank you for considering my request.
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
Personal
hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
Email Address
4/14/2020 eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
11:51:00 PM PIO (Email from Langsjoen Brett
dammann@p Is there a signup form to participate in the MSNLF or MSELF? Are there details on the underwriting or participation agreement between the
4/14/2020 eoplesbank- bank and the SPV? Thanks.
11:53:00 PM PIO (Email from Ammann Dennis ms.com Peoples Bank
audrey@savi Please consider supporting non profit organizations in this Covid-19 pandemic. It is impossible to get donations or grants right now..We do
4/15/2020 nghorsesinc. Saving Horses, pay staff or have to let them go if we dont have enough funds to pay them...
12:02:00 AM PIO (Email from Reynolds Audrey com Inc.
Personal CARES ACT: This facility will support up to $600B in new bank lending to small and mid-sized businesses. Unfortunately, the Administration
4/15/2020 Email Address and the Fed, as of today, are excluding nonprofits, many institutions of higher learning and Minority-Serving Institutions. It is unacceptable to
12:11:00 AM PIO (Email from BREN LAURIE L Bren exclude non-profits and Minority-Serving institutions!
4/15/2020 Drattray@uni Non profits are key part of the safety net and support system to help low income workers rebound and should be included.
12:51:00 AM PIO (Email from Rattray David tela.com UNITE-LA
Personal Please call me at Cell Phone to discuss my eligibility for Main Street Lending. Where can I go to apply? Thank you! Kim Cell Phone
4/15/2020 Email Address N b
12:00:00 AM PIO (Email from Teng Khang CK Auto Image
Page 82 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
LMena@Mo hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/15/2020 1:08:00 mentumMH.o Momentum for eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
AM PIO (Email from Mena Lisa rg Mental Health
The Main Street loans should not have the same restrictions as the SBA, otherwise it is useless. SBA has requirements in reference to
previously incarcerated and back child support. Many of these people own businesses and have been negatively affected by this pandemic.
Personal Email Without assistance, their businesses will fail and they will be without the ability to support themselves or their families. Lastly, there should be
4/15/2020 Address a strong policy towards insuring that minorities and veterans owned businesses are able to take advantage of the funds.
12:00:00 AM PIO (Email from St Paul Rich
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/15/2020 Laura.reyes Uplift Family eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
12:00:00 AM PIO (Email from Reyes Laura @upliftfs.org Services
Confidential
I have been following the Economic Injury Disaster Loan program as I was hoping to receive a loan for Business which would have allowed
me to open the restaurants I own. However due to the heavy demand for the EIDL program, SBA has decided to cap the loan amount to
$15,000 instead of the initial 2 million. I would suggest that you should allow Main Street Lending Program to help businesses like mine to
Law Offices of survive and come back after the COVID-19 stay-in-place restrictions have been lifted. If possible the length of the term should be extended to
4/15/2020 2:25:00 flewis@lewis Lewis & 10 years and the interest rate should be capped at 3.75 and businesses who were health pre COVID-19 should be allowed to participate in
AM PIO (Email from LEWIS FITZGERALD atlaw.com Associates, PC the program. Thank you.
Thank you for the opportunity to comment regarding the Main Street Lending Program. Three suggestions to offer.
1. Recommend reducing the minimum loan amount to $10k. Many of the businesses hardest hit by this crisis are too small to qualify for a
$1M loan.
2. Recommend allowing the loan to be used to refinance existing debt not held by the lender involved with the MSNLF or MSELF. Only
allowing a loan when it increases a company's total debt load will guarantee increased risk, but might not necessarily increase the
potential return on that risk. How many businesses will sign up for that?
jmbrowning@
4/15/2020 5:56:00 ogdencity.co 3. Recommend reducing the loan origination fee or having it paid by the SPV. 2% is way above market, and the offered interest rates
AM PIO (Email from Browning John m aren't low enough to justify that cost.
4/15/2020 6:37:00 Personal Have not received any help as of yet please provide forms for main street loan
AM PIO (Email from Hackett Renee Email Address
Page 83 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
As one of 4,000 employees of a regional non-profit health and human services agency that provides programs and services to nearly 10,000
people with intellectual and developmental disabilities, special needs, their families and older adults throughout numerous counties in Western
New York and the Greater Rochester region, I am writing today to inform you that our agency, People Inc., is fully engaged in dealing with the
COVID-19 crisis. We must ensure that our homes and services for people with disabilities remain as safe as possible and are staffed 24/7.
The vulnerable people that depend on us deserve no less. However, because we are providing essential services during the crisis, People
Inc. has incurred highly unusual increased costs in staffing, PPE, and cleaning services.
Since we are not eligible for the Payroll Protection Program (PPP) due to our size and we must remain fully operational, we request that the
Mid-Size Loan Program have provisions to convert to a forgivable loan for nonprofits that face staggering losses due to COVID-19. This would
grant us the same protections as PPP.
Thank you in advance for your support of direct care staff, the people we support and our agency, People Inc.
Sincerely,
4/15/2020 6:53:00 kstearns@pe Karen Stearns
AM PIO (Email from Stearns Karen ople-inc.org People Inc.
As one of 4,000 employees of a regional non-profit health and human services agency that provides programs and services to nearly 10,000
people with intellectual and developmental disabilities, special needs, their families and older adults throughout numerous counties in Western
New York and the Greater Rochester region, I am writing today to inform you that our agency, People Inc., is fully engaged in dealing with the
COVID-19 crisis. We must ensure that our homes and services for people with disabilities remain as safe as possible and are staffed 24/7.
The vulnerable people that depend on us deserve no less. However, because we are providing essential services during the crisis, People
Inc. has incurred highly unusual increased costs in staffing, PPE, and cleaning services.
Since we are not eligible for the Payroll Protection Program (PPP) due to our size and we must remain fully operational, we request that the
Mid-Size Loan Program have provisions to convert to a forgivable loan for nonprofits that face staggering losses due to COVID-19. This would
grant us the same protections as PPP.
4/15/2020 7:02:00 cfurman@pe Thank you in advance for your support of direct care staff, the people we support and our agency, People Inc.
AM PIO (Email from Furman Courtney ople-inc.org People Inc
As one of 4,000 employees of a regional non-profit health and human services agency that provides programs and services to nearly 10,000
people with intellectual and developmental disabilities, special needs, their families and older adults throughout numerous counties in Western
New York and the Greater Rochester region, I am writing today to inform you that our agency, People Inc., is fully engaged in dealing with the
COVID-19 crisis. We must ensure that our homes and services for people with disabilities remain as safe as possible and are staffed 24/7.
The vulnerable people that depend on us deserve no less. However, because we are providing essential services during the crisis, People
Inc. has incurred highly unusual increased costs in staffing, PPE, and cleaning services.
Since we are not eligible for the Payroll Protection Program (PPP) due to our size and we must remain fully operational, we request that the
Mid-Size Loan Program have provisions to convert to a forgivable loan for nonprofits that face staggering losses due to COVID-19. This would
grant us the same protections as PPP.
4/15/2020 7:04:00 rpeters@peo Thank you in advance for your support of direct care staff, the people we support and our agency, People Inc.
AM PIO (Email from Peters Rosemarie ple-inc.org People Inc
Page 84 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
As one of 4,000 employees of a regional non-profit health and human services agency that provides programs and services to nearly 10,000
people with intellectual and developmental disabilities, special needs, their families and older adults throughout numerous counties in Western
New York and the Greater Rochester region, I am writing today to inform you that our agency, People Inc., is fully engaged in dealing with the
COVID-19 crisis. We must ensure that our homes and services for people with disabilities remain as safe as possible and are staffed 24/7.
The vulnerable people that depend on us deserve no less. However, because we are providing essential services during the crisis, People
Inc. has incurred highly unusual increased costs in staffing, PPE, and cleaning services.
Since we are not eligible for the Payroll Protection Program (PPP) due to our size and we must remain fully operational, we request that the
Mid-Size Loan Program have provisions to convert to a forgivable loan for nonprofits that face staggering losses due to COVID-19. This would
grant us the same protections as PPP.
Thank you in advance for your support of direct care staff, the people we support and our agency, People Inc.
dmacmurray
4/15/2020 7:11:00 @people- Dawn MacMurray
AM PIO (Email from MacMurray Dawn inc.org People Inc
As one of 4,000 employees of a regional non-profit health and human services agency that provides programs and services to nearly 10,000
people with intellectual and developmental disabilities, special needs, their families and older adults throughout numerous counties in Western
New York and the Greater Rochester region, I am writing today to inform you that our agency, People Inc., is fully engaged in dealing with the
COVID-19 crisis. We must ensure that our homes and services for people with disabilities remain as safe as possible and are staffed 24/7.
The vulnerable people that depend on us deserve no less. However, because we are providing essential services during the crisis, People
Inc. has incurred highly unusual increased costs in staffing, PPE, and cleaning services.
Since we are not eligible for the Payroll Protection Program (PPP) due to our size and we must remain fully operational, we request that the
Mid-Size Loan Program have provisions to convert to a forgivable loan for nonprofits that face staggering losses due to COVID-19. This would
grant us the same protections as PPP.
4/15/2020 7:12:00 jwallace@pe Thank you in advance for your support of direct care staff, the people we support and our agency, People Inc.
AM PIO (Email from Wallace Jaime ople-inc.org People Inc.
Personal Email How do I apply for the Main street loan? How do I apply for the Main street extended loan? I wil be eligible.
4/15/2020 7:16:00 Address
AM PIO (Email from Chambers Beau Thank you and God Bless! Beau
As one of 4,000 employees of a regional non-profit health and human services agency that provides programs and services to nearly 10,000
people with intellectual and developmental disabilities, special needs, their families and older adults throughout numerous counties in Western
New York and the Greater Rochester region, I am writing today to inform you that our agency, People Inc., is fully engaged in dealing with the
COVID-19 crisis. We must ensure that our homes and services for people with disabilities remain as safe as possible and are staffed 24/7.
