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Federal Reserve Public Comments: Main Street Lending Program Nonprofit Organizations Comments (June 2020)

Summary

Compilation of public comments headed Main Street Lending Program Nonprofit Organizations Comments, with columns for event title, ticket type, received date, name, email address, affiliation and comment. The comments shown respond to the proposed Main Street Lending Program for nonprofit organization facilities and carry the received date 6/15/2020. Several commenters say the minimum employee requirement is too high or should be eliminated, citing small nonprofits and churches that rely on volunteers, contractors and part-time staff. One commenter proposes averaging fundraising revenue over three years and extending the facility termination date for higher education borrowers. Personal emails are omitted.

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Cite this document

“Federal Reserve Public Comments: Main Street Lending Program Nonprofit Organizations Comments (June 2020).” Original at www.federalreserve.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/federal-reserve-public-comments-2-pdf-www-federalreserve-gov-734b8d80b-2d56d6327d/, SHA-256 ed537b81f27feefcff93d578ff166072338a2555437fa7896838e084aaffa4ca.

Full text

                                                                                                                Main Street Lending Program
                                                                                                              Nonprofit Organizations Comments

     Event Title /
     Description       Ticket Type    Received Date   Last Name    First Name      Email Address       Affiliation                                                                         Comment
                                                                                 “Personal Email
 Staff Group - Main    PIO (Email    6/15/2020        Blum        Sam             Address
                                                                                                                     This would be a well used expansion of this program. I would suggest lowering employee counts. I participate on a few boards. One of them
 Street Lending        from Web)     12:00:00 AM                                                                     manages an ice arena in central MN. We are unable to put ice in and operate due to return to play restrictions and without some of our major
 Program - Nonprofit                                                                                                 tenants in place we are unable to run as per normal. I don't thing we would have a problem with the $250k minimum but we only have a
 Organization                                                                                                        few employees. This type of loan would be a lifeline as there is no money available outside of this. EIDL SBA loans are only going to ag right
 Facilities                                                                                                          now. We would pursue that as it is likely a better fit but as mentioned not available at this time. Outside of the personal scope I just detailed,
                                                                                                                     smaller non-profits would likely be able to put this to work but the headcount requirements seem like they are too high to impact a large portion
                                                                                                                     of the non-profit landscape.

 Staff Group - Main                                                                                                  The minimum number of employee requirement is not acceptable. We impact hundreds of people, but many on our staff volunteer time. Some
 Street Lending                                                                                                      act as independent contractors and provide services. This requirement should be eliminated entily.
 Program - Nonprofit                                                              potomacmanag      st paul
 Organization          PIO (Email    6/15/2020                                    ement@verizon     community,
 Facilities            from Web)     12:00:00 AM      williams    carl            .net              development
                                                                                                                     For both programs, the requirements listed as Item 5 in the eligible borrowers may be prohibitive for some borrowers as 2019 may have been a
                                                                                                                     strong year for a capital campaign or fundraising given timing of a gala or other events. I would propose looking to a three year average of 30%
                                                                                                                     rather than the spot in time for 2019. Another concept could be to include a bucket for one -time event related fundraising revenues of not to
                                                                                                                     exceed 10% of a three year average of operating revenues. Also, to better understand their liquidity, it may be helpful to include a requirement
                                                                                                                     that annual endowment draws remained within the lesser of (i) 5% on a three year average investment value or (ii) the Organization's
                                                                                                                     Endowment Draw policy. I would also clarify for Item 7 that the average daily expenses are daily cash expenses, to ensure depreciation is not
 Staff Group - Main                                                                                                  included in the calculation. For the Facility termination date, I would recommend extending that to close to October 31st as eligible higher
 Street Lending                                                                                                      education borrowers may not have final Fall 2020 enrollment figures until the first week of September. The extended date would allow them to
 Program - Nonprofit                                                                                                 provide access to the program if needed to ensure access to sufficient liquidity to carry them through the year / semester.
 Organization          PIO (Email    6/15/2020                                    makai.edwards
 Facilities            from Web)     12:00:00 AM      Edwards     Makai           @pnc.com
 Staff Group - Main                                                                                                  Nonprofits are the strength of this country because they serve others and are not self serving. No company can replace them. The US
 Street Lending                                                                                                      government, we all need them
 Program - Nonprofit
                                                                                 Personal Email
 Organization          PIO (Email    6/15/2020                                   Address
 Facilities            from Web)     12:00:00 AM      Bunkers     Mary Anne
Not Responsive




                                                                                                                     A minimum of 50 employees to be eligible for this loan is absolutely unreasonable - especially since the criteria states the Main Street program
                                                                                                                     is to support 'small' nonprofits also. By having a minimum of 50 employees absolutely eliminates hundreds of thousands of critical
                                                                                                                     small nonprofits, who retain contractors, part time staff, volunteers etc that will now be ineligible, yet are a vital part of our communities. Please
 Staff Group - Main                                                                                                  re-address this minimum employee number so it supports small nonprofits that have a minimum of 2 employees. Many churches and religious
 Street Lending                                                                                                      orgs do not have 50 employees. We need your support and financial help. This current proposal kicks our church, and other small nonprofits,
 Program - Nonprofit                                                                                                 out the playing field and this is unfair. Thank you.
 Organization          PIO (Email    6/15/2020                                    admin@saintpa     Saint Paulus
 Facilities            from Web)     12:00:00 AM      Church      Saint Paulus    ulus.org          Church
 Staff Group - Main                                                                                                  this is a test
 Street Lending
 Program - Nonprofit
 Organization          PIO (Email    6/15/2020                                    jean.p.durr@frb
 Facilities            from Web)     5:09:00 PM       Durr        Jean             .gov




                                                                                                                          Page 1 of 300
                                                                                                            Main Street Lending Program
                                                                                                          Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name    First Name    Email Address       Affiliation                                                                     Comment
                                                                                                                 As a resident of a rural community teeming with important nonprofits that enrich and support our most vulnerable populations, I request that the
                                                                                                                 Main Street Lending program for nonprofit organizations is accessible for nonprofits with a minimum of 10 employees. Limiting it to those with
Staff Group - Main
                                                                                                                 50 or more hurts rural communities like ours who's nonprofit charitable organizations are smaller than 50 employees. PLEASE consider
Street Lending
Program - Nonprofit                                                           bookkeeper@b                       this important request. With gratitude, Adele Lee
Organization          PIO (Email    6/16/2020                                 erkshirewaldorf   Berkshire
Facilities            from Web)     12:00:00 AM     Lee         Adele         school.org        Waldorf school
                                                                                                                 Limiting the availability of funding to nonprofits who employ 50 or more people restricts funding to smaller nonprofits that supply many rural
Staff Group - Main                                                                                               counties with vital services that they can not be without. Please consider providing this critical funding to nonprofit organizations of smaller
Street Lending                                                                                                   sizes (25 employees) and keep the charitable heartbeat of our country continuing far into the future by providing funding needed during this
Program - Nonprofit                                                                                              time of profound financial hardship.
                                                                              Personal Email
Organization          PIO (Email    6/16/2020                                 Address
Facilities            from Web)     12:00:00 AM     Novick      Jeff
Staff Group - Main                                                                                               I respectfully request that you extend the Main Street Lending Program to include non-profits. Non-profits provide jobs and other essential
Street Lending                                                                                                   services that both large and small businesses do not provide. They are an important part of our economy and should be included in this
Program - Nonprofit                                                                                              program.
Organization          PIO (Email    6/16/2020                                 joe@luxcenter.    LUX Center for
Facilities            from Web)     12:00:00 AM     Shaw        Joe           org               the Arts
                                                                                                                 June 16, 2020

                                                                                                                 Philanthropy Ohio is pleased to provide comments on and support the Federal Reserve Board's proposal to expand its Main Street
                                                                                                                 Lending Program to provide access to credit to nonprofit organizations. The proposed expansion to small- and medium-sized nonprofits is a
                                                                                                                 valuable tool to help Ohio's nonprofits as they continue to serve their communities during challenging times that will be with us for months
                                                                                                                 to come.

                                                                                                                 Philanthropy Ohio is an association of foundations, corporate giving programs, individuals and other organizations actively involved in
                                                                                                                 philanthropy in Ohio. Our mission is to lead and equip Ohio philanthropy to be effective, powerful change agents in our communities. Our vision
                                                                                                                 is a just and vibrant Ohio through impactful philanthropy.

                                                                                                                 Operating for almost 35 years as the only statewide philanthropic membership organization, Philanthropy Ohio is well qualified to connect
                                                                                                                 funders to people and ideas that matter and to represent the interests of philanthropy in Ohio and Washington, DC. We provide the network,
                                                                                                                 tools and knowledge to help people engaged in philanthropy become more effective, powerful change agents in our communities.

                                                                                                                 We couldn't agree more with Chairman Powell's statement that "nonprofits are a critical part of our economy," as they
                                                                                                                 employ about 10% of Ohio's workforce, pay more than $26 billion in wages and bring in over $113 billion in revenue in a single year. Yet,
                                                                                                                 the great majority of the state's 37,172 public charities are small, with less than $50,000 in annual revenue. It is these small- and medium­
                                                                                                                 sized organizations that have, for the most part, been left out of the recent federal action taken to help America's economy recover. And,
                                                                                                                 we know nonprofits of all sizes and programmatic focus areas are feeling the pain of the pandemic as it has disrupted their work at the very
                                                                                                                 time that the need for their services is increasing. A recent survey that we co-sponsored with Ohio Attorney General David Yost, and
                                                                                                                 administered by the John Glenn School of Public Affairs, describes the current landscape in Ohio, with 7,723 nonprofit leaders responding to
                                                                                                                 our questions, with the following key findings:
                                                                                                                  82% are providing services at a reduced capacity or not at all;
                                                                                                                  81% have seen a loss of revenue already;
                                                                                                                  78% have seen a decline in donations; and
                                                                                                                  47% have seen a higher demand for services.

                                                                                                                 Many of these nonprofits also provided info on how they have pivoted to continue operations:
                                                                                                                 25% have cut administrative expenses;
                                                                                                                 19% applied for federal loans;
                                                                                                                 18% have dipped into reserves; and
Staff Group - Main                                                                                               15% have cut or furloughed staff.
Street Lending
Program - Nonprofit                                                           vcoleman@phil                      We agree that different options should be offered under the proposal, taking into account the differences between for profit and nonprofit
Organization          PIO (Email    6/16/2020                                 anthropyohio.or   Philanthropy     ventures. We would encourage the Federal Reserve Board to revise the suggested eligibility criteria related to the employee number, so that
Facilities            from Web)     12:00:00 AM     Herrold     Claudia       3                 Ohio             nonprofits with fewer than 50 employees are eligible to apply for the loans and lower the maximum number to much fewer than 15,000, in order
                                                                                                                     Page 2 of 300
                                                                                                           Main Street Lending Program
                                                                                                         Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name    Email Address       Affiliation                                                                     Comment
                                                                                                                to truly open up these loans to small- and medium-sized nonprofits. We do not believe that an organization with 15,000 employees can or
                                                                                                                should be classified as medium-sized.




                                                                                                                Ohio philanthropies have created more than 80 funds for emergency and community responses to the COVID-19 crisis, granting out more than
                                                                                                                $28 million to Ohio nonprofits in rural, suburban and urban areas. The funds have been absolutely critical to nonprofits that are serving on the
                                                                                                                front lines to:
                                                                                                                 Provide food access and distribution;
                                                                                                                 Support senior citizens;
                                                                                                                 Meet mental health and addiction-related needs; and
                                                                                                                 Improve our community's health care infrastructure (i.e. health departments, hospitals and federally qualified health centers).

                                                                                                                Philanthropies have nimbly stepped in to fill immediate needs of nonprofits helping Ohioans but their resources are a drop in the ocean of what
                                                                                                                is needed. We applaud the federal efforts to date that are helping keep nonprofits in operation and return to full capacity and encourage the
                                                                                                                Federal Reserve Board to do its part. Thank you for considering our input and do not hesitate to contact us if you have questions.

                                                                                                                Submitted by:

                                                                                                                Deborah Aubert Thomas
                                                                                                                President & CEO

                                                                                                                Claudia Y.W. Herrold
                                                                                                                Chief Communications and Public Policy Officer


Staff Group - Main                                                                                              Limiting the availability of funding to nonprofits who employ 50 or more people restricts funding to smaller nonprofits that supply many rural
Street Lending                                                                                                  counties with vital services that they cannot be without. Please consider providing this critical funding to nonprofit organizations of smaller sizes
Program - Nonprofit                                                          ataiga@berkshi                     (25 employees) and keep the charitable heartbeat of our country continuing far into the future by providing funding needed during this time of
Organization          PIO (Email    6/16/2020                                rewaldorfschool                    profound financial hardship.
Facilities            from Web)     12:00:00 AM     Taiga       Anna          org
Staff Group - Main                                                                                              : Limiting the availability of funding to nonprofits who employ 50 or more people restricts funding to smaller nonprofits that supply many rural
Street Lending                                                                                                  counties with vital services that they can not be without. Please consider providing this critical funding to nonprofit organizations of smaller
Program - Nonprofit                                                          kpalmer@berks                      sizes (25 employees) and keep the charitable heartbeat of our country continuing far into the future by providing funding needed during this
Organization          PIO (Email    6/16/2020                                hirewaldorfscho   Berkshire        time of profound financial hardship.
Facilities            from Web)     12:00:00 AM     Palmer      Krista       ol.org            Waldorf school
Staff Group - Main                                                                                              Limiting the availability of funding to nonprofits who employ 50 or more people restricts funding to smaller nonprofits that supply many rural
Street Lending                                                                                                  counties with vital services that they can not be without. Please consider providing this critical funding to nonprofit organizations of smaller
Program - Nonprofit                                                                                             sizes (25 employees) and keep the charitable heartbeat of our country continuing far into the future by providing funding needed during this
                                                                             Personal Email
Organization          PIO (Email    6/16/2020                                Address                            time of profound financial hardship.
Facilities            from Web)     12:00:00 AM     Meier       Soheireh
Staff Group - Main                                                                                              Limiting the availability of funding to nonprofits who employ 50 or more people restricts funding to smaller nonprofits that supply many rural
Street Lending                                                                                                  counties with vital services that they can not be without. Please consider providing this critical funding to nonprofit organizations of smaller
Program - Nonprofit                                                                                             sizes (25 employees) and keep the charitable heartbeat of our country continuing far into the future by providing funding needed during this
                                                                             Personal Email
Organization          PIO (Email    6/16/2020                                Address                            time of profound financial hardship.
Facilities            from Web)     12:00:00 AM     Kennedy     Sean




                                                                                                                    Page 3 of 300
                                                                                                              Main Street Lending Program
                                                                                                            Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name    First Name    Email Address        Affiliation                                                                         Comment



                                                                                                                   The proposed expansion of the Main Street Lending program to not for profit entities is a welcomed addition to the program. HumanGood is a
                                                                                                                   non-profit provider of housing and supportive services for the elderly through its affordable housing and continuing care retirement communities
                                                                                                                   ("CCRC"). HumanGood serves approximately 13,000 residents in over 115 communities and employs approximately 5,000
Staff Group - Main                                                                                                 dedicated team members. HumanGood's CCRCs have been hit especially hard by the COVID-19 outbreak as they have lost over 15%
Street Lending                                                                                                     occupancy in their skilled nursing facilities and are 75% below budget on the collection of entrance fees (a major source of revenue and cash
Program - Nonprofit                                                           andy.mcdonald                        flow for the business). This loan program expansion will support us in bridging the lost cash flow from these disruptions to our occupancy and
Organization          PIO (Email    6/16/2020                                 @humangood.                          entrance fee cash flows and we are highly supportive of its adoption.
Facilities            from Web)     12:00:00 AM     McDonald    Andrew        org                HumanGood
Staff Group - Main                                                                                                 Limiting the availability of funding to nonprofits who employ 50 or more people restricts funding to smaller nonprofits that supply many rural
Street Lending                                                                                                     counties with vital services that they can not be without. Please consider providing this critical funding to nonprofit organizations of smaller
Program - Nonprofit                                                           Dcoleman@ber                         sizes (25 employees) and keep the charitable heartbeat of our country continuing far into the future by providing funding needed during this
Organization          PIO (Email    6/16/2020                                 kshirewaldorfsc    Berkshire         time of profound financial hardship.
Facilities            from Web)     12:00:00 AM     Coleman     Dana          hool.org           Waldorf school
Staff Group - Main
Street Lending                                                                                                     Please, reduce the number of staff for nonprofits to receive a loan. Please, reduce this number so that schools like ours and other other
Program - Nonprofit                                                           jgreen@berkshi                       nonprofits in rural
Organization          PIO (Email    6/16/2020                                 rewaldorfschool    Berkshire         communities, such as Berkshire County, who often employ less then 50 people, will have access to this vital, and life giving loan.
Facilities            from Web)     12:00:00 AM     GREEN       JENNIFER       org               Waldorf school
Staff Group - Main                                                                                                 Limiting the availability of funding to nonprofits who employ 50 or more people restricts funding to smaller nonprofits that supply many rural
Street Lending                                                                                                     counties with vital services that they can not be without. Please consider providing this critical funding to nonprofit organizations of smaller
Program - Nonprofit                                                                                                sizes (25 employees) and keep the charitable heartbeat of our country continuing far into the future by providing funding needed during this
                                                                              Personal Email
Organization          PIO (Email    6/16/2020                                 Address
                                                                                                 Berkshire         time of profound financial hardship.
Facilities            from Web)     12:00:00 AM     Konrad      Cindy                            Waldorf school
Staff Group - Main                                                                                                 Limiting the availability of funding to nonprofits who employ 50 or more people restricts funding to smaller nonprofits that supply many rural
Street Lending                                                                                                     counties with vital services that they can not be without. Please consider providing this critical funding to nonprofit organizations of smaller
Program - Nonprofit                                                                                                sizes (25 employees) and keep the charitable heartbeat of our country continuing far into the future by providing funding needed during this
                                                                              Personal Email
Organization          PIO (Email    6/16/2020                                 Address
                                                                                                 Berkshire         time of profound financial hardship.
Facilities            from Web)     12:00:00 AM     Hascup      Kirsten                          Waldorf school
Staff Group - Main                                                                                                 Limiting the availability of funding to nonprofits who employ 50 or more people restricts funding to smaller nonprofits that supply many rural
Street Lending                                                                                                     counties with vital services that they can not be without. Please consider providing this critical funding to nonprofit organizations of smaller
Program - Nonprofit                                                                                                sizes (25 employees) and keep the charitable heartbeat of our country continuing far into the future by providing funding needed during this
                                                                              Personal Email
Organization          PIO (Email    6/16/2020                                 Address
                                                                                                 Berkshire         time of profound financial hardship.
Facilities            from Web)     12:00:00 AM     Weld        Tyler                            Waldorf school
Staff Group - Main
Street Lending                                                                                                     While I am supportive of this program to nonprofits, however, I don't want the employee requirements at 50. There are some with 40-45
Program - Nonprofit                                                                                                and they should also be included. Some were not able to get the disaster loan, so giving them a shot using this program if they wish to use it
Organization          PIO (Email    6/16/2020                                 kbuer@genesis                        could be helpful. I would also like to see the term payback expanded.
Facilities            from Web)     12:00:00 AM     Buer        Kim           prep.org           300


                                                                                                                   The program minimums leave out the vast majority of the nonprofits that the Virginia Department of Housing and Community Development
                                                                                                                   works with, specifically on the Community Development side. Of our 26 designated Virginia Main Street organizations all have three or fewer
Staff Group - Main                                                                                                 employees. In fact, all 26 of them together do not have 50 employees. Similarly, we know that much of the federal stimulus missed the small,
Street Lending                                                                                                     micro, and sole proprietor businesses (20 or 25 employees or less). I would strongly encourage the Federal Reserve to consider a program
Program - Nonprofit                                                           rebecca.rowe@                        that will reach the small and micro nonprofits that have three or fewer staff. If a program like this would be outside of the mission or scope of
Organization          PIO (Email    6/16/2020                                 dhcd.virginia.go                     the Federal Reserve work, a program could be funded through VADHCD to work directly with those entities.
Facilities            from Web)     12:00:00 AM     Rowe        Rebecc        V                  VADHCD
Staff Group - Main
Street Lending                                                                                                     Government reimbursements aren't appropriate, nor is funding for only mission and not covering administrative and general operating
Program - Nonprofit                                                                              Seniors           costs for Non-Profits. ALL organizations need to have funding that allows operations - not limited to service funding only this includes
Organization          PIO (Email    6/16/2020                                 jsanvido@srca      Resource          GRANTS, LOANS and all types of funding. Non-profits are not set up to front costs and wait for lagging reimbursement processes.
Facilities            from Web)     12:00:00 AM     Sanvido     Joey          ging.org           Center
                                                                                                                       Page 4 of 300
                                                                                                           Main Street Lending Program
                                                                                                         Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name    Email Address       Affiliation                                                                      Comment


                                                                                                                Why would you set an employee minimum of 50 employees on non-profits? By relying on volunteer efforts, we have multiplied the impact of
                                                                                                                our message beyond the scope of our endowment, but we need our staff more than any large organization to do that!

                                                                                                                The floor penalizes us for the dedication of our board and supporters. Our fundamental objective is to inspire youth to overcome hurdles and
                                                                                                                work to create and produce the things people need. Thomas Edison came from very humble beginnings, overcame what is now known as
                                                                                                                ADD, and used fever induced deafness to help focus and concentrate - and do remarkable things in scientific research and innovate that met
                                                                                                                peoples' needs.

                                                                                                                Now, more than ever, that STEM message that "Edison" embodies is needed. Rather than penalize us for our successes, you
                                                                                                                might at least give us a shot at a low interest loan. The Pandemic induced uncertainty has not helped our modest endowment. Tapping that for
                                                                                                                additional income in these uncertain times sets us up for failure. That is not something any non-profit Board should do.
Staff Group - Main
Street Lending                                                                                                  Just because we are small does not mean we are insignificant. There is a statue in the Capitol Rotunda and the Treasury's most
Program - Nonprofit                                                                            Edison           successful Commemorative Coin (to its issue date) that are the result of this organization's effort. The primary objective of both being -
                                                                             Personal Email
Organization          PIO (Email    6/16/2020                                Address
                                                                                               Birthplace       inspire youth to pursue research and science, to innovate and create, and to provide what people need most.
Facilities            from Web)     12:00:00 AM     Sloane      J Heywood                      Association
                                                                                                                COVID-19 has significantly impacted our ability to generate revenue through fundraisers. We have been forced to cancel or postpone (and
Staff Group - Main                                                                             LAKE             potentially cancel) fundraisers through which we raise roughly $250K per year to keep the facility alive. We are a small 501 (c) 3 organized for
Street Lending                                                                                 PONTCHARTR       education and survive on Field Trips, Guided Tours, and social events such as weddings and showers (bridal Samp; baby). These loan
Program - Nonprofit                                                                            AIN BASIN        packages would be a vital link to getting us through into the next year when hopefully a vaccine is in place and people can congregate without
Organization          PIO (Email    6/16/2020       MacPherso                director@lpbm     MARITIME         fear of contracting the virus.
Facilities            from Web)     12:00:00 AM     n           James        m.org             MUSEUM INC

                                                                                                                Please make a special forgivable Loan, grant that furthers Religious Organizations & Churches, during these tough times religion &
                                                                                                                churches will prevent further chaos in our society & Bring Unity to everyone. Please fund the church many people attend with a forgivable
                                                                                                                loan of $970million - $1.97 Billion

                                                                                                                If you do not fund churches people will revolt, please examine history that is my case study, lets face it were in a depression and we need
                                                                             Personal Email
                                                                                                                churches, PLEASE FUND CHURCHES otherwise society will Revolt. Please give our church $970,000,000 + Plus To UNIT ALL OF US AS
Coronavirus           PIO (Email    6/16/2020                                Address
                                                                                                                AMERICANS Confidential Business G0D BLESS AMERICA!
                                                                                                                              Infnrm ntinn
(COVID-19)            from Web)     12:00:00 AM     Pena        Dan                            Church
                                                                                                                50 non-profit employees? Is this a mistake? 25 or 30 employees for a non-profit organization should be big enough to qualify for a loan to
                                                                                                                extend there mission in helping with the evolution of humanity through education.
                                                                             schooldirector
Coronavirus           PIO (Email    6/16/2020                                @berkshirewal     Berkshire        This 50 employee number feels discriminative.
(COVID-19)            from Web)     12:00:00 AM     Arches      Lynn         dorfschooll.org   Waldorf school



                                                                                                                Dear Sir or Madam,
                                                                                                                Please consider expanding this loan program to include non-profit 501 c9 organizations. We are a maritime training and conference center
                                                                                                                organized as a VEBA Beneficiary Trust (501 c9). We have been unable to obtain a PPP or other government sponsored loan due to our legal
                                                                                                                structure.

