Main Street Lending Program Comments — Federal Reserve public comments
Summary
This is a compilation of public comments on the Federal Reserve's Main Street Lending Program, headed Main Street Lending Program Comments. The opening comment, logged 4/15/2020, advocates restoring the applicability of the Main Street Lending Program to nonprofits with 500 or more employees, and says eligibility for the Main Street New Loan Facility should include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion. Another comment dated 4/15/2020 asks that nonprofits, institutions of higher learning and Minority-Serving Institutions be included. A further comment argues that the method for determining loan amounts under the Facility would exclude growing companies that are not yet profitable.
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Cite this document
“Main Street Lending Program Comments — Federal Reserve public comments.”
Original at www.federalreserve.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/federal-reserve-public-comments-2-pdf-www-federalreserve-gov-f64d0ba3f-db0626e5d1/
, SHA-256 a1fb34f3eabe7086d1f2fb2a8967e24b57c2787f6dfe4f58406eaff79fd63211.Full text
Main Street Lending Program Comments
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/15/2020 sabrina.thaku Uplift Family eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
11:45:00 AM PIO (Email from Thakur Sabrina r@upliftfs.org Services
4/15/2020 lagata@pacb Please make sure to include nonprofits, many institutions of higher learning and Minority-Serving Institutions in the CARES Act. Excluding
11:46:00 AM PIO (Email from Remez J ell.net these types of businesses would be a travesty.
Currently, the loan amount available to a borrower under the Facility is the lesser of $25M and an amount calculated using a multiple of
EBIDTA. Should the Federal Reserve maintain only this method of determining loan amounts, it would negatively impact businesses across
the country that are successful, growing, and vital contributors to the national economy - but which are still on the path to profitability.
For example, a high-impact company with 510 employees and a monthly payroll of $4M can inject $1B into the economy each year, but
because it will not be profitable for another 6 months, the company does not qualify for any loan amount under the Facility. What is worse is
that this same type of company does not qualify for a PPP loan either because it has 10 too many employees. However, a similar company
with a negative EBITDA and 10 less employees would qualify for $10M under the PPP. Surely, this was not Congresses' intent.
I urge the Board to reconsider the method of determining loan amounts under the Facility to include the lesser of $25M or 4 times the Average
Monthly Payroll Costs (a component already approved from the PPP). Doing so would serve the intent of Congress, which was to support
employees and the companies that employ them, and not exclude high-impact businesses that are vital to the American worker and economy.
adam.martine Thank you.
4/15/2020 z@offerpad.c
11:46:00 AM PIO (Email from Martinez Adam om Offerpad
Non-profit organizations with more than 500 employees have been left out of coronavirus funding by the Federal Government. Many of these
organizations are providing exceptional services during this crisis. Their ability to raise private funds, even to pre crisis levels, is severely
impaired because they can't conduct normal outreach business and because their donors and clients are unable to provide support.
Personal
4/15/2020 Email IT IS ESSENTIAL TO INCLUDE LARGER NONPROFIT ORGANIZATIONS IN THE MAIN STREAM LENDING AND PPP GRANTS
11:47:00 AM PIO (Email from Peskoe Julie Address Independent
Good Morning,
I'm writing to urge you to include non-profits as eligible recipients of the Main Street Lending program. Non-profits across the country are
providing critical services to support front-line workers addressing the coronavirus pandemic. In Washington, our YMCA is providing free
emergency child care to health care workers and first responders, free meals to children who can't access meals at their schools, and
health outreach services to seniors in Pierce and Kitsap counties.
The CARES Acts didn't include relief for non-profits with more than 500 employees. This act was the first step toward supporting non-
profits through the economic crisis stemming from the pandemic, but more help is needed.
The Main Street Loan program will provide much-needed relief to non-profits with 500 to 10,000 employees. Please also consider loan
forgiveness, similar to the Paycheck Protection Program, to eliminate the burden of repayment in these uncertain times.
Prior to the pandemic, our YMCA employed more than 2,300 staff. We were not able to access these relief packages and have had to
furlough 93% of our staff. Without access to support, our YMCA will not be able to resume operations as we knew it or retain our staff. Please
help us ensure that we have the resources necessary to continue supporting our neighbors and staff.
Thank you for your consideration,
Charlie Davis
4/15/2020 cdavis@ymc President and CEO
11:48:00 AM PIO (Email from Davis Charlie apkc.org Mr. YMCA of Pierce and Kitsap Counties
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Main Street Lending Program Comments
Red Mountain Theatre Company is Alabama's premier professional theatre having a long history of producing high-quality musical
theatre and hosting one of the most highly-regarded arts education programs in the Southeast. RMTC's 2019-2020 Season promised an
exciting line-up of shows, tours, classes, and workshops. However, due to the COVID-19 pandemic, we were forced to abruptly cancel or
postpone all programming, including our four remaining productions for this season.
We are asking The Federal Reserve for your strong consideration to please include nonprofits in the new "Main Street Lending"
smorales@re provisions!
dmountainthe Red Mountain In order for RMTC to be prepared for the curtain to rise again, we must keep our highly qualified staff and talented artists connected to RMTC
4/15/2020 atrecompany. Theatre and in Birmingham. Receiving federal funds is crucial to the continued success of our nonprofit, as we hope to be a vehicle for providing vital
11:49:00 AM PIO (Email from Morales Stacey org Company community connection through the arts once this difficult time passes.
Community Corp is concerned about the exclusion of nonprofits to get bank loans via the PPP program from the CARES act. As a nonprofit
tbarauskas@ Community that provides affordable housing, we are facing large shortfalls due to inability of our residents to pay rent, lack of ability to collect income for
4/15/2020 communityco Corporation of services and commitment to continue paying all staff at current salaries. Please make sure nonprofits are NOT excluded from CARES Act
11:51:00 AM PIO (Email from Barauskas Tara rp.org Santa Monica assistance.
Please consider including non-profit organizations in this initiative. Non-profits are an essential part of the economy, both because they
cspratling@r employ millions of U.S. citizens and because they provide crucial services to Americans. Americans need as much help as they can get right
4/15/2020 ailroadpark.or Railroad Park now, and non-profits are most adept at providing that help.
11:54:00 AM PIO (Email from Spratling Camille g Foundation Thank you for your consideration.
To whom it may concern:
I am the VP of Finance for a national auto auction chain with 23 locations and approximately 1,500 employees. While our business did
not/could not qualify for the COVID-19 relief being offered through the SBA, I believe we would qualify for federal relief under the Federal
Reserve's newly announced Main Street Lending Program based on the term sheet that has been published. I am seeking more
information on qualification for this program, the anticipated roll-out of the program and the next steps to participate in the program. I have
already reached out to the Dallas Federal Reserve and left a voicemail. I appreciate your time and response.
jason.nichols
@americasa Regards,
4/15/2020 utoauction.co America's Auto
12:00:00 AM PIO (Email from Nichols Jason m Auction Jason Nichols
4/15/2020 jill.warner@ja Please include nonprofits in the "Main Street" lending program. Jawonio and our community need this support.
11:58:00 AM PIO (Email from Warner Jill wonio.org Jawonio Inc
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Main Street Lending Program Comments
MSELF and MSNLF Overall Comments:
2019 EBITDA Impacts: UAW strike, severe weather, trade. Allow 2019 EBITDA to be normalized to reflect one-time events. Alternative: 2018
actuals or pre-virus 2020 budget to set Applicable EBITDA
Limit interest to 25bp greater than existing term or other Eligible Lender loan, not to exceed SOFR + 400bp
Program loans allowed to repay virus-related over advances/bridge loans
Clarify: lease and rental payments defined as mandatory principal and interest. Debt includes leases and rent obligations, other than normal
course trade
Eligible Borrower can use the Loan Proceeds to make intercompany loans; intercompany borrowers to comply with Program rules
General Parameter:
Max loan: greater of: i) 50% of existing and committed but undrawn secured debt; or ii) amount when added to all existing and committed but
undrawn debt not to exceed 8x Applicable EBITDA.
MSELF: Max $150MM
MSNLF: Max $50MM
MSELF Specific:
Maturity date of existing portion of the enhanced loan may be extended by up to 36 months: revised maturity date not past 4/8/2024.
Understood that enhanced tranche of existing loan may have a later maturity than existing portion
Existing term loan secured by real estate does not require a revised appraisal
rcampbell@b MSNLF Specific:
4/15/2020 eardiversified Bear Diversified
11:59:00 AM PIO (Email from Campbell Ronald .com Properties Total Borrower's Loan Origination and Facility Fee not to exceed 125bp
Our communities need nonprofits like YMCA's now more than ever. Please ensure nonprofits are explicitly named as eligible recipients
of the Main Street Lending program, and also ensure that nonprofit employers with between 500 and 10,000 employees are able to access
the loans. Consider loan forgiveness for nonprofits similar to the Paycheck Protection Program to eliminate the burden of repayment in these
uncertain times. The YMCA of Greater Brandywine employed 1778 staff prior to the COVID-19 pandemic and have had to furlough and/or
layoff 1725 of our staff members. Without access to support, our Y will not be able to resume operations as we knew it and bring back our
staff. Despite being closed, we coordinate with the Red Cross and run blood drives at several of our locations. We are working with local food
banks in our county to serve as food distribution centers. We are posting online workouts across our social media platforms to keep our
members active. We are hosting online coffee chats with our senior members to keep them connected, as they are the most isolated during
this crisis. While we are privileged to serve our community in this manner, it goes without saying that this situation poses a significant financial
burden to our organization. We are at a point of critical financial drain. Our Y is committed to serving our community throughout this pandemic
4/15/2020 dday@ymcag YMCA of Greater and beyond. Please help us ensure that we have the resources necessary to support our neighbors and our staff.
12:02:00 PM PIO (Email from Day Denise bw.org Brandywine
"I am affiliated with a non-profit behavioral health organization in California, and I am writing to advocate for the inclusion of non-profits
as part of the Main Street Lending Program. Non-profit behavioral health agencies provide critical services to hundreds of thousands of
Californians, yet have been left out of the Main Street Lending Program. Without the vital aid provided by the program, these agencies will
Tarzana have to make cuts to staff and services which impacts their ability to serve some of the most vulnerable clients in California. PLEASE
4/15/2020 sgalperson@ Treatment INCLUDE THESE NON-PROFIT BUSINESSES AND IN TURN INCREASE THE CAPACITY OF THE SAFETY NET SYSTEM."
12:03:00 PM PIO (Email from Galperson Stan tarzanatc.org Centers
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Main Street Lending Program Comments
It is an injustice not to include those who need and would benefit most from the CARES Act! Excluding non-profits, institutions of higher
learning and especially Minority serving institutions is a huge set back for the country as well as those who are trying to better themselves in a
time where COVID-19 has forced individuals into a state of unemployment and hunger.
byanca.under How can we divide funding without including the people who need it most? I guess it's true; The rich gets richer and the poor gets
4/15/2020 wood@aidsal AIDS Alabama, poorer!
12:05:00 PM PIO (Email from Underwood Byanca abama.org Inc I hope this changes.
I don't think that it is fair or prudent to distinguish between "for profit" and "non-proft" when determining
qualifications for the Main Stream Lending program. Each group functions as a "company". As such, all of them have expenses
Personal that need to be covered in order to function. To discriminate against non-profits will only hinder their ability to function. If they have earned
4/15/2020 Email their status and qualify as a "business", then they are entitled to the same treatment as "for profit" companies. If the
12:06:00 PM PIO (Email from Kelly Jim Address Love on 4 Paws cannot cover expenses, then they might not be able to exist. Society would pay the price.
4/15/2020 catjsk@hofstr You must include medium and large nonprofits in the Main Street Lending Program as they are needed to help communities such as mine in
12:08:00 PM PIO (Email from Kaufman Judith a.edu New Rochelle, New York survive and recovery from the Covid-19 pandemic.
Much of the funding made available so far as excluded 501c6 organizations. These designation contains many types of organizations such as
director@geo Georgetown trade groups and chambers of commerce. Due to the pandemic, many of our revenue streams have all but dried up leaving us in much the
4/15/2020 rgetowncoc.c Chamber of same place as many of our retail, hospitality and non-essential members. We urge Congress, the Federal Reserve and any others involved to
12:08:00 PM PIO (Email from Thompson Kevin om Commerce include 501c6 organizations in any potential funding opportunities during this pandemic.
I work for a public non-profit childcare/education program. We have multiple sites with over 500 employees so we have been left out of any
usefully relief funding. Why would you not want to help non-profit programs like ours? Non-profits help keep this country strong. Our
programs are largely located on public school sites. We rely on parent funding, which is at zero because schools are not open, and money
from the state for our low income students on grants. The grant money comes in usually 3 months after we have fronted payroll costs. We
Personal need to be ready to start when schools reopen but without funding help we will continue to have close to 1000 employees on unemployment.
4/15/2020 Email Address Being able to receive relief money for non-profits should be easier than what is happening now, not harder. PLEASE HELP PUBLIC NON-
12:09:00 PM PIO (Email from Wilken Debra STAR Education PROFITS WITH OVER 500 EMPLOYEES!
8 physical locations (we just had to close our Gaffney location, so now 7). We employ about 5,000 people a year, provides Temporary and
Direct Hire employment services. The majority of our customers are in the manufacturing industry (to include: automotive suppliers to major
manuf. co. like BMW and pharmaceuticals). As result of the novel Coronavirus, my firm Confidential Business Information
Our product is our people, and if we're unable to put these people to work we no
longer have a product, and can no longer support the structure of our business. Confidential Business Information
rgilbert@philli SB Phillips Co., Therefore, I respectfully request that you take the following actions now: Establish priority
4/15/2020 psstaffing.co Inc. DBA Phillips status, for the staffing industry for Main Street Lending. Defer ALL employer tax payments due from 4/1/2020-6/30/2020 (for now).
12:11:00 PM PIO (Email from Gilbert Robyn m Staffing
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Main Street Lending Program Comments
To Whom It May Concern:
I am writing on behalf of Washington Trails Association, a nonprofit organization in Washington state. WTA represents the interests of hikers
and everyone who loves the outdoors to explore, steward and champion trails and public lands.
Please include nonprofits, institutions of higher learning and Minority-Serving Institutions in the Federal Reserve's "Main Street
Lending" program. Right now the Federal Reserve is excluding these important organizations. This funding mechanism is especially
important to those entities that were ineligible for the Paycheck Protection Program.
America's 1.3 million nonprofit organizations employ 12.3 million people -- more than 10% of America's workforce -- with payrolls
exceeding those of many other U.S. industries, including construction, transportation and finance. In addition, many nonprofits play a key role
as a safety net to and voice for the communities being hit hardest by the current coronavirus crisis.
Right now across our country, nonprofits are facing the same economic difficulties that other for-profit businesses face with a loss of revenue
and jobs. I ask you to modify the current eligible entities in the Main Street Lending program and include nonprofits, institutions of higher
learning and Minority-Serving Institutions so that they can receive this much needed financial support as well.
Washington Thank you,
4/15/2020 aimler@wta.o Trails Andrea Imler
12:15:00 PM PIO (Email from Imler Andrea rg Association Washington Trails Association
The YMCA of Greater Kansas City was not able to apply for the Paycheck Protection Program because of their size. Please also consider
loan forgiveness for nonprofits like the Y, similar to the Paycheck Protection Program, to eliminate the burden of repayment in these uncertain
times. Without additional resources, many nonprofit organizations will be lost to their communities, including YMCAs. Our communities need
nonprofits like the Y now more than ever. Despite their facilities being closed, the Y has been providing essential child care services for
4/15/2020 sean@southt Southtown healthcare workers, first responders and other essential services. Without access to support, our YMCAs will not be able to resume
12:16:00 PM PIO (Email from Ackerson Sean own.org Council operations, provide needed community services, or retain their staff.
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
Personal hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/15/2020 Email eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
12:17:00 PM PIO (Email from Yue Byron Address
We are a 650 employee trucking company. Given the PPP program's 500 employee limit, we have been unable to obtain any assistance
during the pandemic (except by furloughing employees to the unemployment system). We greatly need assistance and have looked hard for
Confidential Business Information
it. There is the rumored "Mainstreet" loan program, but as far as we can tell it does not yet exist.
It is a shame that politicians put the 500 ee limit in place and did not think of companies like ours. Businesses of our size are vital to the
American economy. Further, the 500 ee companies get what is essentially a grant. If the main street program comes into place, we will have
to pay it back. That will be challenging given our revenue will have gone to zero for a period, and we have obtained deferrals on some key
expenses that will also need to be paid back. That said, we will be glad to get a loan to keep the company viable once the pandemic recedes.
Incidentally, the news reported today that the airlines are getting $25bn in loan assistance. Small gets help, mega gets help, middle-market
has yet to get anything...
steved@virgi Virginia
4/15/2020 niatransportat Transportation Please let us know how to apply for the Mainstreet loan program, asap, days matter...
12:00:00 AM PIO (Email from Doire Steve ion.com Corporation
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Main Street Lending Program Comments
Excluding nonprofit organizations from the Main Street legislation is absolutely devastating for institutions of higher learning and other minority
serving nonprofits. These nonprofits serve the community and are worthy of receiving these funds.
esmith@assi
4/15/2020 sifoundation. This vote is a terrible blow to the nonprofit community that provides services to the entire community, many times, when government does not
12:23:00 PM PIO (Email from Smith Ernestine org Ms. provide the services needed.
Is there an exception to the following MSLP Required Attestation for tax distributions to owners of S- corporations and other pass-through
4/15/2020 kathleen.sifer Grant Thornton businesses: "The Eligible Borrower must attest that it will follow compensation, stock repurchase, and capital distribution restrictions that
12:24:00 PM PIO (Email from Sifer Kathleen @us.gt.com LLC apply to direct loan programs under section 4003(c)(3)(A)(ii) of the CARES Act"?
I am writing to advocate for restoration of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees.
Non-profit corporations need financial assistance even more than large for-profit companies. Please give us the opportunity to continue
serving some of the most vulnerable people during this crisis. It is imperative that the Main Street New Loan Facility eligibility include
ldelman@mo Momentum for nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
4/15/2020 mentummh.o Mental Health La
12:24:00 PM PIO (Email from Delman Laila rg Selva Group Thank you.
4/15/2020 Chilbig@peo Make this loan program forgivable
12:24:00 PM PIO (Email from Hilbig Cara ple-inc.irg People Inc
Hello,
I am writing to advocate for the inclusion of non-profits as eligible entities for the Main Street Lending Program. Non-profits, and especially
behavioral health agencies, provide critical services to hundreds of thousands of Californians, yet have been left out of the Main Street
Lending Program. Without the vital aid provided by the lending program, many agencies will have to make cuts, both staff and service levels,
which will, in turn, diminish their ability to help some of the most vulnerable people. As a representative of a non-profit behavioral health
organization in California I respectfully request that non-profits be included in the loan program.
Thanks,
4/15/2020 blindstrom@ Amity Barry Lindstrom, Regional Administrator
12:26:00 PM PIO (Email from Lindstrom Barry amityfdn.org Foundation Amity Foundation
PLEASE include non profits like my children's museum in the "Main Street" Lending Program. Most of our part time staff has
been laid off, and our non profit just celebrated its 4th birthday and will not be able to survive without help to get us through this closure that
has brought all of our revenue to a standstill. Larger non profits than ours that are ineligible for the Paycheck Protection Program are also in
Mdematteo@ Westchester dire need of this help. Non profits are the life blood of culture, advocacy, and social justice, and without them our society will suffer a huge
4/15/2020 discoverWC Children's loss. Please help sustain them by including them in this program. Thank you so much.
12:26:00 PM PIO (Email from De Matteo Martine M.org Museum
BOKF has significant concerns about the Main Street Lending Program. For our Borrowers, the combination of high fees and interest make
the cost unattractive. The short amortization may represent a burden and CARES ACT restrictions are a disincentive to participate and
enforce. Therefore, the program is likely needed only in workout situations which may not be the best strategy.
For Banks, the expanded loan leverages up existing collateral reducing coverage of overall debt. At the same time, the new loan program is
required to be unsecured, increasing risk. The loans are sized based on multiple of EBITDA likely requiring classification as leveraged loans,
especially in the absence of collateral.
Both loan programs require repayment priority of Main St. debt putting the banks in a subordinated position on its debt. There are significant
restrictions on managing non-Main St. debt which is exacerbated when multiple banks are lenders to the borrower. SOFR based loans create
an operational issue for BOKF.
The lack of details provided makes assessment difficult. Essentially, BOKF makes loans to this market on a case by case basis. It is difficult
to create a standard product to meet all customers' needs. The better option is for the program to provide mezzanine debt financing at a
4/15/2020 mmaun@bok reasonable rate with warrants attached. Let the company manage through the crisis and then if successful, can refinance the debt rather than
12:26:00 PM PIO (Email from Maun Marc f.com BOK Financial predetermined amortization.
Personal The lack of inclusion of non-profits is both harmful and insulting. Without the work of non-profits, our business community would suffer. To
4/15/2020 Email Address JUICE Orange not financially support one entity while making provision for the others is a poor decision. We need support as well and are feeling the impact
12:26:00 PM PIO (Email from Thornton Britney Mound of needed to fulfill our missions without the funds to do so.
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Main Street Lending Program Comments
Tbradford@c We are a Native CDFI in Anchorage Alaska serving Small Businesses across the State of Alaska. We are interested in being able to offer the
4/15/2020 ookinletlendin Cook Inlet Main Street Lending loan in conjunction with our Relief program. I am wanting to find out how to become an eligible lender for the program.
12:27:00 PM PIO (Email from Bradford Trevor g.com Lending Center
"I am affiliated with a non-profit behavioral health organization in California, and I am writing to advocate for the inclusion of non-profits
as part of the Main Street Lending Program. Non-profit behavioral health agencies provide critical services to hundreds of thousands of
Californians, yet have been left out of the Main Street Lending Program. Without the vital aid provided by the program, these agencies will
Tarzana have to make cuts to staff and services which impacts their ability to serve some of the most vulnerable clients in California. PLEASE
4/15/2020 TMartinez@t Treatment INCLUDE THESE NON-PROFIT BUSINESSES AND IN TURN INCREASE THE CAPACITY OF THE SAFETY NET SYSTEM."
12:27:00 PM PIO (Email from Martinez Tom arzanatc.org Centers
Personal Please include nonprofits in the Main Street Lending program.
4/15/2020 Email Address Also please allocate relief funds equitably with regard to COVID 19 - give number of dollars according to number of patients in every state.
12:28:00 PM PIO (Email from Stavropoulos Christine CS
SMB's that are owned by private equity firms but that have <500 employees should be eligible for grants and loans on a similar basis
as the SBA lending program. The Affiliate rule for majority owned companies should not apply. Just because there is common ownership of a
company, each business is individually capitalized and managed separately. As an example, I work with one business that manufacturers
dbrinkenhoff dental products for dentists. With dental offices closed, they have had to furlough over 80% of their 300 person workforce. Access to
4/15/2020 @centrepartn government backs loans and/or grants will help us keep employees on the payroll and will keep manufacturing jobs in the U.S.
12:34:00 PM PIO (Email from Brinkenhoff Daniel ers.com Centre Partners
The Federal Reserve is tasked by the CARES ACT to support up to $600 billion in bank lending to small and medium-sized businesses.
Unfortunately, as of today, the Trump Administration is planning to exclude nonprofits, many institutions of higher learning and Minority-
Serving Institutions from this new lending facility.
That is wrong.
4/15/2020 Personal
New legislation should correct this. Non-profits and minority-serving institutions are disproportionately impacted in a negative way by the CV-
Email Address
12:35:00 PM PIO (Email from Warren Peter Retired 19 and should not be excluded from the program.
It is very confusing to tell the difference between the Main Street Lending Program and the Mid-Size business loans discussed in the CARES
Act. There was no explanation for the difference or when the mid-size loans will be available. Also, the provision stating "30% of the
Eligible Borrower's existing outstanding and committed but undrawn bank debt" is a bit unclear. Does that mean we could borrow
4/15/2020 janderson@b Basic American 30% of all debt we have, both outstanding and outdrawn? Or does that mean just 30% of undrawn debt? That should be clarified.
12:35:00 PM PIO (Email from Anderson Jennifer af.com Foods
Westchester nonprofits that are important members of the community and help strengthen communities financially, educationally, and
Caramoor recreationally. Many rely on attendance for income (which will be null this year) and on donations (which will be impacted because of the
4/15/2020 gayle@cara Center for Music downturn). We must survive as an important part of our society's fabric.
12:36:00 PM PIO (Email from Schmidt Gayle moor.org and the Arts
4/15/2020 Personal Email Please DO NOT exclude nonprofits, institutions of higher learning or Minority-Serving Institutions from the new lending facility.
12:36:00 PM PIO (Email from Fancy Joanna Address
Please expand the Main Street program to include medium and large non-profits. The social fabric of the United States depends on them.
4/15/2020 Personal Email
Address
12:37:00 PM PIO (Email from Schulz Laurie LHS Coaching
Is this program open to the public? If so how does one follow up or get guidance on applying for it?
I am interested in applying but the literature discusses "lenders" and "borrowers".
andrew@blu
4/15/2020 eprintcoffee.c Blueprint Coffee Thanks,
12:38:00 PM PIO (Email from Timko Andrew om LLC Andrew Timko
4/15/2020 Personal Please include non profit businesses in the Main St Lending program. They include food pantries and other community organizations that
12:39:00 PM PIO (Email from BONADONNA SUSAN Email Address Dr people rely on. Thanks so much.
What is the amortization on the acceptable loans?
How are the deferred payments handled? Will it be added as a balloon payment or when they start to pay, the payments would be applied first
cindy.fujiwara to the deferred interest?
4/15/2020 @fremontban Is the rate a monthly adustable or fixed for the 4 yr term?
12:39:00 PM PIO (Email from Fujiwara Cindy k.com Fremont Bank Is a private university eligible?
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Main Street Lending Program Comments
I think it would be a misstep to exclude minority institutions, non-profits and certain higher education organizations from the Cares Act funding
legislation. Covid-19 disproportionately attacks minority groups who traditionally have more risk factors than average Americans and this
4/15/2020 bosticpf@lah LA Harbor group also benefits tremendously from non-profits. Higher education is their pathway to better health and income so it makes no logical sense
12:40:00 PM PIO (Email from Bostic Peter c.edu College not to protect this most vulnerable group of citizens. Thank you.
It is extremely important that the Federal Reserve include 501c3 nonprofits as eligible entities for the Main Street loan program in response to
the COVID-19 pandemic and other relief efforts designed to support businesses and corporations..
The nonprofit sector is the third largest employment sector in the country, and shutting nonprofits out of these important resources will result in
many community-based organizations permanently shutting their doors, adding a huge number of people to the unemployment rolls, and
eliminating vital services in communities across the country. There will be an incredible toll on citizen well-being as well as quality of life if
these vital organizations are lost, and the cost of rebuilding the nonprofit ecosystem will far outweigh current resources allocated to relief
programs.
Please ensure that nonprofits are explicitly invited to participate in the Main Street lending program, as well as other programs available to
support businesses.
Personal
4/15/2020 Email Thank you,
12:45:00 PM PIO (Email from Wolanski Nancy Address GCRI Nancy Wolanski
4/15/2020 esimpson@vi Should the Payroll Protection Program loan amount be included in the eligible borrower's outstanding debt amount if it will be forgiven?
12:48:00 PM PIO (Email from Simpson Emily pauto.com
The Federal Reserve is discussing $600 billion in bank lending to small and mid-sized businesses, with no provisions for institutions of higher
learning. Public higher education institutions are also ineligible for the Paycheck Protection Program. The COVID-19 pandemic has hit higher
4/15/2020 jhaggar2@m University of education particularly hard affecting both students and faculty/staff. I ask that you please add public higher education institutions to the Main
12:48:00 PM PIO (Email from Haggard Julie ontevallo.edu Montevallo Street lending facility.
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. The enabling legislation (CARES Act,
Section 4003) expressly included nonprofit organizations between 500 and 10,000 employees, but it now appears the Federal Reserve's
initial guidance for the Main Street Lending Program excludes nonprofits for eligibility. These critical providers of the nation's safety net
are not eligible for the Paycheck Protections Program (PPP) (Sections, 1102, 1106) or the Economic Injury Disaster Loans (EIDL) (Section
Personal 1110) or other federal relief. This proposed action threatens the viability of larger nonprofits who provide aid to hundreds of thousands of
4/15/2020 Email Momentum for children and families. Please include non-profits that employ over 500 employees in the Main Street Program to protect the critical safety net.