The vulnerable people that depend on us deserve no less. However, because we are providing essential services during the crisis, People
Inc. has incurred highly unusual increased costs in staffing, PPE, and cleaning services.
Since we are not eligible for the Payroll Protection Program (PPP) due to our size and we must remain fully operational, we request that the
Mid-Size Loan Program have provisions to convert to a forgivable loan for nonprofits that face staggering losses due to COVID-19. This would
grant us the same protections as PPP.
4/15/2020 7:18:00 mvelocci@pe Thank you in advance for your support of direct care staff, the people we support and our agency, People Inc.
AM PIO (Email from Velocci Michelle ople-inc.org People-inc
Page 85 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
As one of 4,000 employees of a regional non-profit health and human services agency that provides programs and services to nearly 10,000
people with intellectual and developmental disabilities, special needs, their families and older adults throughout numerous counties in Western
New York and the Greater Rochester region, I am writing today to inform you that our agency, People Inc., is fully engaged in dealing with the
COVID-19 crisis. We must ensure that our homes and services for people with disabilities remain as safe as possible and are staffed 24/7.
The vulnerable people that depend on us deserve no less. However, because we are providing essential services during the crisis, People
Inc. has incurred highly unusual increased costs in staffing, PPE, and cleaning services.
Since we are not eligible for the Payroll Protection Program (PPP) due to our size and we must remain fully operational, we request that the
Mid-Size Loan Program have provisions to convert to a forgivable loan for nonprofits that face staggering losses due to COVID-19. This would
grant us the same protections as PPP.
Thank you in advance for your support of direct care staff, the people we support and our agency, People Inc.
In Appreciation,
pdibenedetto Patricia DiBenedetto
4/15/2020 7:27:00 @people- Accounting Coordinator
AM PIO (Email from DiBenedetto Patricia inc.org People Inc
One of the attestations required under the MSNLF is that the amount of the loan should not exceed 4 times 2019 EBITDA. Many firms that are
in the process of building their business did not have any earnings (and therefore no EBITDA) in 2019. These firms are excluded from the
MSNLF although they are even more in need of financial support at this time than firms that have been in existence longer. Changing the
attestation requirement to one that is forward looking will help such firms. One standard could be that the firm attests that it expects to earn
Personal enough over the loan's term that it will meet the EBITDA requirement when averaged over its term. This standard would not substantially
4/15/2020 7:57:00 Email increase risk to the Fed as the Eligible Lender would have to review the borrower's business plan and confirm the estimate.
AM PIO (Email from Rao Shiv Address
As one of 4,000 employees of a regional non-profit health and human services agency that provides programs and services to nearly 10,000
people with intellectual and developmental disabilities, special needs, their families and older adults throughout numerous counties in Western
New York and the Greater Rochester region, I am writing today to inform you that our agency, People Inc., is fully engaged in dealing with the
COVID-19 crisis. We must ensure that our homes and services for people with disabilities remain as safe as possible and are staffed 24/7.
The vulnerable people that depend on us deserve no less. However, because we are providing essential services during the crisis, People
4/15/2020 8:03:00 cmcdaniel@p Inc. has incurred highly unusual increased costs in staffing, PPE, and cleaning services.
AM PIO (Email from McDaniel Chip eole-inc.org People Inc
In support of the 4,000 employees of a regional non-profit health and human services agency that provides programs and services to nearly
10,000 people with intellectual and developmental disabilities, special needs, their families and older adults throughout numerous counties in
Western New York and the Greater Rochester region, I am writing today to inform you that People Inc. is fully engaged in dealing with the
COVID-19 crisis. They must ensure that more than 150 community-based homes and services for people with disabilities remain as safe as
possible and are staffed 24/7. The vulnerable people that depend on People Inc. deserve no less. However, because they are providing
essential services during the crisis, People Inc. has incurred highly unusual increased costs in staffing, PPE, and cleaning services.
Since People Inc. is not eligible for the Payroll Protection Program (PPP) due to their size and the fact that they must remain fully operational,
we request that the Mid-Size Loan Program have provisions to convert to a forgivable loan for nonprofits that face staggering losses due to
COVID-19. This would grant them the same protections as PPP.
4/15/2020 8:07:00 Mcalkins@pe Thank you in advance for your support of direct care staff, the people they support and People Inc.
AM PIO (Email from Calkins Megan ople-inc.org People Inc
Page 86 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
Please consider modifying the Main Street Lending Facility to include 501c(6) non-profit organizations. Our organization, Academy of
Nutrition and Dietetics, represents over 100,000 Registered Dietitians and Dietitian Technicians who are currently on the front lines helping
fight this pandemic. Professional organizations, like ours, employee millions of individuals who provide needed support to ensure the most up
to date information and science is available to help slow the spread of this disease. Unfortunately, we are also feeling the pressures of the
economic closure that may require us to close our doors and reduce staff in order to survive. This will eliminate the support needed for our
members to help the public at large. Including 501c(6) organizations in the Payroll Protection Loan program will go a long way to ensuring we
can maintian our staff, our support to our members and their support to the public at large. Your decision to include 501c(6) organizations will
help facilitate a faster economic recovery and save lives. Again, i ask, respectfully, that you reconsider this oversight to not include 501c(6)
Academy of organizations in this program.
4/15/2020 8:12:00 pmifsud@eat Nutrition and
AM PIO (Email from Mifsud Paul right.org Dietetics Thank you
As one of 4,000 employees of a regional non-profit health and human services agency that provides programs and services to nearly 10,000
people with intellectual and developmental disabilities, special needs, their families and older adults throughout numerous counties in Western
New York and the Greater Rochester region, I am writing today to inform you that our agency, People Inc., is fully engaged in dealing with the
COVID-19 crisis. We must ensure that our homes and services for people with disabilities remain as safe as possible and are staffed 24/7.
The vulnerable people that depend on us deserve no less. However, because we are providing essential services during the crisis, People
Inc. has incurred highly unusual increased costs in staffing, PPE, and cleaning services.
Since we are not eligible for the Payroll Protection Program (PPP) due to our size and we must remain fully operational, we request that the
Mid-Size Loan Program have provisions to convert to a forgivable loan for nonprofits that face staggering losses due to COVID-19. This would
grant us the same protections as PPP.
4/15/2020 8:20:00 cbooth@peo Thank you in advance for your support of direct care staff, the people we support and our agency, People Inc.
AM PIO (Email from Booth Charlotte ple-inc.org People, Inc.
lillis@bibandt Please consider including nonprofits in the Main Street Lending initiative so that we can continue to support the most vulnerable citizens of our
4/15/2020 8:26:00 uckersewop. Bib & communities.
AM PIO (Email from Taylor Lillis org Tucker Sew-Op
As one of 4,000 employees of a regional non-profit health and human services agency that provides programs and services to nearly 10,000
people with intellectual and developmental disabilities, special needs, their families and older adults throughout numerous counties in Western
New York and the Greater Rochester region, I am writing today to inform you that our agency, People Inc., is fully engaged in dealing with the
COVID-19 crisis. We must ensure that our homes and services for people with disabilities remain as safe as possible and are staffed 24/7.
The vulnerable people that depend on us deserve no less. However, because we are providing essential services during the crisis, People
Inc. has incurred highly unusual increased costs in staffing, PPE, and cleaning services.
Since we are not eligible for the Payroll Protection Program (PPP) due to our size and we must remain fully operational, we request that the
Cferguson@ Mid-Size Loan Program have provisions to convert to a forgivable loan for nonprofits that face staggering losses due to COVID-19. This would
4/15/2020 8:28:00 people- grant us the same protections as PPP.
AM PIO (Email from Ferguson Concetta inc.org People Inc
As one of 4,000 employees of a regional non-profit health and human services agency that provides programs and services to nearly 10,000
people with intellectual and developmental disabilities, special needs, their families and older adults throughout numerous counties in Western
New York and the Greater Rochester region, I am writing today to inform you that our agency, People Inc., is fully engaged in dealing with the
COVID-19 crisis. We must ensure that our homes and services for people with disabilities remain as safe as possible and are staffed 24/7.
The vulnerable people that depend on us deserve no less. However, because we are providing essential services during the crisis, People
Inc. has incurred highly unusual increased costs in staffing, PPE, and cleaning services.
Since we are not eligible for the Payroll Protection Program (PPP) due to our size and we must remain fully operational, we request that the
Mid-Size Loan Program have provisions to convert to a forgivable loan for nonprofits that face staggering losses due to COVID-19. This would
grant us the same protections as PPP.
alicia.james
4/15/2020 8:28:00 @people- Thank you in advance for your support of direct care staff, the people we support and our agency, People Inc.
AM PIO (Email from James Alicia inc.org People Inc
Page 87 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
I strongly urge you to provide a loan forgiveness component to nonprofits in the Main Street Lending funding. As a mother of one child
receiving services, and another employed by one of the agencies impacted by this loan, I see firsthand how impacted these organizations are.
Like small nonprofits, these larger nonprofits are faced with the same challenges of operating in the midst of coronavirus. Our communities
rely on these organizations and their expenses have actually gone up dramatically as they strive to keep everyone safe while they continue to
Personal serve vulnerable populations. Many of these larger nonprofits operate group homes and support people with disabilities. Their needs are no
4/15/2020 8:29:00 Email Program Savvy different than the smaller nonprofits. The work they do is essential and the need for loan forgiveness is strong.
AM PIO (Email from Debus Mary Beth Address Consulting
cynthia@Phil Please consider nonprofits and CDFI's as they are the conduit to lending in revitalizing small communities.
4/15/2020 8:38:00 anthropydela Philanthropy
AM PIO (Email from Pritchard Cynthia ware.org Delaware
Personal Email Nonprofits need to be included in the Main Street Lending plan.
