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.
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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
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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
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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
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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
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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
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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
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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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