12:50:00 PM PIO (Email from Puopolo Joyce Address Mental Health
Be sure to include nonprofit institutions in your mainstreet lending program. Changes in tax policies in the last few years have already had a
huge negative impact on nonprofits, and this is necessary. Nonprofits take care of so much important work that most countries assign to their
4/15/2020 sarafinn@iola governments. The United States has been decreasing the role of government, and we all need these nonprofits to care for the most
12:58:00 PM PIO (Email from Finnemore Sara ni.org Iolani School vulnerable people in our country.
slarkin@good Please include non profits in assistance packages. We have had to layoff all of our staff at the time our community needs us most.
4/15/2020 willbigbend.c
12:58:00 PM PIO (Email from Larkin Stacy om Goodwill
Feedback on the Federal Reserve "Main Street" lending facility
To whom it may concern:
We would like to urge you to please expand eligibility criteria for the Federal Reserve "Main Street" Lending Facility to include non-
profits and higher education institutions. Like many businesses these entities are suffering losses from the current crisis and require additional
resources to be able to cover those losses. Many of them are ineligible for the Paycheck Protection Program.
These institutions employ more than 5 million dedicated professionals/workers and educate more than 19.9 million students across the United
4/15/2020 1:03:00 cmhayes@st St. Thomas States. Many universities are a main employer in their communities, and some oversee major health systems that are responding to the
PM PIO (Email from Hayes Christine u.edu University pandemic. Their ineligibility to participate may mean some of these institutions may have to close.
4/15/2020 1:03:00 robert_lerner Please include counties and towns as well as medium and large nonprofits in the Main Street Lending Program as they are needed to help
PM PIO (Email from Lerner Robert @nymc.edu Retired communities such as mine in New York survive and recovery from the Covid-19 pandemic.
Page 108 of 363
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Main Street Lending Program Comments
I would like to urge you to please expand eligibility criteria for the Federal Reserve "Main Street" Lending Facility to include non-
profits and higher education institutions. Like many businesses these entities are suffering losses from the current crisis and require additional
resources to be able to cover those losses. Many of them are ineligible for the Paycheck Protection Program.
These institutions employ more than 5 million dedicated professionals/workers and educate more than 19.9 million students across the United
States.
Many universities are a main employer in their communities, and some oversee major health systems that are responding to the pandemic.
Their ineligibility to participate may mean some of these institutions may have to close.
4/15/2020 1:04:00 Kbrady@stu. St. Thomas
PM PIO (Email from Brady Kevin edu University Thank you for your consideration.
To whom it may concern:
We would like to urge you to please expand the eligibility criteria for the Federal Reserve "Main Street" Lending Facility to include
non-profits and higher education institutions. Like many businesses, these entities are suffering losses from the current crisis and require
additional resources to be able to cover those losses. Many of them are ineligible for the Paycheck Protection Program.
These institutions employ more than 5 million dedicated professionals/workers and educate more than 19.9 million students across the United
States. Many universities are the main employer in their communities, and some oversee major health systems that are responding to the
pandemic. Their ineligibility to participate may mean some of these institutions may have to close. Many people will be left without jobs or
ways to sustain their families. We are begging, please reconsider. You would be saving us.
Respectfully,
4/15/2020 1:04:00 eamorales@ St. Thomas Eilleen Morales
PM PIO (Email from Morales Eilleen stu.edu University
To whom it may concern:
I would like to urge you to please expand eligibility criteria for the Federal Reserve "Main Street" Lending Facility to include non-
profits and higher education institutions. Like many businesses these entities are suffering losses from the current crisis and require additional
resources to be able to cover those losses. Many of them are ineligible for the Paycheck Protection Program.
These institutions employ more than 5 million dedicated professionals/workers and educate more than 19.9 million students across the United
4/15/2020 1:04:00 aneymeiyer St. Thomas States. Many universities are a main employer in their communities, and some oversee major health systems that are responding to the
PM PIO (Email from Neymeiyer Anthony @stu.edu University pandemic. Their ineligibility to participate may mean some of these institutions may have to close.
We would like to urge you to please expand the eligibility criteria for the Federal Reserve "Main Street" Lending Facility to include
non-profits and higher education institutions. Like many businesses, these entities are suffering losses from the current crisis and require
additional resources to be able to cover those losses. Many of them are ineligible for the Paycheck Protection Program.
These institutions employ more than 5 million dedicated professionals/workers and educate more than 19.9 million students across the United
States. Many universities are the main employer in their communities, and some oversee major health systems that are responding to the
4/15/2020 1:04:00 imedina@stu. St. Thomas pandemic. Their ineligibility to participate may mean some of these institutions may have to close.
PM PIO (Email from Medina Pascu Isabel edu University
To whom it may concern:
I am writing to urge you to please expand eligibility criteria for the Federal Reserve "Main Street" Lending Facility to include non-
profits and higher education institutions. Like many businesses these entities are suffering losses from the current crisis and require additional
resources to be able to cover those losses. Many of them are ineligible for the Paycheck Protection Program.
These institutions employ more than 5 million dedicated professionals/workers and educate more than 19.9 million students across the United
States. Many universities are a main employer in their communities, and some oversee major health systems that are responding to the
pandemic. Their ineligibility to participate may mean some of these institutions may have to close.
Sincerely,
4/15/2020 1:04:00 lvarela@stu.e St. Thomas
PM PIO (Email from Varela Laura du University Laura J. Varela
Page 109 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
To whom it may concern:
We would like to urge you to please expand eligibility criteria for the Federal Reserve "Main Street" Lending Facility to include non-
profits and higher education institutions. Like many businesses these entities are suffering losses from the current crisis and require additional
resources to be able to cover those losses. Many of them are ineligible for the Paycheck Protection Program.
These institutions employ more than 5 million dedicated professionals/workers and educate more than 19.9 million students across the United
4/15/2020 1:05:00 wrychel@stu. St Thomas States. Many universities are a main employer in their communities, and some oversee major health systems that are responding to the
PM PIO (Email from Rychel William edu University pandemic. Their ineligibility to participate may mean some of these institutions may have to close.
4/15/2020 1:05:00 Mrogers@stu St Thomas Don't forget we are also a big part of the community and have shut down operations and we need to be part of the care act
PM PIO (Email from Rogers Mark .edu University
To whom it may concern: We would like to urge you to please expand eligibility criteria for the Federal Reserve "Main Street"
Lending Facility to include non-profits and higher education institutions. Like many businesses these entities are suffering losses from the
current crisis and require additional resources to be able to cover those losses. Many of them are ineligible for the Paycheck Protection
Program.
These institutions employ more than 5 million dedicated professionals/workers and educate more than 19.9 million students across the United
4/15/2020 1:05:00 yvaldes@stu. St. Thomas States. Many universities are a main employer in their communities, and some oversee major health systems that are responding to the
PM PIO (Email from Valdes Yasdanee edu University pandemic. Their ineligibility to participate may mean some of these institutions may have to close.
To whom it may concern:
We would like to urge you to please expand eligibility criteria for the Federal Reserve "Main Street" Lending Facility to include non-
profits and higher education institutions. Like many businesses these entities are suffering losses from the current crisis and require additional
resources to be able to cover those losses. Many of them are ineligible for the Paycheck Protection Program.
St. Thomas These institutions employ more than 5 million dedicated professionals/workers and educate more than 19.9 million students across the United
4/15/2020 1:06:00 MMCMAHON University States. Many universities are a main employer in their communities, and some oversee major health systems that are responding to the
PM PIO (Email from McMahon Maureen @STU.EDU School of Law pandemic. Their ineligibility to participate may mean some of these institutions may have to close.
To whom it may concern:
We would like to urge you to please expand eligibility criteria for the Federal Reserve "Main Street" Lending Facility to include non-
profits and higher education institutions. Like many businesses these entities are suffering losses from the current crisis and require additional
resources to be able to cover those losses. Many of them are ineligible for the Paycheck Protection Program.
These institutions employ more than 5 million dedicated professionals/workers and educate more than 19.9 million students across the United
States. Many universities are a main employer in their communities, and some oversee major health systems that are responding to the
pandemic. Their ineligibility to participate may mean some of these institutions may have to close.
Personal Sincerely,
4/15/2020 1:06:00 Email
PM PIO (Email from Barberis Carmen Address 1962 Carmen Barberis
I urge you to reconsider those eligible for participation in the Main Street Lending program. Excluding non-profits means that many who
desperately need assistance will be unable to find it, if non-profits serving the marginalized in our communities are forced to close their doors.
Indeed non-profits provide the bulk of social services in communities across America. They often provide these service on a shoestring
budget and with limited staff. Their limitations; however, do not preclude them from being inundated with requests for services, particularly at a
time like this.
Moreover, excluding institutions of higher learning will disproportionately impact minority and smaller institutions, who do not have a strong
donor base and who are already challenged to remain financially sound. Consider for instance, Fisk University in Nashville, Tennessee. This
university is a historically black institution forced to make hard decisions several years ago, due to a lack of financial support. Today, I would
hope this institution, and others like it, will not be forced to decide between a bad choice and a worse one, because they are unable to secure
needed funds to help them during this time of crisis.
Please reconsider your decision. Include non-profits and institutions of higher learning in the Main Street Lending program. As a country we
are obviously only as strong as the weakest among us.
4/15/2020 1:07:00 rjackson@wo The Women's
PM PIO (Email from Jackson, Esq. R. Romona mensac.org Advocacy Center Thank you for your consideration and time.
Page 110 of 363
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Main Street Lending Program Comments
We would like to urge you to please expand eligibility criteria for the Federal Reserve "Main Street" Lending Facility to include non-
profits and higher education institutions. Like many businesses these entities are suffering losses from the current crisis and require additional
resources to be able to cover those losses. Many of them are ineligible for the Paycheck Protection Program.
These institutions employ more than 5 million dedicated professionals/workers and educate more than 19.9 million students across the United
States. Many universities are a main employer in their communities, and some oversee major health systems that are responding to the
pandemic. Their ineligibility to participate may mean some of these institutions may have to close.
4/15/2020 1:07:00 lmarcus@stu. St. Thomas Non-profit institutions also help serve the community and the students from the community and should not be left out of this opportunity to get
PM PIO (Email from Marcus Lorne edu University vital aid needed to keep these non-profits afloat.
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
Personal
4/15/2020 1:07:00 Uplift Family eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
Email
PM PIO (Email from Goldman Monet Services
Address
I am an employee of a nonprofit healthcare organization in California, and I am writing to advocate for the inclusion of nonprofit organizations
as part of the Main Street Lending Program. The exclusion of nonprofits from this program leaves medium-size nonprofits - which are also not
eligible to participate in the Paycheck Protection Program - in precarious financial standing without any way to mitigate economic injury while
preserving workforce and continuing critical services to hundreds of thousands of Californians. Without the vital aid provided by the program,
mspikes@he organizations like ours are at risk of making cuts to staff and services which impacts our ability to serve some of the most vulnerable people in
4/15/2020 1:08:00 althright360.o California. HealthRight 360 . We have over 100 men here. And that is just one program
PM PIO (Email from Spikes Monica rg Healthright360
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
rebecca.knep hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/15/2020 1:10:00 pel@upliftfs.o Uplift Family eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
PM PIO (Email from Kneppel Rebecca rg Services
I would like to urge you to please expand eligibility criteria for the Federal Reserve "Main Street" Lending Facility to include non-
profits and higher education institutions. Like many businesses these entities are suffering losses from the current crisis and require additional
resources to be able to cover those losses. Many of them are ineligible for the Paycheck Protection Program.
These institutions employ more than 5 million dedicated professionals/workers and educate more than 19.9 million students across the United
States. Many universities are a main employer in their communities, and some oversee major health systems that are responding to the
4/15/2020 1:10:00 lbfernandez St. Thomas pandemic. Their ineligibility to participate may mean some of these institutions may have to close.
PM PIO (Email from Fernandez Lourdes @stu.edu University Thank you for your time and consideration!
Feedback on the Federal Reserve "Main Street" lending facility
To whom it may concern:
We would like to urge you to please expand eligibility criteria for the Federal Reserve "Main Street" Lending Facility to include non-
profits and higher education institutions. Like many businesses these entities are suffering losses from the current crisis and require additional
resources to be able to cover those losses. Many of them are ineligible for the Paycheck Protection Program.
These institutions employ more than 5 million dedicated professionals/workers and educate more than 19.9 million students across the United
4/15/2020 1:10:00 tabernet@stu St. Thomas States. Many universities are a main employer in their communities, and some oversee major health systems that are responding to the
PM PIO (Email from Abernethy Ted .edu University pandemic. Their ineligibility to participate may mean some of these institutions may have to close.
Page 111 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
Feedback on the Federal Reserve "Main Street" lending facility
To whom it may concern:
We would like to urge you to please expand eligibility criteria for the Federal Reserve "Main Street" Lending Facility to include non-
profits and higher education institutions. Like many businesses these entities are suffering losses from the current crisis and require additional
resources to be able to cover those losses. Many of them are ineligible for the Paycheck Protection Program.
St. Thomas These institutions employ more than 5 million dedicated professionals/workers and educate more than 19.9 million students across the United
4/15/2020 1:11:00 swarheit@stu University States. Many universities are a main employer in their communities, and some oversee major health systems that are responding to the
PM PIO (Email from Warheit Susan .edu School of Law pandemic. Their ineligibility to participate may mean some of these institutions may have to close.
We would like to urge you to please expand eligibility criteria for the Federal Reserve "Main Street" Lending Facility to include non-
profits and higher education institutions. Like many businesses these entities are suffering losses from the current crisis and require additional
resources to be able to cover those losses. Many of them are ineligible for the Paycheck Protection Program. These institutions employ more
than 5 million dedicated professionals/workers and educate more than 19.9 million students across the United States. Many universities are a
4/15/2020 1:12:00 maribel.smith St. Thomas main employer in their communities, and some oversee major health systems that are responding to the pandemic. Their ineligibility to
PM PIO (Email from SMITH Maribel @stu.edu University participate may mean some of these institutions may have to close.
To whom it may concern:
We would like to urge you to please expand eligibility criteria for the Federal Reserve "Main Street" Lending Facility to include non-
profits and higher education institutions. Like many businesses these entities are suffering losses from the current crisis and require additional
resources to be able to cover those losses. Many of them are ineligible for the Paycheck Protection Program.
These institutions employ more than 5 million dedicated professionals/workers and educate more than 19.9 million students across the United
4/15/2020 1:14:00 vczelusniak St Thomas States. Many universities are a main employer in their communities, and some oversee major health systems that are responding to the
PM PIO (Email from Czelusniak Vernon @stu.edu University pandemic. Their ineligibility to participate may mean some of these institutions may have to close.
To whom it may concern:
We would like to urge you to please expand eligibility criteria for the Federal Reserve "Main Street" Lending Facility to include non-
profits and higher education institutions. Like many businesses these entities are suffering losses from the current crisis and require additional
resources to be able to cover those losses. Many of them are ineligible for the Paycheck Protection Program.
These institutions employ more than 5 million dedicated professionals/workers and educate more than 19.9 million students across the United
4/15/2020 1:14:00 mgrove@stu. St. Thomas States. Many universities are a main employer in their communities, and some oversee major health systems that are responding to the
PM PIO (Email from Grove Malik edu University pandemic. Their ineligibility to participate may mean some of these institutions may have to close.
I encourage you to extend the benefits of the CARES Act to all American businesses, and not to exclude non-profits and educational
organizations, as the Trump Administration proposes.
It is hard to present you with an argument, since it seems self-evident that educational and other non-profits play as valid a role in America as
other businesses. For me, the baseless exclusion of educational and other non profits seems a function of political bias and intellectual
weakness, but perhaps I should venture an economic argument, given my audience here: Since one purpose of the CARES Act is to
encourage businesses to retain employees and thus reduce the incredible burden on the unemployment benefits system, it seems that a
4/15/2020 1:14:00 Personal person saved from unemployment by a non-profit is as valuable as one saved from unemployment from a business.
PM PIO (Email from Goldstein Burt Email
Address
Feedback on the Federal Reserve "Main Street" lending facility
To whom it may concern:
We would like to urge you to please expand eligibility criteria for the Federal Reserve "Main Street" Lending Facility to include non-
profits and higher education institutions. Like many businesses these entities are suffering losses from the current crisis and require additional
resources to be able to cover those losses. Many of them are ineligible for the Paycheck Protection Program.
These institutions employ more than 5 million dedicated professionals/workers and educate more than 19.9 million students across the United
4/15/2020 1:15:00 mrivera@stu. St. Thomas States. Many universities are a main employer in their communities, and some oversee major health systems that are responding to the
PM PIO (Email from Rivera Maritza edu University pandemic. Their ineligibility to participate may mean some of these institutions may have to close.
Page 112 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
To whom it may concern:
We, faculty and staff at St. Thomas University, would like to urge you to please expand eligibility criteria for the Federal Reserve "Main
Street" Lending Facility to include non-profits and higher education institutions such as ours. Like most businesses we are suffering
losses from the current crisis and require additional resources to be able to cover those losses. Many of them are ineligible for the Paycheck
Protection Program.
These institutions employ more than 5 million dedicated professionals/workers and educate more than 19.9 million students across the United
4/15/2020 1:15:00 ajavadzadeh States. Many universities are a main employer in their communities, and some oversee major health systems that are responding to the
PM PIO (Email from Javadzadeh Abdy @stu.edu St. Thomas Univ. pandemic. Their ineligibility to participate may mean some of these institutions may have to close.
I want to encourage you, the Federal Reserve, to include nonprofits, institutions of higher learning, HBCUs, and Minority-Serving Institutions in
the "Main Street" lending program.
info@mcgreg
4/15/2020 1:17:00 orlawoffice.co McGregor Law This pandemic has already ravaged the historically under-represented, disenfranchised, and economically depressed segments of our
PM PIO (Email from McGregor George m Office, PLLC population. Do not exacerbate this inequity by ignoring their financial needs and support.
I am an employee of a nonprofit healthcare organization in California, and I am writing to advocate for the inclusion of nonprofit organizations
as part of the Main Street Lending Program. The exclusion of nonprofits from this program leaves medium-size nonprofits - which are also not
eligible to participate in the Paycheck Protection Program - in precarious financial standing without any way to mitigate economic injury while
esardotz@he preserving workforce and continuing critical services to hundreds of thousands of Californians. Without the vital aid provided by the program,
4/15/2020 1:18:00 althright360.o organizations like ours are at risk of making cuts to staff and services which impacts our ability to serve some of the most vulnerable people in
PM PIO (Email from Sardotz Erik rg Healthright360 California.
To whom it may concern:
We would like to urge you to please expand eligibility criteria for the Federal Reserve "Main Street" Lending Facility to include non-
profits and higher education institutions. Like many businesses these entities are suffering losses from the current crisis and require additional
resources to be able to cover those losses. Many of them are ineligible for the Paycheck Protection Program.
These institutions employ more than 5 million dedicated professionals/workers and educate more than 19.9 million students across the United
States. Many universities are a main employer in their communities, and some oversee major health systems that are responding to the
pandemic. Their ineligibility to participate may mean some of these institutions may have to close.
4/15/2020 1:19:00 ssong@stu.e St. Thomas
PM PIO (Email from Song Seokho du University Please include non-profits and higher education institutions.
To whom it may concern:
We would like to urge you to please expand eligibility criteria for the Federal Reserve "Main Street" Lending Facility to include non-
profits and higher education institutions. Like many businesses these entities are suffering losses from the current crisis and require additional
resources to be able to cover those losses. Many of them are ineligible for the Paycheck Protection Program.
These institutions employ more than 5 million dedicated professionals/workers and educate more than 19.9 million students across the United
States. Many universities are a main employer in their communities, and some oversee major health systems that are responding to the
St. Thomas pandemic. Their ineligibility to participate may mean some of these institutions may have to close.
4/15/2020 1:19:00 ajmarrero@st University / Thank you,
PM PIO (Email from Marrero Ana u.edu School of Law Ana Marrero
Please expand the eligibility criteria for the Federal Reserve Main Street Lending facility to include non-profits and higher education
institutions. These institutions are, like businesses, suffering losses from the current crisis and need additional funds to cover those losses.
These institutions employ more than 5 million dedicated professionals and educate 20 million students across the United States. Many small
universities, such as ours, are ineligible for the Payment Protection Program.
These institutions play a vital role in educating the future leaders of America; their ineligibility to participate in this program may mean some
4/15/2020 1:20:00 Agarcia@stu. Saint Thomas may have to close.
PM PIO (Email from Garcia Alfredo edu University
Page 113 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
To Whom It May Concern:
On behalf of non-profit and higher education institutions, we would like to urge you to please expand eligibility criteria for the Federal Reserve
"Main Street" Lending Facility. Similar to many businesses, these entities are suffering losses from the current crisis and require
additional resources to be able to cover those losses and many are ineligible for the Paycheck Protection Program.
These institutions employ more than 5 million dedicated professionals/workers and educate more than 19.9 million students across the United
St. Thomas States. Many universities are main employers in their communities, and some oversee major health care systems that are responding to the
4/15/2020 1:21:00 eroyal@stu.e University, pandemic. Their ineligibility to participate may mean some of these institutions may have to close. Thank you.
PM PIO (Email from Royal Elias du School of Law
Feedback on the Federal Reserve "Main Street" lending facility
To whom it may concern:
Please expand eligibility criteria for the Federal Reserve "Main Street" Lending Facility to include non-profits and higher
education institutions. Like many businesses these entities are suffering losses from the current crisis and require additional resources to be
able to cover those losses. Many of them are ineligible for the Paycheck Protection Program.
These institutions employ more than 5 million dedicated professionals/workers and educate more than 19.9 million students across the
St. Thomas United States. Many universities are a main employer in their communities, and some oversee major health systems that are responding to
4/15/2020 1:21:00 krizzardi@stu University the pandemic. Their ineligibility to participate may mean some of these institutions may have to close.
PM PIO (Email from Rizzardi Keith .edu School of Law
Sincerely, Keith Rizzardi
As part of the bipartisan CARES Act, the Federal Reserve announced the new "Main Street" lending facility supporting loans to
small and mid-sized businesses. Unfortunately, as of today, you are considering the exclusion of nonprofits 501(c)6 organizations. This would
be a significant, negative blow for our small association working to serve toy stores across North America. We serve to help keep these small
businesses with education, certification, and access to manufacturers. It is through our advocacy efforts, elected leaders here strategies for
American support main street retailing in their communities. And it is through our marketing, the general public learns of the importance of supporting
Specialty Toy their local economy. Without access to the funding proposed, our little association will be out of business. Please reconsider the approach
4/15/2020 1:22:00 kmosley@ast Retailing being proposed for Main Street Lending to include our association. Thank you.
PM PIO (Email from Mosley Kimberly ratoy.org Association
Personal Please do not exclude nonprofits or Minority-Serving Institutions from this new lending facility. All organizations should be eligible. Non profits
4/15/2020 1:22:00 Email especially are taking on the worst of the horror of what we're seeing on the streets, where poverty is right there in front of us.
PM PIO (Email from Kirchen Debbie Address
RE: Federal Reserve "Main Street" lending facility
To whom it may concern:
We would like to urge you to please expand eligibility criteria for the Federal Reserve "Main Street" Lending Facility to include non-
profits and higher education institutions. Like many businesses these entities are suffering losses from the current crisis and require additional
resources to be able to cover those losses. Many of them are ineligible for the Paycheck Protection Program.
These institutions employ more than 5 million dedicated professionals/workers and educate more than 19.9 million students across the United
States. Many universities are a main employer in their communities, and some oversee major health systems that are responding to the
pandemic. Their ineligibility to participate may mean some of these institutions may have to close. Leaving these institutions in peril also
imposes a burden and risk on the students attending those institutions and could cause the students to be unable to finish their degree
Personal
programs.
Email
4/15/2020 1:22:00 St. Thomas Sincerely,
Address
PM PIO (Email from Hernandez John University John F. Hernandez
To whom it may concern:
We would like to urge you to please expand eligibility criteria for the Federal Reserve "Main Street" Lending Facility to include non-
profits and higher education institutions. Like many businesses these entities are suffering losses from the current crisis and require additional
resources to be able to cover those losses. Many of them are ineligible for the Paycheck Protection Program.
These institutions employ more than 5 million dedicated professionals/workers and educate more than 19.9 million students across the United
States. Many universities are a main employer in their communities, and some oversee major health systems that are responding to the
pandemic. Their ineligibility to participate may mean some of these institutions may have to close.
Sincerely,
4/15/2020 1:22:00 mabdel@stu.
PM PIO (Email from Abdel Maria edu Maria Abdel
Page 114 of 363
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Main Street Lending Program Comments
To whom it may concern:
We would like to urge you to please expand eligibility criteria for the Federal Reserve "Main Street" Lending Facility to include non-
profits and higher education institutions. Like many businesses these entities are suffering losses from the current crisis and require additional
resources to be able to cover those losses. Many of them are ineligible for the Paycheck Protection Program.
These institutions employ more than 5 million dedicated professionals/workers and educate more than 19.9 million students across the United
States. Many universities are a main employer in their communities, and some oversee major health systems that are responding to the
pandemic. Their ineligibility to participate may mean some of these institutions may have to close.
Thank you for your consideration regarding this urgent matter.
4/15/2020 1:24:00 hgonzalez@s St. Thomas Respectfully,
PM PIO (Email from Gonzalez Haydee tu.edu University Haydee Gonzalez
The Main Street Lending program must include funding for non-profits such as the Northshore Senior Center which perform crucial services
Personal such as food assistance, chronic disease management, physical/mental health, transportation services, etc. that would otherwise be put on
4/15/2020 1:24:00 Email Bteng government entities to provide the services. It would be a travesty to abandon these organizations and lose the established infrastructure
PM PIO (Email from Teng Bing Address Enterprises supporting our local communities and neighborhoods.
Please consider including nonprofit organizations in the small business provision of the CARES Act. Nonprofits provide vital services to
communities and should be considered on equal footing with other small businesses. Although they may not have the goal of making a profit,
they do contribute to building healthy communities. They also have expenditures and employees to take care of. That means that without aid
Personal some of these employees will be let go, adding to the unemployment numbers. Nonprofit organizations that rely on donations and grants will
Email Creative likely take a hit from the current economy as it is and would greatly benefit from the loans provided by the CARES Act. If we want to keep the
4/15/2020 1:24:00 Address Montessori economy as strong as possible, nonprofit organizations must be included with other small businesses. Thank you for your time.
PM PIO (Email from Kamowski Lara School
We are a 650 employee trucking company. Given the PPP program's 500 employee limit, we have been unable to obtain any assistance
during the pandemic (except by furloughing employees to the unemployment system). We greatly need assistance and have looked hard for
it. There is the rumored "Mainstreet" loan program, but as far as we can tell it does not yet exist. If we don't get help soon, we
may have to close permanently and the economy will lose 700 jobs...
It is a shame that politicians put the 500 ee limit in place and did not think of companies like ours. Businesses of our size are vital to the
American economy. Further, the 500 ee companies get what is essentially a grant. If the main street program comes into place, we will have
to pay it back. That will be challenging given our revenue will have gone to zero for a period, and we have obtained deferrals on some key
expenses that will also need to be paid back. That said, we will be glad to get a loan to keep the company viable once the pandemic recedes.
Incidentally, the news reported today that the airlines are getting $25bn in loan assistance. Small gets help, mega gets help, middle-market
has yet to get anything...
steved@virgi Virginia
4/15/2020 niatransportat Transportation Please let us know how to apply for the Mainstreet loan program, asap, days matter...
12:00:00 AM PIO (Email from Doire Steve ion.com Corporation
4/15/2020 1:26:00 Personal You must include medium and large nonprofits in the Main Street Lending Program as they are needed to help communities such as mine in
PM PIO (Email from Ward Elizabeth Email Address Larchmont, New York, survive and recovery from the Covid-19 pandemic.
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Main Street Lending Program Comments
Please expand the eligibility criteria for the Federal Reserve "Main Street" Lending Facility to include non-profits and higher
education institutions. Like many businesses, these entities are suffering losses from the current crisis and require additional resources to be
able to cover those losses. Additionally, many of them are ineligible for the Paycheck Protection Program.