4/15/2020 8:40:00 Address
AM PIO (Email from Norton Colleen
As one of 4,000 employees of a regional non-profit health and human services agency that provides programs and services to nearly 10,000
people with intellectual and developmental disabilities, special needs, their families and older adults throughout numerous counties in Western
New York and the Greater Rochester region, I am writing today to inform you that our agency, People Inc., is fully engaged in dealing with the
COVID-19 crisis. We must ensure that our homes and services for people with disabilities remain as safe as possible and are staffed 24/7.
The vulnerable people that depend on us deserve no less. However, because we are providing essential services during the crisis, People
Inc. has incurred highly unusual increased costs in staffing, PPE, and cleaning services.
Since we are not eligible for the Payroll Protection Program (PPP) due to our size and we must remain fully operational, we request that the
Mid-Size Loan Program have provisions to convert to a forgivable loan for nonprofits that face staggering losses due to COVID-19. This would
grant us the same protections as PPP.
4/15/2020 8:42:00 rfrederick@p Thank you in advance for your support of direct care staff, the people we support and our agency, People Inc.
AM PIO (Email from Frederick Rhonda eople-inc.org People Inc.
Please ensure nonprofits are explicitly named as eligible recipients of the Main Street Lending program. Please also ensure that nonprofit
employers with between 500 and 10,000 employees are able to access the loans.Please also consider loan forgiveness for nonprofits, similar
to the PPP, to eliminate the burden of repayment in these uncertain times.
Our communities need nonprofits like the Y now more than ever. The CARES Act was a first step toward supporting nonprofits through the
economic crisis stemming from the COVID-19 pandemic, but more help is needed. Without additional resources, many nonprofit
organizations will be lost to their communities, including YMCAs.
The YMCA of Central Ohio employed 2,000 full and part time staff prior to the COVID-19 pandemic and have had to lay off 85% of our staff.
We were not able to apply for the PPP because of our size.
Without access to support, our Y will not be able to provide the critical services to our community like serving the homeless and providing
childcare to thousands of Central Ohio families.
Despite our facilities being closed, the YMCA of Central Ohio is providing emergency homeless shelters including 2 quarantine shelters,
Tony.Collins pandemic childcare centers and community support services like food distribution sites.
4/15/2020 8:47:00 @YMCAColu YMCA of Central Our Y, along with others, are committed to serving our communities throughout this pandemic and beyond. Please help us ensure that we
AM PIO (Email from Collins Tony mbus.Org Ohio have the resources necessary to support the communities we serve.
Nonprofit organization takes any profits it receives from goods, services, donations, or sponsorships, and cycles them back into the
organization to further achieve its mission. The Westchester Public/Private Partnership for Aging Services (PPP) is one of those
organizations.
For over 25 years, the PPP has enhanced the quality of life for thousands of seniors and their caregivers, through the implementation of
unique programs that are evidence-based or evidence-informed. Without these programs supported by the PPP, Westchester residents
might not find life as interesting as they do with them.
Typically, the ultimate goal of a non-profit is to serve communities (clubs, churches, associations, chambers of commerce, etc.), or are
organized around social causes (humanitarian aid, disease research, education funding, etc.).
In the coming weeks and months, nonprofit organizations will be embedded in a larger expression of mutual support, empathy, and solidarity,
Westchester and as the country deals with ever-greater personal loss and stress, charitable organizations like the PPP become increasingly important
mmm0@west Public/Private vehicles for assistance. All of us will need help, and all of us will need to do our best to provide help to others. Include nonprofits in the
4/15/2020 8:49:00 chestergov.c Partnership for "Main Street" Lending program!
AM PIO (Email from Carpenter Mae om Aging Services Source for a portion of this information: https : //hbr.org/2020/04/nonprofit-fundraising-in-the-age-of-coronavirus
Page 88 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
Please expand the Main Street Loan program to include non-profit organizations. Non-profits provide a vital role in our communities and
4/15/2020 8:55:00 tham@advan Advancing Sight typically do not have revenue streams to sustain them. Non-profits rely heavily on contributions and with the state of the economy, it may take
AM PIO (Email from Ham Teresa cingsight.org Network some time for donations to return to normal levels.
I am writing to advocate for consideration to be given to nonprofits, including trade associations, that have been thus far unable to access
International many of the programs offered in response to the COVID-19 crisis - particularly the Paycheck Protection Program. Trade associations, like the
4/15/2020 8:59:00 ewulf@carwa Carwash travel and hospitality industries, are highly reliant on people's ability to travel, and should be afforded the same opportunities as other
AM PIO (Email from Wulf Eric sh.org Association industries similarly affected. Thank you.
"As a non-profit organization that does not meet the size requirements under the Paycheck Protection Program and has more that 500
4/15/2020 9:26:00 Cdelatorre@ Acacia network employees, it would be helpful the Main Street Loan Program to have a forgiveness provision - similar to PPP. Additionally, Fees/origination
AM PIO (Email from De La Torre Caridad basicsinc.org housing points should be waived for qualifying non-profit organizations. Thank you."
Please include 501c6 nonprofit organizations in this program. These organizations are not eligible for the payment protection program and,
therefore, desperately need this program. 501c6 nonprofit organizations support just about every single profession out there (including
healthcare professions) with education, certifications, and additional development. We also support travel, meeting and tourist industries
aschnepf@le through our large and small annual meetings. By excluding us from this lending program, you hinder our ability to support these professions
4/15/2020 9:33:00 adingageil.or LeadingAge and the other industries severely impacted by COVID-19. Such elimination could have a further devastating impact on all of the professions
AM PIO (Email from Schnepf Angela g Illinois and industries we support.
The YMCA of Greater Kansas City was not able to apply for the Paycheck Protection Program because of our size. Please also
consider loan forgiveness for nonprofits, similar to the Paycheck Protection Program, to eliminate the burden of repayment in these uncertain
times. Without additional resources, many nonprofit organizations will be lost to their communities, including YMCAs. Our communities
Personal need nonprofits like the Y now more than ever. Despite our facilities being closed, the Y has been providing essential child care services for
4/15/2020 9:38:00 Email YMCA of Greater healthcare workers, first responders and other essential services.  Without access to support, our Y will not be able to resume
AM PIO (Email from Mikos John Address Kansas City operations as we knew it or retain our staff.
In support of the 4,000 employees of a regional non-profit health and human services agency that provides programs and services to nearly
10,000 people with intellectual and developmental disabilities, special needs, their families and older adults throughout numerous counties in
Western New York and the Greater Rochester region, I am writing today to inform you that People Inc. is fully engaged in dealing with the
Personal
COVID-19 crisis. They must ensure that more than 150 community-based homes and services for people with disabilities remain as safe as
Email Address
possible and are staffed 24/7. The vulnerable people that depend on People Inc. deserve no less. However, because they are providing
4/15/2020 9:39:00 essential services during the crisis, People Inc. has incurred highly unusual increased costs in staffing, PPE, and cleaning services.
AM PIO (Email from Dupre Michelle
Personal Email Please include nonprofits in the Main Street Lending program! Hospitals, mental health services and more are CRUCIAL right now and we
4/15/2020 9:41:00 Address cannot afford for them to lose critical funding right now.
AM PIO (Email from Berman Joelle
Please make this facility available to farms employing less than 10,000 employees also. As a farmer, I have suffered economic injury
Personal resulting from COVID-19 but I am not eligible for an EIDL through SBA because farmers are ineligible for relief through SBA. We have
Email suffered because we exported walnuts to Italy which have sat at the port due to the country being on lockdown. The market for walnuts has
4/15/2020 9:42:00 Address Sukhraj Pamma declined significantly as a result. I appreciate the thought that has been put into this tremendous program, I just ask that farms be included as
AM PIO (Email from Pamma Sukhraj Farms an eligible borrower. Thank you and stay healthy.
The YMCA of Greater Kansas City was not able to apply for the Paycheck Protection Program because of our size. Please also consider loan
forgiveness for nonprofits, similar to the Paycheck Protection Program, to eliminate the burden of repayment in these uncertain times.
Without additional resources, many nonprofit organizations will be lost to their communities, including YMCAs. Our communities need
jillhammond nonprofits like the Y now more than ever. Despite our facilities being closed, the Y has been providing essential child care services for
4/15/2020 9:43:00 @kansascity YMCA of Greater healthcare workers, first responders and other essential services. Without access to support, our Y will not be able to resume operations as
AM PIO (Email from Hammond Jill ymca.org Kansas City we knew it or retain our staff.
4/15/2020 9:43:00 Personal Email It is essential to include medium/large not-for-profits in the Main Street Lending program. Please revise your rules/guidance so that they can
AM PIO (Email from Chatzky Jean Address keep their doors open as well.
4/15/2020 9:47:00 Personal Email Please include nonprofits in the "Main Street" lending program. Their wellbeing is crucial to all communitues. Thank you
Address
AM PIO (Email from Pesce Donna
The YMCA of Greater Kansas City was not able to apply for the Paycheck Protection Program because of our size. Please also consider loan
forgiveness for nonprofits, similar to the Paycheck Protection Program, to eliminate the burden of repayment in these uncertain times.
Without additional resources, many nonprofit organizations will be lost to their communities, including YMCAs. Our communities need
johnnyb@bar Baron nonprofits like the Y now more than ever. Despite our facilities being closed, the Y has been providing essential child care services for
4/15/2020 9:48:00 oncontracting Contracting healthcare workers, first responders and other essential services. Without access to support, our Y will not be able to resume operations as
AM PIO (Email from Bakarich John .com Corporation we knew it or retain our staff.
Page 89 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
The Federal reserve is discussing $600 billion in bank lending to small and mid-sized businesses. Currently institutions of higher learning are
not included in the current provisions. Public higher education institutions are also ineligible for the Paycheck Protection Program. The
4/15/2020 9:54:00 sdillard@mon University of COVID 19 pandemic has hit higher education particularly hard. I ask that you please add public higher education institutions to the
AM PIO (Email from Dillard Scott tevallo.edu Montevallo "Main Street" lending facility.