                                                                                                                MATES is an independent, stand-alone trust subject to the Employee Retirement Income Security Act of 1974, as amended, which is
                                                                                                                administered by an equal number of union and employer trustees for the purpose of providing eligible maritime industry training benefits on a
                                                                                                                voluntary basis. MATES operates two schools, and provides the highly specialized education and training required to obtain and maintain the
                                                                                                                licenses for employees serving as deck officers of the US Merchant Marines, and Captains and Mates aboard large commercial and United
Staff Group - Main                                                                                              States government ships, including those in the Military Sealift Command. Members of the MM&P who are eligible for training through
Street Lending                                                                                                  MATES are currently serving as deck officers navigating the USNS Comfort and the USNS Mercy in service to their fellow citizens during the
Program - Nonprofit                                                                            MM&P         current COVID-19 crisis.
Organization          PIO (Email    6/16/2020                                gpaine@mitags     MATES            Please visit our website at www.mitags.org
Facilities            from Web)     12:00:00 AM     Paine       Glen         -org              Program
                                                                                                                    Page 5 of 300
                                                                                                                 Main Street Lending Program
                                                                                                               Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name    First Name    Email Address         Affiliation                                                                          Comment
                                                                                                                      Unfortunately our small non-profit does not meet these requirements. It could be extremely beneficial for us to have this line of credit as an
Staff Group - Main                                                                                                    option. The future is extremely uncertain and financial standings are shaky at best. Any and all options available could be lifesaving for non­
Street Lending                                                                                                        profits who already live on shoestring budgets.
Program - Nonprofit
Organization          PIO (Email    6/16/2020                                 denice@norfolk    Norfolk Arts          Thank you for your consideration.
Facilities            from Web)     12:00:00 AM     Hansen      Denice        artscenter.org    Center
Staff Group - Main                                                                                                    Limiting the availability of funding to nonprofits who employ 50 or more people restricts funding to smaller nonprofits that supply many rural
Street Lending                                                                                                        counties with vital services that they can not be without. Please consider providing this critical funding to nonprofit organizations of smaller
Program - Nonprofit                                                                                                   sizes (25 employees) and keep the charitable heartbeat of our country continuing far into the future by providing funding needed during this
                                                                              Personal Email
Organization          PIO (Email    6/16/2020       Henderson                 Address
                                                                                                Berkshire             time of profound financial hardship.
Facilities            from Web)     12:00:00 AM     -Fisher     Holly                           Waldorf school


                                                                                                                      I am writing regarding the Revenue cap and source requirements of the NONLF and NOELF that a non profit institution has 2019 Revenues
                                                                                                                      less than $5 billion, with less than 30% sourced from donations. Our non profit is a small organization in New York State with revenues of
                                                                                                                      about $25M. We are completely closed this year due to the coronavirus pandemic and have economic damages of over $10 million. We will
                                                                                                                      need to borrow some of this in order to stay afloat. In 2019, we had a successful year fundraising for a comprehensive campaign that would be
                                                                                                                      close to 30% of total Revenues. This is the most we have ever fundraised, and many of those dollars are restricted for projects that would not
Staff Group - Main                                                                                                    pay expenses or staff costs. I would suggest that the 30% rule be limited to unrestricted gifts since other gifts cannot be used for operating
Street Lending                                                                                  Omega                 costs and don't help with the damage to organization's like ours that don't have enough money for normal operations.
Program - Nonprofit                                                                             Institute for
Organization          PIO (Email    6/16/2020                                 joell@eomega.     Holistic              thank you
Facilities            from Web)     12:00:00 AM     Levitan     Joel          org               Studies, Inc.
Staff Group - Main
Street Lending
Program - Nonprofit                                                           ebrozman@ber                            I believe the threshold level of 50 employees is too high and does not reflect the ability to repay. Our school has been in existence for 50 years.
Organization          PIO (Email    6/16/2020                                 kshirewaldorfsc   Berkshire             We have 40 employees and have a strong financial record in that time.
Facilities            from Web)     12:00:00 AM     Brozman     Edward        hool.org          Waldorf school
Staff Group - Main
Street Lending
Program - Nonprofit                                                                                                   This program is excellent but it should lower the number of employees required for non-profit organizations to be eligible. This should be 20
                                                                              Personal Email
Organization          PIO (Email    6/16/2020                                 Address                                 employees (or even fewer), otherwise it discriminates against organizations in rural communities.
Facilities            from Web)     12:00:00 AM     Bruun       Erik
                                                                                                                      While I am supportive of this program to nonprofits, however, I don't want the employee requirements at 50. There are some with 40-45
Economic Data -                                                               Personal Email                          and they should also be included. Some were not able to get the disaster loan, so giving them a shot using this program if they wish to use it
E.2 - Terms of        PIO (Email    6/16/2020                                 Address           Sensitive Personal
                                                                                                Information           could be helpful. I would also like to see the term payback expanded.
Business Lending      from Web)     12:00:00 AM     Nystrom     -Gary




                                                                                                                          Page 6 of 300
                                                                                                            Main Street Lending Program
                                                                                                          Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name   Email Address         Affiliation                                                                       Comment



                                                                                                                 This could be a potentially beneficial program that would greatly aid the nonprofit sector. However, there are two concerns with the proposal
                                                                                                                 which reflect a lack of understanding of the nonprofit sector that would make this program useful only to large organizations and leave a
                                                                                                                 majority on nonprofits unassisted.

                                                                                                                 While it may seem odd to say, the first concern is the minimum size of the loan at $250,000. The vast majority of nonprofit organizations this
                                                                                                                 country are what are known as "grassroots" organizations. 60% of nonprofits in this country have total budgets of less than
                                                                                                                 $250,000. These smaller organizations do the most with the least amount of money and are the ones who are truly being devastated right now.
                                                                                                                 This loan amount is more than most organizations spend/make in a year. Instead consider making more, smaller loans spreading the impact to
                                                                                                                 underserved segments of the country and reach smaller communities that are frankly being completely overlooked right now.

                                                                                                                 The other concern is the minimum staff size of 50 employees. As should be obvious from the fact that 60% of nonprofits have budgets of less
                                                                                                                 than $250,000 it is safe to say that none of them have more than 50 employees. Most nonprofits in the country rely on small scrappy staffs of
Staff Group - Main                                                                                               just a handful of people doing the job of twice as many people for half the pay.
Street Lending
Program - Nonprofit                                                          director@beatri                     In closing in order for this program to be most effective and impact the most communities the minimum loan size should be reduced enabling
Organization          PIO (Email    6/16/2020                                cecommunitypl      Community        more organizations to receive funds, and the minimum number of employees should be either lowered or completely eliminated.
Facilities            from Web)     12:00:00 AM     Ulmer       Jamie        ayers.com          Players, Inc.

                                                                                                                 We would respectfully ask that consideration be given to include nonprofit hospitals exempt from taxation under IRC Sec. 115 as meeting the
                                                                                                                 definition of a "nonprofit organization" for purposes of the NONLF. Such hospitals are unique in that they often meet the criteria for
                                                                                                                 set forth in IRC 501 (c)(3) and qualify for such exemption but for their tax-exempt status under a separate provision of the IRC.

                                                                                                                 Hospitals exempt from taxation under IRC 115 were considered "eligible borrowers" for purposes of the PPP loan program per
                                                                                                                 question #42 of the PPP FAQs issued by the SB A & Treasury. Many hospitals however were unable to avail themselves of the PPP loans
                                                                                                                 due to other limiting criteria, namely, the number of employees exceeded 500 or revenue exceeded the "size" requirement to qualify
                                                                                                                 under SBA program rules.
Staff Group - Main
Street Lending                                                                                                   Many hospitals that serve rural areas have suffered severe negative revenue impacts due to "lockdowns" and other measures
Program - Nonprofit                                                          charlie.abel@hi                     taken to slow the spread of COVID-19, and yet, many of these same facilities are responding as regional COVID patient care centers and are
Organization          PIO (Email    6/16/2020                                ghcountrybank.     High Country     struggling to maintain staffing requirements due to revenue loss.
Facilities            from Web)     12:00:00 AM     Abel        Charlie      net                Bank
Staff Group - Main                                                                                               Making these low interest loans available to nonprofits would be a welcome addition to hedge against the uncertainty surrounding how long the
Street Lending                                                                                                   revenue losses and increased expenses due to COVID will last. While we have been able to take advantage of the PPP loan based on
Program - Nonprofit                                                          kathi.condon@                       alternative size standards, it is essentially 20 DCOH, and, depending on the length of time this continues, that won't be enough to keep
Organization          PIO (Email    6/16/2020                                christiancare.or                    staff intact.
Facilities            from Web)     12:00:00 AM     Condon      Kathi        9
Staff Group - Main
Street Lending
Program - Nonprofit                                                          Dan@evoque-                         Non-profit employee threshold of 50 has nothing to do with profitability and you're excluding a lot of schools where this could be helpful
Organization          PIO (Email    6/16/2020                                Investments.co                      loan extension for.
Facilities            from Web)     12:00:00 AM     Schaeffer   Daniel       m


                                                                                                                 For the Main Street Lending program, organization size is too restrictive for nonprofits. We work with smaller, efficient year round full time
                                                                                                                 staffs, utilizing volunteers and hiring seasonal Contract talent. A minimum of five full time staff members is much more realistic than 50! During
                                                                                                                 our Admission-free Shakespeare on the Green season we hire 45-50 contract artists/technicians/educators for 8 weeks AND 200 volunteers.
                                                                                                                 We serve 40,000 Individuals, students, and educators annually. Our unwavering commitment to quality is evident in the accolades received
                                                                                                                 from attendees, grantors such as NEA and artists. Please recognize the heroic contributions of nonprofits doing great good with small but
                                                                             mbamber@neb                         mighty staffs!
Coronavirus           PIO (Email    6/16/2020                                raskashakespe      Nebraska         Thank you!
(COVID-19)            from Web)     12:00:00 AM     Bamber      Mary Ann     are.com            Shakespeare

                                                                                                                     Page 7 of 300
                                                                                                            Main Street Lending Program
                                                                                                          Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name    First Name    Email Address       Affiliation                                                                        Comment
Staff Group - Main                                                                                               Limiting the availability of funding to nonprofits who employ 50 or more people restricts funding to smaller nonprofits that supply many rural
Street Lending                                                                                                   counties with vital services that they can not be without. Please consider providing this critical funding to nonprofit organizations of smaller
Program - Nonprofit                                                                                              sizes (25 employees) and keep the charitable heartbeat of our country continuing far into the future by providing funding needed during this
                                                                              Personal Email
Organization          PIO (Email    6/16/2020                                 Address                            time of profound financial hardship.
Facilities            from Web)     12:00:00 AM     Thornton    Tracy
Staff Group - Main                                                                                               Limiting the availability of funding to nonprofits who employ 50 or more people restricts funding to smaller nonprofits that supply many rural
Street Lending                                                                                                   counties with vital services that they can not be without. Please consider providing this critical funding to nonprofit organizations of smaller
Program - Nonprofit                                                           cnordoff@berk                      sizes (25 employees) and keep the charitable heartbeat of our country continuing far into the future by providing funding needed during this
Organization          PIO (Email    6/16/2020                                 shirewaldorfsch   Berkshire        time of profound financial hardship.
Facilities            from Web)     12:00:00 AM     Nordoff     Christi       ool.org           Waldorf school

                                                                                                                 The National Club Association (NCA) represents private social and recreational clubs such as golf, country, city, yacht and athletic clubs. A
                                                                                                                 significant number of these clubs are 501 (c)7 entities. As a result, they are not eligible for the Paycheck Protection Program or the Main Street
                                                                                                                 Lending Program as the Federal Reserve has currently proposed.

                                                                                                                 Due to government-mandated closures covering all but a handful of states, thousands of club employees around the country have been laid
                                                                                                                 off. Even with phased-in openings, limited seating capacity and other operational changes required by state and local governments will
                                                                                                                 continue to affect revenues needed to bring these employees back. According to Club Benchmarking, the average club's non-dues
                                                                                                                 revenue declined by 65% in April alone. For clubs without golf, such as city, athletic and yacht clubs, non-dues revenue declined an average of
                                                                                                                 70.5%.

                                                                                                                 There are approximately 4,300 clubs in the United States who employ more than 500,000 workers. Most of those workers are kitchen staff,
                                                                                                                 servers, bartenders and other occupations that are identical to those of a local restaurant, which is eligible for the PPP. It is our belief that
Staff Group - Main                                                                                               employees of 501 (c)7 organizations should not be made to suffer simply because of an IRS tax classification. As you consider further eligibility
Street Lending                                                                                                   guidelines for the Main Street Program, NCA urges you to consider allowing 501 (c)7 organizations to participate. Should this be a possibility,
Program - Nonprofit                                                                                              NCA also encourages you to make adjustments to the EBITDA requirements to ensure clubs can qualify for the Main Street lending program.
Organization          PIO (Email    6/16/2020                                 trauger@nation    National Club    Thank you.
Facilities            from Web)     12:00:00 AM     Trauger     Joe           alclub.org        Association


                                                                                                                 To the Federal Open Market Committee,

                                                                                                                 I have grave concern over too much assistance, too widespread, and reaching into dangerous area like non-profits and high-yield bonds. Not
                                                                                                                 only that, savers may as well just sign up for public assistance as well, since they have been punished for a decade and looks like it's
                                                                                                                 going to continue. Low rates push people into the stock market when maybe they shouldn't be there. How are we ever supposed to get
Staff Group - Main                                                                                               out from under this tremendous debt load? There has never been a civilization in history which has survived this kind of runaway debt. The day
Street Lending                                                                                                   will come, maybe not so far away, when no one will want our bonds, notes and bills anymore, not to mention dollars. The Fed mandate is full
Program - Nonprofit                                                                                              employment and 2% inflation limit. It seems to me you are really supporting the stock market. The market cannot work correctly if we keep
                                                                              Personal Email
Organization          PIO (Email    6/16/2020                                 Address                            putting a floor underneath it and yet no roof. Thank for the opportunity to comment.
Facilities            from Web)     12:00:00 AM     Font        Patrick
Staff Group - Main
Street Lending
Program - Nonprofit                                                                             Elgin Area       Please consider not only 501 (c)(3) organizations but Chamber of Commerces who are also non-profit. Most Chmabers are 501 (c)(6)
Organization          PIO (Email    6/16/2020                                 cgieske@elginc    Chamber of       organizations but mine is a 501(c)(4) as we were incorporated before there were the other designations. Thank you
Facilities            from Web)     12:00:00 AM     Gieske      Carol         hamber.com        Commerce
Staff Group - Main
Street Lending
Program - Nonprofit                                                           andrew@haym                        In regards to the nonprofit loan program, we are an organization of less than 10 people, have been in business for ten years and have
Organization          PIO (Email    6/16/2020                                 akersforhope.or   Haymakers for    revenues close to $5,000,000.1 would urge you to allow smaller NPO's with a longer track record an opportunity to participate.
Facilities            from Web)     12:00:00 AM     Myerson     Andrew        3                 Hope




                                                                                                                     Page 8 of 300
                                                                                                             Main Street Lending Program
                                                                                                           Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name     First Name   Email Address        Affiliation                                                                        Comment



Staff Group - Main                                                                                                Given our size and the affiliation rules we have been excluded from most programs, however, we serve the most vulnerable population.
Street Lending                                                                                                    Through our diligent efforts, we have kept covid incursions at our communities and within our staff at a very nominal level and we have not lost
Program - Nonprofit                                                                                               any residents or staff to covid. We also have not terminated any employees and we continue to hire new employees. As a nonprofit
Organization          PIO (Email    6/16/2020                                  joe.larue@sunh                     organization we do what's best for our residents regardless. It would be nice to have the NONLF and NOELF help support our cause!
Facilities            from Web)     12:00:00 AM     La Rue        Joseph       ealth.org         Sun Health
                                                                                                                  Good morning,

                                                                                                                  I am the Executive Director of two 501c3 non profits in the Chattanooga, TN area. Both have a tremendous regional impact, generating an
                                                                                                                  estimated $50 million+/year of economic benefits for our community and partners, and we have done so - profitably - with a small staff for
                                                                                                                  years. Our annual
                                                                                                                  Impact reaches hundreds of thousands of people. We are effectively in the mass gathering business: creating community destinations is what
                                                                                                                  we do, an industry ravaged by COVID-19.

                                                                                                                  Unfortunately, your loan proposal does not help us as we are under 50 FTE. In fact, we are less than 10 FTE these days - the struggle to
                                                                                                                  survive has caused us to make tough decisions for the long haul. We've given up our office spaces, cut spending across the board and
                                                                                                                  considering further reductions. We can not cut out way to profitability - we need runway in order for this crisis to pass so that we can return to
                                                                                                                  work.
Staff Group - Main
Street Lending                                                                                                    Please eliminate the minimum 50 FTE requirement from your loan proposal.
Program - Nonprofit                                                            Chris.thomas@     Public Markets
Organization          PIO (Email    6/16/2020                                  publicmarkets.u   / Stadium        Chris Thomas
Facilities            from Web)     12:00:00 AM     Thomas        Chris        s                 Corporation
                                                                                                                  Over 99 percent of America's 28.7 million firms are small businesses. The vast majority (88 percent) of employer firms have fewer than
                                                                                                                  20 employees, and nearly 40 percent of all enterprises have under $100k in revenue.
                                                                                                                  Source: US Census Bureau, Business Dynamics Statistics, 2014
                                                                                                                  There are 96,971 small nonprofits that employ 10 or fewer people. Combined, these nonprofits employ 419,965 people, which is just 1.9% of
Staff Group - Main                                                                                                the 22.0 million people employed by all nonprofits. While these small nonprofits represent 5.5% of all nonprofits, they are a plurality - 35.8% - of
Street Lending                                                                                                    nonprofits that actually employ people. The minimum 50 employee requirement is misdirected if the goal is to maintain payroll levels and it is a
Program - Nonprofit                                                                                               faulty predictor of loan repayment. The term sheet should stick to the financial requirements and reduce or eliminate the employee minimum
Organization          PIO (Email    6/16/2020                                  bnicholson@bi                      criteria altogether.
Facilities            from Web)     12:00:00 AM     Nicholson     Bruce        gadvocate.us      MBGHI

                                                                                                                  Nonprofit organizations are in need of low cost financing to be able to sustain operations during and after the COVID-19 pandemic.
                                                                                                                  Extending the Main Street Lending Program to nonprofit organizations is one perfect way of making available financing that is flexible and low
Staff Group - Main                                                                                                cost, hence an effective way of providing much needed relief to eligible organizations.
Street Lending                                                                                   Coalition for    Please also consider leniency when evaluating liquidity since most of the organizations who will need the financing may just have been
Program - Nonprofit                                                            sntahitagabira    Responsible      deprived of cash due to current high interest loans they entered into to be able to manage cost-reimbursement contracts. The new federal
Organization          PIO (Email    6/16/2020       Ntahitagabi                @coalitionrcd.o   Community        loans should therefore offer an opportunity to refinance existing high interest loans.
Facilities            from Web)     12:00:00 AM     ra            Selerin      LS                Development




                                                                                                                      Page 9 of 300
                                                                                                            Main Street Lending Program
                                                                                                          Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name    First Name    Email Address       Affiliation                                                                         Comment



                                                                                                                 1. Most NPOs have less than 50 employees; DECREASE Minimum Employees to 25.
                                                                                                                 2. Ratio Requirements don't make any sense for most NPOs; most do not have any earnings from operating revenue; DELETE #6, #7,
                                                                                                                 and #8 under Eligible Borrowers.
                                                                                                                 3. Loan Maturity of 5 yrs, 15% principal in 3rd Samp; 4th Yr are simply not doable for most NPOs unless the borrowed amount is so small as to
                                                                                                                 be almost useless. HOW is any NPOs supposed to pay the 70% Balloon payment in Yr 5? I cannot imagine any NPO that can do this.
                                                                                                                 REVISED Maturity and Payments to be consistent with normal loan terms for NPOs.
                                                                                                                 4. Minimum Loan Size of $10MM eliminates all but the largest NPOs......... probably eliminates more than 90% of the NPOs. REDUCE
                                                                                                                 minimum loan to $1MM.
                                                                                                                 5. Maximum Loan Size of 25% of 2019 Revenue means the NPO revenue for 2019 must be above $40MM. Very few NPO have annual
Staff Group - Main                                                                                               Revenue above $40MM. DELETE #6 under Eligible Loans.
Street Lending                                                                                                   6. As currently proposed, I estimate less than 1% of the NPOs in the USA can qualify for a loan. Someone needs to apply these proposed
Program - Nonprofit                                                                                              criteria to a sample of NPOs of all sizes. That obviously hasn't been done, or, if so, the intent is not "Mainstreet" NPO, but
                                                                              Personal Email
Organization          PIO (Email    6/16/2020                                 Address
                                                                                                Eagle Sky        Elite Street NPOs.
Facilities            from Web)     12:00:00 AM     McKean Jr   J D                             Foundation Inc
                                                                                                                 Please consider allowing organizations with fewer staff but who use independent contractors apply. Perhaps set a minimum budget size of 1
                                                                                                                 million or more.
Staff Group - Main
Street Lending                                                                                                   Also concerned about donations at 30%
Program - Nonprofit
                                                                              Personal Email
Organization          PIO (Email    6/16/2020                                 Address                            As performing arts non profits grow the percent of revenue from ticket sales decline and donated revenue rises
Facilities            from Web)     12:00:00 AM     Kurtz       Andrew
Staff Group - Main
Street Lending
Program - Nonprofit                                                                             Sisters of the   I would like to encourage the board to reconsider the 50 employee minimum requirement for program eligibility. This eliminates many
Organization          PIO (Email    6/16/2020                                 jstreit@smmsis    Order of St      community based nonprofit organizations. A more reasonable employee count would be in the 15-20 range.
Facilities            from Web)     12:00:00 AM     Streit      Jeff          ters.org          Benedict


                                                                                                                 The fed should not be lending money to non-profits. They should raise money from donors, cut expenses or close. The purpose of the federal
                                                                                                                 is not to be a lender of last resort to every single institution in the U.S., especially when so many non-profits are political or religious in
Main Street                                                                                                      nature.  Lending money, which we know will never be paid back, to non-profits with endowments in the billions of dollars is even more
Lending Program -                                                                                                egregious. They should send their own money first. Another fed program that exceeds your authority and panders to political interests.
                                                                              Personal Email
NONLF and             PIO (E-       6/16/2020                                 Address                            Helicopter money once again!
NOELF                 mail)         12:00:00 AM     Bresa       Lindita
Staff Group - Main
Street Lending
Program - Nonprofit                                                           shawnta.fridays   Florida
Organization          PIO (Email    6/16/2020       Friday-                   troud@famu.ed     A&M          Clarify regarding any restrictions for state supported nonprofit organizations would be helpful
Facilities            from Web)     12:00:00 AM     Stroud      Shawnta       u                 University


                                                                                                                 As a non-profit professional for 30+ years and now a K-State Research and Extension educator who has taught grant writing to almost 1700
                                                                                                                 people, nonprofits will have to develop their fundraising skills to successfully pay these loans back. It is shocking how few have the capacity
Staff Group - Main                                                                                               and willingness to ask donors for money, but they must get those skills if they're going to be able to pay back the loans. As part of the
Street Lending                                                                                                   technical assistance to this program, it would be helpful to offer this training or to ascertain their capacity in this area. One of those capacity
Program - Nonprofit                                                                             K-State          issues is to get a donor database, but the Cadillac database systems aren't necessarily the best. It must be "easy enough to
Organization          PIO (Email    6/16/2020                                 nkdaniels@ksu     Research and     use" or agency staff won't utilize it successfully. TechSoup has low-cost options available that are easy to use and sustainable.
Facilities            from Web)     12:00:00 AM     Daniels     Nancy         .edu              Extension




                                                                                                                    Page 10 of 300
                                                                                                         Main Street Lending Program
                                                                                                       Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name   Email Address      Affiliation                                                                      Comment




                                                                                                              *** Reduced income while maintaining critical staff and increased expenses such as purchasing PPE has caused a hardship to continue
                                                                                                              operating.

                                                                                                              *** Organization Description: Easterseals South Carolina has been providing services to children with disabilities or special needs statewide for
                                                                                                              nearly 75 years. Easterseals provides services in South Carolina in a way that is unique to each child's needs. All services are community
                                                                                                              based and provided in the child's natural environment. We offer in home services to over 1000 children and their families throughout
                                                                                                              South Carolina. In home services to our clients helps create a family focused environment for children to grow and meet their developmental
                                                                                                              milestones. Services provided by Easterseals South Carolina include: Early Intervention and Pediatric Medical Rehabilitation.
                                                                                                              Our Early Intervention program helps parents/caregivers learn about their child's development and provides them with learning activities
                                                                                                              to enhance their child's development. An Early Intervention Specialist also provides information about available resources to meet their
                                                                                                              needs through service coordination.
Staff Group - Main                                                                                            Easterseals South Carolina offers both school based and home based therapy services through the Pediatric Medical Rehabilitation program.
Street Lending                                                                                                We currently provide occupational, physical and speech and language therapy.
Program - Nonprofit                                                                                           Easterseals South Carolina is committed to providing exceptional services to ensure all children with disabilities or special needs and their
Organization          PIO (Email    6/16/2020                                pguinn@sc.eas                    families have equal opportunities to live, learn, work and play in their communities.
Facilities            from Web)     12:00:00 AM     Guinn       Paul         terseals.com



                                                                                                              In regards to non-profit organizations being eligible for this program, I would encourage you to rethink the minimum number of employees. As it
                                                                                                              reads now, the minimum would be 50 employees and this would exclude several, relevant organizations from participating.

                                                                                                              Non-profit, and trade associations like the KC Tech Council, will make a significant impact on economic recovery. Endowments, such as
                                                                                                              University Endowments, will not have the same impact and should be excluded since they can leverage assets at more competitive rates than
                                                                                                              what is proposed. Additionally, they might choose to invest these dollars for a greater ROI, rather than hire new employees or invest in
                                                                                                              recovery programs. The stock market doesn't need this extra liquidity. If endowments are included, investing these dollars in public or
Staff Group - Main                                                                                            private markets should not be allowed.
Street Lending
Program - Nonprofit                                                                                           My recommendation would be to remove the cap on employees and further assess qualifications based on the diversity of funding sources, the
Organization          PIO (Email    6/16/2020                                ryan@kctechco   KC Tech          intended use of funds, and the overall potential for economic impact. Otherwise, this program may only support those who need it least.
Facilities            from Web)     12:00:00 AM     Weber       Ryan         uncil.com       Council


                                                                                                              My own nonprofit and most of the nonprofits with which we work would only be interested in loans if they were ultimately forgivable. For
                                                                                                              example, the Paycheck Protection Program (PPP) was set up so the SBA loan was forgivable if the funds were used to keep staff employed
Staff Group - Main                                                                                            during the pandemic. Similarly, federal Community Development Block Grants (CDBG) and federal HOME funds are granted in the form of
Street Lending                                                                                                loans that are forgiven after a set period if the funds were used for the agreed charitable purpose (e.g. building low income housing).. The
Program - Nonprofit                                                          danstraughan                     reason most nonprofits in my sector would not be interested in regular loans - even extremely low/no interest loans - is funders both private
Organization          PIO (Email    6/16/2020                                @homelessalli   The Homeless     and governmental will seldom agree to make grants to pay off debt or allow the funds they do grant to be used to retire debt.
Facilities            from Web)     12:00:00 AM     Straughan   Dan          ance.org        Alliance, Inc.