These institutions employ more than 5 million dedicated professionals/workers and educate more than 19.9 million students across the United
States. Many universities are a primary source of employment in their communities, and some oversee major health systems that are
responding to the pandemic. Their ineligibility to participate may mean some of these institutions may have to close. Additionally, institutions
of higher learning will play an important role in developing the skills and career-readiness that potential employers will require to be adaptive
in these adverse times.
Due to the previously noted position, the critical role institutions of higher education and non-profits will play in work-force development, and
their research that will help us to serve our world more effectively, I strongly encourage you to expand Main Street Lending and extend
opportunities to the noted areas. Thanks for your consideration and have a good day.
Anthony Andenoro, PhD
Executive Director & Professor
4/15/2020 1:26:00 andenoro@st St. Thomas Institute for Ethical Leadership
PM PIO (Email from Andenoro Anthony u.edu University St. Thomas University, Miami
I am an employee of a nonprofit healthcare organization in California, and I am writing to advocate for the inclusion of nonprofit organizations
as part of the Main Street Lending Program. The none-profits, are only good as the funding that are administrated to them.
fherrera@he Should our government deem us as essential and necessary for all we do and give to our
4/15/2020 1:27:00 althright360.o community, where lives are always an impact. Thank you.
PM PIO (Email from Herrera Francisco rg
I am 1 of 4,000 employee's of People Inc., a regional not for profit health & human service agency that provides services to nearly
10,000 people with intellectual & developmental disabilities, special needs, their families and older adults throughout the entire Western
New York and Greater Rochester regions. People Inc. is fully engaged in responding to the COVID-19 crisis. We must ensure our services,
especially residential services in our congregate care homes for people with disabilities remain staffed 24 hours a day, 7 days a week as
these highly vulnerable people depend on direct care in a safe environment. As People Inc. is providing essential services during this
pandemic, we have incurred atypical and unforseeable increased costs in staffing, PPE and cleaning services. We are not eligible for the
Payroll Protection Plan (PPP) due to our size. However, we must remain fully operational. Thus, as a staff member of this essential
organization, I am requesting that the Mid-size Loan Program have provisions to convert to a forgiveable loan for Non-profit agencies that face
staggering losses due COVID-19. This would grant us the same protections as PPP. Thank you in advance for your support of our direct
care staff, the people we support and our agency.
In appreciation;
4/15/2020 1:28:00 lbooth@peop Lizbeth J. Booth, Ph.D.
PM PIO (Email from Booth Lizbeth le-inc.org People Inc. Principal Psychologist - People Inc.
Our company, which has been in business since 1833, has a revolving loan today with our bankers in Cleveland, Ohio. We do not have a
term loan from a bank, and therefore under the proposed rules, we do not have a loan to expand. We would like to be able to apply for and
obtain financing under MSELF. We are pleased with the terms of the proposed facility, and believe that our existing banks would be pleased
to make this loan. We want to be eligible, and would like to see that these precious loans are not be limited to existing term loans only. The
MSNLF is not adequate in size to provide necessary relief for us.
mike.gleason Thank you
4/15/2020 1:29:00 @austinpowd Austin Powder Mike Gleason
PM PIO (Email from Gleason Mike er.com Company Vice Chairman
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Main Street Lending Program Comments
Feedback on the Federal Reserve "Main Street" lending facility
To whom it may concern:
We would like to urge you to please expand eligibility criteria for the Federal Reserve "Main Street" Lending Facility to include non-
profits and higher education institutions. Like many businesses these entities are suffering losses from the current crisis and require additional
resources to be able to cover those losses. Many of them are ineligible for the Paycheck Protection Program.
These institutions employ more than 5 million dedicated professionals/workers and educate more than 19.9 million students across the United
States.
Many universities are a main employer in their communities, and some oversee major health systems that are responding to the pandemic.
St. Thomas Their ineligibility to participate may mean some of these institutions may have to close.
4/15/2020 1:30:00 Edema@stu. University, Miami
PM PIO (Email from Dema Eddy Erla edu Gardens, FL Thank you for your consideration
To whom it may concern:
As an employee of a Higher Learning Institution, I would like to urge you to please expand eligibility criteria for the Federal Reserve
"Main Street" Lending Facility to include non-profits and higher education institutions. Like many businesses these entities are
suffering losses from the current crisis and require additional resources to be able to cover those losses. Many of them are ineligible for the
Paycheck Protection Program.
These institutions employ more than 5 million dedicated professionals/workers and educate more than 19.9 million students across the United
States. Many universities are a main employer in their communities, and some oversee major health systems that are responding to the
Personal pandemic. Their ineligibility to participate may mean some of these institutions may have to close.
4/15/2020 1:32:00 Email Address I have witnessed the direct our Institution has had on lower income and minority students that supports the less fortunate in our community in
PM PIO (Email from Mass Louis STU SE Florida. Please pass the bill to help us continue empowering tomorrows leaders
To whom it may concern:
We would like to urge you to please expand eligibility criteria for the Federal Reserve "Main Street" Lending Facility to include non-
profits and higher education institutions. Like many businesses these entities are suffering losses from the current crisis and require additional
resources to be able to cover those losses. Many of them are ineligible for the Paycheck Protection Program.
These institutions employ more than 5 million dedicated professionals/workers and educate more than 19.9 million students across the United
States. Many universities are a main employer in their communities, and some oversee major health systems that are responding to the
4/15/2020 1:34:00 mugalde@st St. Thomas pandemic. Their ineligibility to participate may mean some of these institutions may have to close.
PM PIO (Email from Ugalde Marina u.edu University Thank you.
To whom it may concern:
We would like to urge you to please expand eligibility criteria for the Federal Reserve "Main Street" Lending Facility to include non-
profits and higher education institutions. Like many businesses these entities are suffering losses from the current crisis and require additional
St Thomas resources to be able to cover those losses. Many of them are ineligible for the Paycheck Protection Program.
University. These institutions employ more than 5 million dedicated professionals/workers and educate more than 19.9 million students across the United
4/15/2020 1:34:00 nlledes@stu. Human Rights States. Many universities are a main employer in their communities, and some oversee major health systems that are responding to the
PM PIO (Email from Lledes Nancy edu Institute pandemic. Their ineligibility to participate may mean some of these institutions may have to close.
We would like to urge you to please expand eligibility criteria for the Federal Reserve "Main Street" Lending Facility to include non-
profits and higher education institutions. Like many businesses these entities are suffering losses from the current crisis and require additional
resources to be able to cover those losses. Many of them are ineligible for the Paycheck Protection Program.
These institutions employ more than 5 million dedicated professionals/workers and educate more than 19.9 million students across the United
States. Many universities are a main employer in their communities, and some oversee major health systems that are responding to the
4/15/2020 1:36:00 lcourtle@stu. St. Thomas pandemic. Their ineligibility to participate may mean some of these institutions may have to close. Closing of doors means more lost jobs,
PM PIO (Email from Courtley Todd Laura edu University more devastation and an inability to provide hope.
To whom it may concern: We would like to urge you to please expand eligibility criteria for the Federal Reserve "Main Street"
Lending Facility to include non-profits and higher education institutions. Like many businesses these entities are suffering losses from the
current crisis and require additional resources to be able to cover those losses. Many of them are ineligible for the Paycheck Protection
Program.
These institutions employ more than 5 million dedicated professionals/workers and educate more than 19.9 million students across the United
4/15/2020 1:37:00 jgentile@stu. States. Many universities are a main employer in their communities, and some oversee major health systems that are responding to the
PM PIO (Email from Gentile Juana M edu STUHRI pandemic. Their ineligibility to participate may mean some of these institutions may have to close.
Page 117 of 363
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Main Street Lending Program Comments
As one of 4,000 employees of a regional non-profit health and human services agency that provides programs and services to nearly 10,000
people with intellectual and developmental disabilities, special needs, their families and older adults throughout numerous counties in Western
New York and the Greater Rochester region, I am writing today to inform you that our agency, People Inc., is fully engaged in dealing with the
COVID-19 crisis. We must ensure that our homes and services for people with disabilities remain as safe as possible and are staffed 24/7.
The vulnerable people that depend on us deserve no less. However, because we are providing essential services during the crisis, People
Inc. has incurred highly unusual increased costs in staffing, PPE, and cleaning services.
Since we are not eligible for the Payroll Protection Program (PPP) due to our size and we must remain fully operational, we request that the
Mid-Size Loan Program have provisions to convert to a forgivable loan for nonprofits that face staggering losses due to COVID-19. This would
grant us the same protections as PPP.
jsanderson@
4/15/2020 1:38:00 people- Thank you in advance for your support of direct care staff, the people we support and our agency, People Inc.
PM PIO (Email from Sanderson Jeff inc.org People Inc.
I am an employee of a nonprofit healthcare organization in California, and I am writing to advocate for the inclusion of nonprofit organizations
as part of the Main Street Lending Program. The exclusion of nonprofits from this program leaves medium-size nonprofits - which are also not
eligible to participate in the Paycheck Protection Program - in precarious financial standing without any way to mitigate economic injury while
preserving workforce and continuing critical services to hundreds of thousands of Californians. Without the vital aid provided by the program,
organizations like ours are at risk of making cuts to staff and services which impacts our ability to serve some of the most vulnerable people in
mejones@he California. PLEASE INCLUDE NONPROFIT ORGANIZATIONS OR EXPAND THE PAYCHECK PROTECTION PROGRAM TO INCLUDE
4/15/2020 1:38:00 althright360.o ALL NONPROFITS WHICH WILL INCREASE THE CAPACITY OF THE SAFETY NET SYSTEM.
PM PIO (Email from Jones Megan rg Healthright 360
Main Street New Loan Facility should be expanded to include loans to start-up businesses which can demonstrate the ability to create no
fewer than 100 jobs within the first year of operation and as many as 300 jobs by the end of the third year of operations with minimum wages
of at least $15 per hour with a hiring preference to low income workers residing in the United States. The maturity of these loans should not
exceed 10 years with one-year deferral of principal and interest payments. Maximum loan cannot exceed $25 million with the actual loan
amount calculated based on a multiple of $75,000 times the number of jobs projected to be created by the end of the third year of operations.
Personal Preferential funding of these loans shall occur for businesses which will have a substantial economic or environmental impact. Attestation
4/15/2020 1:39:00 Email Address relating to EBITDA language condition is not applicable to loans to start-up businesses.
PM PIO (Email from Waldrip Mark
We are a non-profit educational organization that is crucially important to the lives of our current and future students. Any additional help will
4/15/2020 1:39:00 jperez9@stu. St. Thomas ensure that we stay open and can continue to be a place where we develop future leaders in our community and country.
PM PIO (Email from Perez Jorge edu University
To whom it may concern:
We would like to urge you to please expand eligibility criteria for the Federal Reserve "Main Street" Lending Facility to include non-
profits and higher education institutions. Like many businesses these entities are suffering losses from the current crisis and require additional
resources to be able to cover those losses. Many of them are ineligible for the Paycheck Protection Program.
These institutions employ more than 5 million dedicated professionals/workers and educate more than 19.9 million students across the United
States. Many universities are a main employer in their communities, and some oversee major health systems that are responding to the
St. Thomas pandemic. Their ineligibility to participate may mean some of these institutions may have to close.
4/15/2020 1:39:00 University
PM PIO (Email from Cos Jorge jcos@stu.edu School of Law I thank you for your attention to this matter!
Page 118 of 363
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Main Street Lending Program Comments
RE:Feedback on the Federal Reserve "Main Street" lending facility
To whom it may concern:
I urge you to please expand eligibility criteria for the Federal Reserve "Main Street" Lending Facility to include non-profits and
higher education institutions. Like many businesses these entities are suffering losses from the current crisis and require additional resources
to be able to cover those losses. Many of these institutions are ineligible for the Paycheck Protection Program.
These institutions employ more than 5 million dedicated professionals/workers and educate more than 19.9 million students across the United
States. Many universities are a main employer in their communities, and some oversee major health systems that are responding to the
pandemic. Their ineligibility to participate may mean some of these institutions may have to close.
Thank you for considering this request.
Sincerely,
4/15/2020 1:41:00 czeiner@stu. St. Thomas Carol L. Zeiner
PM PIO (Email from Zeiner Carol edu University Professor of Law
To whom it may concern: We would like to urge you to please expand eligibility criteria for the Federal Reserve "Main Street"
Lending Facility to include non-profits and higher education institutions. Like many businesses these entities are suffering losses from the
current crisis and require additional resources to be able to cover those losses. Many of them are ineligible for the Paycheck Protection
Program.
These institutions employ more than 5 million dedicated professionals/workers and educate more than 19.9 million students across the United
4/15/2020 1:41:00 clamb@stu.e St. Thomas States. Many universities are a main employer in their communities, and some oversee major health systems that are responding to the
PM PIO (Email from Lamb C. du University pandemic. Their ineligibility to participate may mean some of these institutions may have to close.
4/15/2020 1:41:00 Personal Please extend lending eligibility to non-profit organizations, to all higher education institutions and to every institution that serves minorities,
PM PIO (Email from King Katherine Email Address Hospitals and health care institutions should be given priority
I am an employee of a nonprofit healthcare organization in California, and I am writing to advocate for the inclusion of nonprofit organizations
as part of the Main Street Lending Program. The exclusion of nonprofits from this program leaves medium-size nonprofits - which are also not
eligible to participate in the Paycheck Protection Program - in precarious financial standing without any way to mitigate economic injury while
preserving workforce and continuing critical services to hundreds of thousands of Californians. Without the vital aid provided by the program,
organizations like ours are at risk of making cuts to staff and services which impacts our ability to serve some of the most vulnerable people in
California. PLEASE INCLUDE NONPROFIT ORGANIZATIONS OR EXPAND THE PAYCHECK PROTECTION PROGRAM TO INCLUDE
4/15/2020 1:43:00 pwiley@healt ALL NONPROFITS WHICH WILL INCREASE THE CAPACITY OF THE SAFETY NET SYSTEM.
PM PIO (Email from Wiley Paulette hright360.org Healthright
Feedback on the Federal Reserve "Main Street" lending facility
To whom it may concern: We would like to urge you to please expand eligibility criteria for the Federal Reserve "Main Street"
Lending Facility to include non-profits and higher education institutions. Like many businesses these entities are suffering losses from the
current crisis and require additional resources to be able to cover those losses. Many of them are ineligible for the Paycheck Protection
Program.
St. Thomas These institutions employ more than 5 million dedicated professionals/workers and educate more than 19.9 million students across the United
4/15/2020 1:43:00 ccastleberry University States. Many universities are a main employer in their communities, and some oversee major health systems that are responding to the
PM PIO (Email from Castleberry Carol @stu.edu School of Law pandemic. Their ineligibility to participate may mean some of these institutions may have to close.
We represent a company that has already deferred payroll taxes for 2020 which resulted in substantial savings and ideally would not want to
accelerate those payments in order to apply for loans under the Main Street Lending Program.
Unrelated to the payroll tax deferral question, we are interested in what, if any, possibility exists under the Main Street Lending Program of
narrowing the list of certifications required under that program. Any such narrowing would minimize the burden on companies in a pandemic
of preparing supporting documents and obtaining board approvals and, importantly, minimize exposure if and when loans are scrutinized in
the future. Certification that the loan is necessary to support ongoing operations and that the applicant cannot reasonably obtain credit
morgan@ball elsewhere are excessive. There is already a requirement under the Main Street Lending Program for participants to certify that financing is
4/15/2020 1:44:00 ardpartners.c required due to the existent circumstances of Covid 19 and the applicant will use the loan proceeds to maintain payroll and retain its
PM PIO (Email from DeWitt Morgan om Ballard Partners employees.
Page 119 of 363
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Main Street Lending Program Comments
Please include medium and large nonprofits in the Main Street Lending Program.
Please issue grants to nonprofits of all sizes as well.
Personal They are needed to help communities survive and recovery from the Covid-19 pandemic.
4/15/2020 1:45:00 Email
PM PIO (Email from Osinloye Shane Address Singularity Please also launch a Universal Basic Income program with no strings attached.
The majority of employees of a US company we represent (which is the company that is desirous of applying for a loan under the Main Street
Loan Program) are based in the US (under 500). However, the company has two foreign subsidiaries which employ over 500 individuals in
morgan@ball Europe, neither of which would partake in the proceeds of any loan provided to the company. The question arises whether those employees
4/15/2020 1:48:00 ardpartners.c of the company's European subsidiaries would be considered in determining the company's eligibility for loans under the Main
PM PIO (Email from DeWitt Morgan om Ballard Partners Street Loan Program.
To whom it may concern:
Please take immediate action to expand eligibility criteria for the Federal Reserve "Main Street" Lending Facility to include non-
profits and higher education institutions. Like many businesses these entities are suffering losses from the current crisis and require additional
resources to be able to cover those losses. Many of them are ineligible for the Paycheck Protection Program.
These institutions employ more than 5 million dedicated professionals/workers and educate more than 19.9 million students across the United
States. Many universities are a main employer in their communities, and some oversee major health systems that are responding to the
Personal pandemic. Their ineligibility to participate may mean some of these institutions may have to close.
4/15/2020 1:49:00 Email
PM PIO (Email from Epling Robert Address Thank you for your consideration.
I would like to urge you to please expand eligibility criteria for the Federal Reserve "Main Street" Lending Facility to include non-
profits and higher education institutions. Like many businesses these entities are suffering losses from the current crisis and require additional
resources to be able to cover those losses. Many of them are ineligible for the Paycheck Protection Program.
These institutions employ more than 5 million dedicated professionals/workers and educate more than 19.9 million students across the United
Personal
States. Many universities are a main employer in their communities, and some oversee major health systems that are responding to the
Email Address
4/15/2020 1:49:00 pandemic. Their ineligibility to participate may mean some of these institutions may have to close. I thank you in advance for your time in
PM PIO (Email from Tulande Michelle reading and considering my concerns.
Feedback on the Federal Reserve "Main Street" lending facility
To whom it may concern:
We would like to urge you to please expand eligibility criteria for the Federal Reserve "Main Street" Lending Facility to include non-
profits and higher education institutions. Like many businesses these entities are suffering losses from the current crisis and require additional
resources to be able to cover those losses. Many of them are ineligible for the Paycheck Protection Program.
These institutions employ more than 5 million dedicated professionals/workers and educate more than 19.9 million students across the United
4/15/2020 1:49:00 mmarquez@ St Thomas States. Many universities are a main employer in their communities, and some oversee major health systems that are responding to the
PM PIO (Email from Marquez Maikel stu.edu University pandemic. Their ineligibility to participate may mean some of these institutions may have to close.
To whom it may concern:
We would like to urge you to please expand eligibility criteria for the Federal Reserve "Main Street" Lending Facility to include non-
profits and higher education institutions. Like many businesses these entities are suffering losses from the current crisis and require additional
resources to be able to cover those losses. Many of them are ineligible for the Paycheck Protection Program.
These institutions employ more than 5 million dedicated professionals/workers and educate more than 19.9 million students across the United
States. Many universities are a main employer in their communities, and some oversee major health systems that are responding to the
pandemic. Their ineligibility to participate may mean some of these institutions may have to close.
4/15/2020 1:49:00 cdykas@stu. St. Thomas Thank you for your consideration,
PM PIO (Email from Dykas Cecile edu University Cecile Dykas
Page 120 of 363
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Main Street Lending Program Comments
Nonprofits account for roughly one in 10 jobs in the U.S. workforce, with total employees numbering 12.3M in 2016. Nonprofit employment
now equals manufacturing. Retail trad, accommodation and food services are the only industries that employ more people than nonprofits.
Demand for nonprofit services has risen through the economic downturn that COVID-19 has brought on, while simultaneously cutting out
much of our fundraising and other income streams.
Your current "Main Street" lending options are excluding nonprofits, many institutions of higher learning and Minority-Serving
institutions. By doing so, you are ignoring sectors that have and will have real impact on our communities, and who also can help to re-
4/15/2020 1:50:00 knevins@wfri Women's Fund imagine an economy that is not quite so vulnerable to crises such as the current one. Please INCLUDE these institutions in your funding
PM PIO (Email from Nevins Kelly .org of Rhode Island formulas moving forward!
morgan@ball Accordingly, my question is whether a high growth company that is able to repay a loan based on current quarter financials annualized can be
4/15/2020 1:50:00 ardpartners.c eligible for a new or expanded loan under the Main Street program regardless whether the company had a negative EBITDA in 2019. If not,
PM PIO (Email from DeWitt Morgan om Ballard Partners what facilities exist or will exist for such companies?
Section 5.(ii) of the Main Street Lending terms creates a maximum loan amount of 4 * EBITDA.
This provision prevents solvent, but unprofitable start-ups from participating in the program. Our business (xappmedia.com) provides voice
technology that is key to enabling people to do business without needing to touch devices and can help reduce the spread of coronavirus.
Please consider making the program available to promising start-ups by making the maximum loan amount equal to the greater of 4 and 5,
4/15/2020 1:50:00 path@xappm XAPPMEDIA, which would maintain $1 million as the minimum loan amount. This change will make the program work for start-ups that will be key to the
PM PIO (Email from Higbie Patrick edia.com INC. recovery. Thanks, Pat Higbie
As a non-profit program in New Orleans providing support to business owners, I hear every day that due to lack of revenue, owners cannot
pay their business' rent. Where bank providing Main Street Loan Program funds are also mortgage servicers, the Fed should do more
than encourage banks which are mortgage servicers to place consumers in short-term payment forbearance programs --the Fed should
require it.
In order to maximize employment beyond the PPP, brick and mortar businesses need assurance that they will not be pushed off of the very
Main Street for which the bill is named.
These business owners are stalwart commercial tenants who have rarely if ever caused financial loss to landlords--but if they miss their rent
payments this will cause a domino effect. Their landlords will not be able to make mortgage payments.
Requiring mortgage servicers to place only these consumers in short-term payment forbearance could take a number of shapes, for instance,
it could be limited to mixed-use properties, or applied to all occupied properties within federally defined Opportunity Zones, or linked to CRA
reporting.
StayLocal, an
initiative of the Whatever the method, the need to prevent the market disruption that will be caused by hundreds of thousands of "for rent" signs
4/15/2020 1:51:00 maryann@st Urban on American main streets is of primary and utmost importance. The Fed can prevent a future of abandoned storefronts blighting our
PM PIO (Email from Miller Maryann aylocal.org Conservancy community. Please require banks which are providing Fed loans to relieve mortgages.
To whom it may concern:
We would like to urge you to please expand eligibility criteria for the Federal Reserve "Main Street" Lending Facility to include non-
profits and higher education institutions. Like many businesses these entities are suffering losses from the current crisis and require additional
resources to be able to cover those losses. Many of them are ineligible for the Paycheck Protection Program.
These institutions employ more than 5 million dedicated professionals/workers and educate more than 19.9 million students across the United
4/15/2020 1:51:00 Mgaravito@s St. Thomas States. Many universities are a main employer in their communities, and some oversee major health systems that are responding to the
PM PIO (Email from Bedoya Maria tu.edu University pandemic. Their ineligibility to participate may mean some of these institutions may have to close.
I encourage the Federal Reserve to include nonprofits, institutions of higher learning, HBCUs, and Minority-Serving Institutions in the Main
Street lending program. According to the National Center for Charitable Statistics (NCCS), more than 1.5 million nonprofit organizations are
registered in the U.S. Together they have contributed an estimated $985.4 billion to the US economy in 2015, composing 5.4 percent of the
country's gross domestic product (GDP). The contributions are considerable, to name a few, from the front line medical professionals,
whom work at nonprofit hospitals, combating COVID-19 alongside with the paramedics, firefighters, police officers, and the social workers.
Then you have your professors and graduate students joining forces with the business and military communities undertaking the research to
identify a possible vaccine for the COVID-19. In addition, thousands of nonprofit organizations are doing their part to work with the vulnerable
4/15/2020 1:52:00 Personal Shapard & groups include the homeless citizens, children, senior citizens and families through a variety of prevention and intervention programming
PM Email Accounts, LLC
PIO (Email from Shapard Sarah during this unprecedented times.
Address
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Main Street Lending Program Comments
Questions regarding Main Street New and Expanded Loan Facility;
1) If Borrower utilizes a revolving/operating line of credit with an automated sweep feature will this need to be shut-off to avoid paying down
existing debt via normal course of business?
2) Can Lender charge more than 1% origination fee?
3) How does the pari pass work for the New program? Assume a $1MM loan, SPV buys $950M and bank keeps $50M, we lose $500M, SPV
loses $425M and bank loses $25M?
Thank you.
marty.ersche
4/15/2020 1:53:00 n@wellsfargo Wells Fargo Marty Erschen
PM PIO (Email from Erschen Marty .com Bank, N.A. 317-508-6014
In support of the 4,000 employees of a regional non-profit health and human services agency that provides programs and services to nearly
10,000 people with intellectual and developmental disabilities, special needs, their families and older adults throughout numerous counties in
Western New York and the Greater Rochester region, I am writing today to inform you that People Inc. is fully engaged in dealing with the
COVID-19 crisis. They must ensure that more than 150 community-based homes and services for people with disabilities remain as safe as
possible and are staffed 24/7. The vulnerable people that depend on People Inc. deserve no less. However, because they are providing
essential services during the crisis, People Inc. has incurred highly unusual increased costs in staffing, PPE, cleaning services and other
critical services.
Since People Inc. is not eligible for the Payroll Protection Program (PPP) due to their size and the fact that they must remain fully operational,
Personal we request that the Mid-Size Loan Program have provisions to convert to a forgivable loan for nonprofits that face staggering losses due to
Email COVID-19. This would grant them the same protections as PPP.
4/15/2020 1:53:00 Address
PM PIO (Email from Albond-Buchn Roxane Thank you in advance for your support of direct care staff, the people they support and People Inc.
After review of the Main Street Expanded Lending Program, we find it contains structural restrictions that do not account for the needs of
Retail businesses, particularly those with Asset Based Loan (ABL) credit facilities.
The program loan size limitations in §5(iii) are too restrictive. The phrase 'existing outstanding and committed but undrawn bank
debt' is interpreted as the full value of any committed credit facility for ABL deals. For many retailers, the total size of their committed line
is quite large in order to accommodate short periods of high borrowing levels utilized just prior to peak Holiday season.
E.g. Confidential Business Information
A few ideas:
Use 2019 average outstanding balances rather than full committed lines
Change EBITDA to EBITDA-R (R-rent). This will acknowledge the significant costs rents play in retail earnings and help adapt the calc. to
reflect the unique cost and cash flow structure of retail businesses
Increase the EBITDA multiple to 9x
Orvis is the type of business this program is designed to support, a 165 year old, family owned, American brand with a solid balance sheet. As
4/15/2020 1:54:00 beanr@orvis. currently written, Orvis and other retailers our size are precluded from participating at a time when it is critical to survival.
PM PIO (Email from Bean Rob com Orvis
I encourage you to re examine the terms of the loan and make it more accessible to small home builders. a max loan amount of 4 times 2019
earnings does not provide access to home builders who have high capital needs for construction. Confidential Business Information
Modern Confidential Business Information
Personal
4/15/2020 1:55:00 Construction of
Email Address
PM PIO (Email from Hartung Jesse Minnesota
Page 122 of 363
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Main Street Lending Program Comments
As one of 4,000 employees of a regional non-profit health and human services agency that provides programs and services to nearly 10,000
people with intellectual and developmental disabilities, special needs, their families and older adults throughout numerous counties in Western
New York and the Greater Rochester region, I am writing today to inform you that our agency, People Inc., is fully engaged in dealing with the
COVID-19 crisis. We must ensure that our homes and services for people with disabilities remain as safe as possible and are staffed 24/7.
The vulnerable people that depend on us deserve no less. However, because we are providing essential services during the crisis, People
Inc. has incurred highly unusual increased costs in staffing, PPE, and cleaning services.
Since we are not eligible for the Payroll Protection Program (PPP) due to our size and we must remain fully operational, we request that the
Mid-Size Loan Program have provisions to convert to a forgivable loan for nonprofits that face staggering losses due to COVID-19. This would
grant us the same protections as PPP.
Thank you in advance for your support of direct care staff, the people we support and our agency, People Inc.
In Appreciation,
Trish Kibler
People Inc.