I am writing to extend my support in saying to the Federal Reserve that they should include Main Street Lending Program in receiving the
Personal necessary funds to help in this current crisis. A host of non-profits, including, but not limited too, hospitals, mental health hot lines, food banks
4/15/2020 9:56:00 Email Address are the scaffolds that support the essential functions of our society. PLEASE PROVIDE NECESSARY FUNDING!!
AM PIO (Email from karsten liza
The hotel industry is being decimated by Covid-19. Hotels are closed, in many cases due to mandated stay-at-home orders. Most hotels that
are open are running at negative cash flow. The SBA PPP program in CARES ACT is not a solution for hotel owners since it requires hotels to
hire workers at a time when there are no guests. Many expect that it will take a very long time for the hotel industry to recover - possibly
years. The Fed must step in an provide a comprehensive long term solution involving: (i) a complete refinancing opportunity provided by Fed
for the $300 billion of hotel loans; (ii) no interest for the first 2 years, 2% thereafter; (iii) ten year term for repayment. Lodging is estimated to
be one of the largest contributors to the US economy and is an essential business that must be saved. Currently, lenders are not being
cooperative in granting enough forbearance. Hotel owners need more than a bandaid. They need immediate financial help. This is an
economic crisis like no other. Hotel owners must survive to bring their workers back. A massive number of foreclosures resulting from
defaulted hotel loans will be detrimental to the labor force and the economy. Thousands of hotel owners risk losing, at no fault of their own
4/15/2020 9:56:00 dkessler@as Ashford due to this pandemic, the American Dream that they have worked so hard to achieve.
AM PIO (Email from Kessler Douglas hfordinc.com Hospitality Trust
steve@work Please include non-profits in the Main Street Lending program. Thank you.
4/15/2020 9:58:00 withyourbrain
AM PIO (Email from Samuels Steve .com
Please ensure nonprofits are explicitly named as eligible recipients of the Main Street Lending program. Please also ensure that nonprofit
employers with between 500 and 10,000 employees are able to access the loans and consider loan forgiveness for nonprofits, similar to the
Paycheck Protection Program. Without additional resources, many YMCAs and nonprofit organizations will be lost to their communities.The
YMCA of the Suncoast employed 1304 full and part time staff prior to the pandemic and have had to furlough over 1200 of our staff. We were
not able to apply for the Paycheck Protection Program because of our size. Without access to support, our Y will not be able to resume
operations as we knew it or retain our staff. Including larger organizations would ensure that we can continue to provide urgently needed
services for their neighbors. Our two main sources of revenue are membership fees and program fees related to child care. With the closing
of our membership facilities and schools closing, we no longer are generating enough revenue to remain viable. We project that we could
loose as much as $2.5 million dollars this calendar year as a result. Despite our facilities being closed, we have shifted to offer youth relief
child care for essential workers. We are offering food to those in our community in need and conducting blood drives. Please help us ensure
4/15/2020 9:59:00 sgoyer@sunc YMCA of the that we have the resources necessary to support our neighbors and our staff.
AM PIO (Email from Goyer Scott oastymca.org Suncoast
The YMCA of Greater Kansas City was not able to apply for the Paycheck Protection Program because their employee count is too large.
Please also consider loan forgiveness for nonprofits, similar to the Paycheck Protection Program, to eliminate the burden of repayment in
these uncertain times. Without additional resources, many nonprofit organizations will be lost to their communities, including YMCAs. Our
Kansas State communities need nonprofits like the Y now more than ever. Despite the Y's facilities being closed, the Y has been providing essential
4/15/2020 jbruning@ksy Alliance of child care services for healthcare workers, first responders and other essential services. Without access to support, our Y will not be able to
10:02:00 AM PIO (Email from Bruning Jennifer mca.org YMCAs resume operations as we knew it or retain our staff.
4/15/2020 dricard@mar Marolina Under the Main St New Loan Facility program, there is an earnings test. If we have negative EBITDA in 2019, can we apply for this loan?
12:00:00 AM PIO (Email from Ricard Rhett olina.com Outdoors
Personal The Federal reserve is discussing $600 billion in bank lending to small and mid-sized businesses. Currently institutions of higher learning are
Email Address not included in the current provisions. Public higher education institutions are also ineligible for the Paycheck Protection Program. The
4/15/2020 University of COVID 19 pandemic has hit higher education particularly hard. I ask that you please add public higher education institutions to the
10:05:00 AM PIO (Email from Dahle Tammi Montevallo "Main Street" lending facility.
Personal It is imperative that you include relief for non-profits in the Main Street lending program. We provide a tremendous and varied amount of
4/15/2020 Email Address Jewish teen services to our communities and if we do not survive it will take many years to rebuild what will have been lost to our economy.
10:06:00 AM PIO (Email from Cohen Michele initiative
ekocovic@ac As a non-profit organization that does not meet the size requirements under the Paycheck Protection Program and has more that 500
4/15/2020 acianetwork. employees, it would be helpful the Main Street Loan Program to have a forgiveness provision - similar to PPP. Additionally, Fees/origination
10:11:00 AM PIO (Email from Kocovic Eddie org Acacia Network points should be waived for qualifying non-profit organizations. Thank you
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Main Street Lending Program Comments
Can the Federal Reserve please provide clarification on the linkage between the Cares Act requirements and the Federal Reserve term
sheets? The Federal Reserve Term Sheets do not specifically reference restrictions under 4003(c)(3)(D)(i). The CARES Act provides that the
Secretary shall endeavor to establish a loan program under 4003(c)(3)(D)(i) for mid-sized business with 500-10,000 employees and lays out
requirements.
In the following subparagraph, it separately gives the Federal Reserve the ability to create a MSLP for small and mid-sized businesses (0-
10,000 employees) on such terms and conditions as the Board may set consistent with section 13(3) of the Federal Reserve Act.
The Federal Reserve terms sheets do state there may be restrictions required by applicable statutes and regulations, but there is no specific
4/15/2020 kathleen.sifer Grant Thornton reference to the restrictions under 4003(c)(3)(D)(i).
10:12:00 AM PIO (Email from Sifer Kathleen @us.gt.com LLC
Please include non-profits in the Main Street Lending Program. I work for a non- profit summer camp. We provide education for children and
Personal jobs for young adults in the summer and jobs for about 8 people year round. If we are not able to open in July and August, our main source of
4/15/2020 Email Address Camp Solomon revenue for the whole year will be gone. The camp is 65 years old and is treasured by the community. Please help keep it going strong.
10:12:00 AM PIO (Email from Chivo Julie Schechter
I am very concerned and disheartened to hear you are considering excluding nonprofits from relief packages right now. Like other small and
medium businesses, we contribute directly to the economy through job creation and increasing the GDP. Not only that, but our missions
directly improve the communities we live in, providing homelessness services, education, food, support services, or in my case: access to
critical nature, parks, and trails (the importance of which COVID is clearly demonstrating!).
Personal Washington
Email Address Wildlife & There's no reason nonprofits should be excluded from a relief program like this, especially in the midst of a crisis. Proposals like this not
4/15/2020 Recreation only threaten to close Nonprofit businesses and put our staff onto unemployment, but they threaten all our communities that rely so very much
10:17:00 AM PIO (Email from Mahler Christine Coalition on the work of these nonprofits. Please put our communities first.
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
Personal hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/15/2020 Email Address Momentum for eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
10:17:00 AM PIO (Email from Butti Jeannette Mental Health
The Federal reserve is discussing $600 billion in bank lending to small and mid-sized businesses. Currently institutions of higher learning are
not included in the current provisions. Public higher education institutions are also ineligible for the Paycheck Protection Program. The
4/15/2020 Jgordon6@m University of COVID 19 pandemic has hit higher education particularly hard. I ask that you please add public higher education institutions to the
10:20:00 AM PIO (Email from Gordon Jacob ontevallo.edu Montevallo "Main Street" lending facility.
This needs to be open and supportive to mid-sized companies as well as smaller companies.
4/15/2020 Lcoleman@b
10:22:00 AM PIO (Email from Coleman Lorraine asicsinc.org Acacia Network
"The Federal reserve is discussing $600 billion in bank lending to small and mid-sized businesses. Currently institutions of higher
learning are not included in the current provisions. Public higher education institutions are also ineligible for the Paycheck Protection
4/15/2020 whallman@m University of Program. The COVID 19 pandemic has hit higher education particularly hard. I ask that you please add public higher education institutions to
10:23:00 AM PIO (Email from Hallman Wesley ontevallo.edu Montevallo the "Main Street" lending facility."
Across the United States nonprofit organizations are providing a wide array of critical services to people suffering from COVID19, to front line
workers of all kinds, and to families coping with the reality of job losses, depletion of savings, inability to pay for food and shelter, and the
Personal emotional toll that the pandemic and resulting economic depression are causing. Given the core role nonprofits are playing within their
4/15/2020 Email Address communities, it is imperative that nonprofit organizations be specifically included in the Main Street Lending Program.
10:24:00 AM PIO (Email from Holohean MaryAnn
4/15/2020 jean.p.durr@f this is a test
10:25:00 AM PIO (Email from Durr Jean rb.gov
As a non-profit organization that does not meet the size requirements under the Paycheck Protection Program and has more that 500
4/15/2020 alejandro@loi employees, it would be helpful the Main Street Loan Program to have a forgiveness provision - similar to PPP. Additionally, Fees/origination
10:25:00 AM PIO (Email from Torres Alejandro E. saida.org Loisaida Inc. points should be waived for qualifying non-profit organizations. Thank you.
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Main Street Lending Program Comments
Personal Email
4/15/2020 Address Please include nonprofit organizations in the Federal Reserve's "Main Street" lending program. They are essential to
10:26:00 AM PIO (Email from Dimock Anne providing essential services and recovery from the Covid-19 pandemic.