                                                                                                                 Page 11 of 300
                                                                                                           Main Street Lending Program
                                                                                                         Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name     Email Address      Affiliation                                                                        Comment
                                                                                                                Attention:

                                                                                                                My perception would be to that this program would be of little use to the non-profits that are contained within the greater West Michigan
                                                                                                                footprint for the following reasons:

                                                                                                                1. ) Short payback term of 5 years.
                                                                                                                2. ) Requirement of 90 days cash on hand coupled with only 30% of revenue can come from donations. The non-profits that need assistance
Staff Group - Main                                                                                              are those that rely on individual and corporation donations and fundraising activities to support their annual budget. These donations have
Street Lending                                                                                                  been significantly impacted by COVID-19.
Program - Nonprofit                                                                                             3. ) Requirement of 65% or above liquid assets as compared to debt and debt payments. Those non-profits who fit this criteria and the cash on
Organization          PIO (Email    6/16/2020                                 bhenion@choic    ChoiceOne        hand/ 30% revenue criteria should not have a need for additional loans.
Facilities            from Web)     12:00:00 AM     Henion      Bradley       eone.com         Bank



                                                                                                                I think a special tier should be for nonprofits that have less-than 50 employees. Grassroots organizations are just as important; than bigger
                                                                                                                ones with multi-million dollar budgets anyway. Most African American nonprofits doing the real heavy lifting in LMI neighborhoods and with low-
                                                                                                                income individuals will not have 50 employees. Just as in the CARES Act., 95% did not receive PPP because they could not compete with the
                                                                                                                size standards associated with 'small' business and the high revenue some 'small' businesses actually had. The disparity
Coronavirus           PIO (Email    6/16/2020                                 lazoneg@ibsa-                     in giving by community & corporate foundations, government grants Samp; contracts and general philanthropy is well documented.
(COVID-19)            from Web)     12:00:00 AM     Grays Jr    Lazone        inc.org          IBSA, Inc.
Staff Group - Main
Street Lending                                                                                                  Based on my interaction with the MSL program, I feel that there are a number of issues with the program. Most notably is the minimum loan
Program - Nonprofit                                                                                             amount. The minimum needs to be lowered to appeal to small business owner's needs. The participating lenders that I have spoken with
Organization          PIO (Email    6/16/2020                                 keith.bowers@f   FSBDC at         regarding the MSL have expressed the need for more guidance and user friendly.
Facilities            from Web)     12:00:00 AM     Bowers      Keith         amu.edu          FAMU
Staff Group - Main                                                                                              Limiting the availability of funding to nonprofits who employ 50 or more people restricts funding to smaller nonprofits that supply many rural
Street Lending                                                                                                  counties with vital services that they can not be without. Please consider providing this critical funding to nonprofit organizations of smaller
Program - Nonprofit                                                                                             sizes (25 employees) and keep the charitable heartbeat of our country continuing far into the future by providing funding needed during this
Organization          PIO (Email    6/16/2020                                 pattiregan@opt   Berkshire        time of profound financial hardship.
Facilities            from Web)     12:00:00 AM     Regan       Patricia      online.net       Waldorf school


                                                                                                                Please lower the 50 employee criteria for this loan. Schools, arts organizations, and vital company's to our area exist with smaller staff
                                                                                                                and employees and are always fund raising to stay in business or provide much needed education and artistic opportunities. These companies
                                                                                                                are so needed to feed our souls and now especially during this time of uncertainty. They are our foundations and hope for the future.
                                                                                                                Please have the numbers of employees lowered to 25 so many of the best schools, programs, and company's can continue serving the
Staff Group - Main                                                                                              adults, young people and children of our communities.
Street Lending                                                                                                  Thank you so much.
Program - Nonprofit                                                                                             In gratitude,
                                                                              Personal Email
Organization          PIO (Email    6/16/2020                                 Address
                                                                                               Berkshire        Diane Prusha
Facilities            from Web)     12:00:00 AM     Prusha      Diane                          Waldorf school
Staff Group - Main                                                                                              Limiting the availability of funding to nonprofits who employ 50 or more people restricts funding to smaller nonprofits that supply many rural
Street Lending                                                                                                  counties with vital services that they can not be without. Please consider providing this critical funding to nonprofit organizations of smaller
Program - Nonprofit                                                                                             sizes (25 employees) and keep the charitable heartbeat of our country continuing far into the future by providing funding needed during this
                                                                              Personal Email
Organization          PIO (Email    6/17/2020                                 Address
                                                                                               Berkshire        time of profound financial hardship.
Facilities            from Web)     12:00:00 AM     Riley       Christianna                    Waldorf school
Staff Group - Main
Street Lending                                                                                                  Thank you for these mechanisms being made available to the non profit community. Two recommendations. 1) Consider a 20% drop in
Program - Nonprofit                                                                                             revenues versus 30%. 2) Consider a 60 day working reserve for operations versus 90 days. These two considerations will capture a larger
Organization          PIO (Email    6/17/2020                                 Scott.jackson@                    number of domestic non profits who could qualify for the programs.
Facilities            from Web)     12:00:00 AM     Jackson     Scott         charity.org      Global Impact




                                                                                                                   Page 12 of 300
                                                                                                           Main Street Lending Program
                                                                                                         Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name    First Name   Email Address       Affiliation                                                                        Comment


                                                                                                                Holy Apostles College Samp; Seminary supports the Federal Reserve's opening up the existing Main Street Lending Program to non­
                                                                                                                profit organizations.The terms of the loan are generous. Were we to avail ourselves of such a loan, we'd likely find it easier to repay 25%,
                                                                                               Holy Apostles    25%, 50% in years 3-5 so that the large amount due in year five wouldn't as problematic. It's good, however, to have the 15%, 15%,
Coronavirus           PIO (Email    6/17/2020                                 smahfood@hol     College &    70% option. Thank you for offering this kind of support at this time!
(COVID-19)            from Web)     12:00:00 AM     Mahfood     Sebastian     yapostles.edu    Seminary
Staff Group - Main
Street Lending
Program - Nonprofit                                                                            Gateway          Please make the lending program available to churches and nonprofits with less than 50 employees. Even "large" churches
Organization          PIO (Email    6/17/2020                                 jwing@gateway    Community        typically have less than 10 employees.
Facilities            from Web)     12:00:00 AM     Wing        Jennifer      church.org       Church




                                                                                                                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
Staff Group - Main                                                                                              restaurant and hospitality revenue being central to our revenue model, the CIA is unable to qualify for SBA funds because we are a nonprofit
Street Lending                                                                                                  educational institution with these businesses falling under our one tax ID. As of today CARES funding will not address these components of our
Program - Nonprofit                                                                            The Culinary     operation as were not able to access funds coming through the SBA. As a nonprofit organization the CIA should not be excluded from
Organization          PIO (Email    6/17/2020                                 Rick.Tietjen@C   Institute of     accessing funds through the Main Street funding opportunity which are intended to support business like ours.
Facilities            from Web)     12:00:00 AM     Tietjen     Rick          ulinary.edu      America

                                                                                                                We would not qualify for this loan due to the following reasons. 1) A nonprofit cannot have less than 50 employees. I think this minimum
Staff Group - Main                                                                                              number of employees may need to be reconsidered, especially now during Covid-19 when many nonprofits have been forced to reduce staff.
Street Lending                                                                                                  2) 2019 Revenue must have less than 30% in donations. The majority of our revenue are donations from the general public. To meet the IRS
Program - Nonprofit                                                                            United Way for   code and be classified as a publicly supported nonprofit we must receive a minimum of 33 1/3% of our donations from the general public. You
Organization          PIO (Email    6/17/2020                                 debram@unitd     Southeast        are eliminating all publicly supported nonprofits from qualifying for these funds.
Facilities            from Web)     12:00:00 AM     Modlin      Debra         edwaysela.org    Louisiana

                                                                                                                As affordable housing continues to be one of the most significant barriers to economic, workforce and community development, deferring
Staff Group - Main                                                                             Wyoming          indefinitely the principal and interest for Community Land Trust or Shared Equity models would be incredibly helpful. One subsidy is invested
Street Lending                                                                                 Family Home      up front and remains with the home in perpetuity each time it is sold there by supporting affordability without any additional subsidies....ever. If
Program - Nonprofit                                                                            Ownership        the nonprofit never realizes the dollars gain it is placed in trust for public benefit. Therefore the nonprofit doesn't pay back hard dollars
Organization          PIO (Email    6/17/2020                                 brenda@myfro     Program dba      they never received.
Facilities            from Web)     12:00:00 AM     Birkle      Brenda        ntdoor.org       My Front Door


                                                                                                                Nonprofit organizations employ roughly 12.3M people and the sector spends roughly 2 trillion dollars annual with roughly $826B going to
                                                                                                                spending on payroll and $1 trillion being spent on goods and services that propel the economy. The sector is also the third largest in the
Staff Group - Main                                                                                              country behind retail and manufacturing. Therefore, this kind of lending program is essential for larger nonprofits to enable them to weather the
Street Lending                                                                                                  pandemic. Additionally, we rely on nonprofits to provide essential services in healthcare, human services and education that otherwise would
Program - Nonprofit                                                                                             not be covered through another form of public or private program. It is therefore, that I request the Federal Reserve open this program to 501c3
Organization          PIO (Email    6/17/2020                                 evan@501com                       and 501 c19 nonprofits at a bare minimum. Thank you for your consideration enabling the sector to continue its important work.
Facilities            from Web)     12:00:00 AM     Bennett     Evan          mons.org         501 Commons




                                                                                                                   Page 13 of 300
                                                                                                             Main Street Lending Program
                                                                                                           Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name    First Name    Email Address        Affiliation                                                                        Comment

                                                                                                                  Thank you for extending this to non-profits.

Staff Group - Main                                                                                                The 50 employee minimum will likely preclude non-profits servicing smaller cities and communities. The other provisions seem reasonable.
Street Lending                                                                                                    Perhaps you should change the minimum number of employees to 5? In addition to precluding smaller communities with smaller non-profits,
Program - Nonprofit                                                                                               the higher requirement will also preclude newer non-profits who may be innovating. It seems that we should be supporting innovative non­
                                                                              Personal Email
Organization          PIO (Email    6/17/2020                                 Address
                                                                                                 Working Cities   profits all over and smaller cities and towns.
Facilities            from Web)     12:00:00 AM     Templeton   Huff                             Pittsfield
Staff Group - Main
Street Lending
Program - Nonprofit
Organization          PIO (Email    6/17/2020                                 hiliff@mdnonpr     Maryland         Please remove the minimum number of staff. Nonprofit organizations can be creditworthy at different staffing levels.
Facilities            from Web)     12:00:00 AM     Iliff       Heather       ofit.org           Nonprofits
Staff Group - Main                                                                                                Limiting the availability of funding to nonprofits who employ 50 or more people restricts funding to smaller nonprofits that supply many rural
Street Lending                                                                                                    counties with vital services that they can not be without. Please consider providing this critical funding to nonprofit organizations of smaller
Program - Nonprofit                                                                                               sizes (25 employees) and keep the charitable heartbeat of our country continuing far into the future by providing funding needed during this
                                                                              Personal Email
Organization          PIO (Email    6/17/2020                                 Address
                                                                                                 Berkshire        time of profound financial hardship.
Facilities            from Web)     12:00:00 AM     Riley       Christianna                      Waldorf school
                                                                                                                  We are a very small 501 (c)3 that relies on mostly public donations. We usually fill a 990N for taxes, so any program will hopefully allow for this
                                                                                                                  documentation to be acceptable for the loan.
Staff Group - Main
Street Lending                                                                                                    Please feel free to contact me with any questions.
Program - Nonprofit                                                                              P.A.W.S.
Organization          PIO (Email    6/17/2020                                 michael@paws       Forward          Michael Campbell
Facilities            from Web)     12:00:00 AM     Campbell    Michael       forward.org        Foundation
Coronavirus           PIO (Email    6/17/2020                                                                     Can you extend the Main Street lending program to 501(c)6's. Since we do not have access to PPP we could really use some help.
(COVID-19)            from Web)     12:00:00 AM     Dobkin      Jon           jd@natpe.org       NATPE
Staff Group - Main                                                                                                Limiting the availability of funding to nonprofits who employ 50 or more people restricts funding to smaller nonprofits that supply many rural
Street Lending                                                                                                    counties with vital services that they can not be without. Please consider providing this critical funding to nonprofit organizations of smaller
Program - Nonprofit                                                           mwolff@berksh                       sizes (25 employees) and keep the charitable heartbeat of our country continuing far into the future by providing funding needed during this
Organization          PIO (Email    6/17/2020                                 irewaldorfschoo    Berkshire        time of profound financial hardship.
Facilities            from Web)     12:00:00 AM     Wolff       Maria E       I.org              Waldorf school


Staff Group - Main                                                                                                An annual interest rate on loans to nonprofits would be much more impactful at 1% or LIBOR with no additional spread. Lower rates would
Street Lending                                                                                                    much better serve non profits like CDFIs or other non-profit impact lenders struggling to bridge loans, and/or to on-lend at low rates to support
Program - Nonprofit                                                                              Conservation     struggling businesses. Non profits borrowing capital to support operations are likely to be challenged to pay down higher interest rates and
Organization          PIO (Email    6/17/2020                                                    Law              principle even with one year of no interest no principle payments.
Facilities            from Web)     12:00:00 AM     Foote       Virginia      gfoote@clf.org     Foundation
Staff Group - Main                                                                               United Way of
Street Lending                                                                                   Harrisonburg
Program - Nonprofit                                                                              and              I hope you will consider making this available to organizations with fewer than 50 employees, in the community where I live and work, most
Organization          PIO (Email    6/17/2020       Toni-                     laura.toniholsin   Rockingham       nonprofit will not meet this threshold and there are many others out there that would be in the same boat.
Facilities            from Web)     12:00:00 AM     Holsinger   Laura         ger@uwhr.org       County
Staff Group - Main                                                                                                Limiting the availability of funding to nonprofits who employ 50 or more people restricts funding to smaller nonprofits that supply many rural
Street Lending                                                                                                    counties with vital services that they can not be without. Please consider providing this critical funding to nonprofit organizations of smaller
Program - Nonprofit                                                           eorobio@berks                       sizes (25 employees) and keep the charitable heartbeat of our country continuing far into the future by providing funding needed during this
Organization          PIO (Email    6/17/2020                                 hirewaldorfscoo    Berkshire        time of profound financial hardship.
Facilities            from Web)     12:00:00 AM     OROBIO      ELMER         I.org              Waldorf school
Staff Group - Main
Street Lending                                                                                                    I would like to see non-profits receive money ahead of any investment firm. In fact, financial support should first go to mom-and-pop stores, to
Program - Nonprofit                                                                                               US based companies that pay taxes and didn't lay off their staff, and non-profits deserve financial assistance well before giving money to
                                                                              Personal Email
Organization          PIO (Email    6/17/2020                                 Address                             corporations.
Facilities            from Web)     12:00:00 AM     Shriver     Danielle                         US COURTS

                                                                                                                     Page 14 of 300
                                                                                                             Main Street Lending Program
                                                                                                           Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name    Email Address       Affiliation                                                                         Comment
Staff Group - Main                                                                                               Limiting the availability of funding to nonprofits who employ 50 or more people restricts funding to smaller nonprofits that supply many rural
Street Lending                                                                                                   counties with vital services that they can not be without. Please consider providing this critical funding to nonprofit organizations of smaller
Program - Nonprofit                                                                                              sizes (25 employees) and keep the charitable heartbeat of our country continuing far into the future by providing funding needed during this
                                                                             Personal Email
Organization          PIO (Email    6/17/2020                                Address
                                                                                               Berkshire         time of profound financial hardship.
Facilities            from Web)     12:00:00 AM     Far         Renee                          Waldorf school
Staff Group - Main
Street Lending                                                                                                    I would like to voice my request that the MSLP NONLF and NOELF include churches, para-church organizations, and non-profits of any
Program - Nonprofit                                                                            NorthStar          employee size. Employee size should not be a criteria that limits the availability of these loans. Many of these organizations are smaller in
Organization          PIO (Email    6/17/2020                                dgroves@north     Church             employee size but great in their community impact, and should not be limited because they have fewer employees.
Facilities            from Web)     12:00:00 AM     Groves      Dawn         starcnet.org      Network




                                                                                                                 Thank you for taking the time to ask for feedback on the proposed expansion of the Main Street Lending program. We at Goodwill South
                                                                                                                 Florida are thankful to see the recognition of a serious gap in sustaining medium-sized non-profits. The COVID episode has caused the single
                                                                                                                 largest threat to our organization in our 60-year history. Like many of our sister organizations across the nation, Goodwill South Florida stands
                                                                                                                 as the most successful organization in the area of training and placing people with Disabilities and Other Barriers to work. We are quite frankly
                                                                                                                 the employer of last resort for thousands of South Floridians. Aggressive growth in the area of Retail Stores, Apparel Manufacturing, Custodial
                                                                                                                 Services, and Healthcare Laundry, has expanded our employee rolls to 3,100 people, 1,200 of whom have a Federally defined disability. Most
                                                                                                                 of the remainder are people with serious barriers to work, or folks who are deeply disadvantaged.
                                                                                                                 On Friday March 20th, local municipal orders forced us to close our 36 stores, causing the furlough of 1,200 people. On Monday March 23rd,
                                                                                                                 following a positive COVID test result caused the furlough of an additional 1,200. In total, 2,500 were furloughed, and we lost 82% of our
                                                                                                                 revenue. We raced to cut costs and delay other expenses, but regardless, we churned through cash quickly, while we waited patiently for help
                                                                                                                 from our Federal Government. Help never arrived, and we hung perilously close to insolvency. We are fully extended on all current credit
                                                                                                                 facilities, and doing our best to navigate through this. The expansion of the Main Street Lending program, is not only well deserved, it's an
                                                                                                                 incredibly smart move by the government, which would immediately result in the re-hiring of hundreds of employees. The main suggestion we
                                                                                                                 would make in addition to the structure, is the addition of a loan forgiveness component. Other companies that have a far lower impact on the
                                                                                                                 economy, have already been granted this. Thank you so much for listening, and Godspeed in launching the program.
Staff Group - Main
Street Lending                                                                                                    David Landsberg
Program - Nonprofit                                                          dlandsberg@g                         President & CEO
Organization          PIO (Email    6/17/2020                                oodwillmiami.or   Goodwill South     Goodwill South Florida
Facilities            from Web)     12:00:00 AM     Landsberg   David        9                 Florida




                                                                                                                     Page 15 of 300
                                                                                                          Main Street Lending Program
                                                                                                        Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name   Email Address       Affiliation                                                                         Comment
                                                                                                               Omega is aware of the Federal Reserve Bank's efforts, under Chairman Powell's leadership, to extend a version of the Main Street
                                                                                                               Lending Program to non profit organizations that are not eligible for the current Main Street Lending Program. Omega is keenly interested in
                                                                                                               this development, as the program could provide vital financial support for Omega during a time when we are closed for the season due to the
                                                                                                               coronavirus pandemic and need to undergo many campus renovations for a successful 2021 opening that involves capital expenditures to deal
                                                                                                               with new health and safety standards. In addition, funds from this program could provide financial stability that would allow Omega to hire back
                                                                                                               staff that have been furloughed or given reduced hours.

                                                                                                               Omega meets the eligibility requirements of the program in that we are a 501 (c)(3) non profit that has been in operation over 40 years, with
                                                                                                               between 50 and 15,000 employees and less than $5 billion in revenues. We have no endowment to speak of. The one and only area where
                                                                                                               Omega does not meet the initial proposed eligibility requirement is the Revenue cap and source requirement which currently is "2019
                                                                                                               Revenues less than $5 billion, with less than 30% sourced from donations". Omega meets the revenue threshold, but donation income in
                                                                                                               2019 was 33% of total revenues as we were in the midst of a capital campaign.

                                                                                                               It seems that this requirement is very limiting and exclusionary. Many non profits require large amounts of fundraising in much higher
                                                                                                               percentages of total income than Omega has in order to fulfill their mission and they would be excluded from this lending facility. Furthermore,
                                                                                                               there is no distinction between restricted and non-restricted donations. Restricted donations are generally not available for supporting
                                                                                                               operational needs like salaries, employee benefits and operating expenses, which is where most non profits need assistance in the upcoming
                                                                                                               years beyond what is supported by the PPP loan that some, including Omega, have received. For an organization such as Omega, which has
                                                                                                               had to close operations for the entire 2020 season due to the pandemic, last year's success in fundraising has no bearing on the
                                                                                                               challenges presented by a severe drop off in fee for service revenue this year, and likely next year as well, caused by the pandemic. Most of
                                                                                                               last year's raised funds were restricted and were spent by the end of the first quarter of this year before the impact of the pandemic could
                                                                                                               be known.
Staff Group - Main
Street Lending                                                                                Omega            Omega asks your assistance in giving feedback to the Federal Reserve that the Revenue cap and source requirement needs to be expanded
Program - Nonprofit                                                                           Institute for    on the sourcing side to cover more non profits that are in a similar situation to Omega and desperately need to be able to get some financing
Organization          PIO (Email    6/17/2020                                joell@eomega.    Holistic         from the Federal Reserve's program.
Facilities            from Web)     12:00:00 AM     Backus      Robert       org              Studies, Inc.
                                                                                                               Please consider lowering the employee minimum threshold to 10 employees as this would be more in line with the sizing comparable to a
                                                                                                               $250,000 loan minimum.

                                                                                                               In addition, the donation revenue cap is overly restrictive. If the end goal is to ensure financial stability there are other measures that could
                                                                                                               replace the not more than 30% of revenues.
Staff Group - Main
Street Lending                                                                                                 As it stands this would not support "Main Street" non-profits.
Program - Nonprofit
Organization          PIO (Email    6/17/2020                                david@outdoor                     Thank you.
Facilities            from Web)     12:00:00 AM     Nyitray     David        discovery.org    ODC Network




                                                                                                               Loans to Non-profit is critical to existing pandemic disruptions to operations and future operating restraints. We are a community grassroots
                                                                                                               organization and we see the devastation the pandemic is having on local non-profits. Non profits already struggle to find adequate funding
                                                                                                               before the virus. Now under these conditions, it is likely many essential non-profit will have to close their doors. We are a non-profit that has
                                                                                                               served the community since 1993 with training, jobs, social services and emergency needs. We need funding to apply Economic Development
                                                                                                               and training initiatives for 200,000 disadvantage residents in NE Houston. Our "Training to Jobs" program is in place to reach
                                                                             imayhorn@thel                     10,000 or more "Ready To Work" individuals for training, on the job training and new business start up. We need funding under
                      PIO (Email    6/18/2020                                aunchcenter.or   Launch Point     pandemic conditions to reach our goals and create stable economic development for the Northeast Houston area...
Innovation            from Web)     12:00:00 AM     Mayhorn     Ivory        9                CDC, Inc.




                                                                                                                  Page 16 of 300
                                                                                                             Main Street Lending Program
                                                                                                           Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name    First Name    Email Address       Affiliation                                                                         Comment
                                                                                                                  "Nonprofit Organization New Loan Facility" the following language does not apply to nonprofit organizations and is confusing when
                                                                                                                  included.

                                                                              bbmccullough                        "The Eligible Borrower must commit that it will follow compensation, stock repurchase, and capital distribution restrictions that apply to
Other: language re    PIO (Email    6/18/2020       McCulloug                 @brighter-        Brighter          direct loan programs under section 4003(c)(3)(A)(ii) of the CARES Act"
stocks                from Web)     12:00:00 AM     h           Barbara       beginnings.org    Beginnings
Staff Group - Main
Street Lending                                                                                                    One of the requirements is for nonprofits is to have net income. We are a healthy non-profit but as a part of a 3 year strategic plan, we invested
Program - Nonprofit                                                           cwashinko@nc      Girl Scouts       reserves in developing innovative strategies to improve our program services for the long-term As a result, in 2018 and 2019 we budgeted for
Organization          PIO (Email    6/18/2020                                 coastalpines.or   North Carolina    and had a net operating loss in both years. This should not be a requirement or in and of itself, should not be a disqualifying factor.
Facilities            from Web)     12:00:00 AM     Washinko    Carla         g                 Coastal Pines
Staff Group - Main
Street Lending
Program - Nonprofit                                                                                               I highly encourage the implementation of a strong Main Street Lending Program that includes nonprofits, community land trusts, and
Organization          PIO (Email    6/18/2020                                 valerie@richmo    Richmond          cooperative organization.
Facilities            from Web)     12:00:00 AM     Jameson     Valerie       ndland.org        LAND

                                                                                                                  Hello
                                                                                                                  Please restrict funding for Non-Profits with less than 50 employees!