4/15/2020 1:56:00 pkibler@peo Certified Home Health
PM PIO (Email from Kibler Trish ple-inc.org People Inc.
To whom it may concern:
We would like to urge you to please expand the eligibility criteria for the Federal Reserve "Main Street" Lending Facility to include
non-profits and higher education institutions. Like many businesses, these entities are suffering losses from the current crisis and require
additional resources to be able to cover those losses. Many of them are ineligible for the Paycheck Protection Program.
These institutions employ more than 5 million dedicated professionals/workers and educate more than 19.9 million students across the United
States. Many universities are the main employer in their communities, and some oversee major health systems that are responding to the
pandemic. Their ineligibility to participate may mean some of these institutions may have to close.
Thank you in advance,
Personal
4/15/2020 1:56:00 St. Thomas Manny Canoura.
Email
PM PIO (Email from Canoura Manuel University
Address
Feedback on the Federal Reserve "Main Street" lending facility
To whom it may concern:
I would like to urge you to please expand the eligibility criteria for the Federal Reserve "Main Street" Lending Facility to include
non-profits and higher education institutions. Like many businesses, like St. Thomas University, these entities are suffering losses from the
current crisis and require additional resources to be able to cover those losses. Many of these institutions, including ours, are ineligible for the
Paycheck Protection Program.
St. Thomas University, including many other institutions, employ more than 5 million dedicated professionals/workers, and educate more than
19.9 million students across the United States. Also, in my department, we not only teach students, but we also have a unique program
based on a non-profit organization model, whose mission is to serve, educate and train students to become the best advocates. In doing so,
we have been teaching and preparing students and providing free legal services to the community for over twenty-five years.
Similar to St. Thomas University, many universities are the leading employer in their communities, and some oversee major health systems
St. Thomas that are responding to the pandemic. The ineligibility for us and other institutions to participate may mean that most of us may have to close
4/15/2020 1:57:00 ylaroche@stu University our doors.
PM PIO (Email from Laroche Yanick .edu School of Law
Include Non Profits in Main Street Lending Program! Medium to large-sized nonprofits have been left out of the Main Street Lending program.
This is a double whammy for large agencies that were already shut out of the Paycheck Protection Program.
Personal Email
Address
4/15/2020 1:59:00 Hospitals, food banks, mental health hotlines and a host of other nonprofits are the societal scaffolding holding us together right now. We
PM PIO (Email from Schmeidler Lynn need to make sure they get the funding to continue operating right now and are ready to help with the recovery.
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Main Street Lending Program Comments
I respectfully request a contact to discuss a manufacturing & job creation opportunity for the Mississippi Delta. Our company is located is
Washington County. Our poverty level for our citizens in Greenville MS is FORTY percent. Our employment rate is DOUBLE the national
average. Greenville needs jobs. And our company can provide them. Our company can provide jobs. Why? Because we have developed a
absorbent technology that is bio based and USDA BIo Prefferred. Federal laws require the purchase by Federal Agencies and their
contractors. These products are more absorbent, safer to use and cost less than the products currently purchased. Federal Agencies and
Distributors want to buy our new Absorbents now. Confidential Business
Information
Personal
4/15/2020 2:01:00 Email Delta Dry of Please contact
PM PIO (Email from Eifling Boyd Address America Inc Boyd at 662-931-5844 to discuss this opportunity.
I wish to express my disapproval at the (hopefully tentative) decision to exclude nonprofit organizations from the Main Street Lending
Program. Nonprofits play a major part in the quality of life, character, and all around prosperity (including revenue to businesses through
drawing tourism, and significant employment among other things) of my city and our collective culture and higher learning as a whole. It is
Personal clear from direct local observation they are among the organizations suffering severely enough right now it is unclear if they will be able to
4/15/2020 2:03:00 Email resume without assistance once the dust settles, despite being a crucial part of the lifeblood of my city and state. I urge you to reconsider and
PM PIO (Email from Magin Mary Address include nonprofits in financial relief during these unprecedented times.
What banks or agencies will be working on these loans in the eastern NC areas near New Bern, NC?
Thanks,
bill@nautical Bill Wheeler
4/15/2020 2:06:00 wheelersnc.c NAUTICAL Nautical Wheelers
PM PIO (Email from Wheeler Bill om WHEELERS 252-241-0532
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act I am
affiliated with a nonprofit organization in California and I am writing to advocate for restoration of the applicability of the Main Street Lending
Program to nonprofits with more than 500 employees. The enabling legislation (CARES Act, Section 4003) expressly included nonprofit
organizations between 500 and 10,000 employees, but it now appears the Federal Reserve's initial guidance for the Main Street Lending
Program excludes nonprofits for eligibility. These critical providers of the nation's safety net are not eligible for the Paycheck Protections
Program (PPP) (Sections, 1102, 1106) or the Economic Injury Disaster Loans (EIDL) (Section 1110) or other federal relief. This proposed
action threatens the viability of larger nonprofits who provide aid to hundreds of thousands of children and families. Please include nonprofits
4/15/2020 2:11:00 trishd@good Goodwill of that employ over 500 employees in the Main Street Program to protect the critical safety net.
PM PIO (Email from Dorsey Trish willsv.org Silicon Valley
Is the Main Street Lending Program a loan product?
Personal
If yes, please give me the eligibility requirements and max loan amount, rate and terms, etc...
Email
4/15/2020 2:11:00
Address
PM PIO (Email from Prenatt Marie Retired thank you
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act I am
affiliated with a nonprofit organization in California and I am writing to advocate for restoration of the applicability of the Main Street Lending
Program to nonprofits with more than 500 employees. The enabling legislation (CARES Act, Section 4003) expressly included nonprofit
organizations between 500 and 10,000 employees, but it now appears the Federal Reserve's initial guidance for the Main Street Lending
Program excludes nonprofits for eligibility. These critical providers of the nation's safety net are not eligible for the Paycheck Protections
Program (PPP) (Sections, 1102, 1106) or the Economic Injury Disaster Loans (EIDL) (Section 1110) or other federal relief. This proposed
amy.feldman action threatens the viability of larger nonprofits who provide aid to hundreds of thousands of children and families. Please include nonprofits
4/15/2020 2:12:00 @allgoodwor All Good Work that employ over 500 employees in the Main Street Program to protect the critical safety net.
PM PIO (Email from Feldman Amy k.org Foundation
4/15/2020 2:14:00 Mrogers@stu St Thomas Don't forget we are also a big part of the community and have shut down operations and we need to be part of the care act
PM PIO (Email from Rogers Mark .edu University
Personal Please include all nonprofits in the Main Street Lending Program. They are needed to help communities such as mine in Philadelphia Pa
4/15/2020 2:17:00 Email Address survive and recovery from the Covid-19 pandemic. That means HOSPITALS, FOOD BANKS, MENTAL HEALTH SERVICES! People need
PM PIO (Email from Kaier Charles help now.
4/15/2020 2:18:00 jtoohey@ada Adage It is appalling that the Federal Reserve is considering the exclusion of nonprofits, many institutions of higher learning and Minority-Serving
PM PIO (Email from Toohey Jake getech.com Technologies Institutions. I urge you to add these types of groups to the CARES Act.
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Main Street Lending Program Comments
To Whom it May Concern:
We are the Boston Foundation, in Boston, Massachusetts. We are a 501(c3) community foundation with a long history of providing funding
and resources to Greater Boston's residents in most need. We focus on main areas of impact including education, health, arts,
workforce development, housing, and non-profit effectiveness.
During the current COVID-19 crisis, we have established new funds for efforts to help organizations suffering the most. We have received
hundred of applications for help, and though our fund grows, our resources have a limit. We need your help.
The current Main Street program is not inclusive enough to fight this emergency. The next package should help the survival of the most
vulnerable small businesses, nonprofit leaders, and universities. These organizations that often make the most impact and do the most
significant work, are being left behind because of an Act that you have the power to change.
From all of us at the Boston Foundation, our 100+ staff, our donors, partners, and organizational grantees we urge you to include nonprofits,
institutions of higher learning and Minority-Serving institutions. Please change the eligibility to this initiative and include these entities.
In Boston, in Massachusetts, and in all the United States we stand strong because of how we support and thrive together. Please do not deny
us that privilege.
Best,
the Boston Foundation
75 Arlington Street 3rd Floor
4/15/2020 2:20:00 brianna.alois Boston, MA 02116
PM PIO (Email from Aloisio Brianna o@TBF.ORG
Please expand eligibility for MSL to as many organizations as possible. Nonprofits and other community organizations are as important to our
rejuvenation as viable small businesses. The SBA is taking the lead for small and medium businesses, as they should. The Federal Reserve
Personal should include those not covered by SBA. Thank you for listening.
4/15/2020 2:20:00 Email
PM PIO (Email from Albrecht Douglas Address Doug
To whom it may concern:
We would like to urge you to please expand eligibility criteria for the Federal Reserve "Main Street" Lending Facility to include non-
profits and higher education institutions. Like many businesses these entities are suffering losses from the current crisis and require additional
resources to be able to cover those losses. Many of them are ineligible for the Paycheck Protection Program.
These institutions employ more than 5 million dedicated professionals/workers and educate more than 19.9 million students across the United
4/15/2020 2:20:00 amihnea@st Saint Thomas States. Many universities are a main employer in their communities, and some oversee major health systems that are responding to the
PM PIO (Email from Mihnea Amalya u.edu University pandemic. Their ineligibility to participate may mean some of these institutions may have to close.
Feedback on the Federal Reserve "Main Street" lending facility
To whom it may concern:
We would like to urge you to please expand eligibility criteria for the Federal Reserve "Main Street" Lending Facility to include non-
profits and higher education institutions. Like many businesses these entities are suffering losses from the current crisis and require additional
resources to be able to cover those losses. Many of them are ineligible for the Paycheck Protection Program.
These institutions employ more than 5 million dedicated professionals/workers and educate more than 19.9 million students across the United
4/15/2020 2:21:00 tstafford@stu St. Thomas States. Many universities are a main employer in their communities, and some oversee major health systems that are responding to the
PM PIO (Email from Stafford Timothy .edu University pandemic. Their ineligibility to participate may mean some of these institutions may have to close.
Couple of specific Questions/comments on the Main St. "New Loan" Program that need clarity.
The term of the loan states 4 years with 1 year P&I deferred but does not specify if the loan is to be amortized over the remaining 3
years?
gklein@tomp There is flexibility in the loan pricing with a spread of 250-400 over SOFR; is this at Bank discretion or Fed?
4/15/2020 2:22:00 kinsfinancial. Tompkins Does "mandatory Principal Payments" include balloon payments?
PM PIO (Email from Klein Gerald, Jr com Mahopac Bank Thank you.
4/15/2020 2:24:00 Personal You should include medium and large nonprofits in the Main Street Lending Program as they are needed to help communities such as mine in
PM PIO (Email from BOYAJIAN BEATRICE Email Address New Rochelle, New York survive and recovery from the Covid-19 pandemic.
I am an employee of a nonprofit healthcare organization in California, and I am writing to advocate for the inclusion of nonprofit organizations
as part of the Main Street Lending Program. The exclusion of nonprofits from this program leaves medium-size nonprofits - which are also not
eligible to participate in the Paycheck Protection Program - in precarious financial standing without any way to mitigate economic injury while
preserving workforce and continuing critical services to hundreds of thousands of Californians. Without the vital aid provided by the program,
organizations like ours are at risk of making cuts to staff and services which impacts our ability to serve some of the most vulnerable people in
lchavez@hea California. PLEASE INCLUDE NONPROFIT ORGANIZATIONS OR EXPAND THE PAYCHECK PROTECTION PROGRAM TO INCLUDE
4/15/2020 2:25:00 lthright360.or ALL NONPROFITS WHICH WILL INCREASE THE CAPACITY OF THE SAFETY NET SYSTEM.
PM PIO (Email from chavez lilly g Healthright360
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Main Street Lending Program Comments
4/15/2020 2:25:00 Personal Please include medium to larg-sized nonprofits in the Main Street Lending program. These organizations are essential to the success of our
PM PIO (Email from Bordwin Gabrielle Email Address Ms. communities.
The COVID 19 pandemic has hit higher education in unimaginable ways, especially for small public institutions that depend on students living
and taking classes on campus. I come to you with the sincerest of asks, that you please add public higher education institutions to the
4/15/2020 2:26:00 kholmes4@m University of "Main Street" lending facility. Currently institutions of higher learning are not included in the current provisions, and are also
PM PIO (Email from Holmes Kelli ontevallo.edu Montevallo ineligible for the Paycheck Protection Program.
Asking for clarity on the potential amount of loan. If the max amount is limited by 30% of committed but undrawn funds, that would or could be
a very low number and therefore not very helpful.
Would like to clarify that the EBITDA used in the calculation should be pro forma EBITDA including contributions acquisitions from previous
rchalmers@ year. We believe it would be best to use 2019 "bank" or "covenant" EBITDA which would encompass things that have
4/15/2020 2:27:00 meritumener Meritum Energy been added back or included based on negotiated loan documents that would be much easier than for the Fed to outline all the potential
PM PIO (Email from Chalmers Robert gy.com Holdings additions and deductions.
Personal The Main Street Lending program must include funding for non-profits such as the Northshore Senior Center which perform crucial services
Email such as food assistance, chronic disease management, physical/mental health, transportation services, etc. that would otherwise be put on
4/15/2020 2:27:00 Address Northshore government entities to provide the services. It would be a travesty to abandon these organizations and lose the established infrastructure
PM PIO (Email from Dolin John Senior Center supporting our local communities and neighborhoods.
Thousands of men, women and children use non profits as their life lines. Many struggle with mental health, substance abuse, and behavioral
4/15/2020 2:29:00 Personal health issues. We are here to help those people. This will cause less crimes and less people in jails.
PM PIO (Email from Spikes Monica Email Address Healthright360
To whom it may concern:
We would like to urge you to please expand eligibility criteria for the Federal Reserve "Main Street" Lending Facility to include non-
profits and higher education institutions. Like many businesses these entities are suffering losses from the current crisis and require additional
resources to be able to cover those losses. Many of them are ineligible for the Paycheck Protection Program.
These institutions employ more than 5 million dedicated professionals/workers and educate more than 19.9 million students across the United
4/15/2020 2:29:00 jvillalobos2@ States. Many universities are a main employer in their communities, and some oversee major health systems that are responding to the
PM PIO (Email from Villalobos Jahaira stu.edu pandemic. Their ineligibility to participate may mean some of these institutions may have to close.
Nonprofits provide essential care to vulnerable populations, and should not be left out of the Main Street Lending facility.
Personal
4/15/2020 2:29:00 YWCA Greater
Email Address
PM PIO (Email from Schmitt Claire Austin
4/15/2020 2:29:00 dharris@stu. monies need to go to college and university
PM PIO (Email from harris don edu st thomas
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act I am
affiliated with a nonprofit organization in California and I am writing to advocate for restoration of the applicability of the Main Street Lending
Program to nonprofits with more than 500 employees. The enabling legislation (CARES Act, Section 4003) expressly included nonprofit
organizations between 500 and 10,000 employees, but it now appears the Federal Reserve's initial guidance for the Main Street Lending
Program excludes nonprofits for eligibility. These critical providers of the nation's safety net are not eligible for the Paycheck Protections
Program (PPP) (Sections, 1102, 1106) or the Economic Injury Disaster Loans (EIDL) (Section 1110) or other federal relief. This proposed
action threatens the viability of larger nonprofits who provide aid to hundreds of thousands of children and families. Please include nonprofits
4/15/2020 2:30:00 mafoundation M-A Foundation that employ over 500 employees in the Main Street Program to protect the critical safety net.
PM PIO (Email from Meacham Ann-Marie @seq.org for the Future
Instead of limiting companies to 4x EBITDA for all outstanding and committed loan. consideration should be given for the maturity length of
4/15/2020 2:31:00 greg@graced the loan. If I have $2m in EBITDA and $8m in long term debt with a 30 year term my company is healthy and can absorb additional debt.
PM PIO (Email from Fadul Greg igital.com Grace Digital Verses that same company with $2m EBITDA and $8m in a 2 year note.
To whom it may concern:
I would like to urge you to please expand eligibility criteria for the Federal Reserve "Main Street" Lending Facility to include non-
profits and higher education institutions. Like many businesses these entities are suffering losses from the current crisis and require additional
resources to be able to cover those losses. Many of them are ineligible for the Paycheck Protection Program.
These institutions employ more than 5 million dedicated professionals/workers and educate more than 19.9 million students across the United
States. Many universities are a main employer in their communities, and some oversee major health systems that are responding to the
4/15/2020 2:32:00 jasmith@stu. St. Thomas pandemic. Their ineligibility to participate may mean some of these institutions may have to close. Which would mean, I would lose my job.
PM PIO (Email from Smith Jerome edu University Any help you could provide in changing the rules would be greatly appreciated.
Page 126 of 363
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Main Street Lending Program Comments
To whom it may concern:
I would like to urge you to please expand eligibility criteria for the Federal Reserve "Main Street" Lending Facility to include non-
profits and higher education institutions. Like many businesses these entities are suffering losses from the current crisis and require additional
resources to be able to cover those losses. Many of them are ineligible for the Paycheck Protection Program.
atapanes- These institutions employ more than 5 million dedicated professionals/workers and educate more than 19.9 million students across the United
4/15/2020 2:32:00 castillo@stu. St. Thomas States. Many universities are a main employer in their communities, and some oversee major health systems that are responding to the
PM PIO (Email from Tapanes-Cast Alexis edu University pandemic. Their ineligibility to participate may mean some of these institutions may have to close.
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/15/2020 2:32:00 acruz@mom eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
PM PIO (Email from Cruz Avery entummh.org
The Federal Reserve should clarify that nonprofits and universities are eligible for the Main Street Lending Program.
christina.rajm
4/15/2020 2:34:00 aira@marym Marymount Student workers should be exempted for the purpose of determining program eligibility (i.e. they should not count toward the 10,000
PM PIO (Email from Rajmaira Christina ount.edu University maximum).
I am an employee of a nonprofit healthcare organization in California, and I am writing to advocate for the inclusion of nonprofit organizations
as part of the Main Street Lending Program. The exclusion of nonprofits from this program leaves medium-size nonprofits - which are also not
eligible to participate in the Paycheck Protection Program - in precarious financial standing without any way to mitigate economic injury while
preserving workforce and continuing critical services to hundreds of thousands of Californians. Without the vital aid provided by the program,
organizations like ours are at risk of making cuts to staff and services which impacts our ability to serve some of the most vulnerable people in
shardeman@ California. PLEASE INCLUDE NONPROFIT ORGANIZATIONS OR EXPAND THE PAYCHECK PROTECTION PROGRAM TO INCLUDE
4/15/2020 2:39:00 healthright36 ALL NONPROFITS WHICH WILL INCREASE THE CAPACITY OF THE SAFETY NET SYSTEM.
PM PIO (Email from Hardeman Shauna 0.org Healthright360
Feedback on the Federal Reserve "Main Street" lending facility
To whom it may concern:
We would like to urge you to please expand eligibility criteria for the Federal Reserve "Main Street" Lending Facility to include non-
profits and higher education institutions. Like many businesses these entities are suffering losses from the current crisis and require additional
resources to be able to cover those losses. Many of them are ineligible for the Paycheck Protection Program.
These institutions employ more than 5 million dedicated professionals/workers and educate more than 19.9 million students across the United
4/15/2020 2:39:00 mmurch@stu St. Thomas States. Many universities are a main employer in their communities, and some oversee major health systems that are responding to the
PM PIO (Email from Murch Michelle .edu University (Fla.) pandemic. Their ineligibility to participate may mean some of these institutions may have to close.
Page 127 of 363
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Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
Non - for- Profit organizations shouldn't be excluded from the main street lending, we all have been impacted during this covid-19
epidemic, many of us are the first res ponders assisting to aid the immediate need to the most vulnerable members in the communities that
we are working. Many 501 c 3 community based organizations do not have the financial stability to manage covering expenditures during this
JACKIE@UC United crisis. If we don't get help, we will be forced to permanently closed our doors, in a time that our vital services are much needed and there
4/15/2020 2:48:00 CENTER.OR Community is a higher demand in need,not helping us is an act of cruelty, prolonging the suffering of low income families, individuals, elders, single
PM PIO (Email from AGUDELO Jackeline G Center of westc mothers with children affected by this crisis.
I am an employee of a nonprofit healthcare organization in California, and I am writing to advocate for the inclusion of nonprofit organizations
as part of the Main Street Lending Program. Please know that our agency assist the community in creating healthy productive individuals to
enter society. Our work should not go unseen! PLEASE INCLUDE NONPROFIT ORGANIZATIONS OR EXPAND THE PAYCHECK
4/15/2020 2:49:00 amurguia@pr HealthRight 360 PROTECTION PROGRAM TO INCLUDE ALL NONPROFITS WHICH WILL INCREASE THE CAPACITY OF THE SAFETY NET SYSTEM.
PM PIO (Email from Murguia Anna ototypes.org Prototypes
To whom it may concern: We would like to urge you to please expand eligibility criteria for the Federal Reserve "Main Street"
Lending Facility to include non-profits and higher education institutions. These entities continue to lose lots of money daily due to the
Coronavirus crisis and are in desperate need of funding to cover those losses. Many of them are ineligible for the Paycheck Protection
Program.
These institutions employ more than 5 million dedicated professionals/workers and educate more than 19.9 million students across the United
States. Many universities are a main employer in their communities, and some oversee major health systems that are responding to the
pandemic. Ineligibility to participate may lead some institution to close permanently.
4/15/2020 2:49:00 jpeart@stu.e St Thomas
PM PIO (Email from Peart Justin du University Thanks for your kind consideration.
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act I am
affiliated with a nonprofit organization in California and I am writing to advocate for restoration of the applicability of the Main Street Lending
Program to nonprofits with more than 500 employees. The enabling legislation (CARES Act, Section 4003) expressly included nonprofit
organizations between 500 and 10,000 employees, but it now appears the Federal Reserve's initial guidance for the Main Street Lending
Program excludes nonprofits for eligibility. These critical providers of the nation's safety net are not eligible for the Paycheck Protections
heather@co Program (PPP) (Sections, 1102, 1106) or the Economic Injury Disaster Loans (EIDL) (Section 1110) or other federal relief. This proposed
mmunityequit Community action threatens the viability of larger nonprofits who provide aid to hundreds of thousands of children and families. Please include nonprofits
4/15/2020 2:51:00 ycollaborative Equity that employ over 500 employees in the Main Street Program to protect the critical safety net.
PM PIO (Email from Hopkins Heather .org Collaborative
As a small business owner I understand firsthand the stress and uncertainty facing us as a result of the COVID-19 pandemic. As a for-profit
higher education institution owner I also understand being targeted and set aside from assistance eligibility for our students based solely on
my tax status. At this crucial time in our nation's history it is more important than ever that we come together for the good of every
Tri-State business, student, employee and citizen and not continue the divisive nature of excluding entities based on tax filing status. I ask that you
4/15/2020 2:51:00 amy@tristate Cosmetology please reconsider the exclusion of nonprofits, minority-serving institutions and other higher education institutions if they would otherwise
PM PIO (Email from Parker-Morris Amy cos.edu Institute qualify for this program. Thank you for your attention to this matter
mavila@child Include Nonprofits in the "Main Street" Lending Program.
4/15/2020 2:52:00 rensaidnyc.or
PM PIO (Email from Avila Michelle g Children's Aid
memphis Nonprofits should be included in the Main Street Lending program
4/15/2020 2:53:00 larry@mlfonli leadership
PM PIO (Email from Lloyd Larry ne.org foundation
I represent the largest human services provider in New York State. We provide residential services to some of the most vulnerable including
kids with special needs, youth in foster care, families and children in need of shelter, and runaway homeless youth. During this pandemic we
have faced an increased need for our services while facing an unprecedented strain on our resources. Our organization has a workforce well
in excess of 500 persons and the Main Street Lending Program was one of the only programs we would have been able to access to help to
sustain these essential human services. PLEASE include human services nonprofits, regardless of size, in the Main Street Lending program.
This is the only way we can meet the needs of the persons whom we serve, maintain a safe and healthy environment for our staff and
4/15/2020 2:56:00 thassler@sco SCO Family of residents, and ensure that our essential services are sustained during this crisis and beyond.
PM PIO (Email from Hassler Theresa .org Services
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Main Street Lending Program Comments
Please issue guidance on how distributions for S corps/ pass throughs will affect qualifications for loans. I strongly encourage the Federal
Reserve to enact a cap (absolute or relative) as opposed to not permitting any distributions similar to the treatment of dividends. Many small
business owners take a lower salary compared to market rates with the expectation that they will receive some level of distributions for effort
and results, assuming the business is profitable.
Please issue guidance on how to calculate EBITDA e.g. cash vs accrual basis (or either) and what documentation is needed to prove
profitability. I strongly encourage the Federal Reserve to allow small businesses to submit unaudited financial statements from their internal
eschmierer@ accounting system on an accrual basis. Requiring an audit will be too expensive and time-intensive while tax returns often show a formulated
4/15/2020 2:57:00 nebocompan The Nebo and narrow view of business activity and performance. Perhaps the unaudited financial statements can be verified by tax or business
PM PIO (Email from Schmierer Edwin y.com Company advisors.
Please reconsider and make this program available to nonprofit organizations. So many of the vital safety net services once funded by taxes
and other government sources have fallen away, now relegated to the nonprofit organizations to provide in our coastal California county
(Santa Cruz County). Our nonprofits must remain operative to support the vulnerable and under-resourced populations here, particularly
children in the child welfare system, disabled people, field workers so vital to our food supply chain, poor families, the elderly, the homeless....
PLEASE - nonprofits are also major employers, in addition to carrying a huge social services burden not only in this county but across the
Personal Email state and the nation. Their continuing ability to provide essential safety net services deserves the same if not more consideration and support
4/15/2020 3:02:00 Address serve 8 as for-profit businesses.
PM PIO (Email from Bixby Linda organizations Linda Bixby
4/15/2020 3:02:00 Personal You must include medium and large non profits in the main street lending program.
PM PIO (Email from Klugman Arnold Email Address 1934 They are vital to the health of New Rochelle and other municipalities in the battle to survive Covid 19 .
Nonprofits need to be included in this main street lending program.
4/15/2020 3:03:00 Personal Educational Nonprofits are able to directly turn federal dollars into effective outreach in communities that are in the most need in this economic downturn.
PM PIO (Email from Greenstein Howard Email Alliance Please help us to help our fellow Americans.
Address Feedback on the Federal Reserve "Main Street" lending facility
To whom it may concern:
I would like to urge you to please expand eligibility criteria for the Federal Reserve "Main Street" Lending Facility to include non-
profits and higher education institutions. Like many businesses these entities are suffering losses from the current crisis and require additional
resources to be able to cover those losses. Many of them are ineligible for the Paycheck Protection Program.
Many universities are a main employer in their communities, and some oversee major health systems that are responding to the pandemic.
Their ineligibility to participate may mean some of these institutions may have to close.
We, at St. Thomas University, in Miami Gardens, Florida, for example, have a nursing school that works primarily with minorities; many of
these students have great difficulty in paying for tuition. Participating in this program would help benefit these students.
Thank you for your consideration.
Dr. Alfred Cioffi
Associate Professor, Biology and Bioethics
4/15/2020 3:04:00 ACIOFFI@S St. Thomas St. Thomas University
PM PIO (Email from CIOFFI ALFRED TU.EDU University Miami Gardens, FL
Please include non-profit agencies in the Main Street Lending program. As an essential business providing residential services to children in
4/15/2020 3:05:00 gmccaffery@ foster care we have had to keep our programs operating 24/7 with a minimum of PPE and support. This will be vital to our survival.
PM PIO (Email from McCaffery Gerard mercyfirst.org MercyFirst
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Main Street Lending Program Comments
As one of over 4,000 employees of a regional non-profit health and human services agency that provides programs and services to nearly
10,000 people with intellectual and developmental disabilities, special needs, their families and older adults throughout numerous counties in
Western New York and the Greater Rochester region, I am writing today to inform you that our agency, People Inc., is fully engaged in dealing
with the COVID-19 crisis. Our staff are working countless hours to provide needed services to the people we serve. We must ensure that our
homes and services for people with disabilities remain as safe as possible and are staffed 24/7 to provide safety and guidance. The
vulnerable people that depend on us deserve no less. However, because we are providing essential services during the crisis, People Inc.
has incurred highly unusual increased costs in staffing, PPE, and cleaning services.