The YMCA of Greater Kansas City was not able to apply for the Paycheck Protection Program because of our size. Please also consider loan
forgiveness for nonprofits, similar to the Paycheck Protection Program, to eliminate the burden of repayment in these uncertain times.
Without additional resources, many nonprofit organizations will be lost to their communities, including YMCAs. Our communities need
Wyandotte nonprofits like the Y now more than ever. Despite our facilities being closed, the Y has been providing essential child care services for
4/15/2020 dash@wycos County Sheriff's healthcare workers, first responders and other essential services. Without access to support, our Y will not be able to resume operations as
10:26:00 AM PIO (Email from Ash Donald heriff.org Office we knew it or retain our staff.
Navistar is a publicly traded (NYSE: NAV) international manufacturer of International® brand commercial trucks, proprietary diesel
engines, IC BusT ("IC") brand school and commercial buses, as well as a provider of service parts for trucks and diesel engines.
We also provide retail, wholesale and lease financing services for our trucks and parts. Navistar employs approximately 13,000 individuals,
had revenues Confidential Business Information As a manufacturer of commercial, over-the-
road trucks, our operations are vital to supporting the country's increasingly stressed supply chain and as such we have been building
and selling trucks to continue to support the movement of critical lifesaving and life-sustaining medicine, food, and other essential items to
hospitals, first responders, and the general public. To this extent, Navistar has been identified as a critical or essential business per the
Department of Homeland Security's CISA guidance and the various State issued stay-in-place orders. Navistar is concerned that it is
jacqueline.gel not covered under the existing facilities provided under the CARES Act and urges the Treasury department to expand facilities to support
4/15/2020 b@navistar.c identified essential businesses that are non-investment grade companies with employees over 10,000 and revenue higher than $2B like
10:26:00 AM PIO (Email from Gelb Jacqueline om Navistar, Inc. Navistar.
jpedrosa@ac As a non-profit organization that does not meet the size requirements under the Paycheck Protection Program and has more that 500
4/15/2020 acianetwork. employees, it would be helpful the Main Street Loan Program to have a forgiveness provision - similar to PPP. Additionally, Fees/origination
10:27:00 AM PIO (Email from Pedrosa, Jr. Jesus org Acacia Network points should be waived for qualifying non-profit organizations. Thank you."
FDelossantos As a non-profit organization that does not meet the size requirements under the Paycheck Protection Program and has more that 500
4/15/2020 @acacianetw Acacia Network employees, it would be helpful the Main Street Loan Program to have a forgiveness provision - similar to PPP. Additionally, Fees/origination
10:28:00 AM PIO (Email from De Los SantosFelipe ork.org Inc. points should be waived for qualifying non-profit organizations. Thank you.
arwood@mill Is a non-profit (501) c-3 with greater than 500 employees eligible for the Main Street Lending Program?
4/15/2020 ercanfield.co Milier Canfield
10:29:00 AM PIO (Email from Arwood Steve m Consulting
hbowman@hi I would like to know which banks are participating in the program. Our bank is not participating and I need to find a bank that is.
4/15/2020 llairoilandgas. American
10:30:00 AM PIO (Email from Bowman Heidi com Natural Energy
The YMCA of Greater Kansas City was not able to apply for the Paycheck Protection Program because of our size. Please also consider loan
forgiveness for nonprofits, similar to the Paycheck Protection Program, to eliminate the burden of repayment in these uncertain times.
Without additional resources, many nonprofit organizations will be lost to their communities, including YMCAs. Our communities need
AndreaToney nonprofits like the Y now more than ever. Despite our facilities being closed, the Y has been providing essential child care services for
4/15/2020 @KansasCity YMCA of Greater healthcare workers, first responders and other essential services. Without access to support, our Y will not be able to resume operations as
10:31:00 AM PIO (Email from Toney Andrea YMCA.org Kansas City we knew it or retain our staff.
Thank you for supporting businesses with the two Main Street loan programs. It is unclear if nonprofits are included for eligibility for the
dmurray- Michigan program. Nonprofits were included in the Federal PPP programs and this program would be very meaningful for nonprofits with more than
4/15/2020 brown@mna Nonprofit 500 employees. Could you please confirm if eligible borrowers under the programs include nonprofits? Many thanks for your time and
10:33:00 AM PIO (Email from Murray-Brown Donna online.org Association consideration.
Please include 501(c)3 nonprofits in the COVID-19 CARES Act relief package. This pandemic has severely limited our fundraising
opportunities as we have cancelled two major fundraising events. Additionally, typical annual funding from the Alabama Department of Mental
Health for many of our programs is at risk as our state battles the pandemic. Alabama is a non-Medicaid expansion state, and our billing
options were already limited due to that. With the cancellation of many of our group therapy and group skills-building classes, we are unable
to bill Medicaid for these services offered to Medicaid-covered client/participants.
The CARES Act was initially presented as quick relief for non-profits, and it is desperately needed for our AIDS Service Organization (ASO)
located in the Deep South to continue our strong program offerings. Without this relief funding from the CARES Act, our agency and many
caroline.bund other ASOs will not be able to continue services, which could lead to an increase in HIV/AIDS cases in the Deep South, where the epidemic
4/15/2020 y@aidsalaba AIDS Alabama, currently is at its highest.
10:33:00 AM PIO (Email from Bundy Caroline ma.org Inc. Thank you.
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Main Street Lending Program Comments
I am disillusioned that the Fed has not included non-profits in its Main Street rescue program.
This seems pennywise and pound foolish as non-profits are shoring up Americans during this very difficult time and certainly need help. Non-
profits fill in where government leaves holes.
Personal
I hope you will correct this oversight.
Email
4/15/2020 Address Respectfully submitted,
10:33:00 AM PIO (Email from Schwarz Susan Susan Schwarz
The YMCA of Greater Kansas City was not able to apply for the Paycheck Protection Program because of our size. Please also consider loan
forgiveness for nonprofits, similar to the Paycheck Protection Program, to eliminate the burden of repayment in these uncertain times.
Without additional resources, many nonprofit organizations will be lost to their communities, including YMCAs. Our communities need
nonprofits like the Y now more than ever. Despite our facilities being closed, the Y has been providing essential child care services for
Personal healthcare workers, first responders and other essential services. Without access to support, our Y will not be able to resume operations as
Email Address we knew it or retain our staff.
4/15/2020 YMCA of Greater
10:34:00 AM PIO (Email from Snider Rachael Kansas City If the YMCA does not survive this, there will be many negative community health effects. Please consider us.
I just applied for a PPP loan and am concerned about receiving the help I need to keep my employees pain and business open, much as I
imagine other companies like me are. I am in my second year of business, and now have 2 employees, and my payroll in the first quarter of
this year is almost the same as my payroll was for the entire year of 2019. When applying, I was told to take the average payroll over a long
period of time and average a monthly amount that way, to determine the loan amount. Obviously, doing so would not help cover my current
payroll costs AT ALL. Business has increased a lot lately as I've added employees to accomplish more of the demand in our area. Also,
there is a line on the application asking if we are on a registry with the SBA, and that is something I didn't even know existed until we
filled out the application. Is that a requirement too? Are the small businesses, like me, going to be left in the dust in this program? Please
consider our needs too!
Personal
Email Also, what about the income needs of a sole proprietor like myself? I don't get a "paycheck."
4/15/2020 Address Interior Finish
10:35:00 AM PIO (Email from Holcomb Michael Carpentry Thanks.
The US creative economy, comprised of both nonprofit and for profit corporations, is $878 billion or 4.5% of the US economy, responsible for
10 million jobs, and an annual $25 billion trade surplus. The value added by arts, culture and creativity to the U.S. economy significantly
exceeds that of the construction industry, the transportation industry -- and is five times greater than the value from the agricultural sector.
Social distancing and sheltering in place in response to the current health crisis has cost the creative economy thousands of jobs and millions
in earned revenue -- and the economic downturn has significantly shrunk the endowments of America's cultural institutions which
previously totaled more than $58 billion.
For profit and nonprofit corporations work across 145 industries that comprise the creative economy including architecture, AR/VR, art
galleries, fashion, film/TV, food, graphic design, industrial design, jewelry, literature, music, photography, theater, toys, and video games.
LauraCallana These for profit and nonprofit corporations must be fully eligible to participate in all economic relief efforts mounted in response to the
4/15/2020 n@UpstartCo- economic crisis triggered by COVID19, include the Main Street Lending Program of the Federal Reserve.
10:37:00 AM PIO (Email from Callanan Laura Lab.org Upstart Co-Lab
Nonprofit health care providers are bearing the brunt of this crisis and deserve to be included in programs designed to get our economy back
CHOICES. on track. Even our small health clinic employs more than 30 people full time. Don't exclude our profession or our workers - they and
rterrell@mem Memphis Center their families need help also.
4/15/2020 phischoices.o for Reproductive
10:44:00 AM PIO (Email from Terrell Rebecca rg Health
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Main Street Lending Program Comments
Comment on Concerning Provision in the Coronavirus Economic Stabilization Act of 2020
F. Vincent Vernuccio, Senior fellow, Mackinac Center for Public Policy
Employees deserve to hear from their employers during unionization campaigns, and employers need flexibility to protect their employees
during and after the COVID-19 crisis.
Subsections (3) (D) (IX) and (X) of Sec. 4003 of the Coronavirus Economic Stabilization Act of 2020 require mid-sized businesses (employers
with 500 to 10,000 employees) taking loans under the section to make a good faith certification that they "will not abrogate existing
collective bargaining agreements for the term of the loan and 2 years after completing repayment." It also requires that employers
without unions "remain neutral in any union organizing effort for the term of the loan."
These provisions have nothing to do with protecting the health of employees or the economic stability of workers and their mid-sized
employers.