                                                                                                                  Limiting the availability of funding to nonprofits who employ 50 or more people restricts funding to smaller nonprofits that supply many rural
                                                                                                                  counties with vital services that they can not be without. Please consider providing this critical funding to nonprofit organizations of smaller
                                                                                                                  sizes (25 employees) and keep the charitable heartbeat of our country continuing far into the future by providing funding needed during this
Staff Group - Main                                                                                                time of profound financial hardship.
Street Lending
Program - Nonprofit                                                                                               Thank you
                                                                              Personal Email
Organization          PIO (Email    6/18/2020                                 Address                             Norm
Facilities            from Web)     12:00:00 AM     Mosher      Norm
Staff Group - Main
Street Lending
Program - Nonprofit                                                                                               Exciting to see this expansion to include non-profits, however, it would better serve under-resourced communities if it included smaller non­
Organization          PIO (Email    6/18/2020                                 mariela@mand      Mandela           profits doing real community based development, rather than being made available to larger institutional non-profits.
Facilities            from Web)     12:00:00 AM     Cedeno      Mariela       elapartners.org   Partners
Staff Group - Main
Street Lending                                                                                                    Please, reduce the number of staff for nonprofits to receive a loan. Please, reduce this number so that schools like ours and other other
Program - Nonprofit                                                           jgreen@berkshi                      nonprofits in rural
Organization          PIO (Email    6/18/2020                                 rewaldorfschool   Berkshire         communities, such as Berkshire County, who often employ less then 50 people, will have access to this vital, and life giving loan.
Facilities            from Web)     12:00:00 AM     GREEN       JENNIFER       org              Waldorf school



                                                                                                                  Settegast Heights Redevelopment Corporation Northeast Community mission is to serve as the catalyst for the Settegast Heights Northeast
                                                                                                Settegast         community, because of the circumstances of COVID-19, Settegast Heights Redevelopment Corporation economic status had to minimize its
                                                                                                Heights           expansion and operation to effectively serve the community specifically the seniors and children.The corporation is in an in dept financial bind
                                                                                                Redevelopment     due to COVID-19. The nonprofit given the opportunity for the Federal Reserve and the U.S. Department of the Treasury to support nonprofits
                                                                                                Corporation       to help stabilize COVID-19 economic status will help the nonprofit emerge and to sustain its ability to effectively address community needs and
                                                                              Personal Email
Coronavirus           PIO (Email    6/18/2020                                 Address
                                                                                                Northeast         concerns during this pandemic.
(COVID-19)            from Web)     12:00:00 AM     Francis     Rosalyn                         Community




                                                                                                                     Page 17 of 300
                                                                                                          Main Street Lending Program
                                                                                                        Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name    Email Address      Affiliation                                                                         Comment




                                                                                                                Dear Fed,

                                                                                                                Thank you so much for all the work you are doing to support the economy, I and so many others recognize what a heavy lift it is, and we are
                                                                                                                very grateful for your support, your independence, and your foresight. Being in the non-profit performing arts sector, we are dealing with grave
                                                                                                                challenges in this time. While I very much appreciate the extension of the Main Street Lending program to 501c3's, and understand the
                                                                                                                Fed's need to have reliable partners, this program is leaving out a vast swath of those who need the help the most now.

                                                                                                                Cutting off the eligibility at 50 employees, means that only the biggest organizations can apply and benefit. Those orgs that have only 1
                                                                                                                employee and many independent contractors are very common, have done great work for decades, and are made up the artists you have seen
                                                                                                                and heard in your ventures out to the performing arts for many years. Being a larger org doesn't guarantee fiscal responsibility either, as
                                                                                                                many large orgs have shown bad fiscal management in the past. For example, the org I run, is 5 years old, has been awarded solid funding
                                                                                                                and public support, and is so fiscally conservative that it maintains at least 5 years of operating cash in the 6 figure range with no debt. We and
                                                                                                                many others would be a perfect candidate, and the rules as such don't allow even for our participation to be an option.

                                                                                                                I would humbly suggest allowing for 3 years of existence (which is the standard the NEA uses for funding eligibility), and going all the way
                                                                                                                down to 1 employee instead of 50 to be eligible. Allow us to at least try to apply with our great fiscal record of success, and if we are denied for
                                                                                                                other reasons, then fine. But please don't cut off those who need the help the most by capping eligibility at 50 employees.

                                                                                                                Thank you for your consideration in adjusting this program, the Fed, while I see it as an essential institution, has a necessary and unfortunate
                                                                                                                habit of only being able to help the investor class and large businesses with their policies. It seems like the whole point of having a "Main
                                                                                                                Street" program is to reach the masses of people not represented in big business (whether for profit, or non-profit) or the large investor
Staff Group - Main                                                                                              class. Don't miss this opportunity to actually help "Main Street" by making the guidelines so that they benefit only the largest
Street Lending                                                                                                  organizations, let us compete with our strong fiscal habits, in a fair a just manner.
Program - Nonprofit
                                                                             Personal Email
Organization          PIO (Email    6/18/2020                                Address
                                                                                              Small Art Music   Thank you for your time and the best of luck in implementing this program, we appreciate your consideration of the ideas above!! M
Facilities            from Web)     12:00:00 AM     Small       Matt                          Projects




                                                                                                                   Page 18 of 300
                                                                                                              Main Street Lending Program
                                                                                                            Nonprofit Organizations Comments

    Event Title /
    Description       Ticket Type    Received Date   Last Name    First Name    Email Address     Affiliation                                                                         Comment
Staff Group - Main    PIO (Email    6/18/2020        Parker      Cynthia       cparker@bridg    BRIDGE             June 18,2020
Street Lending        from Web)     12:00:00 AM                                ehousing.com     Housing
Program - Nonprofit                                                                                                Board of Governors
Organization                                                                                                       Federal Reserve System
Facilities                                                                                                         Washington, DC

                                                                                                                   Re: Expansion of Main St Lending Program - Nonprofit Organization Facilities

                                                                                                                   Dear Honorable Board of Governors:

                                                                                                                   I am writing to express my enthusiastic support for the expansion of the Main St. Lending Program to include nonprofit organizations. As
                                                                                                                   Chairman Powell said, "nonprofits provide vital services across the country" at this critical time. The Covid-19 pandemic has set­
                                                                                                                   back many low- and moderate-income families, nonprofits are usually the first inline to offer help and support.

                                                                                                                   The nonprofit sector has evolved a sophisticated financial accountability system, which will be revealed as you start underwriting this sector,
                                                                                                                   while also maintaining a high-level of support for our communities. BRIDGE Housing is an affordable housing developer with a 35-year history
                                                                                                                   of developing, owning and maintaining affordable homes throughout the West Coast. We have an A+ rating from Standard and Poors and have
                                                                                                                   developed more than 18,000 units. The expansion of the Main St. Lending Program, to nonprofit organizations would mean that we would be
                                                                                                                   able to help more families and communities through this unprecedented crisis.

                                                                                                                   Please feel free to reach out to me if you have any questions or comments.

                                                                                                                   Sincerely,

                                                                                                                   Cynthia Parker
                                                                                                                   President and CEO
                                                                                                                   BRIDGE Housing



                                                                                                                   On behalf of the Union for Reform Judaism, whose nearly 850 congregations across North America encompass 1.5 million Reform Jews, and
                                                                                                                   the Central Conference of American Rabbis, whose membership includes more than 2,000 Reform rabbis, we urge the Federal Reserve to
                                                                                                                   ensure nonprofits are eligible for support lending under the Main Street Lending Program during the COVID-19 emergency and economic
                                                                                                                   recession.

                                                                                                                   As Americans struggle with the impact of shuttered businesses, closed schools, and more, nonprofits are being called on more than ever to
                                                                                                                   provide critical aid while their own financial resources are greatly diminished. In this time of need, we urge the Federal Reserve to make
                                                                                                                   necessary improvements to the Main Street New Loan Facility and the Main Street Expanded Loan Facility and ensure that nonprofits are able
                                                                                                                   to sustain their critical work.

                                                                                                                   We are inspired by Jewish tradition and values that teach the importance of strong communal institutions that help individuals become self-
                                                                                                                   sufficient. The Jewish philosopher Moses Maimonides taught that the highest form of tzedakah, charity, was that which helped people to
                                                                                                                   become self-sufficient. America's nonprofits help community members become more self-sufficient every day. Now, in their own time of
                                                                                                                   need, the Federal Reserve must help nonprofits continue their essential work.

                                                                                                Union for          Guided by our teachings, we strongly urge the Federal Reserve to support including eligibility for nonprofits in the Main Street Lending
Coronavirus           PIO (Email    6/18/2020                                  bweinstein@ra    Reform             Program.
(COVID-19)            from Web)     12:00:00 AM      Weinstein   Barbara       c.org            Judaism




                                                                                                                      Page 19 of 300
                                                                                                           Main Street Lending Program
                                                                                                         Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name   Email Address      Affiliation                                                                           Comment

                                                                                                                This program will be yet another way public policy lifts up suburban and urban places while leaving rural places behind. Our organization works
                                                                                                                exclusively in small towns and rural regions, and is highly supportive of CRA, CDBG, HOME, and other federal housing and community
                                                                                                                development programs. Yet, we also recognize that these programs were not designed to benefit the most persistently impoverished areas in
                                                                                                                the nation, namely: border colonias, central Appalachia, southern black belt thru the Delta, tribal lands and farmworker communities. 14% of
                                                                                                                persistent poverty counties are suburban and urban. 86% are rural.

                                                                                                                The Main Street program's eligibility has minimum and maximum sizes based on employees set so high that it privileges only the very
                                                                                                                large nonprofits, those who already have relatively better access to capital - grant, social, and loan. This is a particular problem for rural places,
                                                                                                                as the nation's largest non-profits have almost no presence in rural places.

                                                                                                                It is extremely rare that a rural non-profits will have more than 50 employees. And since the program does nothing to support non-profits with
                                                                                                                fewer than 50 employees, this will be a resource that one set of communities (suburban and urban) can access, that another (rural) will be
                                                                                                                denied.

                                                                                                                Undoubtedly a small rural non-profit would borrow closer to the $250,000 program minimum, automatically de-risk the loan in the program
                                                                                                                portfolio relative to a large suburban/urban non-profit borrowing $300M.

                                                                                                                How about establishing a small-balance Main Street Loan for small non-profits, with a cap far lower than $300M, reduced underwriting based
                                                                                                                on the relative risk of small loans, and a fixed rate. Organizations with fewer than 50 people rarely have the sophistication on-staff to manage
                                                                                                                risk in a variable rate environment.

                                                                                                                This is a great program, but not one for our organization or rural communities in general.
Staff Group - Main
Street Lending                                                                                                  Secondly, I think many non-profits lack the financial sophistication to manage the interest risk associated with variable rate debt.
Program - Nonprofit                                                                          Housing
Organization          PIO (Email    6/18/2020                                david@ruralho   Assistance         I haven't looked at the term sheet because these are such high barriers to entry.
Facilities            from Web)     12:00:00 AM     Lipsetz     David        me.org          Council


Staff Group - Main                                                                                              I write in support of the Main street Lending Program for Non Profit Organizations. This is desperately needed by so many not for profit
Street Lending                                                                                                  corporations who are critical to their towns and communities in this time. From those serving those most in need right now to those whose
Program - Nonprofit                                                                          Bristol            survival is critical because their services will be indispensable when our ravaged communities fully re-open, not for profit organizations form the
Organization          PIO (Email    6/18/2020                                amyk@brtstage   Riverside          backbone of critical services in our communities. Please support this fund.
Facilities            from Web)     12:00:00 AM     Kaissar     Amy           °[2            Theatre




                                                                                                                   Page 20 of 300
                                                                                                              Main Street Lending Program
                                                                                                            Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name     First Name     Email Address       Affiliation                                                                        Comment
                                                                                                                   We've discussed your criteria internally, and extensively: "To be eligible, nonprofit organizations must be tax-exempt, endowments
                                                                                                                   of no more than $3 billion, and meet certain financial thresholds. Organizations must have at least 50 employees and no more than 15,000
                                                                                                                   employees, or annual revenue of $5 billion or less." And lost 50% revenue due to Covid-19.

                                                                                                                   What you've proposed eliminates 99.999+% of nonprofits, validating the Fed had absolutely no genuine or authentic intention to support
                                                                                                                   small, cash flow damaged nonprofits. It's crystal clear this program was just to appease the nonprofits industry that petitioned publicly i.e.
                                                                                                                   your criteria is a publicity stunt with false pretense to silence nonprofits.

                                                                                                                   #1 Any nonprofit with $3b or $5b shouldn't be needing a loan - they'd be taking away from nonprofits that's never seen $1m,
                                                                                                                   never mind $1b.
                                                                                                                   #2 Any nonprofit with $3b or $5b wouldn't be small or medium, of which you publicize are the target sizes.
                                                                                                                   #3 Any nonprofit with 15,000 employees would be 'large,' not small or medium.
                                                                                                                   #4 Any nonprofit with a min of 50 employees would not be small, your minimal criteria.
                                                                                                                   #5 Any nonprofit that lost 50% revenue yet has billions banked should NOT be receiving a dime.

                                                                                                                   What you've proposed is on par with the same disastrous errors as the PPP loan where public corps, with billions under their belt,
                                                                                                                   hemorrhaged the cash and took from small companies that the funds were designed for. Any nonprofit with billions and a few thousands
                                                                                                                   employees don't need a loan at any time. Please learn from the PPP disaster and change your criteria so a: lt's reasonable, b:
                                                                                                                   lt's logical and c: You're genuinely wanting to support struggling nonprofits vs listing rules that ridicules worthy nonprofits that will
                                                                                                                   never, in a million years, match your unreasonable criteria.

                                                                                                                   Consider this rationale rule set: 2-1000 employees with max $10m in endowments that have lost a minimum 40% of their revenue due to
Staff Group - Main                                                                                                 Covid-19.
Street Lending
Program - Nonprofit                                                                                                Keeping the current criteria is absolutely throwing taxpayers cash down the drain and making the rich, richer while every other worthy nonprofit
Organization          PIO (Email    6/18/2020                                   admin@saintpa     Saint Paulus     burns in poverty.
Facilities            from Web)     12:00:00 AM     Church       Saint Paulus   ulus.org          Church
Staff Group - Main                                                                                                 Limiting the availability of funding to nonprofits who employ 50 or more people restricts funding to smaller nonprofits that supply many rural
Street Lending                                                                  Personal Email                     counties with vital services that they can not be without. Please consider providing this critical funding to nonprofit organizations of smaller
Program - Nonprofit                                                             Address
                                                                                                                   sizes (25 employees) and keep the charitable heartbeat of our country continuing far into the future by providing funding needed during this
Organization          PIO (Email    6/18/2020                                                                      time of profound financial hardship.
Facilities            from Web)     12:00:00 AM     Randolph     Helen
Staff Group - Main
Street Lending                                                                                    Housing
Program - Nonprofit                                                                               Solutions of     I would encourage FHLB to expand it's loan program to include nonprofits. We're businesses and would also benefit from access to
Organization          PIO (Email    6/18/2020                                   devonnam@ho       Northern         capital to keep critical social services programs running and, potentially, to expand offerings.
Facilities            from Web)     12:00:00 AM     McLaughlin   Devonna        usingnaz.org      Arizona, Inc.



Staff Group - Main                                                                                                 Eligible Borrowers, as currently proposed, miss most of the nonprofits in our community. The majority of us have less than 50 employees (if
Street Lending                                                                                                     any, as many are volunteer-based organizations or have other employers of record). Most of us receive more than 30% of our revenue from
Program - Nonprofit                                                             julie.evans@ca                     donations. Accordingly, the minimum loan size of $250K is more than most would need to weather the COVID-19 storm. My guess is that a
Organization          PIO (Email    6/18/2020                                   safoundation.or   Casa de la Luz   minimum of $50K would be more in line with what the average nonprofit would need and could take on, in terms of repayment.
Facilities            from Web)     12:00:00 AM     Evans        Julie          g                 Foundation


Staff Group - Main                                                                                                 I believe this would be a critical safety net for small nonprofits depending upon the terms and restrictions. Many of us rely on local donations for
Street Lending                                                                                                     match to leverage additional funding as well as for operating expenses. These donations have been and will continue to be dramatically
Program - Nonprofit                                                                                                impacted by COVID in terms of amounts and availability. In addition, the needs of the less fortunate have significantly increased. Therefore,
Organization          PIO (Email    6/18/2020                                   lcolbrese@csar                     flexibility and access will be critically important.
Facilities            from Web)     12:00:00 AM     Colbrese     Leslie         eno.org           CSA




                                                                                                                      Page 21 of 300
                                                                                                           Main Street Lending Program
                                                                                                         Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name     Email Address      Affiliation                                                                       Comment


                                                                                                                To whom it may concern,

                                                                                                                The Main Street Lending Program for non-profits is a critical component of the current economic recovery efforts. It would be strengthened by
                                                                                                                providing a reduced interest rate of 1-2% per annum combined with a longer term of 7-10 years. By reducing the cost and lengthening the term
                                                                                                                of these loans, they could be more effectively distributed not only to larger nonprofits but also to smaller grassroots nonprofits and social
Staff Group - Main                                                                                              enterprises through intermediary re-lenders, including CDFIs and other, similar entities.
Street Lending                                                  Conservatio
Program - Nonprofit                                             n Law                          Conservation     Best,
Organization          PIO (Email    6/18/2020                   Foundation    alinkow@clf.or   Law              Alex Linkow
Facilities            from Web)     12:00:00 AM     Linkow      c/            g                Foundation
                                                                                                                Why is the lending program for non profits only available to organizations that have more than 50 employees. Many non profits have less than
                      PIO (Email    6/18/2020       Loewenber                 saloewenberg     LA Theatre       that number.
General Inquiry       from Web)     12:00:00 AM     g           Susan         @latw.org        Works


                                                                                                                The Federal Reserve should explicitly state that all public institutions of higher education are eligible for the Main Street Lending Program even
Staff Group - Main                                                                                              if they do not have 501(c)(3) non-profit status. Final guidance on eligibility should include the definition of institutions of higher education as
Street Lending                                                                                                  defined by Sec. 101 (a) of the Higher Education Act of 1965 (20 U.S.C. 1001(a)). A longer repayment period (at least 6-8 years) as well as a
Program - Nonprofit                                                                                             longer interest deferment period (2 years or longer) will help to ensure nonprofits are on better financial standing to make payments on these
                                                                              Personal Email
Organization          PIO (Email    6/18/2020                                 Address                           loans.
Facilities            from Web)     12:00:00 AM     Tarr        Matthew




                                                                                                                   Page 22 of 300
                                                                                                          Main Street Lending Program
                                                                                                        Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name   Email Address       Affiliation                                                                         Comment




                                                                                                               Arts Wisconsin appreciates the opportunity to comment on the proposal to expand its Main Street Lending Program to provide access to credit
                                                                                                               for nonprofit businesses. Our comments are specifically related to the arts and cultural nonprofit sector.

                                                                                                               Arts Wisconsin is the state's community cultural development organization, and provides advocacy, service, and engagement to keep the
                                                                                                               creative economy strong and available to everyone, everywhere in Wisconsin.

                                                                                                               Before the pandemic, Wisconsin's creative sector was a vital component of the state's and the U.S. economy. According to the
                                                                                                               latest data issued on March 17, 2020 by the US Department of Commerce and National Endowment for the Arts, $10.1 billion was value-added
                                                                                                               to the state's economy through the arts, with 96,651 jobs involved in this sector - more jobs than in the the state's beer,
                                                                                                               papermaking and biotech industries. Nationally, arts and cultural economic activity accounted for 4.5 percent of gross domestic product (GDP),
                                                                                                               or $877.8 billion, in 2017. More info atwww.artswisconsin.org/actioncenter/beanea/.

                                                                                                               The creative sector landscape has been and will continue to be dramatically impacted by COVID-19. The impact in Wisconsin alone includes:

                                                                                                               Over $28 million negative financial impact to date, with a median financial impact per arts organization of $21,000, according to results
                                                                                                               collected by the Americans for the Arts' ongoing survey, "The Economic Impact of Coronavirus (COVID-19) on the Arts and Cultural
                                                                                                               Sector." This report estimates there has been a national impact of $6.7 billion overall and $24,500 median per-organization impact due to
                                                                                                               lost income, attendance, or other impacts. More info at www.americansforthearts.org/by-topic/disaster-preparedness/the-economic-impact-of-
                                                                                                               coronavirus-on-the-arts-and-culture-sector .

                                                                                                               Providing access eligibility to nonprofits has the potential to provide significant relief to this sector, particularly to small- and medium-sized
                                                                                                               businesses. This will support the intent expressed by Congress in the CARES Act that the program should provide liquidity support to all
                                                                                                               industries through federally guaranteed lending. This action will help arts and cultural nonprofits weather the current crisis until they can fully
Staff Group - Main                                                                                             operate again.
Street Lending
Program - Nonprofit                                                                                            We urge the Federal Reserve Board to approve the Nonprofit Organization Expanded Loan Facility to facilitate lending to nonprofit
Organization          PIO (Email    6/18/2020                                akatz@artswisc                    organizations by eligible lenders under the Main Street Lending Program. Thank you for your consideration of these comments.
Facilities            from Web)     12:00:00 AM     Katz        Anne         onsin.org        Arts Wisconsin




                                                                                                                  Page 23 of 300
                                                                                                           Main Street Lending Program
                                                                                                         Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name   Email Address        Affiliation                                                                       Comment
                                                                                                                As Congress works to address the economic impacts of COVID-19, we urge you to ensure that nonprofit organizations receive substantial
                                                                                                                emergency assistance as part of the next legislative response package. While our constituents' need for the crucial services provided by
                                                                                                                nonprofits has never been greater, the current crisis has made it more difficult for nonprofits to access charitable donations, grant funding, and
                                                                                                                other resources. As a result, nonprofits across Maine are facing significant financial strain and require direct assistance in order to continue
                                                                                                                providing vital community services.

                                                                                                                Throughout the development and Congressional consideration of the Families First Coronavirus Response Act and the Coronavirus Aid, Relief,
                                                                                                                and Economic Security (CARES) Act, we worked with our colleagues to ensure that nonprofits are eligible for the same economic relief as
                                                                                                                other employers. By delivering the paid sick and family leave tax credits and employee retention tax credit through the payroll tax system, the
                                                                                                                Families First Act made certain that tax-exempt nonprofits could fully access this financial assistance. The CARES Act provided many
                                                                                                                nonprofits with forgivable loans through the Small Business Administration's Paycheck Protection Program.

                                                                                                                We also strongly supported the CARES Act's explicit statutory direction to the Federal Reserve to endeavor to provide nonprofits access
                                                                                                                to low-interest emergency loans through its Main Street Lending Program. However, though the Families First Act and the CARES Act
                                                                                                                provided initial relief to nonprofit organizations, we have heard from many in Maine that require significantly greater assistance in order to
                                                                                                                continue serving vulnerable families and front-line responders.

                                                                                                                Nonprofits have stepped up during this crisis to meet emerging housing, education, employment, food, and healthcare needs in our state, and
                                                                                                                to modify existing services to limit the spread of COVID-19. Meanwhile, as nonprofits have worked to provide these services, many have also
                                                                                                                lost significant financial and staffing resources due to the crisis. In order to ensure that nonprofit organizations can successfully meet the
                                                                                                                growing needs of our constituents, it is imperative that Congress quickly advance another COVID-19 relief package which provides direct,
                                                                                                                dedicated emergency assistance for nonprofits.

                                                                                                                This need for further support is made all the more urgent by the unfortunate delay by the Federal Reserve in providing nonprofits with access
                                                                                                                to its Main Street Lending Program, which provides emergency loans to mid-size businesses with up to 15,000 employees or up to $5 billion in
                                                                                                                annual revenue. Despite the CARES Act directing the Federal Reserve to endeavor to provide emergency loans to mid-size nonprofits, these
                                                                                                                organizations are still unable to access this significant assistance program. Nonprofit organizations in our state need immediate and direct
                                                                                                                financial assistance in order to continue providing crucial community services. As the nonprofit sector continues to provide services to
                                                                                                                individuals and families who are struggling during the COVID-19 crisis, we urge you to ensure that nonprofits receive urgently needed
                                                                                                                emergency financial assistance in the next legislative response passed by Congress.
Staff Group - Main
Street Lending                                                                                                  In addition, most nonprofit organizations do not have months of cash reserves on hand and, therefore, are unable to take on large amounts of
Program - Nonprofit                                                                            Maine            debt. We urge the Federal Reserve to consider making the Main Street Lending Program forgivable for nonprofits so that they may continue to
Organization          PIO (Email    6/18/2020                                swoodard@non      Association of   employ 1 in 6 Maine workers in the sector and serve their communities.
Facilities            from Web)     12:00:00 AM     Woodard     Sarah        profitmaine.org   Nonprofits



                                                                                                                The eligibility requirement currently to participate in the Main Street Lending program for nonprofits is that there is a minimum of 50 employees.
Staff Group - Main                                                                                              The program would be able to reach more nonprofits if the minimum employee requirement was dropped. Prevent Blindness is a 112-year old
Street Lending                                                                                 National         nonprofit organization providing education, resources, screening and advocacy to all ages to improve vision and eye health. We have 25
Program - Nonprofit                                                          khartman@pre      Society to       employees working throughout the country. Since the intention of the program is to provide nonprofits with financial support if needed to deal
Organization          PIO (Email    6/18/2020                                ventblindness.o   Prevent          with the ongoing COVID-19 pandemic, excluding organizations based on employee count seems counter to that objective. Thank you.
Facilities            from Web)     12:00:00 AM     Hartman     Karen        rg                Blindness


                                                                                                                This seems designed to help a very small number of nonprofits, who have large endowments and need no relief as compared to the sector at
                                                                                                                large-hospitals, etc. These nonprofits may need relief but there should be integrity in disclosure. Indeed, the technical details, like the limit on
Staff Group - Main                                                                                              donations and the minimum number of employees, confirm the goal of the program.
Street Lending
Program - Nonprofit                                                          rhreese@cityof                     One limit, I would add to the restrictions would be a limit on executive compensation of the top 10% of employees (with a ban on raises,
Organization          PIO (Email    6/18/2020                                aylumpittsburg    City of Asylum   bonuses, stock options in related entities, etc. for the duration of the loan period), as the purpose is to aid nonprofits.
Facilities            from Web)     12:00:00 AM     Reese       Ralph        h.org             Pittsburgh



                                                                                                                   Page 24 of 300
                                                                                                               Main Street Lending Program
                                                                                                             Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name     Email Address       Affiliation                                                                          Comment


                                                                                                                    For almost 40 years, Rebuilding Together Houston has provided free home repair to our neighbors most in need, low income homeowners who
                                                                                                                    are seniors, US military Veterans and families impacted by disaster. We work in many of the oldest inner city neighborhoods in Houston, and
                                                                                                                    90% or more of the neighbors we serve live in communities of color.

                                                                                                                   We utilize volunteers for exterior work, and we hire contractors to make critical systems repair, therefore we have small staff of 18 people to
Staff Group - Main                                                                                                 manage the work. Making 50 or more employees a qualification would exclude not only our organization, but most of the organizations who
Street Lending                                                                                                     support affordable housing in Houston.
Program - Nonprofit                                                           cholland@rebui    Rebuilding
Organization          PIO (Email    6/18/2020                                 Idinghouston.or   Together            Please consider eliminating this qualification.
Facilities            from Web)     12:00:00 AM     Holland     Christine     g                 Houston



                                                                                                                   The Federal Reserve Board on 15 June 2020 announced it will be seeking public feedback on a proposal to expand its Main Street Lending
                                                                                                                   Program to provide access to credit for nonprofit organizations ("NPO"). We applaud the Board's initiative and wish to provide
                                                                                                                   the following feedback to assist in efforts to make the proposed program as efficient and effective as possible.