Since we are not eligible for the Payroll Protection Program (PPP) due to our size and we must remain fully operational, we request that the
Mid-Size Loan Program have provisions to convert to a forgivable loan for nonprofits that face staggering losses due to COVID-19. This would
grant us the same protections as PPP.
Thank you in advance for your support of direct care staff, the people we support and our agency, People Inc. Your time and efforts are
appreciated.
Sincerely
Christopher Zienski
4/15/2020 3:05:00 czienski@pe Program Director
PM PIO (Email from Zienski Christopher ople-inc.org People Inc
To whom it may concern: We would like to urge you to please expand eligibility criteria for the Federal Reserve "Main Street"
Lending Facility to include non-profits and higher education institutions. Like many businesses these entities are suffering losses from the
current crisis and require additional resources to be able to cover those losses. Many of them are ineligible for the Paycheck Protection
Program.
St. Thomas These institutions employ more than 5 million dedicated professionals/workers and educate more than 19.9 million students across the United
4/15/2020 3:07:00 inathenson@ University States. Many universities are a main employer in their communities, and some oversee major health systems that are responding to the
PM PIO (Email from Nathenson Ira stu.edu School of Law pandemic. Their ineligibility to participate may mean some of these institutions may have to close.
Please DO NOT exclude non-profits from the Main Street Lending. The local non-profit (501c3) senior center (Northshore Senior Center in
Bothell, WA) is essential for the health and wellness of the surrounding communities. It is a "regional" center, providing activities,
daily lunches, Meals on Wheels, and social services for residents of three cities and the surrounding areas, straddling two counties. It is the
only senior center in Washington with an Adult Day Center which provides respite for caregivers, and all-day care for seniors and those with
Personal
4/15/2020 3:09:00 disabilities. the transportation department provides shuttle services to medical appointments and to the activities both the senior center and
Email Address
PM PIO (Email from Gustafson Patricia the Adult Day Center.
The American Lung Association employs more than 500 employees and have not been able to access the Paycheck Protection Program,
which contains critical loan forgiveness provisions which are necessary to help ensure we will be able to continue to provide services during
the crisis and assist with our nation's recovery efforts when the crisis is over.
As the Federal Reserve works to create a program as directed under the CARES Act section 4003(c)(3)(D) to provide financing to banks and
other lenders to make loans to nonprofits and other mid-size business of between 500-10,000 employees, we request that the program:
Include a 0.50% interest rate (50 basis points) for 501(c)(3) charitable nonprofits at a 5 year amortization
Provide priority to 501(c)(3) charitable nonprofits responding to COVID-19 relief efforts
Payments shall not be due until two years after a direct loan is made
Employee retention provisions should begin on January 31, 2020, the date the public health emergency took effect
In implementing any workforce restoration and retention provisions, "workforce" should be defined as full-time employees or full-
time equivalents
These recommendations will help to keep us financially strong and allow the American Lung Association to continue to meet the immediate
4/15/2020 3:11:00 erika.sward@ American Lung lung health needs facing our nation during this pandemic.
PM PIO (Email from Sward Erika lung.org Association
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Main Street Lending Program Comments
To whom it may concern:
We would like to urge you to please expand eligibility criteria for the Federal Reserve "Main Street" Lending Facility to include non-
profits and higher education institutions. Like many businesses these entities are suffering losses from the current crisis and require additional
resources to be able to cover those losses. Many of them are ineligible for the Paycheck Protection Program.
These institutions employ more than 5 million dedicated professionals/workers and educate more than 19.9 million students across the United
4/15/2020 3:14:00 amarrero@st St. Thomas States. Many universities are a main employer in their communities, and some oversee major health systems that are responding to the
PM PIO (Email from Marrero Andres u.edu University pandemic. Their ineligibility to participate may mean some of these institutions may have to close.
4/15/2020 3:20:00 Personal Email Please include non-profits in the Main Street Lending program. Non-profits provide many essential programs needed to sustain communities,
PM PIO (Email from Daniel Robert Address AT&T especially in this time of economic difficulty for so many.
As the director of a non-profit that directly serves low-income communities, I am highly disappointed to learn that the decision was made to
NOT include non-profit entities in the loan program. We are struggling with loss of revenue, just like for-profit businesses. If we do not have
access to the same options, the fallout will be unimaginable.
Please reconsider and offer organizations that are working FOR the people the same opportunities as those who are making money off the
Personal people.
Email Address
4/15/2020 3:24:00 Thank you,
PM PIO (Email from Wilson Jana Jana Wilson
I write to you today on behalf of Lutheran Services in America and the 300 health and human services providers throughout the United States
that comprise our network. As the Treasury Department creates a program as directed under the CARES Act to provide financing to lenders
to make loans to entities with between 500-10,000 employees, we urge you to ensure that nonprofits are eligible for these loans and to
include the following specific measures in the program:
A 0.50% interest rate (50 basis points) for 501(c)(3) charitable nonprofits at a 5 year amortization;
Priority for 501(c)(3) charitable nonprofits responding to COVID-19 relief efforts;
Repayments to begin no earlier than two years after a direct loan is made; and
Employee retention provisions that begin on the date that loan funding is received by the borrower.
Our 300 health and human service organizations are on the frontlines of the COVID-19 pandemic caring for people while taking extraordinary
steps to protect their staff and people served. At the same time, many of our member organizations employ more than 500 people and thus
have not been able to access the Paycheck Protection Program. Without specific support for nonprofit health and human service
sdobson@lut Lutheran organizations with over 500 employees via this loan program during this time of crisis, including priority access and very low interest rates, we
4/15/2020 3:25:00 heranservice Services in will be unable to meet the increasing needs of individuals and communities at their most vulnerable time.
PM PIO (Email from Haberaecker Charlotte s.org America
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
Thank you so much for all of your advocacy efforts during the past few weeks as we navigate the many challenges occurring in our funding
sources at all levels of government. We appreciate all that you do for the agency and for the children and families that we serve. You are all
champions!
With gratitude,
samantha.mc
4/15/2020 3:26:00 gill@upliftfs.o Uplift Family Samantha McGill
PM PIO (Email from McGill Samantha rg Services
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Main Street Lending Program Comments
As a nonprofit serving a vulnerable population, individuals with developmental disabilities, our financial existence is highly dependent on a
Personal
vibrant main street. Our fundraising is dependent upon our for profit business neighbors. We need a healthy economy to survive and fulfill our
Email Address
4/15/2020 3:26:00 mission of empowerment.
PM PIO (Email from McKinney Catherine Clallam Mosaic Please make sure that small businesses survive this unprecedented time of closure.
As the Department creates a program as directed under the CARES Act to provide loans to nonprofits and other mid-size business of
between 500-10,000 employees, Goodwill Industries International requests:
A 0.50% interest rate for 501(c)(3) nonprofits at a 5 year amortization
Priority to 501(c)(3) nonprofits responding to COVID-19 relief efforts
Payments shall not be due until two years after a direct loan is made
Employee retention provisions should begin on the date that loan funding is received by the borrower
In implementing any workforce restoration/retention provisions, "workforce" should be defined as full-time employees
Many nonprofits employ more than 500 employees and have not been able to access the PPP, which contains loan forgiveness provisions
critical to Goodwills and necessary to help ensure they will be able to continue to provide services during the crisis and assist with our
nation's recovery efforts when the crisis is over. These recommendations will help keep these organizations financially strong, allowing
them to continue to meet the immediate needs of their communities while planning for the future when their services will be needed most.
laura.walling Goodwill Nonprofit organizations are our country's only institutions solely focused on making communities stronger. In the toughest times, we do
4/15/2020 3:28:00 @goodwill.or Industries the toughest work. When it's time to restore and repair our wellbeing, nonprofits need to be equipped to do that and their unique needs
PM PIO (Email from Walling Laura g International, Inc. should not be overlooked.
I am an employee of a nonprofit healthcare organization in California, and I am writing to advocate for the inclusion of nonprofit organizations
as part of the Main Street Lending Program. The exclusion of nonprofits from this program leaves medium-size nonprofits - which are also not
eligible to participate in the Paycheck Protection Program - in precarious financial standing without any way to mitigate economic injury while
preserving workforce and continuing critical services to hundreds of thousands of Californians. Without the vital aid provided by the program,
organizations like ours are at risk of making cuts to staff and services which impacts our ability to serve some of the most vulnerable people in
Personal California. PLEASE INCLUDE NONPROFIT ORGANIZATIONS OR EXPAND THE PAYCHECK PROTECTION PROGRAM TO INCLUDE
4/15/2020 3:29:00 Email Address ALL NONPROFITS WHICH WILL INCREASE THE CAPACITY OF THE SAFETY NET SYSTEM.
PM PIO (Email from huggins michael Healthright 360
please help non profits of over 500 employees, we could benefit from some kind of relief similar to the PPP plan that smaller organizations
have received
4/15/2020 3:31:00 sandym@ym
PM PIO (Email from Morander sandy casatx.org thank you
4/15/2020 3:33:00 Personal "You must include medium and large nonprofits in the Main Street Lending Program as they are needed to help communities such as
PM PIO (Email from Morris Teir Email Address mine in New Rochelle, New York survive and recovery from the COVID-19 pandemic."
Personal You must include medium and large nonprofits in the Main Street Lending Program as they are needed to help communities such as mine in
4/15/2020 3:33:00 Email Address New Rochelle, New York survive and recovery from the Covid-19 pandemic.
PM PIO (Email from Wharton Emily
Personal You must include medium and large nonprofits in the Main Street Lending Program as they are needed to help communities such as mine in
4/15/2020 3:35:00 Email Address New Rochelle, New York survive and recovery from the Covid-19 pandemic.
PM PIO (Email from Wharton Molly
1. For non-profits, increase the FTE limit to 500 -10,000 for eligibility for the PPP program.
4/15/2020 3:37:00 bobo@metan YMCA of Greater 2. For non-profits, increase the re-imbursement for self-funded unemployment benefits from 50% to 100%.
PM PIO (Email from Oliver Robert oenergy.com San Antonio
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Main Street Lending Program Comments
I write to ask that the Board of Governors consider including higher education institutions as eligible applicants for the Main Street Lending
Program, which is a core part of the recently announced $2.3 trillion in loans to support the nation's economy.
In New England, our public and independent postsecondary institutions comprise one of the region's most precious resources and
critical industries, the fourth largest in terms of overall economic impact. They are the core economic engines of cities and towns across the
region, enrolling more than 1 million students, employing more than 256,000 faculty and staff and paying over $12.8 billion a year in salaries-
for an annual economic impact of over $23 billion. Moreover, their graduates are the primary source of skilled talent consistently sought by
employers in all industries. Their research and development are at the core of innovation and the region's current and future
competitiveness. Their response to the pandemic has been rapid and significant-but they desperately require additional economic resources.
Public and non-profit independent postsecondary institutions need expanded access to credit to stabilize their financial circumstances, which
New England have been negatively impacted by the pandemic. In our region, where many postsecondary institutions were already facing financial
4/15/2020 3:38:00 mthomas@n Board of Higher sustainability challenges, a broad range of borrowing alternatives is needed.
PM PIO (Email from Thomas Michael ebhe.org Education
Greater Lynn Senior Services (GLSS) is a non-profit agency dedicated to meeting the needs of more than 5000 elders and people living with
disabilities across multiple communities north of Boston, MA. During this pandemic, GLSS staff are literally on the barricades delivering meals
and groceries to vulnerable elders and hungry families; providing daily paratransit transport - often to urgent medical appointments like
dialysis -- to hundreds of our most at-risk residents; ensuring vital in-home supports for those who would be hospitalized without them; and
providing a host of other services that are literally saving lives, supporting the health care system, and preserving the community. To meet
increasingly emergent demands and also support our over 500 employees, GLSS is perilously stretched financially and needs access to the
financial resources afforded businesses through the Main Street Lending program. (We do not qualify for CARES PPP.) Although a strong
business for 40 years, GLSS simply cannot sustain staff and mission without critical cash flow. Like other non-profits across the nation, the
role GLSS plays is hugely vital to the social and economic survival of thousands of individuals as well as to the community infrastructure it
Greater Lynn helped build and support for decades. There is little more "Main Street" than GLSS and we strongly urge that GLSS, as a non-
4/15/2020 3:39:00 vparkercallah Senior Services, profit, be eligible for Main Street lending programs. To do otherwise will have profound and costly consequences.
PM PIO (Email from Parker CallahaValerie an@glss.net Inc.
Dear Board of Governors of the Federal Reserve,
Thank you for your attention. You must include medium and large nonprofits in the Main Street Lending Program as they are needed to help
communities such as mine in New Rochelle, New York survive and recovery from the Covid-19 pandemic. Your advocacy is greatly
Personal appreciated.
4/15/2020 3:42:00 Email Address Sincerely,
PM PIO (Email from Williams Valarie Public School Valarie Williams
I am writing to encourage the expansion of the CARES Act/Main Street Lending facility to include nonprofit organizations. Nonprofit
organizations provide services to millions of people in communities around the country. Not only do they provide needed services, they also
employ a significant portion of the American workforce. According to a 2019 report by the Center for Civil Society Studies at Johns Hopkins
University, "nonprofits account for roughly one in 10 jobs in the U.S. private workforce, with total employees numbering 12.3 million in
2016." Since many of these organizations may not be otherwise eligible for the Paycheck Protection Program, it is especially important
these organizations have other sources of support. We cannot make a significant portion of employers (and their employees) ineligible to
4/15/2020 3:44:00 lauren@acfp receive aid, just because they are not "for profit" businesses. I urge you to consider expanding the eligibility of the Main Street
PM PIO (Email from Hunsaker Lauren m.com Lending facility to include nonprofit organizations.
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Main Street Lending Program Comments
Re: Feedback on the Federal Reserve Main Street Lending Facility
To Whom It May Concern:
We urge you to expand eligibility criteria for the Federal Reserve Main Street Lending Facility to include non-profits and higher education
institutions. Like many businesses, these entities are suffering losses from the current crisis and require additional resources to cover those
losses. Many of them are ineligible for the Paycheck Protection Program.
These institutions employ more than 5 million dedicated professionals/workers and educate more than 19.9 million students across the United
States. Many universities are a main employer in their communities, and some oversee major health systems that are responding to the
pandemic. Ineligibility to participate may result in the closure of some of these institutions.
St. Thomas Thank you for your consideration,
4/15/2020 3:46:00 LSmoker@st University
PM PIO (Email from Smoker Liza u.edu School of Law Liza Smoker
Please consider expanding guidelines to include non-profits, hospitals, and vulnerable small businesses.
Metropolitan
Youth
4/15/2020 3:47:00 Admin@myor Orchestras for
PM PIO (Email from Shum Julie ch.org Central Alabama
I am writing to advocate for the inclusion of non-profits as eligible entities for the Main Street Lending Program. Non-profits, and especially
Asian American behavioral health agencies, provide critical services to hundreds of thousands of Californians, yet have been left out of the Main Street
Drug Abuse Lending Program. Without the vital aid provided by the lending program, many agencies will have to make cuts, both staff and service levels,
4/15/2020 3:51:00 miwat@aada Program, Inc. which will, in turn, diminish their ability to help some of the most vulnerable people. As a representative of a non-profit behavioral health
PM PIO (Email from Watanabe Michael pinc.org (AADAP) organization in California I respectfully request that non-profits be included in the loan program.
The Jewish Federations of North America ("JFNA") is the umbrella organization representing 146 Jewish Federations, 300
network communities and hundreds of affiliated social service agencies. Together we serve millions of Americans across the country, many of
whom are among the most vulnerable among us.
As the Treasury Department works to create a Mid-Sized Businesses loan program to provide needed financial assistance to businesses and
nonprofits with up to 10,000 employees, we respectfully request that the program:
*include a 0.5 percent interest rate (50 basis points) at a five-year amortization for nonprofits qualifying as Sec. 501(c)(3) charities
*provide priority to such charities responding to COVID-19 relief efforts
*defer payment for two years after a direct loan is made
*begin any employee retention provisions on the date the loan funding is received by the borrower
*define "workforce" using full-time employees or equivalents in any work force restoration and retention provisions
Charities throughout the country are focused on providing front-line services and will be vital to assist with our nation's recovery efforts
when the crisis is over. We urge you to adopt a loan program that meets the needs of such charities as they continue to respond to needs of
Personal Jewish all Americans.
4/15/2020 3:51:00 Email Federations of
PM PIO (Email from Woolf Steven Address NA Please feel free to contact JFNA if you have any questions or if we can be of further assistance.
Please consider adding non-profits to your Main Street lending program. In Los Angeles, a Federally Qualified Health Center, run by the
LGBT Center is unable to access support to help keep its staff employed because it employs close to 800 people.
As well as specializing in medical care for people with HIV/AIDS, the Center provides a variety of health, social and cultural programs,
welcoming around 50,000 client visits per month. Most of the work is geared to assisting homeless youth and vulnerable seniors.
The Center needs assistance to continue operating on the front lines in responding to this pandemic.
Your consideration is greatly appreciated.
4/15/2020 3:57:00 sburn@lalgbt Los Angeles Stephen Burn
PM PIO (Email from Burn Stephen center.org LGBT Center
Re: Main Street Lending.
Personal
4/15/2020 3:59:00 "You must include medium and large nonprofits in the Main Street Lending Program as they are needed to help communities such as
Email Address
PM PIO (Email from Cole-Hollis Phyllis mine in New Rochelle, New York survive and recovery from the Covid-19 pandemic
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Main Street Lending Program Comments
I am writing to you on behalf of Robin Hood, New York City's largest poverty fighting organization, to express our deep concern that
large non-profit organizations with more than 500 employees are ineligible for the Federal Reserve System's Main Street Lending
program to stabilize organizations impacted by the COVID-19 pandemic. Furthermore, no other lending facility has been announced or
implemented to comply with the CARES Act §4003(c)(3)(D) to support this vital sector of the economy and response to this public health
and economic crisis. Robin Hood funds over 200 non-profit organizations across New York City. As Treasury Department and the Federal
Reserve work to create a program as directed under §4003(c)(3)(D) providing financing to banks and other lenders to make loans to
non-profits and other mid-size business of up to 10,000 employees, we believe the program must include the following terms that satisfy the
dictates of the CARES Act:
Include an interest rate of 0.50% (50 basis points) for 501(c)(3) charitable nonprofits at a 5-year amortization
Provide priority to 501(c)(3) charitable nonprofits responding to COVID-19 relief efforts and require lenders to make a proportionate number
and value of loans to nonprofits to prevent the crowding out that is being seen in the Paycheck Protection Program
4/15/2020 4:03:00 jcone@robin Set a certain date for when employee retention provisions should begin
PM PIO (Email from Cone Jason hood.org Robin Hood Payments shall not be due until two years after a direct loan is made
gpepping@c Include nonprofits. They help people. They employ people. They solve problems. They extend the reach of government.
oastal- Coastal
4/15/2020 4:06:00 watershed.or Watershed
PM PIO (Email from Pepping Greg g Council
We are a retail company that started with 15 stores in Iowa and have since expanded to acquire 4 more formalwear companies and grow the
store base to over 100 stores in 17 states. Confidential Business Information
We are uniquely affected in that we have had to close all retail outlets and our business revolves around gatherings of more than 10 people,
which are prohibited from taking place during the busiest time of the year for formalwear (March, April and May are when weddings and
proms happen).
eduardo.carn
4/15/2020 4:07:00 eiro@tttux.co With around 650 employees in 17 states Tip Top Tux serves the formalwear needs of thousands of customers all over the country. It would be
PM PIO (Email from Carneiro Eduardo m Tip Top Tux LLC a shame due to bad timing that a company like ours has to close through no fault of our own.
Regarding MSNLF, there has been some confusion about one item mentioned by the National Law Review:
"The Federal Reserve's initial release does not indicate whether an exception to the dividend prohibition will be available to allow
for tax distributions to owners of S corporations and other pass-through businesses."
Personal As a great number of S-Corp owner/operators get income through annual distributions, many would be forced to move that money back into
Email Address the form of a salary which would cause an unnecessary burden of additional taxation during the 4 year duration of the loans. While I agree
4/15/2020 4:10:00 that total compensation caps should be set to avoid pass through of excess dollar amounts, I do think S-Corp owners should be allowed to
PM PIO (Email from Collins-Black Jon maintain their current annual distributions.
ted.beaman It would be beneficial for companies open less than one year to be able to participate. Current guidance suggests the loan amount will be
4/15/2020 4:10:00 @kidzaniaus capped at four times 2019 EBITDA. Our business opened in Q4 2019 so using 2019 EBITDA won't yield a loan greater than $1M, but if
PM PIO (Email from Beaman Ted a.com Kidzania the banks had some flexibility in how to calculate the loan amount we could take advantage of this program.
GCN is Georgia's association of nonprofits serving over 5000 entities throughout the state. We write in opposition to the exclusion of
nonprofits, institutions of higher learning and HBCU's from the the Main Street New & Expanded Loan Facilities. Over 300 nonprofit
organizations in Georgia employ over 500 staff members. They include Goodwill, Visiting Nurse Health Sys, Boys and Girls Clubs, United
Cerebral Palsy, Young Harris College, Morehouse College, Spelman College, Sheltering Arms (child care), the historic Fox Theater, and
YMCA, to name a few. These agencies will not qualify for PPP relief, nor relief within these Main Street Programs. Large institutions support
an array of small businesses -from janitorial to food service -acting as economic anchors to communities, they provide critical services at a
scale that would be impossible to replace should they falter, and as large employers should not be allowed to fail. Finally, HBCU's are
critically important and endangered organizations that must unequivocally be included in any and all relief packages available. Nonprofits
should not be excluded from relief packages provided to businesses, as our sector is just as critical to economic stability and recovery. We
urge the Federal Reserve to include nonprofits as qualifying for the Main Street Loan program including our institutions of higher education
4/15/2020 4:15:00 Georgia Center and HBCU's which are critical to service provision to and the economic recovery of communities throughout Georgia.
PM PIO (Email from Beavor Karen kb@gcn.org for Nonprofits
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Main Street Lending Program Comments
Confidential Business
Information
Created 30 years ago, ARC Document Solutions is the largest document services provider to the industries that build and maintain our
country's infrastructure. ARC's 170 service centers and 2,000 employees also serve the housing, healthcare, technology and retail
industries. ARC has been consistently profitable and a responsible borrower since its inception, but with Covid-19, our Confidential Business
Information We have
tried to keep employees in their jobs during the pandemic, but Confidential Business Information
That is why we strongly support the requirement for a borrower "to make reasonable efforts to maintain its payroll and
retain its employees," rather than insisting on employing a defined percentage of their staff. It makes sense for businesses like ours that
Personal Email Confidential Business
if permitted to use the loan to flex payrolls and bring back employees as business recovers
Information
Less restrictive employment requirements also protect taxpayers from borrowers who would be unable to reduce employment to
steve.biernba preserve their business and thus default on their loans. We believe the U.S. Main Street Lending program protects the economy, taxpayers
4/15/2020 4:15:00 um@e- ARC Document and employees, and will help prevent the collapse of businesses throughout the country.
PM PIO (Email from Biernbaum Steven arc.com Solutions, Inc
To whom it may concern:
I would like to urge you to please expand eligibility criteria for the Federal Reserve "Main Street" Lending Facility to include non-
profits and higher education institutions.
Like many businesses these entities are suffering losses from the current crisis and require additional resources to be able to cover those
losses. Many of them are ineligible for the Paycheck Protection Program.
These institutions employ more than 5 million dedicated professionals/workers and educate more than 19.9 million students across the United
States. Many universities are a main employer in their communities, and some oversee major health systems that are responding to the
pandemic. Their ineligibility to participate may mean some of these institutions may have to close.
St.Thomas Thank you.
4/15/2020 4:16:00 irogatinsky@ University
PM PIO (Email from Rogatinsky Iris stu.edu School of Law Iris Rogatinsky
We need your help. Non-profits are the backbone of each community and we help more people with each dollar than any other industries.
4/15/2020 4:18:00 bill.coon@elp YMCA of El Please consider including non-profits in this program.
PM PIO (Email from Coon Bill asoymca.org Paso
You must include non profits in the Main Street proposal - there are many human services providers that will be instrumental in putting the
Personal interAgency economy back together - they need to be kept whole so they can restart America - the PPP doesn't work for many larger NFP's
4/15/2020 4:19:00 Email Address Council of DD with over 500 employees.
PM PIO (Email from Schiff Winifred Agencies Excluding NFP's is a grave mistake!
I am writing to encourage the expansion of the CARES Act/Main Street Lending facility to include nonprofit organizations. Nonprofit
organizations provide services to millions of people in communities around the country. Not only do they provide needed services, they also
employ a significant portion of the American workforce. According to a 2019 report by the Center for Civil Society Studies at Johns Hopkins
University, "nonprofits account for roughly one in 10 jobs in the U.S. private workforce, with total employees numbering 12.3 million in
2016." Since many of these organizations may not be otherwise eligible for the Paycheck Protection Program, it is especially important
Frieda C. Fox these organizations have other sources of support. We cannot make a significant portion of employers (and their employees) ineligible to
4/15/2020 4:20:00 21gomezj@p Family receive aid, just because they are not "for profit" businesses. I urge you to consider expanding the eligibility of the Main Street
PM PIO (Email from Gomez Jonah cscharter.org Foundation Lending facility to include nonprofit organizations.
1. When we are looking at the index of SOFR. Is there another index or rate option that is able to be used and still be eligible?
2. Is there a standard participation agreement the federal reserve will use for the 95% portion of the loan?
First National
4/15/2020 4:21:00 brandon.will Bank of Thank you,
PM PIO (Email from Will Brandon @fnbotn.com Tennessee Brandon
4/15/2020 4:21:00 Personal Please allow not-for-profit organizations to remain within the Main Street Federal Lending Program. They provide services no other groups do
PM PIO (Email from Paulson Loretta Email Address self employed and should be treated as a business for the purposes of borrowing funds to survive.
4/15/2020 4:21:00 Personal Please include non profits in the funding. They are keeping people in my community of New Rochelle from going under. We cannot make it
PM PIO (Email from Maria Katherine Email Address without them.
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Main Street Lending Program Comments
I urge you to INCLUDE non-profits that serve in the social services sector in the current Main Street Covid-19 relief package. These
organizations are the lifeblood of the communities they serve providing essential services to the most vulnerable people in a community.
Additionally, these non-profits, such as the over 200 affiliates of the YWCA USA are in turn employers in the markets they operate in. These
Personal organizations, by mandate of their non-profit status and their oversight governance are the MOST efficiently run organizations that perennially
4/15/2020 4:26:00 Email DO THE MOST with the operating dollars they have. To EXCLUDE these essential organizations is a grave misstep at a time when they are
PM PIO (Email from Sims Tara Address MOST needed by the communities they serve.
I am a supporter of a nonprofit healthcare organization in California, and I am writing to advocate for the inclusion of nonprofit organizations as
part of the Main Street Lending Program. The exclusion of nonprofits from this program leaves medium-size nonprofits - which are also not
eligible to participate in the Paycheck Protection Program - in precarious financial standing without any way to mitigate economic injury while
preserving workforce and continuing critical services to hundreds of thousands of Californians. Without the vital aid provided by the program,
organizations like ours are at risk of making cuts to staff and services which impacts our ability to serve some of the most vulnerable people in
Personal Email California. PLEASE INCLUDE NONPROFIT ORGANIZATIONS OR EXPAND THE PAYCHECK PROTECTION PROGRAM TO INCLUDE
4/15/2020 4:27:00 Address ALL NONPROFITS WHICH WILL INCREASE THE CAPACITY OF THE SAFETY NET SYSTEM.
PM PIO (Email from Hill Al
4/15/2020 4:31:00 Personal I believe it is imperative to include nonprofit organizations--501(c)3s-- in this program. Thank you.
PM PIO (Email from Busillo Erica Email Address
To whom it may concern:
We would like to urge you to please expand eligibility criteria for the Federal Reserve "Main Street" Lending Facility to include non-
profits and higher education institutions. Like many businesses these entities are suffering losses from the current crisis and require additional
resources to be able to cover those losses. Many of them are ineligible for the Paycheck Protection Program, due to having large numbers of
employees.