Further, the neutrality provision may infringe on the First Amendment rights of employers to speak about unionization, as well as 29 U.S.
Code §?158 (c), which protects an employer's "expression of views" on unionization.
vinnie@vernu The Federal Reserve should interpret these provisions narrowly to ensure that an employer's freedom of speech is protected and that
4/15/2020 cciostrategies Mackinac Center employees have a right to make a fully informed decision on unionization, as well as ensuring employer flexibly to the full extent of the law.
10:44:00 AM PIO (Email from Vernuccio F. Vincent .com for Public Policy
4/15/2020 staff@repme We urge you to include non profits in this program as they provide vital services to communities and employ millions of people.
10:48:00 AM PIO (Email from Babb Sara mphis.org
I urge the FED to expand its "Main Street" lending program to include non-profit organizations, institutions of higher learning, and
minority-serving institutions. These front-line organizations are working diligently during this pandemic to meet the needs of our most
jen@provide Providence vulnerable community members. Non-profit funding is a constant challenge. In expanding the "Main Street" lending program to
4/15/2020 ncecityarts.or ¡CityArts! these organizations, the FED will help to ensure the continuance of their life-saving and live-giving work.
10:50:00 AM PIO (Email from Vincent Jennifer g for Youth
frances@met I strongly encourage you to include nonprofits in the Main Street Lending Program. Nonprofits in every community face difficult times now, and
4/15/2020 almuseum.or in the future, as both beneficiaries and donors evaluate their financial standing. Now, more than ever, nonprofits need assistance from the
10:50:00 AM PIO (Email from Tortorich Frances g Metal Museum federal government. I appreciate your consideration of this request.
Personal Email You must include medium and large nonprofits in the Main Street Lending Program as they are needed to help communities survive and
4/15/2020 Address recovery from the Covid-19 pandemic.
10:51:00 AM PIO (Email from Bradbury Margaret
1.Clarify the full eligibility criteria for smaller businesses seeking all types of Small Business Administration (SBA) and/or Main Street
Lending Program financial relief: We understand that smaller businesses seeking temporary SBA financial assistance through the Paycheck
Protection Program (PPP) are also eligible to pursue further financial support through the Main Street Lending Program.
a.We applaud the Federal Reserve for ensuring that smaller businesses are not excluded from this additional loan program.
b.However, we urge the Federal Reserve, in consultation with the Department of Treasury and the SBA, to categorically clarify if smaller
businesses seeking assistance through the SBA's Economic Injury Disaster Loan (EIDL) program would also be eligible to apply to the
Main Street Lending Program since many medical practices are pursuing both loan options offered by or through the SBA-EIDL and PPP.
c.Advanced clarification ensures that small businesses are informed and able to take on reasonable relief while avoiding crushing debt
burdens.
4/15/2020 wbrady@aad
10:51:00 AM PIO (Email from BRADY WILLIAM .org AADA
I write to ask that nonprofit agencies be included in the Main Street Lending program. These agencies provide critical services from food to
Personal
education to arts that will be necessary both before and after the coronavirus pandemic is over. If they cannot survive the pandemic for lack
Email Address
4/15/2020 of funds, their long-term viability will be threatened and they will be unable to carry on their important work. Thank you.
10:53:00 AM PIO (Email from Fine Amy Free-lance
Personal You must include medium and large nonprofits in the Main Street Lending Program as they are needed to help communities such as mine in
4/15/2020 Email Dobbs Ferry, New York survive and recover from the Covid-19 pandemic. They fill in the gaps and help in ways that are crucial
10:53:00 AM PIO (Email from Ascher Shari Address
4/15/2020 Personal Email You must include medium and large nonprofits in the Main Street Lending Program as they are needed to help communities survive and
Address
10:54:00 AM PIO (Email from Porder Deborah (None) recover from the Covid-19 pandemic.
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Main Street Lending Program Comments
The Gateway Region YMCA in St Louis employed approximately 4000 staff prior to the COVID-19 pandemic and have had to furlough almost
3900 of them. We aren't able to apply for the Payroll Protection Program due to our size and need help. Including larger organizations
will ensure that we can continue to provide much needed community support and programming during the pandemic and beyond. The
CARES Act was a first step toward supporting nonprofits through the economic crisis stemming from the COVID-19 pandemic, but more help
4/15/2020 tim.helm@gw Gateway Region is needed for larger not for profit organizations like the YMCA. Thank you for your consideration
10:54:00 AM PIO (Email from Helm Tim rymca.org YMCA
2.As smaller businesses, exercising various loan options, may be saddled by unsustainable debt obligations, we urge the Federal Reserve
to consider relaxing the following Main Street Lending Program terms and conditions through targeted exemptions for smaller business:
a.Longer repayment schedule: extend repayment beyond the current four years with a one-year deferral to provide a more affordable time
table for smaller businesses.
b.Lower loan rate: reduce Main Street Lending Program's rate of loan from 2.5% - 4.0% for smaller businesses to align closer with the
1% offered by the SBA's PPP option.
c.Lenders should not discriminate against smaller business: remind lenders to avoid discriminatory protocols that may involve privileging
and preferring mid-sized business clients to the detriment of smaller businesses.
3.Provide clear, concise and timely instructions and guidance to lenders to guarantee that prospective loans to smaller business borrowers
are not delayed.
a.As smaller businesses face survival decisions, it is urgent that lenders are fully equipped to advise borrowers on all the applicable terms,
conditions, exemptions and exclusions afforded by the Main Street Lending Program.
4/15/2020 wbrady@aad b.This will enable small business medical practice owners to continue to contribute to the health of the national economy.
10:54:00 AM PIO (Email from BRADY WILLIAM .org AADA
tmartini@goo Due to the COVID-19 shutdown, our 97-year-old non-profit agency is near bankruptcy and the Main Street Lending Program would provide
4/15/2020 dwillmemphis Memphis much-needed cash critical to our survival. It is unfair and wrong-headed to exclude large non-profits from this program. I implore Congress to
10:54:00 AM PIO (Email from Martini Tony .org Goodwill, Inc. reconsider its position on this matter.
The YMCA of Greater Kansas City was not able to apply for the Paycheck Protection Program because of our size. Please also consider loan
forgiveness for nonprofits, similar to the Paycheck Protection Program, to eliminate the burden of repayment in these uncertain times.
Without additional resources, many nonprofit organizations will be lost to their communities, including YMCAs. Our communities need
nonprofits like the Y now more than ever. Despite our facilities being closed, the Y has been providing essential child care services for
Personal Email healthcare workers, first responders and other essential services. Without access to support, our Y will not be able to resume operations as
4/15/2020 Address YMCA of Greater we knew it or retain our staff. We have been served the Kansas City community for 160 years and provide essential support to many people.
10:56:00 AM PIO (Email from Grassi Kelley Kansas City
It's come to my attention that the Main Street Lending program does not include non-profit organizations, which are exactly the service
Personal businesses that we need most during this pandemic, and the businesses that we will continue to rely on. The Main Street Lending program
4/15/2020 Email Address must be reconfigured to include small- to medium-sized non-profits organizations.
10:57:00 AM PIO (Email from Livenstein Barbara Thank you.
Excluding nonprofits, institutions of higher learning, HBCUs, and Minority-Serving Institutions in the "Main Street" lending program
is not only a huge mistake but a Financial Disaster in the Making. As the President has pointed out repeatedly in his statements to the public,
small business, which includes non-profits and all of the above, make up about one half of all the economy in the US. While the P.P.P.
loans/grants were a step in the right direction, it will not be enough to keep many of these facilities operating throughout the Pandemic. If we
cmorse@frie Friendship Adult lose these, they may never come back, and it will strike at the very heart of the economy and in all communities across the nation. Vital
4/15/2020 ndshipadultd Day Services, services to the elderly, disabled, minorities and the poor may be lost forever, putting a bigger burden on us all. We are part of "Main
10:57:00 AM PIO (Email from Morse Connie ay.com Inc Street".
It is essential that you include medium and large nonprofits in the Main Street Lending Program as they are needed to help communities such
Personal
4/15/2020 as mine in Westchester County, New York to survive and recover from the Covid-19 pandemic so they can continue to provide essential
Email Address
10:58:00 AM PIO (Email from Wharton Philippa social services.
The Federal Reserve is discussing $600 billion in bank lending to small and mid-sized businesses. Currently institutions of higher learning
are not included in the current provisions. Public higher education institutions are also ineligible for the Paycheck Protection Program as well
4/15/2020 shayes5@mo University of as tax credits afforded in the Families First Act. The COVID 19 pandemic has hit higher education very hard. I ask that you please add public
11:00:00 AM PIO (Email from Hayes Susan ntevallo.edu Montevallo higher education institutions to the "Main Street" lending facility.
Personal You must include medium and large nonprofits in the Main Street Lending Program. Communities, like mine in New Rochelle, NY, need these
4/15/2020 Email Address organizations to survive and recover from the Covid-19 pandemic. We can't make it without them.
11:00:00 AM PIO (Email from Field Anne 1955
Page 95 of 363
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Main Street Lending Program Comments
It would seem appropriate in the case of The Main Street Expanded Loan Facility (MSELF) that EBITDA be defined consistent with such
definition as has been previously agreed in the loan agreement supporting the existing Eligible Loan. Credit facilities commonly allow for the
addback of certain additional non-cash charges (versus the more narrowly defined add-backs of interest expense, taxes, depreciation and
ptaggart@ma Mansfield amortization) to EBITDA in the calculation of financial covenants governing such loans. The EBITDA definition as currently agreed and
4/15/2020 nsfieldplumbi Plumbing documented by the Eligible Lender and the Eligible Borrower should be consistently utilized in any calculation associated with the upsized
11:02:00 AM PIO (Email from Taggart Philip ng.com Products, LLC tranche to the existent Eligible Loan.