                                                                                                                    Consider loan forgiveness terms particularly for NPOs who have traditionally demonstrated outstanding operating performance as evidenced
                                                                                                                   by a ratio of adjusted 2019 EBIDA to unrestricted 2019 operating revenue considerably greater than 5%. Alternatively, allow flexibility
                                                                                                                   concerning other prohibitions such as existing debt repayments and disbursement amounts to affiliated NPOs providing associated services
                                                                                                                   that require funding.
                                                                                                                    An Eligible Borrower must certify that it has a reasonable basis to believe it has the ability to meet its financial obligations and does not expect
                                                                                                                   to file for bankruptcy. As such, Borrower should have the unfettered ability to manage its capital structure by paying down outstanding debts
                                                                                                                   whether mandatory or discretionary without utilizing NONLF / NOELF proceeds as appropriate in Borrower's professional judgement.
                                                                                                                    § 4003(c)(3)(A)(ii) of the CARES Act requires that in connection with any direct loan under any program or facility pursuant to Xsect;
                                                                                                                   4003(b)(4), Borrower must agree (a) for a period of 12 months from the date such loan is no longer outstanding, (ii) (not to) pay any dividend or
                                                                                                                   make other capital distribution. This requirement may be waived by the Secretary of the Treasury only if such waiver is deemed necessary to
                                                                                                                   protect the interests of the Federal Government. Certain payments to affiliated NPOs wherein the first NPO's mission is to provide funding
                                                                                                                   for the second NPO whose corollary mission is to provide services for example to individuals with developmental disabilities should be
                                                                                                                   stipulated as non-capital distributions and permitted in accordance with protecting the interests of the Federal Government.
                                                                                                                    Provided that the upsized tranche of the loan is a term loan that has all of the following features:
                                                                                                                   o 5 year maturity;
                                                                                                                   o Principal payments deferred for two years and interest payments deferred for one year (unpaid interest will be capitalized);
                                                                                                                   o Principal amortization of 15% at the end of the third year, 15% at the end of the fourth year, and a balloon payment of 70% at maturity at the
                                                                                                                   end of the fifth year;
Staff Group - Main                                                                                                 Refinancing the balloon payment of 70% at maturity at the end of the fifth year should be encouraged as appropriate to facilitate financial
Street Lending                                                                                                     flexibility and solvency.
Program - Nonprofit
Organization          PIO (Email    6/18/2020                                 bstahlman@arc     Arc Thrift          Thank you.
Facilities            from Web)     12:00:00 AM     Stahlman    Bruce         thrift.com        Stores
Staff Group - Main                                                           Personal Email
Street Lending                                                               Address
Program - Nonprofit
Organization          PIO (Email    6/18/2020                                                   ACT theatre -       I support the Main Street Lending Program for Nonprofits Proposed by Federal Reserve and encourage you to adopt this program
Facilities            from Web)     12:00:00 AM     Ray         Leslie                          seattie




                                                                                                                       Page 25 of 300
                                                                                                              Main Street Lending Program
                                                                                                            Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name    First Name   Email Address        Affiliation                                                                         Comment

                                                                                                                   Dear Main Street Lending Program,

                                                                                                                   Thank you for this opportunity to express my support of the proposed NONLF and give public comment. As the Executive Director of a
Staff Group - Main                                                                                                 nonprofit who has slowly grown its presence in San Francisco and its funding pre-COVID, I am in favor of this lending program. The uncertainty
Street Lending                                                                                                     of what lies ahead and City budget delays and cuts weighs on every ED I know. Having the security of the Main Street Lending Program would
Program - Nonprofit                                                                             3rd Street         give many nonprofits the safety nets needed to guide us through these unprecedented times. I am in full support of the NONLF and I hope you
Organization          PIO (Email    6/18/2020       Jackson-                  joi@3rdstyouth.   Youth Center       consider expanding this program to nonprofits this fiscal year. Thank you again.
Facilities            from Web)     12:00:00 AM     Morgan      Joi           org               & Clinic
Staff Group - Main
Street Lending                                                                                                    This is a brand new program. We are trying to get our arms around it and see if it is something that will work for some of our clients. Initially,
Program - Nonprofit                                                                             First Farmers     their seemed to be some confusion on the structure and the way it would be handled, but those issues have been addressed to some degree
Organization          PIO (Email    6/18/2020                                 cary.mawbey@      Bank Samp;        more recently and we hope that allows us to work on some of these loans.
Facilities            from Web)     12:00:00 AM     Mawbey      Cary          ffbt.com          Trust
                                                                                                                  For the Main Street Lending Program for non-profits, I would ask that you consider:
Staff Group - Main                                                                                                1) Lowering the employee size as much as possible, preferably to a minimum of one employee as there are significant non-profit organizations
Street Lending                                                                                                    with way less then ten employees.
Program - Nonprofit                                                                             NorthStar         2) Including churches as non-profits and not just 501 c3s
Organization          PIO (Email    6/18/2020                                 kharding@nort     Church            Thank you.
Facilities            from Web)     12:00:00 AM     Harding     Katie         hstarcnet.org     Network
Staff Group - Main
Street Lending                                                                                                    The minimum Employee threshold of 50 seems too high....25 would be a more practical cutoff. There are many non-profits of 25-50 people
Program - Nonprofit                                                                                               providing essential front-line support services - especially community hubs. (Note - this change would not impact me or my non-profit - i.e. we
Organization          PIO (Email    6/18/2020                                 wweber@CAW        Communities       would still not qualify.)
Facilities            from Web)     12:00:00 AM     Weber       William       -RVA.org          At Work
                                                                                                                   I am writing today to note that, while I expect nearly all Life Plan Communities will meet the general qualifications, many communities will not
                                                                                                                   meet the financial ratios as of the loan origination date. These covenants, especially Cash to Debt, are concerning since the program will not
                                                                                                                   be available to the organizations who need immediate support the most. Why are we not being given the same grace as other corporate
                                                                                                                   "fallen angels"?

                                                                                                                   In the specific case of the Alliance Community for Retirement Living, we did not qualify for the PPP program upon consultation with our
                                                                                                                   external CPA firm given our affiliation with other C&MA denomination communities and the perceived control of having shared board
                                                                                                                   members and certain executives. We also will not qualify for the Main Street Lending Program based on the required ratios, so I am writing to
                                                                                                                   make you all aware of a gap in the design of these programs since I am sure there are other communities who will be in a similar situation of
                                                                                                                   being left out.

                                                                                                                  While we did receive funding from HHS, it will not be sufficient enough for us to also maintain our Assisted Living and Independent Living over
Staff Group - Main                                                                                                this prolonged pandemic given all the additional safety protocols and procedures undertaken in accordance with the guidelines and regulations
Street Lending                                                                                  Alliance          from the CDC, CMS, AHCA, and the DOH. These safety protocols and procedures have served us very well in protecting our seniors but they
Program - Nonprofit                                                                             Community for     come at elevated costs that I am afraid many communities such as ourselves are not able to bear without burning through reserves and/or
Organization          PIO (Email    6/18/2020                                 burkerainey@s     Retirement        receiving private donations.
Facilities            from Web)     12:00:00 AM     Rainey      Burke         hellpoint.org     Living
                                                                                                                   It is good to hear that the Fed is planning to extend its Main Street lending program to non-profits. The program would be useful for LEAF if we
                                                                                                                   qualified, as it would provide access to liquidity during the crisis.

Staff Group - Main                                                                                                 However, we would be too small (10 employees). Also, the LIBOR + 3% interest would be too high. The reason is that when LEAF borrows it is
Street Lending                                                                                                     usually for loan capital to on-lend. And our cost of capital is under 3%.
Program - Nonprofit                                                                             LEAF - Local
Organization          PIO (Email    6/18/2020                                 jrojas@leaffund   Enterprise         It is great that the Fed and the SBA have rolled out these various emergency programs! Thank you!
Facilities            from Web)     12:00:00 AM     Rojas       Jose Luis      .org             Assitance Fund




                                                                                                                      Page 26 of 300
                                                                                                            Main Street Lending Program
                                                                                                          Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name    Email Address        Affiliation                                                                         Comment


                                                                                                                   As a CDC and CDFI, this loan program can help reserve unrestricted cash/working capital while dealing with delays in credit approval due to
                                                                                                                   covid tightening for projects. We would use this loan as a bridge facility for a real estate development or as a warehouse line equivalent gto
Staff Group - Main                                                                                                 fund loans that we originate.If loan is unsecured, it would enhance credit worthiness. Our staff is less than 50 so we would not qualify under the
Street Lending                                                                                                     existing rules. I would suggest that you evaluate this as there a CDC's and CDFI with strong balance sheets and track records in real
Program - Nonprofit                                                                                                estate development and lending activites that have significant capital and financing needs disproportionate to their staff level that are disrupted
Organization          PIO (Email    6/18/2020                                Tony@HomeSi                           by the Covid situation.
Facilities            from Web)     12:00:00 AM     To          Tony         ghtWA.org          HomeSight


                                                                                                                   As the CFO of a private non-profit University in South Florida with more than 7,200 enrolled students, I strongly support expedited expansion of
                                                                                                                   the Main Street Loan program to non-profits that were not eligible for the PPP program or the Main Street Loan program as it is currently
                                                                                                                   designed. Our university employs over 2,000 full and part-time employees with a gross payroll of nearly $80 million. Higher Education
                                                                                                                   institutions that are enrollment dependent like ours have a seasonal cash position with low points during the summer in late-July, and high
                                                                                                                   points when students pay tuition in late-August and January. Given the additional and unprecedented cash strain from COVID-19, it is critical
Staff Group - Main                                                                                                 that we are able to access this funding source in an expedited way to continue to pay our employees throughout the summer.
Street Lending
Program - Nonprofit                                                                                                For this reason, we join others who have called upon the Federal Reserve to update their recent guidance and term sheets as soon as possible
Organization          PIO (Email    6/18/2020                                srosenthal@ba      Barry              to allow both nonprofit private and public institutions of higher education to participate in the Main Street Lending Facilities.
Facilities            from Web)     12:00:00 AM     Rosenthal   Sue          rry.edu            University
Staff Group - Main
Street Lending                                                                                                     Many small non profits (arts and other municipal support organizations) are smaller than 50 employees. In small communities (10,000 or less in
Program - Nonprofit                                                                             AWC;               pop.) you leaving them without access to the financial "lifeboat" if you make the cutoff size so large. I would suggest the cutoff be
Organization          PIO (Email    6/18/2020                                andym@awcne        Association of     20 employees with a corresponding reduction in budget.
Facilities            from Web)     12:00:00 AM     Meyer       Andy         t.org              WA Cities
Staff Group - Main
Street Lending
Program - Nonprofit                                                                                                Lending to nonprofit organizations would be very beneficial. Many established nonprofits would be excluded from the program based on the
Organization          PIO (Email    6/18/2020                                ryant@firstcallk                      minimum of 50 employees. Organizations with less than 50 employees are also struggling during this time and could use relief.
Facilities            from Web)     12:00:00 AM     Toothaker   Ryan         c.org



                                                                                                                   Our thanks to the Board for considering all COVID affected organizations in the Main Street Lending Program initiative. A few comments on the
                                                                                                                   qualifications for your consideration.
                                                                                                                   1. On average across Goodwills nationally, and true in our organization, is that revenue from the Goodwill business model is generated from
                                                                                                                   about 70% donated goods operations. Very few Goodwills including ours will meet the 30% from donations requirement. However, if it is clear
                                                                                                                   that the under 30% applies only to monetary donations, and does not apply to material donations, most Goodwills would qualify.
                                                                                                                   2. We and many other Goodwills, and likely many nonprofits in general, would not meet the above 5% earnings threshold. Goodwills and
                                                                                                                   nonprofits spend funds to deliver their mission, and do not generate earnings above this level. An operating profit at any level would be a better
Staff Group - Main                                                                                                 measure, and a few years prior could be used for consistency.
Street Lending                                                                                                     3. For the same reasons above, 90 days liquidity would also be a challenge for us and many. 45 days would give more an opportunity.
Program - Nonprofit                                                          davidwells@ala     Alabama            We understand financial considerations to mitigate risk. If the Board could look at nonprofit longevity and business immediately preceeding and
Organization          PIO (Email    6/18/2020                                bamagoodwill.o     Goodwill           following COVID shutdowns, that might help more participate while mitigating risk.
Facilities            from Web)     12:00:00 AM     Wells       Dave         rg                 Industries, Inc.
Staff Group - Main
Street Lending
Program - Nonprofit
                                                                             Personal Email
Organization          PIO (Email    6/18/2020                                Address                               The requirement to have at least 50 employees excludes almost every nonprofit in Baltimore City that is working diligently to keep people alive.
Facilities            from Web)     12:00:00 AM     Keely       Linda
Staff Group - Main
Street Lending
Program - Nonprofit                                                                                                Providing lending capital to non-profits will not only benefit local communities but can strengthen the non-profits on the ground serving our most
Organization          PIO (Email    6/18/2020                                maria.benjamin                        vulnerable communities.
Facilities            from Web)     12:00:00 AM     Benjamin    Maria        @sfgov.org         MOHCD

                                                                                                                      Page 27 of 300
                                                                                                          Main Street Lending Program
                                                                                                        Nonprofit Organizations Comments

    Event Title /
    Description       Ticket Type   Received Date   Last Name   First Name    Email Address      Affiliation                                                                           Comment
Staff Group - Main
Street Lending
Program - Nonprofit
                                                                             Personal Email
Organization          PIO (Email    6/18/2020       Herschens                Address
                                                                                              ACT Theatre-       I support the Main Street Lending Program for Nonprofits Proposed by Federal Reserve and encourage to adopt this program.
Facilities            from Web)     12:00:00 AM     ohn         Michael                       Seattle
                                                                                              Mercy and          You wanted comments on the non-profit lending program. We do not have 50 associates so I wish that number could be decreased. Smaller
                                                                             Personal Email
Coronavirus           PIO (Email    6/18/2020                                Address
                                                                                              Truth Medical      non-profits are doing amazing things with so little and should be eligible, especially if they have sound and solid financials.
(COVID-19)            from Web)     12:00:00 AM     Rauth       Anne                          Missions
Staff Group - Main
Street Lending                                                                                                   I am not in favor of the NONLF and NOELF programs (nor the other Fed stimulus programs for that matter). The credit markets are functioning
Program - Nonprofit                                                                                              properly. Asset prices are artificially inflated as a result of the Fed's persistent actions. Please disclose the names of the legal entities that
Organization          PIO (Email    6/18/2020                                jon@cycadcap.                       received capital via the NONLF and NOELF programs.
Facilities            from Web)     12:00:00 AM     Maietta     Jon          com              Cycad Capital
                                                                                                                 Please open the Main Street Lending Program to not-for-profit organizations. Although, we are in the not-for-profit sector, we are still
                                                                                                                 businesses and we are facing the same challenges as the for-profit sector. And, in some cases, the pressures are even worse with the limited
                                                                                                                 access to capital and reduced revenues from donations. This loan program will give us flexibility to apply for assistance like any other business
                                                                                                                 entity.

                                                                                                                 Thank you,

Coronavirus           PIO (Email    6/18/2020                                mclean@afev.u    Air Force          Brooke
(COVID-19)            from Web)     3:27:00 PM      McLean      Brooke       s                Enlisted Village
                                                                                                                 It would be great to support local, small CDFIs, and local nonprofits that provide technical assistance, microloans and loans with zero interest,
                                                                                                                 some small grants, to help small businesses, home- based and some that use incubators or common areas, to build capacity, specially, in the
                                                                                                                 business side. There are funds, with grants still available, but many small businesses, over 50% in LMI areas, don't qualify because they
                                                                             tomas.porturas                      don't have the documentation needed like financial statements, etc. I think, it could be a great opportunity to help these small businesses
Coronavirus           PIO (Email    6/19/2020                                @wellsfargo.co                      succeed so that they become bigger contributors to our economy, thank you!.
(COVID-19)            from Web)     12:00:00 AM     porturas    tomas        m                wells fargo




                                                                                                                    Page 28 of 300
                                                                                                           Main Street Lending Program
                                                                                                         Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name     Email Address      Affiliation                                                                      Comment
                                                                                                                The California Association of Nonprofits (CalNonprofits) appreciates the opportunity to submit our comments in support of a Main Street
                                                                                                                Lending Program for nonprofit organizations. CalNonprofits is a statewide policy alliance of more than 10,000 organizations and the voice for
                                                                                                                California's nonprofit community. Through our advocacy work, we protect and enhance the ability of California's nonprofits to serve
                                                                                                                our state, the nation, and the world.

                                                                                                                We have heard from a number of larger nonprofits that they are struggling because they have been ineligible to participate in economic relief
                                                                                                                programs like the Small Business Administration's Paycheck Protection Program (PPP) or the Advance Program of the Economic Injury
                                                                                                                Disaster Loan (EIDL). Yet, these larger nonprofits are providing essential services to their communities, while at the same time, experiencing
                                                                                                                increased operational costs and reduced revenues. The Main Street Lending Program will help these organizations continue to provide, during
                                                                                                                and after this crisis, vital programs relied on by their communities.

                                                                                                                So, we are pleased to see this new Main Street Lending Program that will include nonprofits up to 15,000 employees. However, some of the
                                                                                                                details of the proposed program are not well suited to the wide range of nonprofit organizations that could benefit and are misaligned with the
                                                                                                                economic realities of nonprofit operations.

                                                                                                                Given these concerns, we make the following recommendations with regard to the current program proposal:
                                                                                                                 Eliminate the 50-employee minimum eligibility requirement.
                                                                                                                 Provide eligible nonprofits with access to loan forgiveness.
                                                                                                                 Eliminate the requirement that no more than 30 percent of an organization's 2019 revenues come from donations.
                                                                                                                 Eliminate or lessen borrower requirements 7 and 8.
                                                                                                                 Offer interest rates comparable to the rate for the SBA's PPP (1%), if possible, but no higher than the nonprofit rate for the EIDL (2.75%).
                                                                                                                 Eliminate or reduce loan origination and service fees.
                                                                                                                 Offer the opportunity to negotiate amortization over a longer time period to reduce possible balloon payments.
                                                                                                                 Eliminate the requirement that the ratio of adjusted 2019 earnings before interest, depreciation, and amortization to unrestricted 2019
                                                                                                                operating revenue be greater than or equal to 5%.
                                                                                                                 Clarify the terms: "maintain its payroll" and "retain its employees."
                                                                                                                 Determine reasonable efforts based on the totality of the circumstances, including taking into account fundraising abilities, revenue-generating
                                                                                                                activities, and demand for services.
                                                                                                                 Adopt safe harbors for the employee retention provisions.
                                                                                                                 Increase flexibility re collateral requirements and clarify the resources that should be included in endowment calculations.

                                                                                                                To make this loan opportunity one that truly benefits nonprofits and the communities they serve, the program elements and requirements must
Staff Group - Main                                                                                              reflect the unique economic realities of nonprofit operations. To do otherwise would be counterproductive, leading to long-term economic
Street Lending                                                                                                  challenges for these organizations at a time when communities need strong, thriving nonprofits serving them.
Program - Nonprofit                                                                            California
Organization          PIO (Email    6/19/2020                                  lucyc@calnonp   Association of   Please do not hesitate to contact CalNonprofits should you have questions regarding the above recommendations.
Facilities            from Web)     12:00:00 AM     Carter      Lucy Salcido   rofits.org      Nonprofits



                                                                                                                I definitely support the Federal Reserve Board's proposal to expand its Main Street Lending Program to provide access to credit for
Staff Group - Main                                                                             San Francisco    nonprofit organizations. As a grant-maker in San Francisco, I have seen and heard how deeply the COVID-19 pandemic has impacted our
Street Lending                                                                                 Mayors Office    nonprofit partners, especially smaller grassroots organizations. I recommend that, to ensure these funds go to the less-resourced organizations
Program - Nonprofit                                                                            of Housing and   that truly need it, that U.S. nonprofits may be eligible for loans only if they meet either of the following conditions: (1) the nonprofit has 100
Organization          PIO (Email    6/19/2020                                  michael.king@   Community        employees or fewer; or (2) the nonprofit had 2019 revenues of $10 million or less. Thank you for the opportunity to provide this feedback!
Facilities            from Web)     12:00:00 AM     King        Michael        sfgov.org       Development




                                                                                                                   Page 29 of 300
                                                                                                           Main Street Lending Program
                                                                                                         Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name    Email Address       Affiliation                                                                         Comment



                                                                                                                Arizona State University shares the concerns expressed by APLU regarding the plans to expand the Main Street Lending Program (MSLP) to
                                                                                                                non-profit organizations. Arizona State University supports the following proposed modifications to the MSLP expansion to non-profit
                                                                                                                organizations.

                                                                                                                Ensure public colleges and universities are eligible for the nonprofit MSLP facility

                                                                                                                Under the proposed terms for the new facility, "nonprofit" is defined as "a tax-exempt nonprofit organization described in
                                                                                                                section 501(c)(3) of the Internal Revenue Code (IRC)." The proposal also notes that "other forms of organization may be
                                                                                                                considered for inclusion as a Nonprofit Organization under the Facility at the discretion of the Federal Reserve." Some public institutions
                                                                                                                of higher education do not have separate 501 (c)(3) status, however, and instead are organized as an entity of the state.

                                                                                                                Since the proposed terms note that other forms of organization may be considered for inclusion as nonprofit organizations, we urge the Federal
                                                                                                                Reserve to make explicit that both public institutions are eligible for these loans in the final guidance. We recommend that the final guidance on
                                                                                                                eligibility include the definition of institutions of higher education as defined by Sec. 101 (a) of the Higher Education Act of 1965 (20 U.S.C.
                                                                                                                1001(a)).

                                                                                                                Expand eligibility thresholds to ensure all colleges and universities can access the program

                                                                                                                Even with the expansion of the program to nonprofits with up to 15,000 employees, some large public universities and systems of higher
                                                                                                                education will not qualify under the current threshold. We ask that public and nonprofits of all sizes be made eligible for these loans, regardless
                                                                                                                of the number of their employees, given the importance of these institutions to their communities and regions, as well as their direct and
                                                                                                                indirect economic impact within their states.

                                                                                                                Lengthen the term of the loans to account for the unique needs of universities

                                                                                                                Given the financial cycle of public universities, the Federal Reserve should offer longer deferments and repayment terms for nonprofits than
Staff Group - Main                                                                                              what is currently included in the MSLP. For example, at colleges and universities, any enrollment declines at the start of fall 2020 will affect our
Street Lending                                                                                                  institutions for at least an additional four years as that smaller class advances through their degree programs. A longer repayment period (at
Program - Nonprofit                                                                                             least 6-8 years) as well as a longer interest deferment period (2 years or longer) will help to ensure nonprofits are on better financial standing
Organization          PIO (Email    6/19/2020                                joanne.wamsle     Arizona State    to make payments on these loans.
Facilities            from Web)     12:00:00 AM     Wamsley     Joanne       y@asu.edu         University
                                                                                                                I think it is great that at the federal reserve is working to assist businesses and non-profits as we all try to navigate the pandemic challenges. I
                                                                                                                would like to ask you to please consider lowering your employee minimum. You are falsely assuming that more employees equates to larger
                                                                                                                capacity and possibly the ability to pay back a loan. I can speak for my organization - and have numerous colleagues who run high impact
                                                                                                                organizations - with a small and dedicated team. We seem to be penalized here even though we have been negatively impacted by the virus
                                                                                                                and are trying to recalibrate back to PRE-virus revenue. The loan would make a huge difference for the organization and the million + people
                                                                                                                we support. We have less than 10 employees and generate 6-8M annually in revenue. It's not thousands or employees and billions of
                                                                                                                dollars but we make a big difference. If we had access to $1.5-2M loan it would allow us to thrive and we would pay that back within 3 years.
Staff Group - Main                                                                                              We are a 501-C-3 just like any other 501-C-3. Why discriminate based on size. We can't compete with the "non-profit"
Street Lending                                                                                 The National     universities and hospitals but if the goal is impact and payback please allow for smaller non-profits to be considered in this plan. This is really
Program - Nonprofit                                                                            Society of       important because it is the difference between 26 years of making a difference and literally considering closing even though we know we will
Organization          PIO (Email    6/19/2020                                                  Collegiate       be back on track once we are all beyond covid. Thanks so much for considering.
Facilities            from Web)     12:00:00 AM     LofI in     Stephen      loflin@nscs.org   Scholars
Staff Group - Main
Street Lending                                                               Personal Email
Program - Nonprofit                                                          Address                            I personally support expanding the Main Street Lending Program to non-profit organizations. For broader access, I further support halving the
Organization          PIO (Email    6/19/2020                                                                   minimum thresholds of 50 employees and minimum loan of $250,000 to 25 employees and $125,000 respectfully.
Facilities            from Web)     12:00:00 AM     Hanson      Alan




                                                                                                                   Page 30 of 300
                                                                                                        Main Street Lending Program
                                                                                                      Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name   Email Address     Affiliation                                                                        Comment




                                                                                                             The Composite Recycling Technology Center (CRTC) fully supports the idea of including not for profits in the Main Street Lending Programs.
                                                                                                             501 (c)3's like the CRTC have been hit hard by the pandemic and need assistance in order to recover and get back on our feet again.

                                                                                                             I have 3 upgrades to the program for your consideration:
                                                                                                             1. Years in Operation: At least 5 years -1 would like to see this be set at 3 years for the minimum. Newer not for profits are likely going to need
                                                                                                             more help then more well established entities. 3 years seems like a decent compromise by avoiding brand new not for profits but being more
                                                                                                             inclusive tothose who are at least established and have proved their ability to operate for 3 or more years.