These institutions employ more than 5 million dedicated professionals/workers and educate more than 19.9 million students across the United
States. Many universities are a main employer in their communities, and some oversee major health systems that are responding to the
4/15/2020 4:35:00 mattroche@s pandemic. Their ineligibility to participate may mean some of these institutions may have to close. Please add them to the entities able to
PM PIO (Email from Roche Matthew tu.edu receive funds from this program.
CHAIRMAN POWELL
Federal Reserve Board
I support the Federal Reserve Board's Main Street New Loan Facility to help small and medium-sized businesses borrow money during
this difficult economy. This new program has the potential to help many Louisiana firms stay afloat, and perhaps even expand, during the
Coronavirus pandemic.
As you roll out this program please consider widening its potential impact by including loans to start-up businesses. Even the largest and
most prominent American businesses were once start-ups. Main Street loans to new firms could be limited to those willing to pay a
substantial wage, hire low-income individuals, and otherwise demonstrate the potential for significant economic impact.
Thank you for considering my views. Please let me know if you have any questions or need additional information.
LA Public COMMISSIONER FOSTER CAMPBELL
4/15/2020 4:38:00 foster.campb Service LA Public Service Commission, District 5
PM PIO (Email from Campbell Foster ell@la.gov Commission
The Main Street Lending program should be expanded to include nonprofits, who are the glue to the civic engagement that takes place in
local communities. Many nonprofits, like the League of Women Voters of Los Angeles, are supported by direct engagement with individuals
for the success of their programs, services and donation activities. Many of these nonprofits do not have access to credit and depend on
grassroots organizing that cannot be done at the moment. With a major election around the corner and the ongoing Get Out the Census
League of campaigns, it is critical to provide financial support to nonprofit businesses in order to ensure that this impactful work continues. The federal
4/15/2020 4:38:00 ed@lwvlosan Women Voters government can facilitate support by expanding relief programs and providing repayment flexibility to nonprofits.
PM PIO (Email from Guevara Marilu geles.org of Los Angeles
4/15/2020 4:41:00 vonnejob@o Please. You must include medium and large nonprofits in the Main Street lending program as they are needed to help communities such as
PM PIO (Email from Brooking Joe ptonline.net mine in New Rochelle, New York survive and recover from the Covid 19 pandemic. Thank you
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Main Street Lending Program Comments
On behalf of nonprofits in Massachusetts, we urge you to ensure that the Main Street Lending Program and any subsequent mid-size loan
programs are fully available to nonprofits, including those with 500 employees or more.
The CARES Act made two loan programs (EIDL, PPP) available to nonprofits with 500 employees or fewer. Those provide important relief but
they are not available to nonprofits that employ more than 500 people. This is a significant barrier to relief for nonprofit institutions with large
workforces administering critical programs and services.
As Treasury and the Fed work to implement §4003(c)(3)(D), providing financing to lenders to make loans to nonprofits and other
employers with up to 10,000 employees, we urge you to:
- Include an interest rate of 0.50% (50 basis points) for 501(c)(3) charitable nonprofits at a 5 year amortization;
- Provide priority to 501(c)(3) charitable nonprofits and require lenders to make a proportionate number and value of loans to nonprofits to
prevent the crowding out that is being seen in the Paycheck Protection Program;
- Set a date certain for when employee retention provisions should begin; and
- Set forth that payments shall not be due until two years after a direct loan is made.
Thank you for your consideration.
Sincerely,
jklocke@mas Massachusetts Jim Klocke
4/15/2020 4:43:00 snonprofitnet. Nonprofit Chief Executive Officer
PM PIO (Email from Klocke Jim org Network Massachusetts Nonprofit Network
I'm very concerned that the new "Main Street" lending facility through the CARES Act may exclude nonprofits, many
institutions of higher learning and Minority-Serving Institutions. I am the President of a non-profit and on the Board and involved with others
that have been unable to qualify for some of the other loan programs created by the CARES Act because of size restrictions. The non-profit
community has been counting on this program including us as employers of so many Americans. Of course, non-profit organizations work on
raiser-thin budgets under good circumstances and will need assistance such as this to make it through this economic downturn when many
sandra@voic Americans will decrease their philanthropy. Simultaneously, communities need non-profits to expand to meet the public health, housing,
4/15/2020 4:45:00 esforprogress economic, advocacy, and other needs created by this crisis. We cannot do so without assistance like these loans.
PM PIO (Email from Fluke Sandra .org
Please amend the Main Street Lending program to include the non-profit sector.
Alcy Ball
4/15/2020 4:46:00 sharkins@alc Development
PM PIO (Email from Harkins Seth yball.org Corp. - Memphis
Please provide more information on the specific SOFR index that will be required for the Main Street Lending and Extended Facilities. Current
jtellinghusen indexes on Bloomberg include overnight, 1 month cummulative average, 30 day average, 90 day average, and 180 day average.
4/15/2020 4:47:00 @watrust.co Washington Thank you.
PM PIO (Email from Tellinghusen Jason m Trust Bank
To whom it may concern:
We would like to urge you to please expand eligibility criteria for the Federal Reserve "Main Street" Lending Facility to include non-
profits and higher education institutions. Like many businesses these entities are suffering losses from the current crisis and require additional
resources to be able to cover those losses. Many of them are ineligible for the Paycheck Protection Program.
Personal Email
These institutions employ more than 5 million dedicated professionals/workers and educate more than 19.9 million students across the United
Address
4/15/2020 4:49:00 States. Many universities are a main employer in their communities and some oversee major health systems that are responding to the
PM PIO (Email from Oyarzun Ramon pandemic. Their ineligibility to participate may mean some of these institutions may have to close.
tgartland@op The act should include nonprofits, institutions of higher learning and Minority-Serving Institutions.
4/15/2020 4:55:00 erationprogre Operation
PM PIO (Email from Gartland Theresa ssla.org Progress
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Main Street Lending Program Comments
I am writing to urge you to include nonprofits as a part of the new "Main Street" lending facility. Nonprofits are a critical part of the
economy, employing many and specifically in the instance of the arts & culture sector, contributing to vital tourism dollars for all states.
4/15/2020 4:55:00 amy@gammt The Gamm Please reconsider your position - our existance as small businesses (and nonprofits) depends on access to programs such as these. Thank
PM PIO (Email from Gravell Amy heatre.org Theatre you!
To whom it may concern:
We would like to urge you to please expand eligibility criteria for the Federal Reserve "Main Street" Lending Facility to include non-
profits and higher education institutions. Like many businesses these entities are suffering losses from the current crisis and require additional
resources to be able to cover those losses. Many of them are ineligible for the Paycheck Protection Program.
Personal
These institutions employ more than 5 million dedicated professionals/workers and educate more than 19.9 million students across the United
Email Address
4/15/2020 4:56:00 St. Thomas States. Many universities are a main employer in their communities and some oversee major health systems that are responding to the
PM PIO (Email from Acevedo Mag Ricardo University pandemic. Their ineligibility to participate may mean some of these institutions may have to close.
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/15/2020 4:57:00 tenisha.webb Uplift Family eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
PM PIO (Email from Webb Tenisha @upliftfs.org Services
To whom it may concern:
We would like to urge you to please expand eligibility criteria for the Federal Reserve "Main Street" Lending Facility to include non-
profits and higher education institutions. Like many businesses these entities are suffering losses from the current crisis and require additional
resources to be able to cover those losses. Many of them are ineligible for the Paycheck Protection Program.
St. Thomas These institutions employ more than 5 million dedicated professionals/workers and educate more than 19.9 million students across the United
4/15/2020 4:58:00 carlos@csjrla University States. Many universities are a main employer in their communities and some oversee major health systems that are responding to the
PM PIO (Email from Santisteban, J carlos w.com School of Law pandemic. Their ineligibility to participate may mean some of these institutions may have to close.
To whom it may concern:
I would like to urge you to please expand the eligibility criteria for the Federal Reserve Main Street Lending Facility to include non-profits and
higher education institutions. Like many businesses, these entities are suffering from the current crisis and require additional resources to
cover their costs so they may provide their student population educational advancement. Many of these entities are ineligible for the Paycheck
Protection Program and thus require other sources of support.
These institutions employ more than 5 million dedicated professionals, educators, support staff and student workers and educate more than
19.9 million students across the United States. Many universities are the main employer in their communities and some oversee major health
systems that are responding to this pandemic. Their ineligibility to participate in this lending program may affect their future in as some of
4/15/2020 4:59:00 hortensia@ull these institutions may have to close permanently leaving a hole not only in the education sector but in the community it serves.
PM PIO (Email from Ullivarri Hortensia ivarri.com
4/15/2020 4:59:00 Personal Diana Aviv Please can you be sure to include 501(c)(3) organizations in this funding. Nonprofits account for over 20% of the workforce and in addition
PM PIO (Email from Aviv Diana Email Address Associates provide help to others in need. Their salaries are modest and they are desperately intneed of financial help
Page 140 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
Here is a sample comment you can use for the submission:
Feedback on the Federal Reserve "Main Street" lending facility
To whom it may concern: We would like to urge you to please expand eligibility criteria for the Federal Reserve "Main Street"
Lending Facility to include non-profits and higher education institutions. Like many businesses these entities are suffering losses from the
current crisis and require additional resources to be able to cover those losses. Many of them are ineligible for the Paycheck Protection
Program.
These institutions employ more than 5 million dedicated professionals/workers and educate more than 19.9 million students across the United
4/15/2020 5:00:00 mngomi@stu St. Thomas States. Many universities are a main employer in their communities, and some oversee major health systems that are responding to the
PM PIO (Email from Ngomi Margret .edu University pandemic. Their ineligibility to participate may mean some of these institutions may have to close.
My understanding is the current language in "Main Street Lending" excludes institutions of higher education. As a college with 600
employees (not eligible for SBA loan) and a main employer in the city of Wilkes-Barre (in an economically distressed area) access to this
4/15/2020 5:03:00 jjryan@kings. lending opportunity is important. For the sake of the survival of main street college, I ask that mid-size schools of higher education be included
PM PIO (Email from Ryan John edu King's College in this opportunity.
Hello,
Can the Main Street Loan Program be used for a new business that is starting up? Or must the business be pre-existing?
If the business is pre-existing and was still in startup phase and did not have any revenue yet, is the business eligible for a Main Street loan?
b.thrasher@c
4/15/2020 oeurholdings. Thank you!
12:00:00 AM PIO (Email from Thrasher Brad com
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
Thanks,
jmccann@mo
4/15/2020 5:12:00 mentummh.o Jerry
PM PIO (Email from McCann Jerry rg
jennifer@sav Nonprofits should be included in this program. Charities pick up the needs of the community where government leaves off and are critical.
4/15/2020 5:13:00 eourplanet.or
PM PIO (Email from Hoffman Jennifer g
4/15/2020 5:14:00 Jlpavich@zo Jen Pavich Nonprofits are working overtime to serve communities, are facing extraordinary financial challenges and should not be excluded from the
PM PIO (Email from Pavich Jennifer ho.com Coaching Main Street lending facility.
With regard to the new Main Street Lending program, we encourage you to include private nonprofit, regionally accredited universities to be
declared eligible for this lending program. Institutions, such as Campbellsville University, play an important role in the economies of many
jechowning@ communities. In our case, we are not eligible for the SBA programs authorized by the CARES Act. Our understanding is that institutions such
4/15/2020 5:15:00 campbellsvill Campbellsville as ours would be eligible for this new program. Thank you for your consideration of these comments.
PM PIO (Email from Chowning John e.edu Universitu
We would like to urge you to please expand eligibility criteria for the Federal Reserve "Main Street" Lending Facility to include non-
profits and higher education institutions. Like many businesses these entities are suffering losses from the current crisis and require additional
resources to be able to cover those losses. Many of them are ineligible for the Paycheck Protection Program.
maureen.she These institutions employ more than 5 million dedicated professionals/workers and educate more than 19.9 million students across the United
4/15/2020 5:15:00 a@rightflorid right States. Many universities are a main employer in their communities and some oversee major health systems that are responding to the
PM PIO (Email from shea maureen a.com management pandemic. Their ineligibility to participate may mean some of these institutions may have to close.
Page 141 of 363
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Main Street Lending Program Comments
4/15/2020 5:16:00 mcrichton@c Can you please discuss the treatment of non-profits under the Main Street Lending Program and whether there will be any separate criteria
PM PIO (Email from Crichton McLean ooley.com Cooley LLP for their participation (namely in relation to leverage requirements under the maximum loan amount)?
I am writing to urge the Federal Reserve to ensure that the Main Street Lending facility under the CARES Act remain open to mid-sized to
Jewish Family large not-for-profit organization as they were not eligible under the PPP program. JFCS of AZ provides healthcare services to indigent
terrence.dani & Children's populations in Arizona and we need the help that the CARES Act provides to remain active in helping serve Arizona.
4/15/2020 5:17:00 els@jfcsaz.or Service of
PM PIO (Email from Daniels Terrence g Arizona
Please do not exclude non-profit nonprofits and higher education institutions like Charles R. Drew University of Medicine and Science a Title
III B, Section 326 institution from Main Street Lending funding opportunities. We have already accrued in excess of $1 million in expenses that
result from transitioning our academic programs to online and our business operations to telework and this does not include payroll expenses
Charles R. Drew that the University continues to encumber to avoid layoffs and higher rates of unemployment. We also recently became a COVID-19 testing
angelaminnie University of site.
4/15/2020 5:18:00 field@cdrewu Medicine and
PM PIO (Email from Minniefield Angela .edu Science Thank you for your consideration.
4/15/2020 5:20:00 mcrichton@c If there is a US headquartered business (e.g. a US parent) that has operations throughout the world, is it disqualified if a majority of their
PM PIO (Email from Crichton McLean ooley.com Cooley LLP employees are not based in the United States?
To Whom It May Concern,
We would like to urge you to please expand eligibility criteria for the Federal Reserve "Main Street" Lending Facility to include non-
profits and higher education institutions. Like many businesses these entities are suffering losses from the current crisis and require additional
resources to be able to cover those losses. Many of them are ineligible for the Paycheck Protection Program.
Personal
These institutions employ more than 5 million dedicated professionals/workers and educate more than 19.9 million students across the United
Email Address
4/15/2020 5:21:00 States. Many universities are a main employer in their communities and some oversee major health systems that are responding to the
PM PIO (Email from ONEIL CATHERINE pandemic. Their ineligibility to participate may mean some of these institutions may have to close.
How will eligibility be determined with regards to total size, employees etc? Will SBA guidelines apply or can affiliated but individual
4/15/2020 5:22:00 hjennings@st Stony Point companies with individual EINs apply?
PM PIO (Email from Jennings Horace onypoint.com Group
Would an entity be permitted to issue convertible notes after the passage of CARES Act if such issuance involved a customary capped call
4/15/2020 5:26:00 mcrichton@c derivative (which would be an obligation to purchase the entities stock in connection with the convert)? The concern is that the stock
PM PIO (Email from Crichton McLean ooley.com buyback restriction incidentally impacts this component of a convertible note.
4/15/2020 5:33:00 Personal You must include medium and large nonprofits in the Main Street Lending Program as they are needed to help communities such as mine in
PM PIO (Email from Rabin-Marron Marni Email IYNY New Rochelle, New York survive and recovery from the Covid-19 pandemic.
I would like to urge you to please expand eligibility criteria for the Federal Reserve "Main Street" Lending Facility to include non-
profits and higher education institutions. Like many businesses these entities are suffering losses from the current crisis and require additional
resources to be able to cover those losses. Many of them are ineligible for the Paycheck Protection Program.
These institutions employ more than 5 million dedicated professionals/workers and educate more than 19.9 million students across the United
4/15/2020 5:39:00 Personal States. Many universities are a main employer in their communities and some oversee major health systems that are responding to the
PM PIO (Email from Balleste Melisande Email Address pandemic. Their ineligibility to participate may mean some of these institutions may have to close.
It is imperative for the health and future of the people and institutions of this country that medium to large-sized nonprofits be able to access
funds to keep their operations afloat (e.g., through the Main Street Lending program or other mechanisms). They are a LIFELIINE for people
most affected by Covid-19 now, and in the future when they recover and re-start their lives.
4/15/2020 5:41:00 Personal
PM PIO (Email from Bangser Maggie Email NONPROFITS OF ALL SIZES need to be protected and strengthened at this time.
The Federal reserve is discussing $600 billion in bank lending to small and mid-sized businesses. Currently institutions of higher learning are
kthomas18@ not included in the current provisions. Public higher education institutions are also ineligible for the Paycheck Protection Program. The
4/15/2020 5:45:00 montevallo.e University of COVID 19 pandemic has hit higher education particularly hard. I ask that you please add public higher education institutions to the
PM PIO (Email from Thomas Kira du Montevallo "Main Street" lending facility.
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Main Street Lending Program Comments
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am a
physician employee with Momentum for Mental Health, a nonprofit behavioral health organization serving children, adults and families in
Santa Clara County, California. I am writing to advocate for restoration of the applicability of the Main Street Lending Program to nonprofits
with more than 500 employees. Without increased access to lending programs intended to sustain payroll and retain employees, many
mental health and substance use service providers are at risk, a circumstance that could leave hundreds of thousands without access to
Personal Email appropriate and desperately needed treatment and care. A lack of access to adequate mental and substance use care will lead many
Address Americans to utilization of emergency services, over-crowding community hospital emergency departments and drastically increasing health
4/15/2020 5:45:00 Momentum for care costs. As such, it is imperative that the Main Street New Loan Facility eligibility include nonprofit organizations employing up to 10,000
PM PIO (Email from Baker Megan Mental Health employees or with 2019 annual revenue up to $2.5 billion.
In my view, it is thoroughly unconscionable that the Main Street Lending program as currently envisioned would exclude nonprofit
organizations, not to mention institutions of higher learning and minority-serving institutions. These groups directly serve, in a way that
business does not, a wide swath of our nation's most vulnerable and needy people. For unknown numbers of people, especially those
who lack flexible financial resources, these organizations are the only safety net. To categorically omit these groups from this relief package
withholds vital assistance for crucial service provision at a time when philanthropic contributions especially will already be greatly diminished. I
Personal
cannot express the depth of my dismay that my government would willfully exclude this sector of our economy and society from any planned
Email
4/15/2020 5:46:00 financial aid package. Please do the right thing and make the Main Street Lending parameters more inclusive.
Address
PM PIO (Email from Swinburne Susan self-employed
The Main Street Lending Program seems like it will be helpful to mid-sized companies. However, the fees associated with the loans
4/15/2020 5:50:00 steve.betts@ (origination of 1%, facility of 1%, servicing of 0.25%) seem aggressive considering the intended purpose of the lending facility. I would
PM PIO (Email from Betts Steven merrick.com suggest dialing back the fees by at least half. Thanks.
Personal Email
4/15/2020 5:52:00 Pleasw include nonprofits in the Main Street Lending Program or create a separate lending program for organizations with more than 500 staff
Address
PM PIO (Email from Riley Kate who are ineligible for the CARES Act PPP/SBA 7(a) loan program.
4/15/2020 5:53:00 Personal Email Please include nonprofits in the Main Street Lending Program, which are needed to help communities such as mine in New Rochelle, NY
PM PIO (Email from Maher Deborah Address survive and recover from the Covid-19 pandemic. Thank you.
Nonprofit New York is an association of 1,500 nonprofit organizations in New York City. We write to express our deep concern that the
Federal Reserve's Main Street Loan Facilities plans will exclude nonprofits. Nonprofits with more than 500 staff members are ineligible
for PPP loans.
If the Main Street Loan program intends to fulfill this section of the CARES Act, excluding nonprofits will be devastating for New Yorkers. The
very nonprofits critical for New York City's survival through and after COVID-19 will not make it to mid-May. We urge the Fed to include
nonprofits in the Main Street Loan program, or create a program for nonprofits to fulfill §4003(c)(3)(D) of the CARES Act that should:
Include an interest rate of 0.50% (50 basis points) for 501(c)(3) charitable nonprofits at a 5 year amortization
Provide priority to 501(c)(3) charitable nonprofits responding to COVID-19 relief efforts and require lenders to make a proportionate number
cjindasurat@ and value of loans to nonprofits to prevent the crowding out that is being seen in the Paycheck Protection Program
4/15/2020 5:54:00 nonprofitnew Nonprofit New Set a date certain for when employee retention provisions should begin
PM PIO (Email from Jindasurat Chai york.org York
During this pandemic, much of the responsibilities of caring and providing essential services for the low income families and people who lost
jobs, have fallen on the shoulders of non-profit organizations, learning Institutions and institutions that provide services to the minorities. The
huge increase of unemployment and the uncertain time for this pandemic, they've put a serious strain on these organizations and
institutions financials.
Equally vulnerable is the small businesses, especially the minority owned small businesses, who have been the back bone of our economic
engine. They urgently need a massive injection of funding from the Government. The access and process of approval of these forgivable
loans must be streamlined and made very easy in order to quickly rescue our most vulnerable economic sector, the small businesses
(especially, the minority owned small businesses that normally do not already have a relationship with financial institutions).
I urge you to create and implement funding grant and forgivable lending programs that are comprehensive, easily accessible every where
across the country without red tapes or bureaucracy. These must be done NOW, not tomorrow or not in a week, not a month from now. These
organizations/institutions and small businesses DESPERATELY NEED the Fed Government assistance NOW!
jk2006@jadaf
4/15/2020 5:55:00 oundation.co Jada We appreciate your very PROMPT action.
PM PIO (Email from Knapp Jacintha m Foundation, Inc.
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Main Street Lending Program Comments
The majority of the residents of Lynwood, California are dis-proportionally below the poverty line and are identified as people of color. Eisner
Health, serving as one of the main sources of primary medical, dental and optometry services in the community, request to be considered and
included in the Main Street lending opportunity.
A communities' health determines the outcomes and success they can achieve in the future. Eisner Health, as a community based
FQHC, helps to insure that dreams and success do come true by helping those in need to stay healthy and productive. By excluding us from
funding it risks the balance needed between supporting commercial businesses and the business of keeping people healthy. These loans, if
available to non-profit entities, would help to sustain and build health infrastructure for the part of the community with the least access. We
4/15/2020 5:58:00 asigney@eis thank you for your consideration and implore you to widen the net so that other community support services are included.
PM PIO (Email from Signey Andrew nerhealth.org Mr.
4/15/2020 6:05:00 Personal PLEASE make this available to nonprofits. PLEASE. Nonprofits are the backbone of so many of our communities, and help to keep
PM PIO (Email from Olson Jena Email Address "Main Street" healthy, educated, and vibrant. NONPROFITS NEED HELP!!!
We ask that all 501(c) organizations be made eligible to access small business interruption loans to prevent layoffs and continue to pay our
employees. While Section 501(c)6 and (c)4 organizations can access certain aid through an employee retention tax credit (Section 2301), and
the Small Business Administration is accepting applications from 501(c)6 organizations for expanded Economic Injury Disaster Loans (EIDL;
Section 1110), it will be difficult for organizations like ours to qualify for aid, particularly through Section 2301, and secure the kind of funding
needed to sustain operations. Additionally, statutory language for EIDLs is unclear in exactly how it treats 501(c)6 and 501(c)4 organizations.
manderson@ The Downtown Local 501(c)6 and (c)4 business alliance organizations vary in size and function but all play an important role across the country to support
4/15/2020 6:15:00 downtownsan San Diego local businesses and commercial properties, clean and manage our urban centers, and disseminate essential information and resources to
PM PIO (Email from Anderson Marshall diego.org Partnership people in need - particularly during times of crisis.
As it currently stands, Sonder is not eligible to apply for either of the Main Street Loan programs because the programs require borrowers to
have positive EBITDA. It is possible that this requirement aims to address the solvency requirements under Section 13(3) of the Federal
Reserve Act. Unfortunately, most start-ups cannot meet this test, but they regularly verify solvency with lenders, investors and business
counterparties by other means.
We therefore recommend the following changes:
melika.carroll Sonder - EBITDA Test. We urge you to ensure that both Main Street Loan programs are available to growing, entrepreneurial companies with
4/15/2020 6:20:00 @sonder.co Hospitality USA negative EBITDA by focusing instead on maximum loan amounts (i) as a percentage of enterprise valuation or (ii) determined by commonly
PM PIO (Email from Carroll Melika m Inc. accepted debt/equity metrics on a per industry basis.
The Federal Reserve is talking about $600 billion in bank lending to small and mid-sized businesses. Currently, institutions of higher learning
are not included in the provisions. Public higher education institutions (state colleges) are also not eligible for the Paycheck Protection
4/15/2020 6:21:00 bunttr@mont University of Program. The COVID-19 pandemic has hit higher education particularly hard. I ask that you please add PUBLIC higher education institutions
PM PIO (Email from Bunt Tiffany evallo.edu Montevallo to the Main Street lending facility.
mmadrigal@ It is of most importance to support our work in order to continue providing services for those in need. it is important to have a healthy
4/15/2020 6:24:00 prototypes.or community.
PM PIO (Email from Madrigal Mariah g Healthright 360
The American College of Emergency Physicians (ACEP) appreciates the opportunity to comment on the Main Street Lending Program. ACEP
is the national medical society representing emergency medicine, with 39,000 emergency physician members. Emergency physicians are on
the frontlines combating the novel coronavirus (COVID-19) pandemic, and as a non-profit medical association, ACEP is honored to advocate
on their behalf to ensure they have the resources they need to safely treat their patients. However, like other organizations, we have been
significantly impacted by pandemic financially. We have had to cancel long-standing meetings that we rely heavily on for revenue and delay
certain projects that we had planned to initiate. Further, many ongoing services we provide for our members have been scaled down as we all
focus our attention on addressing this crisis, putting us at risk for losing members. There are currently no financial support options that can
help us get through this challenging time. We were therefore encouraged that the Federal Reserve created the Main Street Lending Program.
American However, we understand that at this time, non-profits are not eligible for the program. To have the largest impact on the economy-and to
College of support all organizations that have been affected by this crisis-we strongly encourage you to revise the eligibility criteria for this program to
4/15/2020 6:24:00 jdavis@acep. Emergency include non-profits, including tax-exempt organizations under Section 501(c)(6) of the Internal Revenue Code.
PM PIO (Email from Davis Jeffrey org Physicians
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Main Street Lending Program Comments
Dear Sir or Madam:
We would like to urge you to please expand eligibility criteria for the Federal Reserve "Main Street" Lending Facility to include non-
profits and higher education institutions. Like many businesses these entities are suffering losses from the current crisis and require additional
resources to be able to cover those losses. Many of them are ineligible for the Paycheck Protection Program.
These institutions employ more than 5 million dedicated professionals/workers and educate more than 19.9 million students across the United
States. Many universities are a main employer in their communities and some oversee major health systems that are responding to the
pandemic. Their ineligibility to participate may mean some of these institutions may have to close.
Please consider our bona fide nonprofit institutions of education!
Law Offices of
4/15/2020 6:29:00 rmacdonnell Rowan Mac Sincerely,
PM PIO (Email from Mac Donnell Rowan @stu.edu Donnell Rowan Mac Donnell
Like other businesses, Community Health Centers (CHCs), which are non-profit businesses, are experiencing huge financial losses because
of COVID-19. On average CHCs are seeing a drop in primary care visits of 50%. Data projections for California's CHCs suggests a
shortfall of at least $1 billion in revenue over the next three months.
Nationally, CHCs are the Health Homes for 29 million patients. We were viewed as the frontline in the U.S. health care delivery system long
before COVID-19 arrived and will remain at the frontline long after it is gone. It is imperative that CHCs maintain their operations and staffing
levels to assist with diverting our patients from already over-burdened hospitals.
The SBA Payroll Protection Loan is a valuable resource many CHCs are applying for; however, with its 500-employee limit it is out of reach
for 22 CHCs in California alone. These CHCs serve the largest number of patients are at the greatest risk of closing. Not only will they suffer
the greatest revenue losses, ranging from $5-9M per entity, per month; they are also forced to endure this pandemic without the financial
Health Center support that their smaller counterparts have access to, through SBA loans.
Partners of
4/15/2020 6:31:00 jminardi@hcp Southern We respectfully request CHCs with 500 or more employees be included to receive direct financial support via the Main Street Lending
PM PIO (Email from Minardi Julie socal.org California Program.