I am writing today to request that nonprofit corporations be included in the list of eligible entities for the Main Street Lending program. Many
nonprofits provide vital services to their communities, including but not limited to affordable housing, economic development, workforce
training, and more. At a time when both grant funding and earned income for nonprofits are suffering, it is extremely important that these
entities have access to all the tools to maintain their solvency. Excluding nonprofits from this program would set a dangerous precedent and
diminish their role and impact in the nation's response to and recovery from the COVID-19 crisis.
Thank you for your consideration,
John Paul Shaffer, AICP
johnpaul@bld Executive Director
4/15/2020 gmemphis.or Building BLDG Memphis
11:03:00 AM PIO (Email from Shaffer John Paul g Memphis
Personal You must include medium and large nonprofits in the Main Street Lending Program as they are needed to help communities such as mine in
4/15/2020 Email New Rochelle, New York survive and recovery from the Covid-19 pandemic. I am especially concerned about the non-profits that help kids in
11:04:00 AM PIO (Email from Burton Lisa Address our community.
Hello,
Non-profits need to be included in all COVID-19 relief efforts, including Main Street Lending. As a nonprofit employee, I have been impacted
by the lack of government support we have been given. Like most nonprofits, the organization I work for did not have a lot of excess and
quickly started to lose money once the crisis began. Despite the leadership's best efforts, 60 people, including myself, had to be
furloughed and many others had their hours drastically cut. By not supporting nonprofits, organizations that only exist for the good of the
community they serve, you are costing people their jobs and making it harder for these vital organizations to continue to exist. I urge you to
Planned support nonprofits and allow them to qualify for Main Street Lending going forward.
Personal Parenthood of
4/15/2020 Email Address the Pacific Sincerely,
11:04:00 AM PIO (Email from O'Neill Elyse Southwest Elyse O'Neill
Non-profit organizations are the backbone of communities. Please do not overlook their importance, and don't leave them out of the
Personal opportunity for federal funds. This is an economic crisis to rival the Great Depression. Without our non-profit groups thousands of people in
4/15/2020 Email Address distress will be even worse off. If you can give billions to airlines, hotels, and large corporations, you should be able to spare some for the
11:07:00 AM PIO (Email from Rothstein Helene neediest and most vulnerable among us, many of whom are served by not for profit groups.
Personal Larchmont/Mam You must include medium and large nonprofits in the Main Street Lending Program as they are needed to help communities such as mine in
4/15/2020 Email Address aroneck New Rochelle, New York survive and recovery from the Covid-19 pandemic.
11:07:00 AM PIO (Email from strauss gloria Indivisible
Personal You must include medium and large nonprofits in the Main Street Lending Program as they are needed to help communities such as mine in
4/15/2020 Email Dobbs Ferry, New York survive and recovery from the Covid-19 pandemic. Working people need help and that is the role of the federal
11:08:00 AM PIO (Email from Trader Elaine Address Ms. government. Thank you.
The Federal reserve is discussing $600 billion in bank lending to small and mid-sized businesses. Currently institutions of higher learning are
not included in the current provisions. Public higher education institutions are also ineligible for the Paycheck Protection Program. The
4/15/2020 armstrom@m University of COVID 19 pandemic has hit higher education particularly hard. I ask that you please add public higher education institutions to the
11:08:00 AM PIO (Email from Armstrong Mary Beth ontevallo.edu Montevallo "Main Street" lending facility."
I am trying to find a bank that is doing the COVID-19 Main Street Lending program but I have not found any yet. My bank (Cambridge Savings
Bank) is not participating.
4/15/2020 alissa.onigma Do you have list of banks that participating in this lending program?
12:00:00 AM PIO (Email from Onigman Alissa n@venly.com Venly Inc thank you.
Page 96 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
Regarding the Main Street Lending facility proposal
1. It is unreasonable to prohibit dividend distributions (draws) to S-corp owners. For many of us draws against profits (even if reduced by
Covid) are a major source of income, without which we cannot survive financially.
2. It is unreasonable to include loans made by owners to their companies in calculating total indebtedness. This penalizes owners who have
dipped into their own savings to keep businesses afloat and employees on payroll. Owner to business loans should not count against total
indebtedness, and should not be included in prohibitions against paying off existing debt with the main street loans.
4/15/2020 pelican@bres Pelican Thank you
11:09:00 AM PIO (Email from Bennett Michael nan.net Chemicals, Inc.
Hi, my family owns and operates a couple hotels in Clearwater Beach and we are really suffering like every other hotel is during this
shutdown. However, we don't even come close to qualifying under the terms presented so far because of the EBITDA requirement. We
Confidential Business Information
Just from our experience, we don't know any hotel that will qualify for this financing that also needs it as any
hotel that has such a small amount of existing debt to be under the 6x EBITDA requirement would have so much cash earnings from the prior
Danste year that they should easily be able to get through the shutdown without assistance. Even if exceptions aren't granted for cases like our
4/15/2020 sjp2@paged Hospitality renovation, the 2019 EBITDA requirement should be increased to 10x EBITDA for hotels, otherwise most won't be able to survive until
11:12:00 AM PIO (Email from Page II Stephen g.com Group, LLC things normalize.
"I am the President and CEO of Hillsides, a non-profit behavioral health organization in California, and I am writing to advocate for the
inclusion of non-profits as part of the Main Street Lending Program. Non-profit behavioral health agencies provide critical services to hundreds
of thousands of Californians, yet have been left out of the Main Street Lending Program. Without the vital aid provided by the program, our
agencies will potentially have to make cuts to staff and services which impacts our ability to serve some of the most vulnerable clients in
4/15/2020 jcosta@hillsid California. PLEASE INCLUDE THESE NON-PROFIT BUSINESSES AND IN TURN INCREASE THE CAPACITY OF THE SAFETY NET
11:12:00 AM PIO (Email from Costa Joe es.org Hillsides SYSTEM."
As a member of the YMCA of Greater Cincinnati board I am requesting that non profits be included in the Main Street Lending program. The
impact on our Y has been significant with staff reduced from 1,700 to 200! Because our facilities are closed many people have cancelled their
memberships reducing our revenue. Rather than have these buildings sit vacant, we have worked with our governors, we serve both
Kentucky and Ohio, to offer childcare to the children of healthcare workers, providing a safe environment for these children.
The YMCA of Greater Cincinnati is committed to serving our community throughout this pandemic and beyond. Please include non profits in
the Main Street Lending program.
Thank you for your consideration.
4/15/2020 Fender@twc. Kim Fender
11:12:00 AM PIO (Email from Fender Kimber con
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/15/2020 scott.garcia@ Uplift Family eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
11:13:00 AM PIO (Email from Garcia Scott upliftfs.org Service
4/15/2020 Personal Email You MUST include nonprofits in the Main Street Lending program to keep them going!!! All of them are vital to the well-being of our villages,
Address
11:14:00 AM PIO (Email from Modica-Snow Maria cities, states and country!
I am writing to urge you NOT to exclude nonprofits from the recently announced Main Street Lending Program. Nonprofits provide many of the
Community needed services that keep our communities running, both in times of crisis and in times of accord. Nonprofit agencies have been equally
Foundation of devastated by the financial downturn, and should have the opportunity to receive loans through the program. The quicker these nonprofits are
4/15/2020 smorahayes Greater able to get back to full capacity, the sooner they will be able to serve those citizens who have been most affected by the coronavirus outbreak.
11:15:00 AM PIO (Email from Mora Hayes Sutton @cfgm.org Memphis
Page 97 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
The Federal reserve is discussing $600 billion in bank lending to small and mid-sized businesses. Currently institutions of higher learning are
Personal not included in the current provisions. Public higher education institutions are also ineligible for the Paycheck Protection Program. The
4/15/2020 Email Address COVID 19 pandemic has hit higher education particularly hard. I ask that you please add public higher education institutions to the
11:16:00 AM PIO (Email from Lee Kristalyn "Main Street" lending facility.
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
mpollard@m hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/15/2020 omentummh. Momentum for eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
11:17:00 AM PIO (Email from Pollard Marilyn org Mental Health
The YMCA of Greater Kansas City was not able to apply for the Paycheck Protection Program because of our size. Please also consider loan
forgiveness for nonprofits, similar to the Paycheck Protection Program, to eliminate the burden of repayment in these uncertain times.
Without additional resources, many nonprofit organizations will be lost to their communities, including YMCAs. Our communities need
cherimedina nonprofits like the Y now more than ever. Despite our facilities being closed, the Y has been providing essential child care services for
4/15/2020 @kansascity YMCA of Greater healthcare workers, first responders and other essential services. Without access to support, our Y will not be able to resume operations as
11:17:00 AM PIO (Email from Medina Cheri ymca.org Kansas City we knew it or retain our staff.
Greetings-
I'm writing today with the specific request that larger non-profits be included as eligible borrowers under the Main Street Lending
programs. Because of the SBA's definition of employee as using headcount rather than FTEs, many large non-profits who rely on part-
time staff were ineligible for the PPP program. The MLF program also appears to exclude these entities from participating in conduit note
issuance through Eligible Issuers, even those 501c3s regularly participate in the municipal market.
Large non-profits serve our most vulnerable communities and are heavily focused on providing services to children and families. Social
distancing requirements have devastated program income for non-profits. Many already operate on very narrow margins and will soon run
into significant challenges meeting technical covenants in their loan/bond documents and, eventually, will suffer payment defaults.
Regardless of the shape of the recovery, these venerable institutions, once lost, cannot be replaced in the short-term. It's critical that we
ensure these institutions-YMCAs, Boys and Girls Clubs, food banks, women's shelters, etc.-are financial able to continue their missions.