                                                                                                             2. Employee Min/Max: Employees fewer than 15,000 and greater than 50 - The 15,000 max is fine but the minimum threshold is too high at 50.
                                                                                                             There are many fine not for profits that are doing great work with less. Also, many not for profits have a mix of employees and contractors, so
                                                                                                             the definition of an employee should include part-time and full-time contractors. Not for profits have to be efficient and use our donors
                                                                                                             resources wisely, so it does not seem fair to only offer the program to those entities that are large. I propose a minimum of 10 employees. It is
                                                                                                             enough to be of legitimate size but not so high as to eliminate many smaller not for profits.

                                                                                                             3. Revenue cap and source requirement: 2019 Revenues less than $5 billion, with less than 30% sourced from donations -1 am OK with a max
                                                                                                             of less than 5 billion although it seems quite high. Why does the donation percentage need to be so low at 30% or less? This will exclude many
                                                                                                             not for profits that are mainly donation sourced. I am not clear why the percentage is critical to the Fed. Whether a not for profit gets the
                                                                                                             majority of their income from donations or not, should not influence their worthiness to participate in the program. I would like to see the max
                                                                                                             donation percentage eliminated. If that is not doable then it should be raised to at least 75%.

                                                                                                             The CRTC is anxious to participate in this program and we could really use the loan but we would be excluded as we have been in operation
                                                                                                             for only 4 years (rejects us based on item #1 above), we only have 15 employees (rejects us based on item #2 above) and about 60% of our
Staff Group - Main                                                                                           revenue comes from donations (rejects us based on item #3 above).
Street Lending
Program - Nonprofit                                                                                          Thank you for the opportunity to share our perspective. We hope you will consider these adjustments as it sounds like a great program that
Organization          PIO (Email    6/19/2020                                dwalter@crtc-                   would be help many not for profits to be able to survive and make it to the other side of this pandemic.
Facilities            from Web)     12:00:00 AM     Walter      David        wa.org          CRTC




                                                                                                                Page 31 of 300
                                                                                                           Main Street Lending Program
                                                                                                         Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name   Email Address        Affiliation                                                                      Comment
                                                                                                                 The Utah Nonprofits Association has a mission to unify, strengthen, and elevate the nonprofits in Utah. And it is imperative that both Congress
                                                                                                                 and The Fed make necessary changes to the nonprofit organization loan eligibility program.

                                                                                                                 The Utah Nonprofits Association appreciates the opportunity to submit comment to the Federal Reserve about the Nonprofit Organization Loan
                                                                                                                 Facilities. This proposal is aimed more at transactional nonprofits such as hospitals and institutions of higher ed than at nonprofits like The
                                                                                                                 Utah Nonprofits Association that have a larger reliance on donations from the public to support their missions. Indeed, many nonprofits pride
                                                                                                                 themselves on offering their services at no charge. Recognizing that their business models are different, even if both types of charities are
                                                                                                                 inherently organized around a public mission, many of the financial requirements included in this proposal simply are not applicable to
                                                                                                                 organizations that rely on donations. With that in mind, The Utah Nonprofits Association respectfully requests the Federal Reserve to address
                                                                                                                 the concerns and proposed changes outlined below.

                                                                                                                 1. Congress Must Act to Ensure Mid-Sized Nonprofits are Eligible for Loan Forgiveness
                                                                                                                 Congress must ensure that mid-sized nonprofits have access to loan forgiveness. While it is a welcome development to see the Federal
                                                                                                                 Reserve making its Main Street lending program available to some nonprofits, this assistance still falls short of what is most needed by
                                                                                                                 nonprofit organizations - a provision that makes these loans forgivable.

                                                                                                                 In this critical time, nonprofits have stepped up to meet the unprecedented level of need in our country due to the COVID-19 pandemic. Even
                                                                                                                 though they face many of the same economic challenges as other industries, nonprofits are not shutting down. Rather, they are straining to
                                                                                                                 meet increasing demands in our communities on the frontlines, caring for the sick, feeding families, and keeping our communities connected.
                                                                                                                 Furthermore, they will play an integral role as our nation recovers - providing child care, job training, and other core supports.

                                                                                                                 Charitable nonprofits of all sizes and focus areas are struggling to maintain mission-critical operations despite enormous economic challenges.
                                                                                                                 Data released by Independent Sector shows that nonprofits with between 500 to 5,000 employees, key to scaling relief efforts across the
                                                                                                                 nation, have been severely impacted by this health and economic crisis. When asked "What types of additional assistance would be most
                                                                                                                 helpful to your organization?" organizations overwhelmingly (92% of responses) suggested government support in the form of forgivable
                                                                                                                 loans. Smaller nonprofits throughout the country have been hit equally hard.

                                                                                                                 Nonprofit organizations need funding so they can continue to meet the needs of their communities. Many charitable organizations do not have
                                                                                                                 steady streams of commercial income and have little capacity for loan and interest repayment. Furthermore, nonprofits are the third largest
                                                                                                                 employment sector and many hope to hire more workers as their organizations recover. America cannot afford to leave out such a vital part of
                                                                                                                 the economy.

                                                                                                                 Recommendation: Congress must recognize the vital services nonprofits provide to communities and the economy by including loan
                                                                                                                 forgiveness, in the next round of COVID-19 relief legislation

                                                                                                                 2. The Fed's Proposal to Limit Loans to Mid-Size Nonprofits with Less than 30% of Revenue from Donations Disqualifies Many in
                                                                                                                 Charitable Sector
                                                                                                                 The Federal Reserve's criteria that organizations must have revenues from donations that are less than 30% disqualify many charities,
                                                                                                                 including The Utah Nonprofits Association. Overall, this loan facility seems more applicable to for-profit entities, as well as educational
                                                                                                                 institutions and nonprofit hospitals, but not most charitable organizations.

                                                                                                                 We raise money and receives donations from the public, foundations, corporations and others to fund professional development and resources
                                                                                                                 gathering for nonprofit best practices and we do not receive a significant amount of revenue through direct services. Charitable organizations
                                                                                                                 play a fundamental role in strengthening civil society. Our organizations provide vital services for the nonprofits in Utah and the nation, and
                                                                                                                 pride ourselves on the donations we receive rooted in the trust and support that the public has of the sector.

                                                                                                                 Recommendation: Eliminate the requirement that no more than 30 percent of an organization's 2019 revenues come from donations, and
                                                                                                                 instead make 501(c)(3) organizations that are otherwise meet the employee size are eligible.
Staff Group - Main
Street Lending                                                                                                   3. The Fed Needs to Make Loan Terms More Favorable to Charitable Organizations
Program - Nonprofit                                                          krubalcava@ut                       The draft Nonprofit Loan Facility imposes certain liquidity, asset, and reserve requirements that are not required in Main Street New Loan
Organization          PIO (Email    6/19/2020                                ahnonprofits.or   Utah Nonprofits   Facilities available to for-profit businesses.
Facilities            from Web)     12:00:00 AM     Rubalcava   Kate         9                 Association

                                                                                                                    Page 32 of 300
                                                                                                Main Street Lending Program
                                                                                              Nonprofit Organizations Comments

Event Title 1
Description     Ticket Type   Received Date   Last Name   First Name   Email Address   Affiliation                                                                         Comment
                                                                                                     Nonprofit organizations typically provide services with low-profit margins. Indeed, social service organizations report an average aggregate
                                                                                                     margin of 1.5%. According to a recent report by Seachange Capital Partners, the median social services nonprofit has a margin of 1.0%,
                                                                                                     receives 3.6% of its revenue from philanthropy (including investment income), has total financial assets (including endowments and other
                                                                                                     assets that are subject to legal restrictions) equal to 1.9 months of expenses, and operating reserves of less than one month of expenses. Less
                                                                                                     than 20% of large nonprofits have 6 months or more of operating reserves, a widely accepted standard for "financial strength" for
                                                                                                     nonprofits. Social services organizations are the most fragile, with fewer than 10% reaching this standard.

                                                                                                     The statistics above should not be viewed as an indictment of the efficiencies or management policies of nonprofits. It is important to note that
                                                                                                     the vast majority of social service nonprofit funding comes from government grants contracts, recognizing the key role such organizations play
                                                                                                     in serving the most vulnerable. Numerous studies confirm that government funding seldom covers the full cost of providing contracted work,
                                                                                                     which inhibits nonprofits from accumulating reserves through surpluses. In many instances, government grant/contract work creates cash-flow
                                                                                                     challenges since it is paid after the work has been completed and can be subject to significant delays in payment.

                                                                                                     Recommendation: Recognizing the unique nature of nonprofit operations and their importance in continuing to provide vital services as
                                                                                                     partners on the front lines of the COVID-19 crisis, we urge the Federal Reserve to eliminate borrower requirements 7 and 8. If this is not
                                                                                                     possible, we alternatively ask that the requirements be lessened significantly to reflect the economic realities of nonprofit operations, for
                                                                                                     example by requiring only 30 days cash on hand, and bringing the loan origination ratio of 40-50% (down from 65% as proposed).

                                                                                                     We are also concerned that certain eligible loan features are too onerous for nonprofit organizations and are less favorable than those offered
                                                                                                     in other government programs. Specifically, the interest rate of LIBOR plus 300 basis points is significantly higher than that offered for
                                                                                                     Paycheck Protection Program ("PPP") Loans (1.0%) and that for Economic Injury Disaster Loans (2.75%). In addition, the
                                                                                                     imposition of loan origination and service fees adds to the cost under the Nonprofit Facility. Finally, the notion that nonprofits would be faced
                                                                                                     with a 70% balloon payment at the end of the fifth year of the loan would be off-putting for many nonprofits. Nonprofits with existing loans with
                                                                                                     balloon payments are usually provided an opportunity to renegotiate such loans at prevailing market rates.

                                                                                                     Recommendation: We urge that the loan terms including interest rate and balloon payments be revisited and recommend the lowest
                                                                                                     permissible rate such as the 0.5% rate initially proposed for PPP loans. In addition, we urge some flexibility in the balloon payment requirement
                                                                                                     to afford the opportunity for renegotiation. If the 5-year amortization were extended to 7 years, this could lessen the balloon payment. We
                                                                                                     request that the borrower have access to engage with derivatives (change to a fixed rate) without the minimum swap requirements.

                                                                                                     4. The Ratio of Adjusted 2019 Earnings before "EBIDA" Should Be Revised
                                                                                                     In the "Draft for Public Consultation," for both the Nonprofit Organization New Loan Facility and the Nonprofit Organization
                                                                                                     Expanded Loan Facility, one of the eligibility criteria for borrowers is that they must have "a ratio of adjusted 2019 earnings before
                                                                                                     interest, depreciation, and amortization ("EBIDA") to unrestricted 2019 operating revenue, greater than or equal to 5%." (#6)
                                                                                                     In the context of nonprofit operations, this threshold is too high and would make many, if not most, nonprofits ineligible based on these criteria
                                                                                                     alone, which seems written more in the context of for-profit businesses as opposed to nonprofit organizations.

                                                                                                     It may certainly be prudent and necessary to have a positive ratio of adjusted earnings; however, nonprofits generally run on a small margin,
                                                                                                     both out of necessity and also so as to not leave excess surpluses that could be used for fulfilling their missions. Moreover, at times a nonprofit
                                                                                                     may have a planned and manageable deficit as part of a strategic plan-a negative ratio at one isolated point is not always an indication of
                                                                                                     instability.

                                                                                                     Furthermore, the footnotes for criteria #6 clarify that "The Eligible Lender should calculate operating revenue as unrestricted operating
                                                                                                     revenue, excluding funds committed to be spent on capital." Many nonprofits have "restricted revenue" through grants and
                                                                                                     contracts built into their operating budgets. Excluding this revenue would compound the problem of meeting the 5% ratio. Although it would be
                                                                                                     sensible to exclude contributions raised for a "capital campaign," excluding other capital funds included in an annual budget for
                                                                                                     maintenance and planned upgrades would further decrease the required ratio.

                                                                                                     Recommendation: The 5% requirement should be reduced to zero, if not eliminated. In addition, a statement of explanation of a deficit should
                                                                                                     be allowed so that a negative ratio does not mean automatic ineligibility for a nonprofit borrower. Finally, further clarification on the calculation
                                                                                                     methodology -in the context of nonprofit operating budgets- is needed in regard to both restricted funding from grants in annual operating
                                                                                                     budgets, as well as capital funds for improvements that are part of an annual operating budget. This clarification would allow noted revenues to
                                                                                                     remain in calculation to ease the restriction and not further restrict eligibility.

                                                                                                        Page 33 of 300
                                                                                                           Main Street Lending Program
                                                                                                         Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name    Email Address       Affiliation                                                                        Comment

                                                                                                                5. "Reasonable Efforts" Regarding Employee Retention Require Further Clarification
                                                                                                                The description of "Retaining Employees" in the draft term sheet requires refinement if the Federal Reserve expects nonprofits to
                                                                                                                take advantage of this facility. We endorse the analysis of the National Council of Nonprofits on the issue of employee retention, and
                                                                                                                recommend the following:

                                                                                                                Recommendation: "Reasonable efforts" should be interpreted in the totality of the circumstances, taking into consideration not only
                                                                                                                the general economic environment in the community or communities in with the borrower operates, but also factors such as workforce,
                                                                                                                fundraising ability, revenue-generating activities, and overall demand for the services and programs the organization provides. One option
                                                                                                                would be to add the qualifier "mission-based" before "reasonable efforts."

                                                                                                                Recommendation: The terms "maintain its payroll" and "retain its employees" are vague and need further refinement.
                                                                                                                We ask the Federal Reserve to make clear that nonprofits participating in the Main Street loan program generally should endeavor to pay staff
                                                                                                                at the same or increased income levels and should act in good faith to keep staffing levels (measured on the basis of full-time equivalents) at
                                                                                                                the same or increased levels, both for the duration of the loan. It is also important that the loan documents expressly state that the employee
                                                                                                                retention provision begins on the date that loan funding is received by the borrower rather than at an earlier date.

                                                                                                                Recommendation: We ask that the Federal Reserve adopt safe harbors of other loan programs and state clearly that nonprofit borrowers will
                                                                                                                not be penalized under the employee retention provision for the decision of employees to decline offers of rehire, or for those who are fired for
                                                                                                                cause, voluntarily resign, or voluntarily request a reduced schedule during the time that the loan is outstanding.

                                                                                                                6. Limitation of 50-Employee Minimum Should Be Removed
                                                                                                                The term sheet for the proposed nonprofit loan facility imposes a size minimum that is not imposed in the Main Street New, Priority, or
                                                                                                                Expanded Loan Facilities for for-profit businesses. There is no explanation why the Federal Reserve is proposing that nonprofits with fewer
                                                                                                                than 50 employees should not be eligible for Main Street loans for which their small business counterparts of equal size could secure lending
                                                                                                                support.

                                                                                                                Recommendation: The 50-employee floor should be removed.

                                                                                                                7. Additional Recommendations and Requests for Clarification
                                                                                                                The Utah Nonprofits Association respectfully requests the Federal Reserve clarify the following issues in its final expansion notice.
                                                                                                                 Endowment: What resources should be included in endowment calculations? Does it include restricted endowments? Does it extend to include
                                                                                                                cash on hand?
                                                                                                                 Collateral: Flexibility on collateral is requested. The loan should be able to be approved with no more than 50% Loan to Value (LTV) if
                                                                                                                collateral is needed.
                                                                                                                 Other Debts: The proposal requires that borrowers, "refrain from repaying the principal balance of, or paying any interest on, any debt
                                                                                                                until the Eligible Loan is repaid in full, unless the debt or interest payment is mandatory and due." We request that this exclude lines of
                                                                                                                credit and other debt that are assumed to provide financial liquidity related to the impact of COVID-19.

                                                                                                                According to Reuters, the Federal Reserve says that "repayment data showed nonprofits to be a relatively safe group to lend to and that
                                                                                                                the minimum employee size criteria of 50 employees was determined to be a good indicator of a nonprofit's ability to repay any
                                                                                                                loan."

                                                                                                                I strongly disagree. This is a random number that does not have any relevance to a business being able to repay a loan.
                                                                                                                Limiting the availability of funding to nonprofits who employ 50 or more people restricts funding to smaller nonprofits that supply many rural
Staff Group - Main                                                                                              counties with vital services that they cannot be without. Please consider providing this critical funding to nonprofit organizations of smaller sizes
Street Lending                                                                                                  (25 employees) and keep the charitable heartbeat of our country continuing into the future by providing funding needed during this time of
Program - Nonprofit                                                          griley@berkshir                    profound financial hardship, especially in non-urban areas.
Organization          PIO (Email    6/19/2020                                ewaldorfschool.   BBerkshire       Thank you.
Facilities            from Web)     12:00:00 AM     Riley       George       org               Waldorf School
Other: Allowing                                                              Personal Email
Non-Profits to        PIO (Email    6/19/2020                                Address                            I do not support using government funds to bail out Non Profits. This is socialism at its finest. This is not capitalism and should not be allowed!
Benefit               from Web)     12:00:00 AM     Fagan       Karen                          Ms.


                                                                                                                   Page 34 of 300
                                                                                                          Main Street Lending Program
                                                                                                        Nonprofit Organizations Comments

    Event Title /
    Description       Ticket Type   Received Date   Last Name   First Name   Email Address       Affiliation                                                                       Comment
Staff Group - Main
Street Lending                                                                                                 Thank you for these mechanisms being made available to the non profit community. Two recommendations. 1) Consider a 20% drop in
Program - Nonprofit                                                                                            revenues versus 30%. 2) Consider a 60 day working reserve for operations versus 90 days. These two considerations will capture a larger
Organization          PIO (Email    6/19/2020                                Scott.jackson@                    number of domestic non profits who could qualify for the programs.
Facilities            from Web)     12:00:00 AM     Jackson     Scott        charity.org      Global Impact


                                                                                                               Since Congress has yet to authorize 501 C 6 organizations to apply for the PPP, this is a fine alternative. However, so many non-profits have
                                                                                                               less than 50 employees which is the threshold listed in the proposed program. The Fed should reconsider and lower the threshold allowing for
                                                                                                               501 C organizations to qualify for the loans with a minimum of employees. So many of us exist on private sector funding which has been
Staff Group - Main                                                                                             impacted by the C19 virus situation and many need loan assistance to extend operations into the next year.
Street Lending                                                                                Committee of
Program - Nonprofit                                                                           100 for          Michael Olivier
Organization          PIO (Email    6/19/2020                                mjo@c100la.or    Economic         Committee of 100
Facilities            from Web)     12:00:00 AM     OLIVIER     MICHAEL      9                Development
                                                                                                               I am strongly in favor of offering this opportunity to non-profits. We received funding through the PPP but this money will only cover us through
                                                                                                               June. Our agency's mission is providing behavioral health services to students in the Akron, Ohio school district.

                                                                                                               The Covid pandemic had a significant impact on our ability to provide these services once the schools were closed. We anticipate schools will
                                                                                                               not return to normal operation in the fall and thus this will continue to have an impact on our ability to provide services and our revenue stream
Staff Group - Main                                                                                             through the end of the school year.
Street Lending
Program - Nonprofit                                                                           Pastoral         By being able to access additional lending sources, this will allow our agency to continue to operate without having to cut back on providing
Organization          PIO (Email    6/19/2020                                mburke@redoa     Counseling       these vital services to the children and teenagers in the inner city of Akron.
Facilities            from Web)     12:00:00 AM     Burke       Mike         kbh.org          Services
Staff Group - Main
Street Lending
Program - Nonprofit                                                          Personal Email   Shakespeare      The Berkshire Waldorf school is essential to the well-being of our community. Please extend the loan so that they may continue to be a shining
                                                                             Address
Organization          PIO (Email    6/19/2020                                                 &            light and continue to employ all of their wonderful and hard-working faculty and staff. Thank you
Facilities            from Web)     12:00:00 AM     May         Corinn                        Company




                                                                                                               As the Federal Reserve Board considers expanding its Main Street Lending Program to non-profits, I respectfully ask on behalf of our 100 CEO
                                                                                                               members, that it allow all 501c entities to be eligible, regardless of size.

                                                                                                               The Vermont Business Roundtable (Roundtable) is a nonprofit, nonpartisan organization of chief executive officers of Vermont's leading
                                                                                                               private and nonprofit employers, representing geographic diversity and all major sectors of the Vermont economy. The Roundtable is
                                                                                                               committed to sustaining a sound economy and preserving Vermont's unique quality of life by studying and making recommendations on
                                                                                                               statewide public policy issues. You may learn more at www.vtroundtable.org.

                                                                                                               The Roundtable is organized as a 501(c)(4) civic welfare organization and has a very small staff of three. We depend on private sector support
                                                                                                               (through membership dues) to advance our mission. Because our members have universally been impacted by the current economic collapse,
                                                                                                               our viability is also at risk. The Main Street Lending Program will provide an important bridge to economic recovery for our organization and
                                                                                                               other non-profits that are in similar financial straits.

Staff Group - Main                                                                                             Thank you for your consideration.
Street Lending
Program - Nonprofit                                                                           Vermont          s/Lisa Ventriss, President
Organization          PIO (Email    6/19/2020                                lisa@vtroundta   Business         Vermont Business Roundtable
Facilities            from Web)     12:00:00 AM     Ventriss    Lisa         ble.org          Roundtable



                                                                                                                  Page 35 of 300
                                                                                                       Main Street Lending Program
                                                                                                     Nonprofit Organizations Comments

   Event Title /
   Description     Ticket Type   Received Date   Last Name   First Name   Email Address       Affiliation                                                                        Comment




                                                                                                            Thank you for the opportunity to provide input into the Main Street Lending Program for Nonprofits. As a nonprofit with over 500 employees
                                                                                                            serving over 13,000 children and families, we have experienced both revenue losses and increased expenses in serving clients and keeping
                                                                                                            them and staff safe. There has been no available relief to mitigate the financial challenges we have faced. We appreciate the Federal Reserve
                                                                                                            Bank's attention to addressing the needs of mid- to large-sized nonprofits. Following are our comments on the nonprofit program as it has
                                                                                                            been proposed:

                                                                                                            1. Loan forgiveness - Recognizing that the Fed cannot grant loan forgiveness, we call on Congress to pass legislation ensuring that mid-sized
                                                                                                            nonprofits have access to loan forgiveness. This is a priority for the sector.
                                                                                                            2. 30% limit on revenue from donations - This 30% limit seems more aimed at for-profit businesses than nonprofits. It will disqualify many from
                                                                                                            the charitable sector.
                                                                                                            3. Liquidity - The Fed proposal requires high levels of liquidity, however the pandemic has reduced liquidity and makes this a challenge.
                                                                                                            4. Interest rates - The interest rates are proposed as the same as for for-profit businesses. Both the PPP and EIDL provide lower interest rates
                                                                                                            for nonprofits and this program should be comparable. The fees, especially without access to loan forgiveness, are also onerous.
                                                                                                            5. Balloon payment - The proposal includes a 70% balloon payment in five years, though nonprofits do not expect to have excess cash in five
                                                                                                            years to meet this balloon payment. Perhaps this payment schedule could be extended, or provide a potential to renegotiate a few years into
                                                                                                            the loan period?
                                                                                                            6. EBIDA (Earnings before interest, depreciation, and amortization) - Requiring unrestricted 2019 operating revenue be greater than or equal to
                                                                                                            5% is overly restrictive for nonprofits facing financial difficulty. The requirement is not that operating revenue be greater than or equal to 5% but
                                                                                                            that "2019 EBIDA margin" be greater than or equal to 5% ("has a ratio of adjusted 2019 earnings before interest, depreciation,
                                                                                                            and amortization ("EBIDA") to unrestricted 2019 operating revenue, greater than or equal to 5%"). The effect of this is to deny
                                                                                                            eligibility to essential not-for-profit providers who were already operating on a thin margin prior to COVID-19 and whose ability to continue to
                                                                                                            provide those services may have been most profoundly impacted by the business disruptions caused by the pandemic. It is reasonable that
                                                                                                            lenders have some protection in this process, but the liquidity requirement, subject to the feedback noted in #3 above, should already address
                                                                                                            that, such that a further requirement around 2019 EBIDA margin only serves to exclude not-for-profits that may most benefit from the support.
                                                                                                            If the goal here is to support not-for-profits that a) are providing essential services in a time of crisis in our communities, and b) could most
                                                                          carol.grimaldi@                   benefit from that support in order to continue to provide those services, the inclusion of this "EBIDA margin" requirement erodes the
Coronavirus        PIO (Email    6/19/2020                                cornerstonesof    Cornerstones    goal.
(COVID-19)         from Web)     12:00:00 AM     Grimaldi    Carol        care.org          of Care




                                                                                                               Page 36 of 300
                                                                                                          Main Street Lending Program
                                                                                                        Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name    First Name   Email Address      Affiliation                                                                       Comment
                                                                                                               Good morning-

                                                                                                               My firm assists and advises non-profit organizations in the Kansas City metro and around the US on debt, debt management and debt
                                                                                                               issuance. I'm providing these comments on the Nonprofit MSLP generically, but with input from larger non-profit clients like the YMCA of
                                                                                                               Greater Kansas City, who focus on social services. Many of these entities needed but could not qualify for the PPP program due to their
                                                                                                               sizable part-time staffs. These organizations have a number of common characteristics:

                                                                                                                they operate at very thin margins. This is both by necessity and design. A social service non-profit is interested in maximizing its impact on the
                                                                                                               communities it serves. As a result, a fiscal year with a cash breakeven (and, as a result, a GAAP loss) is often considered a positive result

                                                                                                                they rely heavily on program income and typically see very concentrated pockets of positive margin in their operations offsetting operating
                                                                                                               losses in communities that cannot financially support the services being provided

                                                                                                                the programs driving that income are typically people-focused: child care programs, Head Start programming, community functions, etc. As a
                                                                                                               result of COVID-19, social service organizations saw a top line revenue cliff in March: as states imposed stay-at-home orders, non-profits were
                                                                                                               required to shut down their programs immediately suffering an equally immediate loss of income

                                                                                                                knock-on losses continue as the communities they serve cannot afford membership fees, as programs reopen with significant participation
                                                                                                               restrictions, etc.