4/15/2020 6:32:00 revwendy@u Urban Youth We are urging the Federal Reserve to INCLUDE NON-PROFITS in the Main Street Lending program. Non-profits make a significant portion
PM PIO (Email from Calderon Wendy yai.org Alliance of the employment of the USA, and provide valuable services needed at this time.
The YMCA of the East Bay is a community based nonprofit organization serving nearly 90,000 youth, teens, adults and seniors per year. As a
result of the Covid-19 pandemic and the corresponding shelter in place order we have seen a dramatic decline in our revenue, forcing us to
furlough approximately 90% of our 1000+ staff. In spite of the closure and the furloughs, our Y continues to provide services such as meal
distributions, childcare to essential workers, and housing/services for vulnerable populations.
The CARES Act provided some relief to nonprofits like ours, including 50% reimbursement for Unemployment Insurance payments, however,
due to our size we were excluded from many of the most beneficial programs, specifically the PPP. Without assistance, our organization and
many other nonprofits may not survive to provide crucial human services to our communities.
I am asking that you please ensure nonprofits are specifically named as eligible recipients of the Main Street Lending Program and that it
extends to all nonprofits, including those with 500-10,000 employees. Further, I am requesting that you consider including loan forgiveness
similar to the PPP program for the nonprofits with more than 500 employees. Given the uncertain economic future, the prospect of loan
sdelarosa@y repayment is daunting to nonprofits such as ours.
4/15/2020 6:37:00 mcaeastbay. YMCA of the
PM PIO (Email from de la Rosa Sebastian org East Bay Thank you for considering these requests and your support of nonprofits who are needed now more than ever.
1) Please ensure that banks treat applicants with relative equality based on existing relationship status with the bank -- i.e. do not
unreasonably weigh the need for debtor-status with the bank, in considering companies eligible for loans under this program.
mckillop.erlan
4/15/2020 6:40:00 dson@sixt.co Sixt Rent a Car, 2) Please ensure that companies based in the United States with the vast majority of employees in the USA, are not excluded from
PM PIO (Email from Erlandson McKillop m LLC consideration based on ownership by a foreign parent corporation.
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Main Street Lending Program Comments
To whom it may concern:
In order to ensure that the new "Main Street" lending facility fully benefits all segments of our economy, it is critical that you ensure
that nonprofit organizations are included.
In San Diego County alone, 1 in 10 jobs are in the nonprofit sector, constituting 9% of total wages. In light of the current pandemic, nonprofits
are facing unprecedented disruptions in their ability to deliver critical services while confronting mounting financial, technological and
programmatic challenges. As different forms pf federal assistance are rolled out, these organizations should be prioritized given their essential
role as a social safety net and in enhancing our quality of life.
Sincerely,
4/15/2020 6:41:00 emilyyoung@ University of San Emily Young
PM PIO (Email from Young Emily sandiego.edu Diego Executive Director, The Nonprofit Institute at the University of San Diego
The Fed lends to SPV on a recourse basis. What does this mean? Can the participation end up back with the Lender? Under what
conditions?
Eligible borrower- need to clarify:
a) Is annual revenue amount based on internal financials or audit/review? What if audit isn't available in time to apply?
b) Is annual revenue based on consolidated totals (parent/subsidiaries) or the individual entity?
c) Does each individual entity within a consolidated group apply on their own? Or on a consolidated basis?
d) How is "Significant operations" defined? by revenues? number of employees? Assets? What if manufacturing occurs
elsewhere, but sales and finished goods storage is in the US?
e) are revenues based only on FY19 performance? Will FY18 financials be required? Any other years/periods?
How does this program work on syndicated/multiple bank credits? Will they qualify?
a) How will fees be split?
b) Must all banks approve/participate?
Will Fed provide checklist of required documents/analysis? What specific underwriting items will Fed focus on? What prevents Fed from
denying a loan that Lender approved?
Restricted companies: Do companies owned by private equity/investment firms qualify? Do specialty finance companies qualify? What types
dlevin@firstb of commercial real estate companies qualify? Are any excluded?
4/15/2020 6:42:00 ankchicago.c First Bank
PM PIO (Email from Levin Deanna om Chicago Can the unsecured loan be cross-defaulted with other Lender debt?
4/15/2020 6:44:00 Personal Do the right thing...now is the hour to come through...we are in war
PM PIO (Email from Kissel Jerry Email Address NRFL
hank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am affiliated
with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration of the
applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending programs
intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a circumstance that
could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of access to adequate
mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community hospital emergency
Personal Email departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility eligibility include
4/15/2020 6:45:00 Address nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
PM PIO (Email from Mayes Tina Uplift
It is terrible that with the administrations "CARES Act" which was suppose to be an important first step in Congress's efforts
to provide support for WORKERS and businesses for relief due to COVID-19 is planning to exclude nonprofits, many institutions of higher
learning and Minority-Serving Institutions from this new lending facility!!! We are taxpayers and are all being affected. Too often you protect
info@Synerg Wall Street and NOT MAIN STREET! Your constituents are watching . One of the provisions of this legislation enables the Federal Reserve to
4/15/2020 6:48:00 yCollaborativ Sensitive Personal support up to $600 billion in bank lending to small and medium-sized businesses should NOT DESCRIMINATE.
PM PIO (Email from Collaborative Synergy e.com Information
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Main Street Lending Program Comments
We at Instituto de Avance Integral Latino CDC support your efforts, but we strongly encourage you to include the non-profit sector in this plan.
We truly believe that by partnering with non-profits that have established trust and credibility in the community will help you in reaching your
goals but also making sure that no businesses are left behind.
Instituto de
4/15/2020 6:49:00 drincon@ide Avance Integral We also work very closely with the faith community throughout southern CA and have a network of about 400 churches, that we have access
PM PIO (Email from Hamilton Dorima alcdc.com Latino CDC to and can bring these resources to.
There are many businesses including ourselves, PAR Technology Corporation that are getting boxed out of both the PPP and also the Main
Street Lending Program. Due to affiliations rules in SBA we have been boxed out of that program and due to the loan size calculation for
Main Street Lending. The program caters not to all mid size organization but only to mature ones with stable EBITDA. Many tech companies
will be boxed out like PAR. Growing tech companies will not fit this requirement as most growing SaaS companies have larger R&D
and Sales and Marketing Budgets in relation to revenue when in growth phased. If these companies do not get assistance then a significant
amount of engineering, sales and marketing jobs will be lost in this pandemic. The Main Street Lending Program needs to clarify that the $1
bryan_menar million minimum applies even in cases where a borrower has a negative 2019 EBITDA; or come up with a new standard to set a maximum
4/15/2020 6:49:00 @partech.co loan amount to ensure credit-worthy businesses with negative EBITDA are eligible to receive the relief they need.
PM PIO (Email from Menar Bryan m PAR Technology
On behalf of the American Health Information Management Association (AHIMA), I urge you to include nonprofits, including 501(c)(6)
organizations, as eligible borrowers under the Main Street 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 Minister of Public Health. AHIMA was co-organizer of the event and incurred
substantial financial loss from this potential revenue stream as well as opportunities to strengthen our global brand and increase our
membership base.Incurring of additional costs to our Annual Conference in Atlanta. The additional increase in cost to offer face-to-face and
virtual options along with the loss in revenue from a projected drop in attendance will add to the financial impact as a result of COVID-19.
American Health Postponement of AHIMA's annual HIP Week Celebration, scheduled for March 22-28, impacting the annual sale of HIP Week
lauren.ripling Information merchandise; and Temporary closure of Pearson Vue testing centers impacting certification revenue for AHIMA. I urge you to include non-
4/15/2020 6:52:00 er@ahima.or Management profits, including 501(c)(6) organizations, as eligible borrowers under the Main Street New Loan Facility. Thank you for your leadership on this
PM PIO (Email from Riplinger Lauren g Association important issue.
Q.allen@tech Please include nonprofits in your next round of funding. Thanks.
4/15/2020 6:53:00 lincproject.or The TechLinc
PM PIO (Email from Allen Quincy g Project, Inc.
For the expanded loan program:
a) can a multi-year line of credit count as a term loan? Or must it be amortizing?
b) Expanded term portion will differ from existing loan terms. Will the expanded portion be a sublimit under the loan? or a separate note?
c) can maturities of existing loan and expanded portion be different?
d) What happens if the existing loan is secured, but the expanded portion would cause the aggregate loan to be undercollateralized? Must the
expanded portion be secured?
e) Can expanded portion be cross-collateralized with other debt from Lender?
f) If the existing loan has covenants, do they also apply to the expanded portion? If so, what happens for non-compliance? Is this an event of
default on the expanded portion? Can the interest rate be raised by the default rate?
The term sheet is silent to amortization of principal and interest after the one-year deferral is over. Does Lender decide amortization? Will
there be options? Or will Fed determine amortization?
Interest rate:
a) who/what determines spread?
b) will spread be based on risk rating? market conditions? Lender discretion?
c) is there a SOFR floor? Or language to prevent negative SOFR?
dlevin@firstb
4/15/2020 6:53:00 ankchicago.c First Bank Can borrower apply at more than one bank to seek the best rate? Or will single application rule apply?
PM PIO (Email from Levin Deanna om Chicago
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Main Street Lending Program Comments
EBITDA calculation for leverage eligibility:
a) Book EBITDA or adjusted EBITDA per existing loan agreement?
b) based on individual entity or consolidated company?
c) US-based EBITDA only or entire company?
d) IS this a one-time calculation for close? Or ongoing during the life of the loan?
I) if ongoing, how frequent is testing? Will a signed compliance certificate be required?
ii) What happens if company is not in compliance post-close?
What is the process for accepting loan applications?
a) Will Fed provide an application form? And guidance?
b) What support documentation will Fed require?
c) Will Fed provide checklists/FAQs?
dlevin@firstb d) Does Borrower need to document intended use of funds?
4/15/2020 6:58:00 ankchicago.c First Bank e) Under what conditions would Fed not purchase a participation, if stated requirements are met? (i.e, what key issues in underwriting will Fed
PM PIO (Email from Levin Deanna om Chicago require?)
Timing of approval/funding:
a) Does Lender receive Fed approval prior to the Lender funding the loan?
b) Does Fed fund concurrently with Lender? or subsequently?
c) How does the Lender sell the participation to the Fed?
I) Does Fed approve each loan individually?
ii) Will Fed purchase in bulk?
iii) What is risk that Lender approves but Fed does not?
iv) If Lender then doesn't fund this loan (because of Fed denial), is it an adverse action?
d) If Lender is close to Legal Lending Limit (i.e., their 5% share is allowable, but the 95% share would put them over their limit) how is this
handled?
i) is there any recourse to Lender?
ii) Can Lender make this loan?
e) Will the Fed require Lender to fund before providing Fed approval?
f) What is risk of Fed denying a loan funded by Lender?
g) How does Fed pay the Lender? Will Fed fund with each loan individually? In bulk?
h) What closing documents will the Fed require?
i) Will the Fed provide loan documents? Participation documents?
j) if not, will Fed provide list of documents required?
dlevin@firstb What is expected start date for taking applications?
4/15/2020 7:01:00 ankchicago.c First Bank
PM PIO (Email from Levin Deanna om Chicago How frequently does Fed pay Lender the servicing fee? Monthly? Quarterly? annually?:
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Main Street Lending Program Comments
Will the unsecured/expanded loan be required to have the same risk rating as the existing loans? Can the Main Street loan cause a
downgrade?
MSLP term sheet is silent as to TDR treatment. Will Fed waive TDR rules for these loans?
How will loans be sold to the Fed? Via portal with online approval? Or will we have a person to contact? Will Fed provide a standard
application?
Loan servicing:
a) What are Lender's responsibilities to Fed?
b) What are Fed's responsibilities to Lender?
c) How are covenant defaults cured/amended?
What is communication process with Fed?
How long will Fed approval process take? Documentation process? Funding?
For attestations:
a) Are these one-time for close? Or ongoing?
b) Does Lender need to verify? If so, how? What ongoing documents will be required?
c) What happens if Borrower doesn't comply with attestation during the life of the loan?
d) For retaining employees, what is "reasonable"? What if employees are laid off in year 2?
No distribution restriction - How does this impact LLCs, S-Corps, etc that may need distributions to pay taxes? Will tax distributions be
allowed?
If an existing line of credit matures within the next 4 years, is Lender required to renew it? If Lender doesn't, will the MSLP loan be
dlevin@firstb jeopardized?
4/15/2020 7:03:00 ankchicago.c First Bank
PM PIO (Email from Levin Deanna om Chicago What happens to MSLP loan in a default situation? or if credit is in workout?
Overall, the MSLPs are too much like a normal credit facility, not enough like a bailout or assistance that most companies need right now to
continue operating and employing people.
The interest rates are too high to provide meaningful relief (2.5% minimum, up to 5.5%, is not cheap money); and
The EBITDA limits are too low to allow for distressed companies to access the additional credit they need (companies will need something
higher, in the range of 10-12x to help).
The terms of the MSLPs are not the same as those outlined under "Assistance for Mid-sized Businesses" in Section 4003(c)(3)(D)
of the CARES Act. The MSLPs and other facilities will use only a portion of the funds allocated to Treasury under the CARES Act, so further
programs/facilities may be possible, and the full relationship between these facilities and the MSLPs are not defined.
Title IV seem to have better terms (2% interest rate for example). It is not clear that Treasury is going to plan more programs. Are you? If
4/15/2020 7:06:00 PickardG@p Pacific Dental there is any sense that there is more coming around the corner that would be good to know.
PM PIO (Email from Pickard Gary acden.com Services
Please include non profit organizations in the Main Street Lending program. They really need our help!
Personal
4/15/2020 7:12:00 Warm Regards,
Email
PM PIO (Email from McKeige Connie Connie McKeige
Address
To Whom It May Concern:
In the current situation that our country and its citizens find themselves in, its the exact opportunity and moment where its government, its
leadership, and the very institution that is charged with the welfare of the nation....must take immediate and executive action.
Currently excluding the Not-for-Profit sector of institutions is an interesting initial control of the emergency measures but after sometime of
bob@chishol thought and evaluation....the non-for-profit Academic Institutions are on the front lines in preparing future generations. Please re-evaluate the
4/15/2020 7:13:00 marchitects.c RE Chisholm current guideline requirements to include such. Thank you.
PM PIO (Email from Chisholm Robert om Architects Inc
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Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
Nonprofits are a huge sector of the economy.
They employ substantial portion of the workforce.
they provide tremendous service to those most in need, especially now.
They are disproportionately hit by the recession.
4/15/2020 7:19:00 dgluesenkam
PM PIO (Email from Gluesenkamp Daniel p@cnps.org CNPS Please include nonprofits as a key recipient of these programs.
Please include nonprofits, all accredited institutions of higher learning,and especially Minority-Serving Institutions within this new lending
4/15/2020 7:19:00 Personal Crane facility. They are employers who are also crucial to their communities and employees and will also disappear without lending support to get
PM PIO (Email from Crane Patti Email MetaMarketing through the pandemic. Thank you. Patti Crane
Address To whom it may concern:
We would like to urge you to please expand eligibility criteria for the Federal Reserve "Main Street" Lending Facility to include non-
profits and higher education institutions. Like many businesses these entities are suffering losses from the current crisis and require additional
resources to be able to cover those losses. Many of them are ineligible for the Paycheck Protection Program.
Personal These institutions employ more than 5 million dedicated professionals/workers and educate more than 19.9 million students across the United
4/15/2020 7:20:00 Email States. Many universities are a main employer in their communities and some oversee major health systems that are responding to the
PM PIO (Email from Angouand Joel Address pandemic. Their ineligibility to participate may mean some of these institutions may have to close.
4/15/2020 7:20:00 ravalos@ariz Arizona Bank I had a customer with exposure to the hospitality industry inquire about this program. I would like to know how to submit a request and if there
PM PIO (Email from avalos Robert bank.com & Trust is a dedicated contact for questions. Thank you
Good Evening,
How are joint ventures handled when determining employee size? Is the employee size based on who holds the majority legal ownership?
brian.restivo thanks
4/15/2020 7:26:00 @ohiohealth. brian
PM PIO (Email from Restivo Brian com OhioHealth
Can you tell me how to find out which lending institutions will be providing loans from the Main Street Lending program?
4/15/2020 7:27:00 lisa@rehabbi Rehabbing
PM PIO (Email from Kattawar Lisa ngaustin.com Austin LLC
Respectfully, we do not understand the rationale for limiting the definition of Eligible Loan under the Main Street Expanded Loan Facility to a
"term loan." Please clarify or expand the definition of Eligible Loan to include a committed revolving loan facility in addition to a
term loan. We believe this is appropriate as the ability of an otherwise Eligible Borrower to access the Main Street Expanded Loan Facility
should not be dependent on the nature of such Eligible Borrower's existing credit facility, so long as such credit facility is provided by one
or more Eligible Lenders. In fact, the term sheet otherwise seems to account for a committed revolving loan facility since the definition of
justinz@vine Maximum Loan Size refers to an Eligible Borrower's existing outstanding and committed but undrawn debt. Thanks in advance for your
4/15/2020 7:34:00 yardvines.co Vineyard Vines, consideration. We appreciate all that you are doing to support out business and the US Economy during this time.
PM PIO (Email from Zamparelli Justin m LLC
As one of 4,000 employees of a regional non-profit health and human services agency that provides programs and services to nearly 10,000
people with intellectual and developmental disabilities, special needs, their families and older adults throughout numerous counties in Western
New York and the Greater Rochester region, I am writing today to inform you that our agency, People Inc., is fully engaged in dealing with the
COVID-19 crisis. We must ensure that our homes and services for people with disabilities remain as safe as possible and are staffed 24/7.
The vulnerable people that depend on us deserve no less. However, because we are providing essential services during the crisis, People
Inc. has incurred highly unusual increased costs in staffing, PPE, and cleaning services.
Since we are not eligible for the Payroll Protection Program (PPP) due to our size and we must remain fully operational, we request that the
Mid-Size Loan Program have provisions to convert to a forgivable loan for nonprofits that face staggering losses due to COVID-19. This would
grant us the same protections as PPP.
Personal
4/15/2020 7:36:00 Thank you in advance for your support of direct care staff, the people we support and our agency, People Inc.
Email Address
PM PIO (Email from Banner Richard People Inc
Page 150 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. The County
of Santa Clara partners with numerous nonprofit organizations for the delivery of a broad range of services to meet the needs of our most
vulnerable residents. Our partnerships with nonprofit organizations are pivotal to the success of County safety net programs and the services
provided help improve the lives of our community members. I write to advocate for the restoration of the applicability of the Main Street
Lending program to nonprofits with more than 500 employees. The enabling legislation (CARES Act, Section 4003) expressly included
nonprofit organizations between 500 and 10,000 employees, but it now appears the Federal Reserve's initial guidance for the Main
Street Lending Program excludes nonprofits from eligibility. These critical providers of the nation's safety net are not eligible for the
Paycheck Protections Program (PPP) (Sections, 1102, 1106) or the Economic Injury Disaster Loans (EIDL) (Section 1110) or other federal
Danielle.Chri relief. This proposed action threatens the viability of larger nonprofits who provide aid to thousands of children and families in our County and
4/15/2020 7:45:00 stian@ceo.sc County of Santa hundreds of thousands of people throughout the nation. Please include nonprofits that employ over 500 employees in the Main Street
PM PIO (Email from Christian Danielle cgov.org Clara Program to protect the critical safety net.
I am a supporter of a nonprofit healthcare organization in California, and I am writing to advocate for the inclusion of nonprofit organizations as
part of the Main Street Lending Program. The exclusion of nonprofits from this program leaves medium-size nonprofits - which are also not
eligible to participate in the Paycheck Protection Program - in precarious financial standing without any way to mitigate economic injury while
preserving workforce and continuing critical services to hundreds of thousands of Californians. Without the vital aid provided by the program,
organizations like ours are at risk of making cuts to staff and services which impacts our ability to serve some of the most vulnerable people in
Personal Email California. PLEASE INCLUDE NONPROFIT ORGANIZATIONS OR EXPAND THE PAYCHECK PROTECTION PROGRAM TO INCLUDE
4/15/2020 7:57:00 Address ALL NONPROFITS WHICH WILL INCREASE THE CAPACITY OF THE SAFETY NET SYSTEM.
PM PIO (Email from Givan Rebecca
I urge the Federal Reserve to expand eligibility requirements for the Main Street Lending Program ("MSLP") to include institutions
of higher education. As a public university, Rowan is entrusted with a special responsibility for the health and welfare of 19,600 students and
4,460 employees, as it has shifted to remote learning and shut down activities on campus. As the fourth fastest growing public doctoral
research university in the United States, the changes are very disruptive for those engaged in the extensive research activities at Rowan.
The CARES Act provides only a small percentage of the expenses that Rowan has incurred to provide remote learning and the revenue lost
from the cancellation of in-class activities and shutdowns of our dormitories. Rowan does not qualify for aid available to small businesses, the
MSLP is an important lifeline of support.
Extending eligibility is necessary to ensure that Rowan can continue to operate and serve the postsecondary education needs of the students.
Expanding eligibility also makes good economic sense. Rowan is the engine that drives economic growth throughout the South Jersey
region; Rowan's impact is $1.53 billion; It supports nearly 7,000 jobs indirectly.
We would also observe that the State of New Jersey has extended its fiscal year 3 months and higher ed funding is uncertain. The ability to
4/15/2020 8:03:00 weinsteins@r tap resources through the MSLP is critical to the fall semester.
PM PIO (Email from Weinstein Steven owan.edu Rowan Univ
Personal I believe nonprofit organizations should both be eligible for the program and receive a reduced rate of 50 basis points, given their role in
4/15/2020 8:06:00 Email society, work with the most vulnerable Americans, and high need to keep people employed.
PM PIO (Email from Nix Thompson Denise Address Equally Alive
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/15/2020 8:08:00 gsotelo@pahl- eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
PM PIO (Email from Sotelo Ginger mccay.com
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Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
Opportunity Village (OV) is a 501(c)3 non-profit organization serving people with intellectual and developmental disabilities in southern
Nevada. The organization was founded in 1954 by seven families and remains centered on the mission of service to people with disabilities.
Now serving more than 3,000 people annually, services provided include diverse selections such as employment, job development, vocational
and pre-vocational training, day habilitation, social, and recreational opportunities.
Relied efforts have provided little help for nonprofit safety net systems. Funding, loans, and tax assistance targeting non-profits is needed to
ensure the safety net is sustained. Providing exemptions for mid-size non-profits in forgivable loan programs and allowing non-profits to
participate in lending at significantly reduced rates is essential. Consideration is needed for non-profit organizations operating multiple
locations.
Throughout this crisis, OV maintained payroll for 750 employees. Now working remotely to support our clients, the organization is not eligible
for payroll protection relief and other efforts targeted at small business. Please don't leave non-profits out of future relief efforts; we are
mayt@opport important to ensuring American citizens receive services during some of their most troubling times. Opportunity Village's positive
4/15/2020 8:09:00 unityvillage.or Opportunity economic impact totals more than $46 million annually. Failing to save the non-profits fails America's most vulnerable citizens.
PM PIO (Email from Brown-May Tracy g Village
EBITDA Test. Our company, like many other successful start-ups, would not qualify for the Main Street New Loan Facility because the
program requires borrowers to have positive EBITDA. We urge you to modify the program's terms to ensure its availability to growing,
entrepreneurial companies with negative EBITDA by focusing instead on maximum loan amounts (i) as a percentage of enterprise valuation,
(ii) determined by commonly accepted debt/equity metrics on a per industry basis and/or (iii) as determined by the lending bank (who retains
4/15/2020 8:12:00 alon.rotem@t 5% risk) in applying reasonable underwriting criteria relevant to growth-stage companies, such as cash on hand, existing debt, operating
PM PIO (Email from Rotem Alon hredup.com Thredup Inc. costs, gross margins, etc.
Now, more than ever, CBOs are a beacon of hope and a lifeline to populations most deeply impacted by the health and economic implications
of this pandemic. We are in the frontlines, providing daily essential services, educational and information resources.
We are essential workers, liaisons for government especially during times of crisis. We are profoundly impacted as workers and institutions as
we struggle to remain sustainable, operational and committed to our service. We call for our representatives to ensure that government works
for "Main Street" - this includes nonprofits.
CBOs essential to the fabric of our nation. We play an essential role in holding communities together. Without financial support, nonprofits will
be forced to lay off staff and suspend services, representing a devastating loss of vital serves for community and further unemployment.
We are partnering with you, government, to help mitigating impacts to health and economic downturn - partner with us to sustain this
important work.
The public message is "We're in this together". However, a vital pillar of support for Main Street - nonprofits - are abandoned
by the exclusion from financial relief. We fight for justice and equity, especially now that this pandemic is highlighting the profound inequities
Mission and injustices in this country, exacerbated by the manner in which our government responds to this moment. We demand better from our
4/15/2020 8:13:00 lila.carrillo@ Neighborhood representatives. We demand equity and equity is about access.
PM PIO (Email from Carrillo Lila mncsf.org Centers, Inc.
In support of the 4,000 employees of a regional non-profit health and human services agency that provides programs and services to nearly
10,000 people with intellectual and developmental disabilities, special needs, their families and older adults throughout numerous counties in
Western New York and the Greater Rochester region, I am writing today to inform you that People Inc. is fully engaged in dealing with the
COVID-19 crisis. They must ensure that more than 150 community-based homes and services for people with disabilities remain as safe as
possible and are staffed 24/7. The vulnerable people that depend on People Inc. deserve no less. However, because they are providing
essential services during the crisis, People Inc. has incurred highly unusual increased costs in staffing, PPE, and cleaning services.
Since People Inc. is not eligible for the Payroll Protection Program (PPP) due to their size and the fact that they must remain fully operational,
we request that the Mid-Size Loan Program have provisions to convert to a forgivable loan for nonprofits that face staggering losses due to
COVID-19. This would grant them the same protections as PPP.
Personal
4/15/2020 8:14:00 Email Address Niagara County Thank you in advance for your support of direct care staff, the people they support and People Inc.
PM PIO (Email from Rainey Stacy SPCA
I worked in a non profit with about 390 regular full time & part time employee. However, we hire contingent workers & freelancer
during the course of the year who can provide few hours or few days of work and are paid via payroll. These pool are not considered in our
employee roster but it makes us exceeds the 500 employee threshold to be eligible with SBA Paycheck Protection Program (PPP), which I
think needs to be revisit. Also, the Main Street Lending does not include non profit, and has no forgiveness provision too. I respectfully request
4/15/2020 8:16:00 kohc@wnet.o that the employee count for non profit be considered be the regular FT and PT employee for PPP. Thank you.
PM PIO (Email from Koh-Tungol Cristina rg
Page 152 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/15/2020 8:18:00 glessing@ew eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
PM PIO (Email from Lessing Gary ingfoley.com Ewing Foley Inc
Please ensure that nonprofit employers with up to 10,000 employees are explicitly included and able to access the Main Street Lending
Program. It is imperative that consideration to loan forgiveness for nonprofits, similar to the Paycheck Protection Program, to eliminate the
burden of repayment in these uncertain times. Our communities need nonprofits like the Y now more than ever. Also as major employers,
including non profits in the program stimulates the economy by ensuring the nonprofit employee is not just working but ensuring the other can
work as well. Consider that non profits ease the burden of government by providing services like child care, day camps and other youth and
family services.
I encourage you to Include larger organizations that do so much great work in community.
This would ensure that we can continue to provide urgently needed services for their neighbors. YMCA like ours serve large communities. In
fact in Cleveland we serve people that live and work in 7 counties and a large geographic area. Despite our facilities being closed,
YMCA's like ours continue to provide Pandemic Child Care Centers and homeless shelters and are on the front line in distributing food.
Our Cleveland Y has a major transitional homeless shelter that assists upwards of 250 men and women every day. Thanks for your
4/15/2020 8:23:00 thilk@clevela YMCA of Greater consideration in allowing YMCA's and other major large non profits the opportunity to assist in the rebuilding of our economy and our
PM PIO (Email from Hilk Timothy ndymca.org Cleveland communities.
Personal Funding for non-profits is essential in the Main Street Lending program being considered by congress. They are the backbone of our towns.
4/15/2020 8:26:00 Email Address Thank you!
PM PIO (Email from Stone Michele
To whom it may concern:
We would like to urge you to please expand eligibility criteria for the Federal Reserve "Main Street" Lending Facility to include non-
profits and higher education institutions. Like many businesses these entities are suffering losses from the current crisis and require additional
resources to be able to cover those losses. Many of them are ineligible for the Paycheck Protection Program.