I urge you to engage with the leadership of these organizations to ensure their needs are met by these stimulus programs. For many
populations, the vitality of these organizations is much more important to their livelihoods than, say, the airlines.
jwhite@colu Jeff White
4/15/2020 mbiacapital.c
11:18:00 AM PIO (Email from White Jeff om
The YMCA of Greater Kansas City was not able to apply for the Paycheck Protection Program because of our size. Please also consider loan
forgiveness for nonprofits, similar to the Paycheck Protection Program, to eliminate the burden of repayment in these uncertain times.
Without additional resources, many nonprofit organizations will be lost to their communities, including YMCAs. Our communities need
loratidwell@k nonprofits like the Y now more than ever. Despite our facilities being closed, the Y has been providing essential child care services for
4/15/2020 ansascityymc YMCA of Greater healthcare workers, first responders and other essential services. Without access to support, our Y will not be able to resume operations as
11:20:00 AM PIO (Email from Tidwell Lora a.org Kansas City we knew it or retain our staff.
andrew+feder Please include nonprofits and minority-serving institutions in all CARES/Coronavirus Relief programs!
alreserve@a
4/15/2020 ndrewwilder.c
11:23:00 AM PIO (Email from Wilder Andrew om
Personal You must include medium and large nonprofits in the Main Street Lending Program as they are needed to help communities such as mine in
4/15/2020 Email Address New Rochelle, New York survive and recovery from the Covid-19 pandemic.
11:23:00 AM PIO (Email from Nielsen Lynellen
4/15/2020 Personal Email You must include medium and large nonprofits in the Main Street Lending Program as they are needed to help communities such as mine in
11:24:00 AM PIO (Email from Winkelstein Nancy Address New Rochelle, New York survive and recovery from the Covid-19 pandemic.
Page 98 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
4/15/2020 Personal You must include medium and large nonprofits in the Main Street Lending Program as they are needed to help communities such as mine in
11:26:00 AM PIO (Email from Baum David Email Address Ridgefield and Danbury, Connecticut survive and recover from the Covid-19 pandemic.
INDIVISIBLE You must include medium and large nonprofits in the Main Street Lending Program as they are needed to help communities such as mine in
4/15/2020 Personal NEW New Rochelle, New York survive and recovery from the Covid-19 pandemic.
Email
11:26:00 AM PIO (Email from SNEDEKER FRANCES ROCHELLE
Address
Florida's nonprofit sector employees 5.5% of the state's workforce and is an economic driver larger that the construction industry. It
is disappointing to see another loan option excluding the nonprofit sector. The Florida Nonprofit Alliance encourages the Fed and Treasury to
launch loan programs expressly available to charitable nonprofits that satisfy the favorable terms in the CARES Act. Many nonprofits have
SPERWAIZ struggled to access the benefits associated with the CARES Act due to their limited assets or challenges accessing a bank that will service
4/15/2020 @FLNONPR Florida Nonprofit them. Florida's 84,000 nonprofits serve as a critical catch all for all our state's communities and cannot be forgotten in our
11:27:00 AM PIO (Email from Perwaiz Sabeen OFITS.ORG Alliance nation's recovery efforts.
I am affiliated with a non-profit healthcare organization in California, and I am writing to advocate for the inclusion of non-profits as part of the
Main Street Lending Program. The exclusion of non-profits in this program leaves non-profits which are not eligible to participate in PPP in
precarious financial standing without any way to mitigate economic injury while preserving workforce and continuing critical services to
hundreds of thousands of Californians. Without the vital aid provided by the program, these agencies will have to make cuts to staff and
tduong@heal services which impacts their ability to serve some of the most vulnerable clients in California. PLEASE INCLUDE THESE NON-PROFIT
4/15/2020 thRIGHT360. BUSINESSES OR EXPAND ELIGIBLE UNDER PPP TO ALL NON-PROFITS AND IN TURN INCREASE THE CAPACITY OF THE SAFETY
11:28:00 AM PIO (Email from Duong Tony org Healthright360 NET SYSTEM.
The Main Street lending program will support up to $600 billion in bank lending to small and mid-sized businesses, including two lending
options: new loans of $1 million to $25 million, or expansion of a business's existing loan with a bank to up to $150 million.
Unfortunately, the Administration and the Federal Reserve, as of today, are excluding nonprofits, many institutions of higher learning and
christina.paz Minority-Serving Institutions. It is crucial to include nonprofits and universities in this program. I am requesting that the Federal Reserve
4/15/2020 @sanvicente. Centro San implement potential eligibility changes to this initiative as this is a significant blow in particular to entities that are also ineligible for the
11:29:00 AM PIO (Email from Paz Paz org Vicente Paycheck Protection Program.
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/15/2020 jessica.parks Uplift Family eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
11:30:00 AM PIO (Email from Parks Jessica @upliftfs.org Services
4/15/2020 Cynthia@bro Can the PPP loan funds be used to pay the owner of a sole proprietor business? If I can't survive, I won't be able to pay any of the
12:00:00 AM PIO (Email from Riddle Cynthia brubru.com people who worked for me - all independent contractors.
Personal Please make the loans forgiveable for non profits.
4/15/2020 Email Address Thank you.
11:33:00 AM PIO (Email from Gerhard Denise
4/15/2020 Personal Email Please extend lending to local non profits. They are holding our community together.
11:34:00 AM PIO (Email from Tozzi Suellen Address
Personal Congress's covid19 money should be given to all small businesses, whether the are for the purpose of making a profit or are to serve
4/15/2020 Email the public. As long as they employ people, they are entitled to the loan.
11:37:00 AM PIO (Email from Albright Helen Address
4/15/2020 Sylvia@lvns. Little Village Nonprofits need support more then ever and they are employers! My school is a nonprofit cooperative and will suffer during this time that we
11:37:00 AM PIO (Email from Rath Sylvia org Nursery School can not charge tuition. Now, all the Teachers will have to be laid off.
I have heard that non- profit organizations and institutions of higher learning are to be excluded from the small business loans/ payroll grants
provision of the stimulus packages. Is this true? If so, this is blatantly unfair to those employees that work just as hard as employees of other
Personal small businesses and at the same time benefit our communities addressing felt needs. They also provide enriching experiences that will
4/15/2020 Email encourage and prepare our people for generations to come. Why would support for the workers in these businesses be withheld? Sincerely,
11:38:00 AM PIO (Email from Nye Deanne Address Private Citizen Deanne Nye
Page 99 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
I strongly encourage you to include non-profits in the Federal Reserve's Main Street Lending Program.
Otherwise, you will be excluding many institutions of higher learning and Minority-Serving Institutions.
While for-profit institutions are certainly being affected by the COVID-19 pandemic, so too are our non-profit organizations, many of which are
on the front line of defense against this virus, or who are providing indispensable research, and more.
And you know this virus is hitting minority populations in disproportionate numbers across the United States. It's equally imperative to
support non-profit Minority-Serving Institutions to combat this disparity.
michael@pla
4/15/2020 yhouseonthe Circuit I hope you will make the right decision and support the inclusion of non-profits in the Federal Reserve's Main Street Lending Program.
11:38:00 AM PIO (Email from Detroit Michael square.org Playhouse, Inc.
I implore the committee to include nonprofits, institutions of higher learning, HBCUs, and Minority-Serving Institutions in the "Main
Piedmont Triad Street" lending program. Without this assistance, many of the small non-profit agencies who provide great services in communities and
Regional Council directly serve the most at-risk populations will risk going out of business in these desperate times for businesses during COVID-19. It is very
4/15/2020 tjackson@ptr Area Agency on UNFAIR not to include their needs as well as larger businesses! Please DO NOT FORGET THEM!
11:39:00 AM PIO (Email from Jackson Teresa c.org Aging
As one of 4,000 employees of a regional non-profit health and human services agency that provides programs and services to nearly 10,000
people with intellectual and developmental disabilities, special needs, their families and older adults throughout numerous counties in Western
New York and the Greater Rochester region, I am writing today to inform you that our agency, People Inc., is fully engaged in dealing with the
COVID-19 crisis. We must ensure that our homes and services for people with disabilities remain as safe as possible and are staffed 24/7.
The vulnerable people that depend on us deserve no less. However, because we are providing essential services during the crisis, People
Inc. has incurred highly unusual increased costs in staffing, PPE, and cleaning services.
Since we are not eligible for the Payroll Protection Program (PPP) due to our size and we must remain fully operational, we request that the
Mid-Size Loan Program have provisions to convert to a forgivable loan for nonprofits that face staggering losses due to COVID-19. This would
grant us the same protections as PPP.
jcammarata
4/15/2020 @people- Thank you in advance for your support of direct care staff, the people we support and our agency, People Inc.
11:40:00 AM PIO (Email from Cammarata Jennifer inc.org People Inc
Hi, I am a community mental health provider at the Palo Alto VA. The mental health needs of our community are in crisis right now. I'm
not just talking about veterans, but about the broader California population, particularly those served through community and county mental
health services. It is crucial that these services continue to be robustly funded and protected. It will save money in the long-term to serve the
community's mental health needs now, but more importantly it is a matter of dignity and compassion.
I am writing to advocate for restoration of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees.
Many county and community programs have more employees than this (which is usually a sign that they are functioning really well and serve
a big population). Don't penalize these larger organizations! I cannot impress on you enough, from an on-the-ground perspective, how
Personal Email important it is not to inadvertently leave out crucial organizations from necessary protections. Please recognize the importance of including
Address nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion in the Main Street New Loan Facility
4/15/2020 eligibility. Thank you.
11:45:00 AM PIO (Email from May Margaret Palo Alto VA
Hi,
Nonprofits of all size serve the indigent, at risk and high risk populations throughout America. Smaller size nonprofits serve thousands of
MNICHOLSO Center for Safety individuals in need, Larger nonprofits serve hundreds of thousands of individuals that require support. Funding for nonprofits with staff above
4/15/2020 N@CENTER & Change, 500 via Main Street Lending ensures the lives of the populations served by them are not further destabilized during this crises.
11:45:00 AM PIO (Email from Nicholson Michael SC.ORG Inc.
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