                                                                                                               We appreciate the Fed and the Treasury recognizing that the "third sector" is critically important to the reopening of the economy.
                                                                                                               Unfortunately, the qualification requirements of the Nonprofit MSLP as proposed will not allow a number of our worthy and desiring social
                                                                                                               service non-profits to qualify. Key concerns include:

                                                                                                               1) Operating margin requirements (EBIDTA as % of top line revenue). We encourage the Fed to consider a smaller margin threshold for social
                                                                                                               service non-profits (1-2%) and to consider allowing a pattern of positive margin over a short historical period (3 of 5 years or 2 of 3 years),
                                                                                                               rather than a one-time test.

                                                                                                               2) The days-cash-on-hand requirement at the time of loan origination is particularly challenging given that these organizations have been in
                                                                                                               dramatic cash-burn situation since mid-March. Some of these organizations suffered nearly 100% top line revenue loss as program income
                                                                                                               simply stopped; expenses cannot be stopped equally quickly. We encourage the Fed to consider a lookback to 2019 or 2018/19 to provide
                                                                                                               non-profits with the ability to show that, under normal conditions, they were able to maintain sufficient liquidity cushion for operations.

                                                                                                               3) Many social service non-profits have significant real estate portfolios with secured debt outstanding on those facilities. Fundraising tends to
                                                                                                               be focused on capital construction and not endowment-building. As a result, the unrestricted cash/investments (UCI) to debt test is nearly
                                                                                                               impossible for many of my clients to meet, despite having material amounts of amassed equity in their real estate portfolios. Again, the purpose
                                                                                                               of a social service non-profit is to drive resources into the communities it serves. Very few benefit from significant pools of UCI in their
                                                                                                               operating budgets and even fewer have sizable endowments or quasi-endowments.

                                                                                                               We encourage the Fed to explore more deeply the mission of social service non-profits in the context of its underwriting criteria and also to
                                                                                                               consider many of these venerable organizations have existed for more than 100 years. Despite operating on a proverbial shoestring, they
                                                                                                               manage to continue to operate year-after-year in the face of uncertainty. Commercial lenders operating in this space are forced to consider
                                                                                                               these "intangible" factors when doing loan underwriting because traditional commercial lending requirements often cannot be met.
                                                                                                               We encourage the Fed and the Treasury to do the same.

                                                                                                               Respectfully submitted,
                                                                                                               COLUMBIA CAPITAL MANAGEMENT, LLC
Staff Group - Main
Street Lending                                                                                 Columbia        Jeff White
Program - Nonprofit                                                                            Capital         Managing Member
Organization          PIO (Email    6/19/2020                                 jwhite@columbi   Management,     913.312.8077
Facilities            from Web)     12:00:00 AM     White       Jeff          acapital.com     LLC


                                                                                                                  Page 37 of 300
                                                                                                          Main Street Lending Program
                                                                                                        Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name   Email Address       Affiliation                                                                            Comment
                                                                                                                 Providing access eligibility to nonprofits has the potential to provide significant relief to small- and medium-sized organizations. This will
                                                                                                                 support the intent expressed by Congress in the CARES Act that the program should provide liquidity support to all industries through federally
Staff Group - Main                                                                                               guaranteed lending. This action will help arts and cultural nonprofits weather the current crisis until they can fully operate again.
Street Lending
Program - Nonprofit                                                          Sss Ema"         Missouri           We respectfully urge the Federal Reserve Board to approve the Nonprofit Organization Expanded Loan Facility to facilitate lending to nonprofit
Organization          PIO (Email    6/19/2020                                                 Citizens for the   organizations by eligible lenders under the Main Street Lending Program. Thank you for your consideration of these comments.
Facilities            from Web)     12:00:00 AM     Iman        Kyna                          Arts




                                                                                                                 Despite mandated facility closures, cancellation of traditional programming and a decrease in giving, YMCAs have stepped up to address the
                                                                                                                 critical need for safe childcare options and other needed services across the country. At the height of the pandemic the Y offered emergency
                                                                                                                 childcare at more than 1,100 locations nationwide for families of medical personnel, essential employees and first responders. With school
                                                                                                                 closures, children cannot access USDA breakfasts and lunch and during this time of economic uncertainty, a rapidly increasing number of
                                                                                                                 adults and families are facing food insecurity. In response, over 1,000 Ys nationwide are providing free grab-and-go meals to help address this
                                                                                                                 urgent need. As the YMCAs in ND, SD, and NE begin to reopen their facilities, the emergency work needed that they gladly stepped up to fulfill
Staff Group - Main                                                                                               doesn't stop; it will be added to the traditional programs and services that will begin again. To accomplish all that is being asked of these
Street Lending                                                                                                   Ys, congress must ensure that mid-sized nonprofits have access to loan forgiveness. While it is a welcome development to see the Federal
Program - Nonprofit                                                                                              Reserve making its Main Street lending program available to some nonprofits, this assistance still falls short of what is most needed by
Organization          PIO (Email    6/19/2020                                mike.gulick@ya   YMCAs of ND,       nonprofit organizations - a provision that makes these loans forgivable. Thank you.
Facilities            from Web)     12:00:00 AM     Gulick      Mike         lliance.org      SD, and NE
                                                                                                                 To Whom It May Concern:

                                                                                                                 The YMCA of the USA (Y-USA) is respectfully submitting these comments in response to the Federal Reserve Board's announcement on
                                                                                                                 June 15, 2020 that it is seeking public feedback on the proposal to expand its Main Street Lending Program for nonprofit organizations. We
                                                                                                                 appreciate the Federal Reserve Board making this program available to nonprofits; however, there are several concerns outlined below that
                                                                                                                 could help improve the program and make it truly applicable and accessible to nonprofit organizations, such as local YMCAs.

                                                                                                                 YMCA of the USA is the national resource office for the nation's 2,700 local 501 (c)3,
                                                                                                                 charitable, nonprofit YMCAs. Each of these YMCAs helps strengthen their local communities through youth development, healthy living, and
                                                                                                                 social responsibility. Annually, YMCAs engage 22 million men, women, and children-regardless of age, income, or background-to nurture the
                                                                                                                 potential of children and teens, improve the nation's health and well-being, and provide opportunities to give back and support neighbors.
                                                                                                                 The Y works side-by-side with its neighbors to make sure everyone has the opportunity to learn, grow, and thrive.

                                                                                                                 Despite mandated facility closures, cancellation of traditional programming and a decrease in giving, the Y has stepped up to address the
                                                                                                                 critical need for safe childcare options and other needed services across the country. At the height of the pandemic the Y offered emergency
                                                                                                                 childcare at more than 1,100 locations for families of medical personnel, essential employees and first responders. With school closures,
                                                                                                                 children cannot access USDA breakfasts and lunch and during this time of economic uncertainty, a rapidly increasing number of adults and
                                                                                                                 families are facing food insecurity. In response, over 1,000 Ys nationwide are providing free grab-and-go meals to help address this urgent
                                                                                                                 need.

                                                                                                                 Citizens in communities of all sizes are depending on local charitable nonprofits to a far greater degree during the response and relief phases
                                                                                                                 to the COVID-19 health and economic crises, and that reliance will only grow during the recovery period ahead (including response and relief
                                                                                                                 for any second and third waves of the virus).

                                                                                                                 Y-USA has worked with YMCA State Alliances and local Ys to identify and address areas of confusion and contradiction in regard to the much-
                                                                                                                 anticipated Mainstreet Lending Program. These real-life, current concerns and questions based on experiences of Ys across America are the
Staff Group - Main                                                                                               basis for the following comments and recommendations.
Street Lending
Program - Nonprofit                                                                                              Comments and Recommendations
Organization          PIO (Email    6/19/2020                                Neal.Denton@     YMCA of the        1. Congress Must Act to Ensure Mid-Sized Nonprofits are Eligible for Loan Forgiveness
Facilities            from Web)     12:00:00 AM     Denton      Neal         ymca.net         USA                Congress must ensure that mid-sized nonprofits have access to loan forgiveness. While it is a welcome development to see the Federal

                                                                                                                    Page 38 of 300
                                                                                                Main Street Lending Program
                                                                                              Nonprofit Organizations Comments

Event Title /
Description     Ticket Type   Received Date   Last Name   First Name   Email Address   Affiliation                                                                       Comment
                                                                                                     Reserve making its Main Street lending program available to some nonprofits, this assistance still falls short of what is most needed by
                                                                                                     nonprofit organizations - a provision that makes these loans forgivable.

                                                                                                     In this critical time, nonprofits have stepped up to meet the unprecedented level of need in our country due to the COVID-19 pandemic. Even
                                                                                                     though they face many of the same economic challenges as other industries, nonprofits are not shutting down. Rather, they are straining to
                                                                                                     meet increasing demands in our communities on the frontlines, caring for the sick, feeding families, and keeping our communities connected.
                                                                                                     Furthermore, they will play an integral role as our nation recovers - providing childcare, job training, and other core supports.

                                                                                                     Charitable nonprofits of all sizes and focus areas are struggling to maintain mission-critical operations despite enormous economic challenges.
                                                                                                     Data released by Independent Sector shows that nonprofits with between 500 to 5,000 employees, key to scaling relief efforts across the
                                                                                                     nation, have been severely impacted by this health and economic crisis. When asked "What types of additional assistance would be most
                                                                                                     helpful to your organization?" organizations overwhelmingly (92% of responses) suggested government support in the form of forgivable
                                                                                                     loans. Smaller nonprofits throughout the country have been hit equally hard.

                                                                                                     Nonprofit organizations need funding so they can continue to meet the needs of their communities. Many charitable organizations do not have
                                                                                                     steady streams of commercial income and have little capacity for loan and interest repayment. Furthermore, nonprofits are the third largest
                                                                                                     employment sector and many hope to hire more workers as their organizations recover. America cannot afford to leave out such a vital part of
                                                                                                     the economy.

                                                                                                     Recommendation: Congress must recognize the vital services nonprofits provide to communities and the economy by including loan
                                                                                                     forgiveness, in the next round of COVID-19 relief legislation

                                                                                                     2. The Federal Reserve Needs to Make Loan Terms More Favorable to Charitable Organizations
                                                                                                     The draft Nonprofit Loan Facility imposes certain liquidity, asset, and reserve requirements that are not required in Main Street New Loan
                                                                                                     Facilities available to for-profit businesses.

                                                                                                     Nonprofit organizations typically provide services with low-profit margins. Indeed, social service organizations report an average aggregate
                                                                                                     margin of 1.5%. According to a recent report by Seachange Capital Partners, the median social services nonprofit has a margin of 1.0%,
                                                                                                     receives 3.6% of its revenue from philanthropy (including investment income), has total financial assets (including endowments and other
                                                                                                     assets that are subject to legal restrictions) equal to 1.9 months of expenses, and operating reserves of less than one month of expenses. Less
                                                                                                     than 20% of large nonprofits have 6 months or more of operating reserves, a widely accepted standard for "financial strength" for
                                                                                                     nonprofits. Social services organizations are the most fragile, with fewer than 10% reaching this standard. The statistics above should not be
                                                                                                     viewed as an indictment of the efficiencies or management policies of nonprofits.

                                                                                                     Also, many nonprofits are facility-based and carry planned debt which may be disqualified under the proposed calculation. Furthermore,
                                                                                                     creditworthiness can be established on other criteria.

                                                                                                     Recommendation: Recognizing the unique nature of nonprofit operations and their importance in continuing to provide vital services as
                                                                                                     partners on the front lines of the COVID-19 crisis, we urge the Federal Reserve to eliminate borrower requirements 7 and 8. If this is not
                                                                                                     possible, we alternatively ask that the requirements be lessened significantly to reflect the economic realities of nonprofit operations, for
                                                                                                     example by requiring only 30 days cash on hand, and eliminating the specific 65% debt ratio requirement and instead allow a statement of
                                                                                                     explanation for debt that may be of concern as it relates to credit worthiness.

                                                                                                     We are also concerned that certain eligible loan features are too onerous for nonprofit organizations and are less favorable than those offered
                                                                                                     in other government programs. Specifically, the interest rate of LIBOR plus 300 basis points is too high. In addition, the imposition of loan
                                                                                                     origination and service fees adds to the cost. Finally, the 70% balloon payment at the end of the fifth year of the loan would be difficult for many
                                                                                                     nonprofits, unless provided an opportunity to refinance such loans at low rates.

                                                                                                     Recommendation: Revisit the loan terms including interest rate and balloon payments and recommend the lowest permissible rate such as the
                                                                                                     0.5% rate initially proposed for PPP loans. We also urge some flexibility in the balloon payment requirement to afford the opportunity for
                                                                                                     renegotiation. Extending the 5-year amortization to seven years could lessen the balloon payment. We request that borrowers have access to
                                                                                                     engage with derivatives (change to a fixed rate) without the minimum swap requirements.


                                                                                                        Page 39 of 300
                                                                                                Main Street Lending Program
                                                                                              Nonprofit Organizations Comments

Event Title 1
Description     Ticket Type   Received Date   Last Name   First Name   Email Address   Affiliation                                                                          Comment
                                                                                                     3. The Ratio of Adjusted 2019 Earnings before "EBIDA" Should Be Revised
                                                                                                     In the "Draft for Public Consultation," one of the eligibility criteria for borrowers is that they must have "a ratio of adjusted 2019
                                                                                                     earnings before interest, depreciation, and amortization (EBIDA) to unrestricted 2019 operating revenue, greater than or equal to 5%."
                                                                                                     (#6) In the context of nonprofit operations, this threshold is too high and would make many, if not most, nonprofits ineligible based on these
                                                                                                     criteria alone, which seems written more in the context of for-profit businesses as opposed to nonprofit organizations.

                                                                                                     It may be prudent and necessary to have a positive ratio of adjusted earnings; however, nonprofits generally run on a small margin, both out of
                                                                                                     necessity and also so as to not leave excess surpluses that could be used for fulfilling their missions. Moreover, at times a nonprofit may have
                                                                                                     a planned and manageable deficit as part of a strategic plan-a negative ratio at one isolated point is not always an indication of instability.

                                                                                                     Furthermore, the footnotes for #6 clarify that "The Eligible Lender should calculate operating revenue as unrestricted operating revenue,
                                                                                                     excluding funds committed to be spent on capital." Many nonprofits have "restricted revenue" through grants and contracts
                                                                                                     built into their operating budgets. Excluding this revenue would compound the problem of meeting the 5% ratio. Although it would be sensible
                                                                                                     to exclude contributions raised for a "capital campaign," excluding other capital funds included in an annual budget for maintenance
                                                                                                     and planned upgrades would further decrease the required ratio.

                                                                                                     Recommendation: The 5% requirement should be reduced to zero, if not eliminated. In addition, a statement of explanation of a deficit should
                                                                                                     be allowed so that a negative ratio does not mean automatic ineligibility for a nonprofit borrower. Finally, further clarification on the calculation
                                                                                                     methodology-in the context of nonprofit operating budgets-is needed in regard to both restricted funding from grants in annual operating
                                                                                                     budgets, as well as capital funds for improvements that are part of an annual operating budget. This clarification would allow noted revenues to
                                                                                                     remain in calculation to ease the restriction and not further restrict eligibility.

                                                                                                     4. " Reasonable Efforts" Regarding Employee Retention Require Further Clarification
                                                                                                     The description of "Retaining Employees" in the draft term sheet requires refinement if the Federal Reserve expects nonprofits to
                                                                                                     take advantage of this facility. We endorse the analysis of the National Council of Nonprofits on the issue of employee retention, and
                                                                                                     recommend the following:

                                                                                                     Recommendation: "Reasonable efforts" should be interpreted in the totality of the circumstances, taking into consideration not only
                                                                                                     the general economic environment in the community or communities in which the borrower operates, but also factors such as workforce,
                                                                                                     fundraising ability, revenue-generating activities, and overall demand for the services and programs the organization provides. One option
                                                                                                     would be to add the qualifier "mission-based" before "reasonable efforts."

                                                                                                     Recommendation: Further refine the terms "maintain its payroll" and "retain its employees" are vague, and make clear
                                                                                                     that nonprofits participating in the Main Street loan program generally should endeavor to pay staff at the same or increased income levels and
                                                                                                     should act in good faith to keep staffing levels (measured on the basis of full-time equivalents) at the same or increased levels, both for the
                                                                                                     duration of the loan. It is also important that the loan documents expressly state that the employee retention provision begins on the date that
                                                                                                     loan funding is received by the borrower rather than at an earlier date.

                                                                                                     Recommendation: Adopt the safe harbors of other loan programs and state clearly that nonprofit borrowers will not be penalized under the
                                                                                                     employee retention provision for the decision of employees to decline offers of rehire, or for those who are fired for cause, voluntarily resign, or
                                                                                                     voluntarily request a reduced schedule during the time that the loan is outstanding.

                                                                                                     5. Limitation of 50-Employee Minimum Should Be Removed
                                                                                                     The proposed nonprofit loan facility imposes a size minimum that is not imposed in the Main Street Loan Facilities for for-profit businesses.
                                                                                                     There is no explanation why the Federal Reserve is proposing that nonprofits with fewer than 50 employees should not be eligible for Main
                                                                                                     Street loans for which their small business counterparts of equal size could secure lending support.

                                                                                                     Recommendation: Remove the 50-employee floor.

                                                                                                     6. The Fed's Proposal to Limit Loans to Mid-Size Nonprofits with Less than 30% of Revenue from Donations Disqualifies Many in
                                                                                                     Charitable Sector
                                                                                                     The Federal Reserve's criteria that organizations must have revenues from donations that are less than 30% disqualify many charities.
                                                                                                     Overall, this loan facility seems more geared to educational institutions and nonprofit hospitals, but not most charitable organizations.

                                                                                                        Page 40 of 300
                                                                                                        Main Street Lending Program
                                                                                                      Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name   Email Address     Affiliation                                                                       Comment

                                                                                                             Recommendation: Eliminate the requirement that no more than 30 percent of an organization's 2019 revenues come from donations.

                                                                                                             7. Additional Recommendations and Requests for Clarification
                                                                                                             Y-USA respectfully requests clarification of the following issues in the final notice.
                                                                                                              Endowment: What resources should be included in endowment calculations? Does it include restricted endowments? Does it extend to include
                                                                                                             cash on hand?
                                                                                                              Collateral: Flexibility on collateral is requested. The loan should be able to be approved with no more than 50% Loan to Value (LTV) if
                                                                                                             collateral is needed.
                                                                                                              Other Debts: The proposal requires that borrowers, "refrain from repaying the principal balance of, or paying any interest on, any debt
                                                                                                             until the Eligible Loan is repaid in full, unless the debt or interest payment is mandatory and due." We request that this exclude lines of
                                                                                                             credit and other debt that are assumed to provide financial liquidity related to the impact of COVID-19.

                                                                                                             Conclusion
                                                                                                             Y-USA appreciates the opportunity to submit these comments to the Federal Reserve about the Mainstreet Lending Program for Nonprofits,
                                                                                                             which, in its proposed form, seems aimed more at nonprofits such as hospitals and institutions of higher education than at nonprofits like local
                                                                                                             YMCAs. Given that, Y-USA respectfully requests the Federal Reserve to address the concerns and proposed changes outlined above.

                                                                                                             Thank you for considering these comments and recommendations. We stand ready to work with you to strengthen the Mainstreet Lending
                                                                                                             Program and give YMCAs the resources to help communities across America get through this crisis and promote a vibrant and equitable
                                                                                                             economic recovery.

                                                                                                             Sincerely,

                                                                                                             Neal Denton
                                                                                                             Senior Vice President and Chief Government Affairs Officer
                                                                                                             YMCA of the USA

                                                                                                             Despite mandated facility closures, cancellation of traditional programming and a decrease in giving, the Y has stepped up to address the
                                                                                                             critical need for safe childcare options and other needed services across the country. At the height of the pandemic the Y offered emergency
                                                                                                             childcare at more than 1,100 locations nationwide for families of medical personnel, essential employees and first responders. With school
                                                                                                             closures, children cannot access USDA breakfasts and lunch and during this time of economic uncertainty, a rapidly increasing number of
                                                                                                             adults and families are facing food insecurity. In response, over 1,000 Ys nationwide are providing free grab-and-go meals to help address this
                                                                                                             urgent need. As YMCAs across ND, SD, and NE restart their operations, their communities will continue to need them more than ever before.

                                                                                                             With traditional revenue streams likely to take months or even years to return to pre-pandemic levels, congress must ensure that mid-sized
                                                                                                             nonprofits have access to loan forgiveness opportunities. While it is a welcome development to see the Federal Reserve making its Main
Staff Group - Main                                                                                           Street lending program available to some nonprofits, this assistance still falls short of what is most needed by nonprofit organizations - a
Street Lending                                                                                               provision that makes these loans forgivable.
Program - Nonprofit
Organization          PIO (Email    6/19/2020                                ctointon@metr   YMCA of         Thank you for your consideration.
Facilities            from Web)     12:00:00 AM     Tointon     Chris        oymca.org       Greater Omaha




                                                                                                                Page 41 of 300
                                                                                                              Main Street Lending Program
                                                                                                            Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name    First Name    Email Address        Affiliation                                                                  Comment
                                                                                                                   On behalf of the American Health Information Management Association (AHIMA), I urge you to include 501(c)(6) organizations as eligible
                                                                                                                   borrowers under the Nonprofit Organization New Loan Facility.

                                                                                                                   At AHIMA, the COVID-19 pandemic has prompted the postponement and cancellation of the following events, resulting in significant financial
                                                                                                                   impact.

                                                                                                                   -Cancellation of AHIMA's long-anticipated eHealth Week Croatia event in Rovinj, Croatia with more than a year invested in preparation,
                                                                                                                   planning, and coordination between AHIMA's staff in Chicago, IL, its international team, and the Ministry of Public Health.
                                                                                                                   -Incurring of additional expenses to our annual Conference and annual educator meeting. The additional increase in cost to offer virtual options
                                                                                                                   along with the loss in revenue from a projected drop in attendance for both meetings, including loss of sponsors and exhibitors will add to the
                                                                                                                   financial impact as a result of COVID-19.
                                                                                                 American          -Postponement of AHIMA's annual HIP Week Celebration, impacting the annual sale of HIP Week merchandise; and
Staff Group - Main                                                                               Health            -Temporary closure of Pearson Vue testing centers impacting certification revenue for AHIMA.
Street Lending                                                                                   Information
Program - Nonprofit                                                                              Management        I urge you to include 501(c)(6) organizations as eligible borrowers under the Nonprofit Organization New Loan Facility. Thank you for your
Organization          PIO (Email    6/19/2020                                 lauren.riplinger   Association       leadership on this important issue.
Facilities            from Web)     12:00:00 AM     Riplinger   Lauren        @ahima.org         (AHIMA)
Staff Group - Main                                                                                                 501(c)(4) entities should be eligible, not just (c)(3) organizations.
Street Lending                                                                                   GREATER           We are a CDFI and a PA Certified Economic Development Organization.
Program - Nonprofit                                                                              BERKS
Organization          PIO (Email    6/19/2020                                 eswoyer@great      DEVELOPMEN        Loans should also be able to be used for capital investment for the borrowing entity.
Facilities            from Web)     12:00:00 AM     SWOYER      EDWARD        erreading.orq      TFUND

                                                                                                                   As a former corporate banker who has recently moved into a nonprofit executive role, I was quite surprised and disappointed by the stringent
                                                                                                                   requirements being considered for the Main Street program for nonprofit organizations. Nonprofits by their very nature tend to have volatile and
                                                                                                                   sometimes unpredictable cash flow, and many have insufficient cash reserves as defined by traditional for profit measures. For those fortunate
                                                                                                                   enough to have endowments, having access to a loan program like this seems unnecessary and redundant. In the absence of a program with
                                                                                                                   loan forgiveness for larger nonprofits, the following conditions should be reconsidered:
                                                                                                                    Ratio of EBIDA to revenue of 5% is too onerous for nonprofits - 2.5% would be a more reasonable test for organizations that do not strive to
                                                                                                                   maximize their bottom line
                                                                                                                    Liquidity tests of 90 days cash on hand and ratio and unrestricted cash to debt plus undrawn facilities of 65% are adequate tests for for-profit
Staff Group - Main                                                                                                 companies, but not nonprofits which struggle to build any cash reserves
Street Lending                                                                                                      Rate of LIBOR +3% - should be lower to reflect absence of any loan forgiveness
Program - Nonprofit                                                                                                 Loan amortization should be minimum of 7-10 years, given lack of loan forgiveness
Organization          PIO (Email    6/19/2020                                 JKinney@asce       Ascentria Care    In summary, this loan program does not seem to have been designed to assist nonprofits who are really struggling during the COVID crisis.
Facilities            from Web)     12:00:00 AM     Kinney      Jeffrey       ntria.org          Alliance


                                                                                                                   Whatever program for non-profits is designed needs to take the following into consideration.

                                                                                                                   No interest payments for two years
                                                                                                                   30 year term
                                                                                                                   2% interest

Staff Group - Main                                                                                                 This is the type of facility that works for the extreme impacts being felt by non-profits. The EIDL program is structured this way but is capped at
Street Lending                                                                                                     $150,000 which is not enough for most non profits to weather the storm. We actually needed $850,000 in order to make it through the year.
Program - Nonprofit                                                           Personal Email
                                                                              Address
Organization          PIO (Email    6/19/2020                                                    Midtown           So make the maximum loan amount at least $1M that non-profits can apply for.
Facilities            from Web)     12:00:00 AM     Mosey       Susan                            Detroit, Inc.
Staff Group - Main
Street Lending                                                                                                     We are a small community bank and do not plan to participate. The program is too complex (e.g. risk sharing, borrower covenants, etc.) and its
Program - Nonprofit                                                                              Chesapeake        rate is not attractive to our small business borrowers. If they are credit worthy, we can lend directly to them. If they are struggling, adding more
Organization          PIO (Email    6/19/2020                                 gwilson@chesa      Bank and Trust    debt may not be the right solution.
Facilities            from Web)     12:00:00 AM     Wilson      Glenn         peaketrust.com     Company


                                                                                                                      Page 42 of 300
                                                                                                           Main Street Lending Program
                                                                                                         Nonprofit Organizations Comments

    Event Title /
    Description       Ticket Type   Received Date   Last Name   First Name    Email Address       Affiliation                                                                       Comment
Staff Group - Main
Street Lending
Program - Nonprofit
Organization          PIO (Email    6/19/2020                                Joe.khawaja@t                      The main street lending program will be beneficial for non-profits, if loans are offered to small to medium non-profits at current LIBOR
Facilities            from Web)     12:00:00 AM     Khawaja     Tauseef      chabitat.org


                                                                                                                Given the loan can be unsecured, this would make it difficult, as a Bank, from a credit standpoint to make these loans to non-profits. On the flip
                                                                                                                side, if we were to make a secured loan under this program, it is not very enticing for a Borrower to tie up collateral and then have to repay this
                                                                                                                debt over a quick three year payback following the initial two year deferral. That being said, we believe it will be hard for both the Bank and
                                                                                                                Borrower to come to an agreement, as the Bank does not want to make unsecured loans, but a Borrower will likely not want to tie up collateral
                                                                                                                on a quick repayment.

                                                                                                                Churches would likely be the main non-profits that we would expect interest from for this program. Based on the terms including minimum 50
                                                                                                                employees and donations not to surpass 30% of revenue, we assume that this would likely eliminate nearly all churches from being able to
                                                                                                                qualify. That being said, we do not anticipate very much demand for this program.

Staff Group - Main                                                                                              We have not made a decision on whether or not we will participate in the Main Street Lending program as a whole, but the way the non-profit
Street Lending                                                                                                  program is setup currently, we do not expect much demand at all. Some of the issues raised above are also issues with the standard Main
Program - Nonprofit                                                          mattdaly@firstc                    street Lending Program for small businesses as well, as it pertains to quick paybacks on secured loans. Overall, we do not believe the program
Organization          PIO (Email    6/19/2020                                arolinabank.co                     in its current form is enticing for both parties, Bank & Borrower, and it will likely result in less than desired production.
Facilities            from Web)     12:00:00 AM     Daly        Matt         m
Staff Group - Main
Street Lending
Program - Nonprofit                                                                                             I would like you to add loan forgiveness opportunities in the Nonprofit loan program. This would really help non profits be able to respond to our
Organization          PIO (Email    6/19/2020                                dross@hshn.or     Head Start       individual community needs, without putting us in a position of having a loan guiding our decisions.
Facilities            from Web)     12:00:00 AM     Ross        Deb          9                 CFDP Inc.



                                                                                                                On principle, I believe that most Federal programs available to small businesses should also be available to nonprofits. The program proposed
                                                                                                                here has eligibility requirements that are for so much larger nonprofits that it is difficult for me to comment. Other than hospitals and assisted
Staff Group - Main                                                                                              living facilities, I know of only a few nonprofits in NM that would qualify based on number of employees. Because of COVID-19 and based on
Street Lending                                                                                                  the nonprofit hospitals and assisted living facilities I do know, this could be very helpful to those. However, if these were poor performers pre-
Program - Nonprofit                                                          Personal Email    New Mexico       COVID-19, perhaps the program might be more useful for other types of applicants. If local governments could apply or departments within
Organization          PIO (Email    6/19/2020                                Address           Caregivers       local government like first responders, this could be VERY useful and much-needed,.
Facilities            from Web)     12:00:00 AM     Smith       Adrienne                       Coalitionn




                                                                                                                   Page 43 of 300
                                                                                                           Main Street Lending Program
                                                                                                         Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name    Email Address       Affiliation                                                                        Comment
                                                                                                                On behalf of the one in 50 Americans who rely on the 300 Lutheran health and human services providers throughout the United States that
                                                                                                                comprise Lutheran Services in America, I write to you today to thank you for inviting comments on the proposal to include nonprofits as eligible
                                                                                                                participants in the Main Street Lending Program. At the same time, I urge you to support additional changes to the program, including of utmost
                                                                                                                importance, making these loans forgivable for nonprofit health and human service organizations including larger nonprofits, which will ensure
                                                                                                                this program is of the most possible benefit to nonprofits on the front lines of the pandemic and the countless people throughout America they
                                                                                                                serve.

                                                                                                                With the active presence of the Lutheran Services in America network in over 1,400 communities in 45 states as seen on this map our work
                                                                                                                http : //bit.ly/LSA_member_map, is critically important in improving the lives of America's most vulnerable people, ranging from seniors,
                                                                                                                veterans and people with disabilities to children, youth and families, and the homeless.

                                                                                                                Our work is deeply embedded in communities across the country where we have provided services for over 150 years. The COVID-19
                                                                                                                pandemic dramatically affects all of the people we serve and the services we provide. Our 300 health and human service organizations are on
                                                                                                                the front lines caring for people while taking extraordinary steps to protect their staff and people served. Yet they increasingly struggle with
                                                                                                                equipment shortages, especially personal protective equipment and testing resources; severe workforce shortages necessitating hazard and
                                                                                                                overtime pay; and the need to reduce or eliminate much-needed services. These severe challenges are occurring while our organizations
                                                                                                                simultaneously face limited cash reserves and already-tight margins.

                                                                                                                The work of our national network at Lutheran Services in America-which comprises a significant part of America's health and human
                                                                                                                services delivery system-cannot continue without specific measures taken soon to support nonprofit health and human service organizations
                                                                                                                with over 500 employees. At the same time, many of our member organizations employ more than 500 people and thus have not been able to
                                                                                                                access the existing Paycheck Protection Program. Without specific support for nonprofit health and human service organizations with over 500
                                                                                                                employees via the Main Street Loan Program during this crisis, including priority access, zero percent interest rates, and loan forgiveness, we
                                                                                                                will be unable to meet the increasing needs of individuals and communities at their most vulnerable time.

                                                                                                                Therefore, while we thank the Federal Reserve Board for recognizing the critical role that nonprofit organizations play throughout the economy,
                                                                                                                and using the authority granted by Section 4003 of the Coronavirus Aid, Relief, and Economic Security (CARES) Act to propose including
                                                                                                                nonprofits as eligible borrowers under this loan program, this proposal still unfortunately falls far short of what is most needed by nonprofit
                                                                                                                organizations. We urge you to make or support the following changes to this proposal:

                                                                                                                1) Recognizing that the Federal Reserve Board cannot grant loan forgiveness under its own authority, support a call to Congress to pass
                                                                                                                legislation ensuring that nonprofits with more than 500 employees have access to forgivable loans under this program. Loan forgiveness has
                                                                                                                been and remains central to the sustainability of many of our front line, community-based organizations that have no capacity for loan, interest
                                                                                                                and balloon repayments. America simply cannot afford to leave out such a vital part of the nonprofit community.

                                                                                                                2) In the absence of loan forgiveness, offer loans at zero-percent interest to nonprofits in recognition of the unique nature of nonprofit
                                                                                                                operations and their importance in continuing to provide vital services as partners during the COVID-19 crisis.

                                                                                                                3) Grant priority access to these loans to nonprofits, especially those on the front lines providing health care and human services during this
Staff Group - Main                                                                                              pandemic.
Street Lending
Program - Nonprofit                                                                            Lutheran         Thank you in advance for giving your time and rapid attention to this crucial issue. Our over 300 health and human services organizations and
Organization          PIO (Email    6/19/2020       Haberaeck                sdobson@luthe     Services in      the one in 50 Americans we serve each year are counting on you during this unprecedented time of crisis.
Facilities            from Web)     12:00:00 AM     er          Charlotte    ranservices.org   America
Staff Group - Main
Street Lending
Program - Nonprofit                                                                            Berks County     What possible argument could exist for NOT making this available to nonprofits? Nonprofit businesses employ people, pay taxes and make up
Organization          PIO (Email    6/19/2020                                 kevinm@bccf.o    Community        a significant part of the economy. The question seems a little silly, frankly.
Facilities            from Web)     12:00:00 AM     Murphy      Kevin        J2                Foundation




                                                                                                                   Page 44 of 300
                                                                                                          Main Street Lending Program
                                                                                                        Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name   Email Address       Affiliation                                                                       Comment


                                                                                                               We are a 501 c6 non-profit organization that is dedicated to providing assistance to businesses. The business community has taken a huge hit
                                                                                                               with COVID-19 and have turned to the Chambers of Commerce for assistance - informational and educational resources, marketing,
                                                                                                               encouraging support of local businesses rather than online shopping and more. It is during these critical times that the role of Chambers is
                                                                                                               equally critical. Yet, these organizations are not allowed to apply for the PPE program or other assistance offered to other non-profits in
                                                                                                               response to COVID. The reason, I am told, is that Chambers are considered to be primarily lobbying organizations. I must disagree. In rural
                                                                                                               areas of the United States, Chambers are not linked to lobbying in the same fashion as the US Chamber and larger organizations are. Our
                                                                                                               Chamber does not have a lobbyist on staff nor do we contract for those services.
                                                                                              Grand Island
Coronavirus           PIO (Email    6/19/2020                                cjohnson@gich    Chamber of       Please consider adding Chambers of Commerce to the list of non-profits eligible for financial assistance as a result of COVID. Thank you.
(COVID-19)            from Web)     12:00:00 AM     Johnson     Cindy        amber.com        Commerce



                                                                                                               I represent a small nonprofit and find this loan program, while well intentioned, would not be helpful to my organization - or many of the ones I
                                                                                                               work closely with throughout the state of Virginia.

                                                                                                               The minimum loan size, loan rate and the fact that none of the loan is forgivable are all things that make this a poor fit for my organization. We
                                                                                                               would need a micro loan program, 0 interest terms for at least a year and a percentage forgiven to even begin thinking about taking on the
                                                                                                               process of finding a lender willing to work with us and the mountain of paperwork required.
Staff Group - Main
Street Lending                                                                                                 As a very small nonprofit (budget under $750,000 and 5FTE) we need assistance that is simple and quick. For us, small grants would be much
Program - Nonprofit                                                                                            better and have a greater positive impact. If that's not possible, much smaller loans at more favorable terms with little paperwork is
Organization          PIO (Email    6/19/2020                                ayarcich@rxpar                    needed.
Facilities            from Web)     12:00:00 AM     Yarcich     Amy          tnership.org     Rx Partnership




                                                                                                                  Page 45 of 300
                                                                                                          Main Street Lending Program
                                                                                                        Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name   Email Address       Affiliation                                                                 Comment
                                                                                                               Comments regarding Main Street Lending Program - Nonprofit Organization Facilities


                                                                                                               Dear Members of the Board of Governors of the Federal Reserve System,

                                                                                                               It is encouraging to see that the Federal Reserve Bank is considering nonprofits and that the social and economic impact of the sector is
                                                                                                               recognized. Charitable organization of all sizes and focus areas are being hit hard by the pandemic and face unprecedented economic
                                                                                                               challenges. Data released by Independent Sector on June 15 shows that nonprofits with between 500 to 5,000 employees, key to scaling relief
                                                                                                               efforts across the nation, have been severely impacted by this health and economic crisis. Smaller nonprofits throughout the country are taking
                                                                                                               an even harder hit. Further, data from Johns Hopkins University estimate that 1.6 million nonprofit jobs have been lost in the last three months,
                                                                                                               which translates to 13 percent of jobs in the nation's third largest industry. It is clear that without appropriate federal assistance, many
                                                                                                               organizations on which Americans rely are not likely to survive.

                                                                                                               We welcome the efforts of the Federal Reserve to extend eligibility for the Main Street Lending Program to mid-sized nonprofits, which would
                                                                                                               provide immediate financial assistance and enable uninterrupted provision of services and conducting mission-driven activities.

                                                                                                               However, there are some concerns with the current proposal.

                                                                                                                The 5-year repayment time frame is a serious concern. This very short time period is likely to be a struggle for many nonprofit organizations,
                                                                                                               and especially small nonprofits. The 5-year time frame is surprising considering that a typical SBA loan has a 30-year repayment period. We
                                                                                                               strongly encourage that the time frame be extended to a longer and more manageable period. This would better allow for nonprofits with
                                                                                                               capital projects such as building affordable housing to access funds to do so.

                                                                                                               The minimum loan size of $10 million means that only large organizations will be eligible to borrow through this program.

                                                                                                               We would like to better understand the rationale for excluding nonprofits that may receive more than 30% of their revenue from donations.
                                                                                                               Nonprofits have many different types of funding models, and reliance on donations is not inherently better or worse than other sources. In fact,
                                                                                                               donations from a broad base of supporters is among the most reliable sources of nonprofit revenue.

                                                                                                                "Reasonable Efforts" Regarding Employee Retention Require Further Clarification. The description of "Retaining
                                                                                                               Employees" in the draft term sheet requires refinement if the Federal Reserve expects nonprofits to take advantage of this facility. We
                                                                                                               endorse the analysis of the National Council of Nonprofits on the issue of employee retention.

                                                                                                               We wish to underscore that while this program is an important tool for sustaining large nonprofits that rely on earned revenues, like universities
                                                                                                               and health care facilities, many mid-sized nonprofit organizations will not have capacity to repay the loan and interest. A loan forgiveness
                                                                                                               provision is central to the sustainability of many of the frontline, community-based organizations.

                                                                                                               The nonprofit community has made clear since passage of the CARES Act that a broad package of relief is necessary. America cannot afford
Staff Group - Main                                                                                             to leave out such a vital part of the social fabric. The federal government must recognize the vital services nonprofits provide to communities
Street Lending                                                                                                 and the economy and include multiple solutions.
Program - Nonprofit                                                          daniel@washin
Organization          PIO (Email    6/19/2020                                gtonnonprofits.   Washington      -Washington Nonprofits
Facilities            from Web)     12:00:00 AM     Parkhurst   Daniel       org               Nonprofits




                                                                                                                  Page 46 of 300
                                                                                                     Main Street Lending Program
                                                                                                   Nonprofit Organizations Comments

   Event Title /
   Description     Ticket Type   Received Date   Last Name   First Name   Email Address     Affiliation                                                                       Comment
                                                                                                          Comments regarding Main Street Lending Program - Nonprofit Organization Facilities


                                                                                                          Dear Members of the Board of Governors of the Federal Reserve System,

                                                                                                          It is encouraging to see that the Federal Reserve Bank is considering nonprofits and that the social and economic impact of the sector is
                                                                                                          recognized. Charitable organization of all sizes and focus areas are being hit hard by the pandemic and face unprecedented economic
                                                                                                          challenges. Data released by Independent Sector on June 15 shows that nonprofits with between 500 to 5,000 employees, key to scaling relief
                                                                                                          efforts across the nation, have been severely impacted by this health and economic crisis. Smaller nonprofits throughout the country are taking
                                                                                                          an even harder hit. Further, data from Johns Hopkins University estimate that 1.6 million nonprofit jobs have been lost in the last three months,
                                                                                                          which translates to 13 percent of jobs in the nation's third largest industry. It is clear that without appropriate federal assistance, many
                                                                                                          organizations on which Americans rely are not likely to survive.

                                                                                                          We welcome the efforts of the Federal Reserve to extend eligibility for the Main Street Lending Program to mid-sized nonprofits, which would
                                                                                                          provide immediate financial assistance and enable uninterrupted provision of services and conducting mission-driven activities.
                                                                                                          However, there are some concerns with the current proposal.
                                                                                                           The 5-year repayment time frame is a serious concern. This very short time period is likely to be a struggle for many nonprofit organizations,
                                                                                                          and especially small nonprofits. The 5-year time frame is surprising considering that a typical SBA loan has a 30-year repayment period. We
                                                                                                          strongly encourage that the time frame be extended to a longer and more manageable period. This would better allow for nonprofits with
                                                                                                          capital projects such as building affordable housing to access funds to do so.
                                                                                                           The minimum loan size of $10 million means that only large organizations will be eligible to borrow through this program.
                                                                                                           We would like to better understand the rationale for excluding nonprofits that may receive more than 30% of their revenue from donations.
                                                                                                          Nonprofits have many different types of funding models, and reliance on donations is not inherently better or worse than other sources. In fact,
                                                                                                          donations from a broad base of supporters is among the most reliable sources of nonprofit revenue.

                                                                                                          We wish to underscore that while this program is an important tool for sustaining large nonprofits that rely on earned revenues, like universities
                                                                                                          and health care facilities, many mid-sided nonprofit organizations will not have the capacity to repay the loan and interest. A loan forgiveness
                                                                                                          provision is central to the sustainability of many of the frontline, community-based organizations.

                                                                                                          The nonprofit community has made clear since the passage of the CARES Act that a broad package of relief is necessary. America cannot
Other Nonprofit                                                                                           afford to leave out such a vital part of the social fabric. The federal government must recognize the vital services nonprofits provide to
loan program       PIO (Email    6/19/2020                                nancy@501co                     communities and the economy and include multiple solutions.
proposal           from Web)     12:00:00 AM     Long        Nancy        mmons.org       501 Commons




                                                                                                             Page 47 of 300
                                                                                                        Main Street Lending Program
                                                                                                      Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name   Email Address     Affiliation                                                                        Comment
                                                                                                             June 19, 2020

                                                                                                             Mr. Eric S. Rosengren
                                                                                                             President & Chief Executive Officer
                                                                                                             Federal Bank of Boston
                                                                                                             600 Atlantic Avenue
                                                                                                             Boston, MA 02210

                                                                                                             Re: MAIN STREET LENDING PROGRAM EXTENSION TO NON-PROFIT COMPANIES

                                                                                                             Dear Mr. Rosengren:

                                                                                                             The Union League Club of Chicago is a nonprofit 501(c)7organization that was established in 1879. We are a Chicago institution that has been
                                                                                                             in existence for over 141 years, and whose motto is Commitment to Community and Country.

                                                                                                             Financial Impact of COVID-19
                                                                                                             The Union League Club has annual revenue of $29,000,000 (FY 2019), or $7,000,000 quarterly We employ over 290 full time (not seasonal)
                                                                                                             staff and we have over 3,800 members. Our fiscal year runs May 1 through April 30th. On March 20th, Governor Pritzker ordered businesses
                                                                                                             to halt operations in Illinois due to COVID-19. Essentially all our services were suspended. The Club's revenue plummeted (decrease of
                                                                                                             73% from prior year) immediately and we immediately suspended all employees except those essential workers needed to maintain our 92-
                                                                                                             year-old building. Our employees work in our dining and meeting facilities, and maintain and clean our facilities, including the overnight guest
                                                                                                             rooms. In short, our employees are suffering the same reduction in employment as for-profit business in the restaurant and hospitality
                                                                                                             businesses.

                                                                                                             In the last 3 months our organization has lost $6,430,500 dollars in revenue and we continue to lose $400,000 per month, using all our cash
                                                                                                             reserves, even our line of credit that we borrowed from the bank. In June 2019, our Club revenues were $2,800,000. In June 2020, our Club
                                                                                                             revenues will be less than $800,000, a loss of $500,000. Additionally, we lost over 125 members due to this shutdown.

                                                                                                             The ULCC monthly expenses continue to be in excess of $500,000 for Property Taxes, heat, light, power, and medical insurance, not including
                                                                                                             any payroll.

                                                                                                             Our institution as a 501 (c)7 nonprofit has been left out of any potential financial support to weather the COVID 19 pandemic and support our
                                                                                                             employees. We are not eligible for PPP loans of any kind, and we have a small chance of recouping some wages through the Employee
                                                                                                             Retention Payroll Tax Credit.

                                                                                                             At this time, we have a limited staff serving our members, but as we begin to run out of money, our great institution is at risk of closing and our
                                                                                                             employees would be permanently harmed.

                                                                                                             The Union League Club of Chicago serves the Chicago community
                                                                                                             The Club was instrumental in helping to draft the 17th Amendment, development of the Columbian Exposition, the Art Institute of Chicago, The
                                                                                                             Harold Washington Library, and many other Chicago establishments.

                                                                                                             Additionally, Club members support three foundations, the 100-year-old Union League Boys & Girls Foundation which serves the after­
                                                                                                             school development needs of Chicago's disadvantaged youth. The ULBGC provides programming centered on academic success, good
                                                                                                             character and citizenship, and healthy lifestyles to nearly 15,000 youth at 11 locations

                                                                                                             The Luminarts Cultural Foundation of the Union League Club cultivates Chicago's vibrant arts community by supporting exemplary young
                                                                                                             artists through its competitive programs that offer financial awards, artistic opportunities, and mentoring that bridge the gap between education
                                                                                                             and career, and the Chicago Engineers' Foundation of the Union League Club whose mission is to encourage and empower young
Staff Group - Main
Street Lending                                                                                               people to become the next generation of engineers through scholarship opportunities, outreach to educational institutions, and promoting
Program - Nonprofit                                                                          Union League    interest in engineering careers. Our reach in philanthropy to the youth in Chicago runs deep.
Organization          PIO (Email    6/19/2020                                mtunney@ulcc.   Club of
Facilities            from Web)     12:00:00 AM     Tunney      Mark         org             Chicago         Mr. Rosengren, It is our belief that employees of 501 (c)7 organizations should not be made to suffer simply because of an IRS tax

                                                                                                                Page 48 of 300
                                                                                                Main Street Lending Program
                                                                                              Nonprofit Organizations Comments

Event Title /
Description     Ticket Type   Received Date   Last Name   First Name   Email Address   Affiliation                                                                           Comment
                                                                                                     classification. As you consider further eligibility guidelines for the Main Street Program we along with the National Club Association urge the
                                                                                                     Federal Reserve Bank of Boston to consider including 501(c)7organizations among the Non-Profit companies being considered for the Main
                                                                                                     Street Lending Program extension.


                                                                                                     Sincerely,



                                                                                                     Nancy Ross Mark Tunney
                                                                                                     131st President General Manager/COO




                                                                                                        Page 49 of 300
                                                                                                          Main Street Lending Program
                                                                                                        Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name   Email Address       Affiliation                                                                       Comment
                                                                                                               The Florida State Alliance of YMCAs is the organization that represents all the YMCA in the state of Florida. Each of our YMCAs in Florida are
                                                                                                               vital to the communities they serve especially during these times of high need by providing food, child care and social connnection as well as
                                                                                                               supporting other non-profits that are struggling through the Covid-19 situation. Our Ys in the larger city have not had access to any federal
                                                                                                               funding to help them continue to serve the community due to not being eligible for the PPP loans due to staff size.
                                                                                                               These real-life, current concerns and questions based on experiences of Ys across America are the basis for the following comments and
                                                                                                               recommendations.

                                                                                                               Comments and Recommendations
                                                                                                               1. Congress Must Act to Ensure Mid-Sized Nonprofits are Eligible for Loan Forgiveness
                                                                                                               Congress must ensure that mid-sized nonprofits have access to loan forgiveness. While it is a welcome development to see the Federal
                                                                                                               Reserve making its Main Street lending program available to some nonprofits, this assistance still falls short of what is most needed by
                                                                                                               nonprofit organizations - a provision that makes these loans forgivable.

                                                                                                               In this critical time, nonprofits have stepped up to meet the unprecedented level of need in our country due to the COVID-19 pandemic. Even
                                                                                                               though they face many of the same economic challenges as other industries, nonprofits are not shutting down. Rather, they are straining to
                                                                                                               meet increasing demands in our communities on the frontlines, caring for the sick, feeding families, and keeping our communities connected.
                                                                                                               Furthermore, they will play an integral role as our nation recovers - providing childcare, job training, and other core supports.

                                                                                                               Charitable nonprofits of all sizes and focus areas are struggling to maintain mission-critical operations despite enormous economic challenges.
                                                                                                               Data released by Independent Sector shows that nonprofits with between 500 to 5,000 employees, key to scaling relief efforts across the
                                                                                                               nation, have been severely impacted by this health and economic crisis. When asked "What types of additional assistance would be most
                                                                                                               helpful to your organization?" organizations overwhelmingly (92% of responses) suggested government support in the form of forgivable
                                                                                                               loans. Smaller nonprofits throughout the country have been hit equally hard.

                                                                                                               Nonprofit organizations need funding so they can continue to meet the needs of their communities. Many charitable organizations do not have
                                                                                                               steady streams of commercial income and have little capacity for loan and interest repayment. Furthermore, nonprofits are the third largest
                                                                                                               employment sector and many hope to hire more workers as their organizations recover. America cannot afford to leave out such a vital part of
                                                                                                               the economy.

                                                                                                               Recommendation: Congress must recognize the vital services nonprofits provide to communities and the economy by including loan
                                                                                                               forgiveness, in the next round of COVID-19 relief legislation

                                                                                                               2. The Federal Reserve Needs to Make Loan Terms More Favorable to Charitable Organizations
                                                                                                               The draft Nonprofit Loan Facility imposes certain liquidity, asset, and reserve requirements that are not required in Main Street New Loan
                                                                                                               Facilities available to for-profit businesses.

                                                                                                               Nonprofit organizations typically provide services with low-profit margins. Indeed, social service organizations report an average aggregate
                                                                                                               margin of 1.5%. According to a recent report by Seachange Capital Partners, the median social services nonprofit has a margin of 1.0%,
                                                                                                               receives 3.6% of its revenue from philanthropy (including investment income), has total financial assets (including endowments and other
                                                                                                               assets that are subject to legal restrictions) equal to 1.9 months of expenses, and operating reserves of less than one month of expenses. Less
                                                                                                               than 20% of large nonprofits have 6 months or more of operating reserves, a widely accepted standard for "financial strength" for
                                                                                                               nonprofits. Social services organizations are the most fragile, with fewer than 10% reaching this standard. The statistics above should not be
                                                                                                               viewed as an indictment of the efficiencies or management policies of nonprofits.

                                                                                                               Also, many nonprofits are facility-based and carry planned debt which may be disqualified under the proposed calculation. Furthermore,
                                                                                                               creditworthiness can be established on other criteria.

                                                                                                               Recommendation: Recognizing the unique nature of nonprofit operations and their importance in continuing to provide vital services as
                                                                                                               partners on the front lines of the COVID-19 crisis, we urge the Federal Reserve to eliminate borrower requirements 7 and 8. If this is not
Staff Group - Main
Street Lending                                                                                                 possible, we alternatively ask that the requirements be lessened significantly to reflect the economic realities of nonprofit operations, for
Program - Nonprofit                                                                           Florida State    example by requiring only 30 days cash on hand, and eliminating the specific 65% debt ratio requirement and instead allow a statement of
Organization          PIO (Email    6/19/2020                                lynne@floriday   Alliance of      explanation for debt that may be of concern as it relates to credit worthiness.
Facilities            from Web)     12:00:00 AM     Wilcox      Lynne        mcas.org         YMCAs

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