Personal These institutions employ more than 5 million dedicated professionals/workers and educate more than 19.9 million students across the United
4/15/2020 8:27:00 Email Address St. Thomas States. Many universities are a main employer in their communities and some oversee major health systems that are responding to the
PM PIO (Email from Ford Max University pandemic. Their ineligibility to participate may mean some of these institutions may have to close.
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
Personal Email hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/15/2020 8:28:00 Address eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
PM PIO (Email from Brady Margaret
Page 153 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
The Child Mind Institute is an independent, national nonprofit dedicated to transforming the lives of children and families struggling with
mental health and learning disorders. Our teams work every day to deliver the highest standards of care, advance the science of the
developing brain and empower parents, professionals and policymakers to support children when and where they need it most.
We write to request that as Treasury and the Fed work to create a program under §4003(c)(3)(D) providing financing to lenders to make
loans to nonprofits and other employers with up to 10,000 employees, the program should include the following terms to satisfy the
requirements of the CARES Act:
Include an interest rate of 0.50% (50 basis points) for 501(c)(3) charitable nonprofits at a 5 year amortization
Provide priority to 501(c)(3) charitable nonprofits responding to COVID-19 relief efforts and require lenders to make a proportionate number
and value of loans to nonprofits to prevent the crowding out that is being seen in the Paycheck Protection Program
Set a date certain for when employee retention provisions should begin
Payments shall not be due until two years after a direct loan is made
4/15/2020 8:30:00 brett.dakin@ Child Mind We also ask that Treasury and the Fed utilize all authority to establish protocols to convert loans under this program into grants, similar to the
PM PIO (Email from Dakin Brett childmind.org Institute terms established for the Paycheck Protection Program.
April 16, 2020
Re: Main Street Lending
On behalf of the Arc Thriftstores of Colorado, a 52 year old non profit which funds advocacy for persons with intellectual, I write to express
our concern that the Main Street Loan Facilities announced on April 9th fails to provide essential relief to nonprofit organizations and appear
inconsistent with the requirements of §4003(c)(3)(D) of the CARES Act.
Our 52 year old non profit has been SEVERELY impacted by the COVID-19 crisis, and we have been forced to furlough 700 of our 1,800
employees given a reduction of $2 million PER WEEK in revenue.
A program that provides financing for loans to nonprofits with 500 to 10,000 employees and meets the requirements of §4003(c)(3)(D)
of the CARES Act should include the following terms:
Include an interest rate of 0.50% (50 basis points) for 501(c)(3) charitable nonprofits at a 5 year amortization.
Make it a priority to support 501(c)(3) charitable nonprofits responding to COVID-19 relief effort;
Require lenders to make a proportionate number and value of loans to nonprofits in order to prevent the crowding-out effect seen in the
Paycheck Protection Program;
I ask that Treasury and the Fed exercise authority to convert loans under this program into grants, similar to the terms of the Paycheck
Protection Program
Sincerely,
Lloyd Lewis
4/15/2020 8:32:00 llewis@arcthr Arc Thriftstores President/CEO
PM PIO (Email from Lewis Lloyd ift.com of Colorado Arc Thriftstores of Colorado
Our communities need nonprofits like the Y now more than ever. The CARES Act was a first step toward supporting nonprofits through the
economic crisis stemming from the COVID-19 pandemic, but more help is needed. Please consider loan forgiveness for nonprofits, similar to
the Paycheck Protection Program, to eliminate the burden of repayment in these uncertain times. Without additional resources, many
nonprofit organizations will be lost to their communities, including YMCAs. The YMCA of Greater Louisville employed 2100 staff prior to the
COVID-19 pandemic and have had to furlough 95% of our staff. Despite our facilities being closed, our Y is providing child care for health,
emergency and other essential services workers as outlined by the Governor's office; teen shelter for homeless and neglected/abused
youth; shelter for homeless men; making hundreds of welfare calls; offering thousands of virtual experiences for activity, engagement, and
making connections. Without access to support, our Y will not be able to resume operations as we knew it or retain our staff.
Personal Please help us ensure that we have the resources necessary to support our neighbors, our staff, and our community.
Email
4/15/2020 8:37:00 Address YMCA of Greater Thank you, be safe and stay well.
PM PIO (Email from Holloman Howard Louisville
Page 154 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
Personal
4/15/2020 8:40:00 eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
Email
PM PIO (Email from Radlo Edward Address Radlo & Su
As a seasonal employer and with a large youth employment - we are wondering if we need to count part time employees in the calculation.
Many of our employees are only with us 90 days; another large percentage are between 16 and 21 years old and not relying on their wages
for all living expenses. We need clarification on who to count. We also need clarification on when to count - if we count upon application we
are well under 10,000. But, at certain times of the year we are well over. Finally, is this program tied to any particular credit rating? At
corrine.brindl SeaWorld Parks SeaWorld Parks & Entertainment we have yet found a program for us, but all our parks are closed and we have tremendous expense as
4/15/2020 8:41:00 ey@seaworld & we care for animals. Our rescue centers are also still operating. Plus animal life support. Please advise. Thank you
PM PIO (Email from Brindley Corrine .com Entertainment
adburns@ym The YMCA of Greater Louisville employed 2100 staff prior to the COVID-19 pandemic and have had to furlough 95% of our staff.
4/15/2020 8:42:00 calouisville.or Without access to support, our Y will not be able to resume operations as we knew it or retain our staff.
PM PIO (Email from Desanovski-B Aleksandra g YMCA
On behalf of Saint Louis University, we are seeking clarification from the Federal Reserve related to the Main Street Lending Program and ask
that you provide written guidance to clarify that non-profit, private institutions of higher education are eligible to participate in the program.
Saint Louis University is a significant employer in our local community and we are facing a major cash flow crisis due to the reduced revenue
and increased expenses imposed by the COVID-19 pandemic. Our university expects to refund over $10 million in room and board, parking
and select fees, alone. Additionally, our anticipated sources of auxiliary revenue have dried up as campus events and summer programs
have been canceled, too.
In this uncertain time, access to low-interest loans is critical to non-profit colleges and universities, including ours. We would very much like to
be able to access the credit and loans available under the Main Street Lending Program. However, there is confusion about whether non-
profits are eligible, because current guidance does not comment on this matter. We ask that the Federal Reserve update the guidance to
clarify that non-profit, private institutions of higher education are eligible to participate in the program. We believe this to be an important
clarification given that institutions of higher education are often the largest, or one of the largest, employers within their community and region.
Thank you for your consideration.
4/15/2020 8:45:00 president@sl Saint Louis
PM PIO (Email from Pestello Fred u.edu University
1) What will be the capital requirements for lenders for loans made under MSLP? Will there be any relaxation in regulatory requirements?
2) For an existing borrower applying for this program, would a credit rating downgrade mean that the lender is required to hold more capital
for this borrower on the existing loan(s) as well? This may discourage lenders from lending under MSLP
3) Lenders will likely charge the borrower both facility fees and origination fees - it amounts to 1.95% of the entire principal for a new loan
facility and may be viewed negatively by the borrower and discourage participation
4) When will the lender receive servicing fee from the SPV? Would it be paid at the end of the year on an annual basis?
5) How should the lender determine the spread (b/w 250-400 bps)? Would the methodology be prescribed by the Fed?
6) Borrowers may have liquidity issues at the end of first year. What would the amortization schedule for these loans be?
udayant.khe 7) Government imposed restrictions may discourage borrowers from availing loans under this program. Is there any consideration to relax the
4/15/2020 8:49:00 mani@oliver restrictions on borrowers?
PM PIO (Email from Khemani Udayant wyman.com Oliver Wyman
As a Chamber of Commerce, an organization focused on promoting economic growth and a strong quality of life for the community, we
recognize the importance of Main streets. Main streets are the reflection of the city's pride. A great Main Street promotes prosperity and
mrichards@w Waltham a sense of community. Along with the City's pride, Main Streets are a center for employment. 1000s of jobs are created from the
4/15/2020 8:59:00 althamchamb Chamber of businesses on Main Streets. A strong Main Street also increases the property value for the city/town which increases the taxes which helps
PM PIO (Email from Richards Molyna er.com Commerce with infrastructure, schools and so on. And this is my reason for writing this.
Page 155 of 363
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Main Street Lending Program Comments
Nareit, the representative voice for REITs and publicly traded real estate, requests a waiver for REITs from the dividend restriction applicable
to direct loan programs under Section 4003(c)(3)(A)(ii) of the CARES Act because REITs are required by law to annually distribute their
taxable income to shareholders.
A waiver is appropriate because many REITs are experiencing financial hardship from the COVID crisis; because application of the dividend-
related restriction to REITs would not be consistent with the longstanding Federal interest of supporting REIT-based real estate investment;
and because the absence of an exception for REITs is an oversight stemming from the emergency nature of the CARES Act.
Congress created REITs to provide a way for individuals from all walks of life to obtain the savings and investment diversification benefits of
real estate. Today, more than 87 million Americans own REITs directly or indirectly. REITs are invested in every part of the country in every
type of real estate including hotels, hospitals, nursing homes and retail.
The economic disruption associated with the pandemic makes it difficult for many tenants of REIT-owned property across the nation to
currently pay rent. This extraordinary development means that a number of REITs must prioritize maintaining liquidity. Like other U.S.
businesses which are not required by law to pay dividends equivalent to taxable income, these REITs equally need access to the direct loan
4/15/2020 9:07:00 cbarre@narei program.
PM PIO (Email from Barre Catherine t.com Nareit
Hello,
Confidential Business Information
I do not know how the camping/canoeing season is going to be this year, but am hoping that I will be able to make enough money to pay back
the loan, but it would be helpful to have the one year delay as well.
Thank you for your time,
4/15/2020 9:08:00 Personal
PM PIO (Email from Roehrenbeck Kath Email Address My Own Kathy Roehrenbeck
Our communities need nonprofits like the Y now more than ever. Please also consider loan forgiveness for nonprofits, similar to the
Paycheck Protection Program, to eliminate the burden of repayment in these uncertain times.
4/15/2020 9:13:00 mcox@ymcal YMCA of Greater
PM PIO (Email from Cox Melanie ouisville.org Louisville Your thoughtful consideration is greatly appreciated.
I hope you'll open eligibility to include non-profits in your COVID-19 relief programs for small and mid-sized businesses. Non-profits are
Personal Email employers, health insurance providers and essential to maintaining and rebuilding community through the crisis and beyond. Non-profits, like
4/15/2020 9:15:00 Address small businesses, struggle to access capital from traditional means as individual and corporate donors cut back charitable giving and stock
PM PIO (Email from Foster Autumn market losses restrict larger grantmakers' ability to support organizations.
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Main Street Lending Program Comments
American Cancer Society Cancer Action Network, advocacy affiliate of American Cancer Society, respectfully requests that implementation of
section 4003(c)(3)(D)(ii) to provide financing to banks and other lenders to make loans to employers including nonprofits up to 10,000
employees:
Include 0.50% interest rate (50 basis points) for Section 501(c)(3) nonprofits at a 5- year amortization;
Prioritize 501(c)(3) charitable nonprofits;
Payments not begin until two years after a direct loan is made;
Employee retention provisions should begin on the date that loan funding is received by the borrower; and
In implementing workforce restoration and retention provisions, "workforce" should be defined as full-time employees or full-time
equivalents.
Many charities, the third largest employer sector in the economy, may not meet standards that would allow access the Paycheck Protection
Program, which contains loan forgiveness provisions. We know income recovery, including charitable giving, is a slow process and loan
American forgiveness would be necessary to ensure nonprofits be able to provide services during the crisis and recovery. Please keep our
Cancer Society organizations financially strong so we can meet the needs of our communities and plan for the future. In the toughest times, we do the
4/15/2020 9:20:00 gregg.haifley Cancer Action toughest work. Our unique needs should not be overlooked. Please contact Gregg Haifleyat Gregg.Haifley@cancer.org.
PM PIO (Email from Haifley Gregg @cancer.org Network
I am writing to request and encourage you to include Nonprofits and Universities in CARES Act Lending Facilities. Unfortunately, as of today,
excluded from the provision are nonprofits, many institutions of higher learning and Minority-Serving Institutions. This is a particular challenge
for those entities that are also ineligible for the Paycheck Protection Program. These entities are often the employers serving and employing
the most vulnerable and at-risk in America's communities. It is also critical that nonprofits and businesses that serve our nation's
4/15/2020 9:24:00 cpowell@yap Youth Advocate minority communities have an equal opportunity to access financial resources to help overcome the economic distress of this pandemic.
PM PIO (Email from Powell Carla inc.org Programs Thank you, Carla Powell
1. Eligible Lenders should include non-depository lenders to maximize the benefit of the Programs. 2. The requirement that the Eligible Lender
not cancel or reduce existing lines of credit should not adversely affect rights of Eligible Lenders on a default. 3.The Programs should provide
that the SPV is a participant purchasing interests in loans by Eligible Lenders, is not in privity with Borrowers and Lenders may manage the
lending relationship in all respects. 4. The Programs should state that Eligible Lenders do not make any representations and are not liable as
to value or collectability of debt, collateral, information from Borrowers, performance by Borrowers, financial condition of Borrowers and similar
matters and actions taken in administering the credit in its reasonable judgment. 5. Term loans under the Expanded Loan Facility if pari passu
with revolving loans under an asset-based facility will reduce funds available to Eligible Borrowers, an adverse unintended consequence.
Asset-based lenders determine how much credit to make available based on being repaid from the collateral first. If any debt shares that
position the asset-based lender reduces the amount it lends by the amount of such debt. The Programs need to shift the priority of the
repayment of the participation. 6. Given the current status of systems for the use of SOFR and the developing nature of its formulation,
4/15/2020 9:31:00 rgumbrecht@ Secured Finance Eligible Lenders should be allowed to continue to use LIBOR for some period of time.
PM PIO (Email from Gumbrecht Richard sfnet.com Network, Inc.
To whom it may concern:
We would like to urge you to please expand eligibility criteria for the Federal Reserve "Main Street" Lending Facility to include non-
profits and higher education institutions. Like many businesses these entities are suffering losses from the current crisis and require additional
resources to be able to cover those losses. Many of them are ineligible for the Paycheck Protection Program.
Personal
Email Address These institutions employ more than 5 million dedicated professionals/workers and educate more than 19.9 million students across the United
4/15/2020 9:33:00 States. Many universities are a main employer in their communities and some oversee major health systems that are responding to the
PM PIO (Email from Moya de Cast Mirtha pandemic. Their ineligibility to participate may mean some of these institutions may have to close.
Hungarian Kindly include nonprofits in the Main Street Lending Program or create a separate lending program for organizations with more than 500 staff
4/15/2020 9:35:00 Emese@hhrf. Human Rights who are ineligible for the CARES Act PPP/SBA 7(a) loan program. Thank you.
PM PIO (Email from Latkoczy Emese org Foundation
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
Personal
hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
Email
4/15/2020 9:42:00 Therapy in your eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
Address
PM PIO (Email from Groves Julie home
Page 157 of 363
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Main Street Lending Program Comments
To whom it may concern:
We would like to urge you to please expand eligibility criteria for the Federal Reserve "Main Street" Lending Facility to include non-
profits and higher education institutions. Like many businesses these entities are suffering losses from the current crisis and require additional
resources to be able to cover those losses. Many of them are ineligible for the Paycheck Protection Program.
Personal
Email These institutions employ more than 5 million dedicated professionals/workers and educate more than 19.9 million students across the United
4/15/2020 9:46:00 Address States. Many universities are a main employer in their communities and some oversee major health systems that are responding to the
PM PIO (Email from Campbell Andrea St thomas Uni pandemic. Their ineligibility to participate may mean some of these institutions may have to close.
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
Personal
4/15/2020 9:48:00 eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
Email
PM PIO (Email from Daniel Alison
Address
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
Personal Email hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/15/2020 9:49:00 Address eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
PM PIO (Email from Alper B-N. n/a
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
Personal Email
Address hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/15/2020 9:53:00 eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
PM PIO (Email from Daniel Lorrie
Feedback on the Federal Reserve "Main Street" lending facility
To whom it may concern:
We would like to urge you to please expand eligibility criteria for the Federal Reserve "Main Street" Lending Facility to include non-
profits and higher education institutions. Like many businesses these entities are suffering losses from the current crisis and require additional
resources to be able to cover those losses. Many of them are ineligible for the Paycheck Protection Program.
These institutions employ more than 5 million dedicated professionals/workers and educate more than 19.9 million students across the United
4/15/2020 jtully@STU.E States. Many universities are a main employer in their communities and some oversee major health systems that are responding to the
10:02:00 PM PIO (Email from Tully John DU n/a pandemic. Their ineligibility to participate may mean some of these institutions may have to close.
4/15/2020 Personal Please include nonprofits in this program or create a similar program for them they do incredibly important work and should be prioritized at
10:03:00 PM PIO (Email from Brecher Todd Email Address least as much as for profit entities.
Page 158 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/15/2020 meekyung.ha San Jose State eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
10:03:00 PM PIO (Email from Han Meekyung n@sjsu.edu University
We must support the Y, as a large non-profit organization, with a long-standing history of supporting the community. In challenging times, the
Personal Email
4/15/2020 Centene Y continues to respond to the needs of the community (e.g., providing child care for first responders) and it's our obligation to ensure the
Address
10:07:00 PM PIO (Email from Tarver Faith Corporation Ys are also provided every opportunity to sustain operations through this funding.
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
Personal hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/15/2020 Email eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
10:07:00 PM PIO (Email from Tamondong Liza Address
Include non profits in the Main Street Lending programs. Non pros it's are providing essential support Tun communities and they need
4/15/2020 a.acosta@yw help.
10:10:00 PM PIO (Email from Acosta Sylvia caelpaso.org YWCA El Paso
The pronouncement states: must be organized under U.S. Laws.
Does this include businesses in Guam and Saipan too?
4/15/2020 justin.ichikaw Also the pronouncement states: "Significant portion of operations in U.S."
10:12:00 PM PIO (Email from Ichikawa Justin a@cpb.bank Can we assume significant to be 50%-60%?
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
Personal Email hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/15/2020 Address eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
10:14:00 PM PIO (Email from Hom Janice
Feedback on the Federal Reserve "Main Street" lending facility
To whom it may concern: We would like to urge you to please expand eligibility criteria for the Federal Reserve "Main Street"
Lending Facility to include non-profits and higher education institutions. Like many businesses these entities are suffering losses from the
current crisis and require additional resources to be able to cover those losses. Many of them are ineligible for the Paycheck Protection
Program.
These institutions employ more than 5 million dedicated professionals/workers and educate more than 19.9 million students across the United
4/15/2020 hgringarten@ St. Thomas States. Many universities are a main employer in their communities, and some oversee major health systems that are responding to the
10:17:00 PM PIO (Email from Gringarten Hagai stu.edu University pandemic. Their ineligibility to participate may mean some of these institutions may have to close.
Page 159 of 363
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Main Street Lending Program Comments
I am an employee of a nonprofit healthcare organization that spans California, and I am writing to urge you to include nonprofit organizations
such as HealthRight 360 among those eligible for support from the Main Street Lending Program. The exclusion of nonprofits from this
program leaves medium-size nonprofits - which are also not eligible to participate in the Paycheck Protection Program - in precarious financial
standing without any way to mitigate economic injury while preserving workforce and continuing critical services to hundreds of thousands of
Californians. Without the vital aid provided by the program, organizations like ours are at risk of making cuts to staff and services which
impacts our ability to serve some of the most vulnerable people in California. PLEASE INCLUDE NONPROFIT ORGANIZATIONS OR
4/15/2020 jklems@healt EXPAND THE PAYCHECK PROTECTION PROGRAM TO INCLUDE ALL NONPROFITS WHICH WILL INCREASE THE CAPACITY OF THE
10:20:00 PM PIO (Email from Klems Julis hright360.org Healthright 360 SAFETY NET SYSTEM.
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
Personal hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/15/2020 Email Address eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
10:20:00 PM PIO (Email from Parr Jen
Despite our facilities being closed, our YMCA is providing child care for Health, Emergency and other essential services as outlined by the
Governor's Office; Teen Shelter for homeless and neglected/abused youth; Shelter for homeless men; Making hundreds of welfare calls;
Offering thousands of virtual experiences for activity, engagement, and connectedness. The CARES Act was a first step toward supporting
nonprofits through the economic crisis stemming from the COVID-19 pandemic, but more help is needed. We were not able to apply for the
Personal Email Paycheck Protection Program because of our size. Please ensure nonprofits are explicitly named as eligible recipients of the Main Street
4/15/2020 Address Lending program. Please also ensure that nonprofit employers with between 500 and 10,000 employees are able to access the loan.
10:20:00 PM PIO (Email from Borawski Nicole CAE USA
I am a Board volunteer for the YMCA of Metropolitan Dallas. We need your help now. We have furloughed off 90% of our staff of 2,400 and
jmagnuson@ YMCA of serve a critical need in the communities we serve. If we are not able to restore our staff and services we will be leaving a great social service
4/15/2020 nashersculpt Metropolitan need for the government to fill. Please help us today with support in the Main Street Loan program.
10:21:00 PM PIO (Email from Magnuson Jill urecenter.org Dallas
Personal Email Please don't limit help for non-profit groups to those with 500 or fewer employees. Many health & mental health non-profits have
Address
4/15/2020 more the 500 employees and need assistance.
10:21:00 PM PIO (Email from Hammes Paul
4/15/2020 Personal Email We are requesteing that nonprofits get also involved in the Main Street Lending program
10:24:00 PM PIO (Email from Mastaki Haron Address
4/15/2020 Personal Email I urge the Federal Reserve to include nonprofits in the Main Street Lending Program or create a separate lending program for organizations
10:26:00 PM PIO (Email from Roosevelt Verdery Address with more than 500 staff who are ineligible for the CARES Act PPP/SBA 7(a) loan program.
Thank you to the Federal Reserve for credit methods to assist aspects of the oil and gas industry - and the US economy. The term sheet for
kathleennese the main 13(3) corporate program for industry - specifically oil and gas - has a credit rating requirement current as of March 22, 2020. For the
4/15/2020 t@nesetcons oil and gas industry - I would ask that you consider credit rating requirement as of March 6, 2020 which would be the date of the failed OPEC
10:26:00 PM PIO (Email from Neset Kathleen ulting.com NESET meeting when the oil market began to fall out. Thank you. Sincerely, Kathleen Neset
Our Y staff are on the front lines of crisis response, working to provide emergency child care, conduct phone check-ins on senior members,
4/15/2020 jay@jjmadiga and host life-giving blood drives at our Ys across Central Florida. These are critical services our neighbors rely on, and we need help from
10:29:00 PM PIO (Email from Madigan Jerome nllc.com jjmadigan LLC Congress to continue to serve the most vulnerable.
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
Personal hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/15/2020 Email Address eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
10:44:00 PM PIO (Email from Knaak Kris
Page 160 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
There are more than 62,000 trade and professional organizations nationwide;[1]
Nonprofit organizations employ 12.5 million Americans / 10.2 percent of the private workforce;[2] Nonprofit organizations' collective
share of GDP is over five percent;[3] and
4/15/2020 dfroemming According to a recent report, "most charitable nonprofits are relatively small: 97 percent have budgets of less than $5 million annually,
10:51:00 PM PIO (Email from Froemming Denise @irem.org IREM 92 percent operate with less than $1 million per year and 88 percent spend less than $500,000 annually for their work.
4/15/2020 gary@belmo Belmont Farms, I am interested in applying for the Main Street Lending Program to assist in maintaining payroll and farming expenses for my farming
12:00:00 AM PIO (Email from Scarborough Gary ntfarms.us Inc. business. Please send me information on how to apply.
I am writing to express concern that the Main Street Loan Facilities announced on April 9 fails to extend essential relief to nonprofit
organizations.
The Treasury and the Fed need to create a program under §4003(c)(3)(D) to provide financing to lenders to make loans to nonprofits
and other employers with up to 10,000 employees. The program should include the following terms to satisfy the requirements of the CARES
Act:
Include an interest rate of 0.50% (50 basis points) for 501(c)(3) charitable nonprofits at a 5 year amortization
Provide priority to 501(c)(3) charitable nonprofits responding to COVID-19 relief efforts and require lenders to make a proportionate number
and value of loans to nonprofits to prevent the crowding out that is being seen in the Paycheck Protection Program
Set a date certain for when employee retention provisions should begin
Payments shall not be due until two years after a direct loan is made
We also ask that Treasury and the Fed utilize all authority to establish protocols to convert loans under this program into grants, similar to the
terms established for the Paycheck Protection Program. Regardless of size, the needs and realities of nonprofits on the frontlines are the
4/15/2020 tsiporah@nm New Mexico same. Loan programs should provide equal treatment.
11:01:00 PM PIO (Email from Nephesh Tsiporah thrives.org Thrives Please communicate so that nonprofit employers can plan appropriately as the need for their services is growing exponentially.
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
Personal hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/15/2020 Email eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
11:03:00 PM PIO (Email from Kirkaldie Megan Address
* Please clarify the meaning of "reasonable efforts" with respect to maintaining payroll and retaining employees. For many
businesses, it may not be feasible to incur loan obligations while incurring losses to pay employees during periods of little or no sales.
* Regarding the Main Street Expanded Loan Facility, are borrowers required to have had an existing term loan prior to April 8, 2020? If so, do
revolving credit facilities satisfy the requirement? Or, are businesses that do not have either not eligible for that facility?
* Why is there a difference between the maximum loan amount of $25m under the Main Street New Loan Facility vs. $150m under the Main
Street Expanded Loan Facility? This difference appears to penalize new borrowers from fully accessing the Main Street Lending Program.
* For borrowers without any existing secured debt, please clarify that borrowings under the Main Street Expanded Loan Facility do not require
security. If that is not the case, borrowers with existing debt that is unsecured will likely not be able to access the facility without securitizing
all existing debt, which significantly reduces future flexibility.
*Please clarify that the prohibition on debt repayment does not apply to revolving credit facilities, which are typically repaid and drawn upon in
the normal course of business.
* Please clarify that adjustments to EBITDA consistent with customary commercial practices will be permitted for purposes of the leverage
Dylan.Wolin condition.
4/15/2020 @aarcorp.co
11:05:00 PM PIO (Email from Wolin Dylan m
Sgardos@np Please include nonprofits in the "Main Street" lending program.
4/15/2020 westchester. NonProfit
11:07:00 PM PIO (Email from Gardos Suzanne org Westchester
Page 161 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
Personal
4/15/2020 Email Address Please help my mother fund their support programs for the Bay Area.
11:08:00 PM PIO (Email from Daniel Jason Salesforce
Under the Main Street Lending Program, an Eligible Lender is limited to U.S. insured depository institutions, U.S. bank holding companies,
and U.S. savings and loan holding companies. Given the current economic climate, these institutions are already inundated with loan
requests and limiting the pool of eligible lenders to these institutions would only put further strain on these institutions to timely process loan
requests. As it is essential for small and medium sized businesses to receive timely loans under the program, we strongly urge the Federal
Reserve to consider expanding the scope of eligible lenders to include certain types of nonbank lenders, including direct lenders, commercial
finance companies, business development companies and other entities that provide debt financing to other businesses in the ordinary course
of their business. We also note that the current limitation to U.S. banking institutions would make it more difficult for an otherwise eligible
borrower to participate in the Main Street Expanded Loan Facility to the extent it has an existing facility with a non-U.S. banking institution.
We believe that an expanded scope of eligible lenders, both in type of institution and jurisdiction, will allow small and medium size businesses
4/15/2020 jdanner@gor The Gores to access capital more quickly and efficiently in order to retain employees and maintain payroll during this crisis.
11:19:00 PM PIO (Email from Danner John es.com Group
Inclusivity for Nonprofits in the Main Street Lending program is necessary and will provide oxygen to a choking sector. Nonprofits make up
18% of the Massachusetts workforce. Our budgets are thin pre-Covid 19. Generating revenue in this climate is impossible - we cannot gather
together to provide our programs and services to the public - whether it is on the frontline, support services or secondary services such as
scholastic programs,concerts, educational services. The PPP loan and The Economic Injury Loan program will help many (I was #1,286 in
the customer service queue today and applied weeks ago) The SBA site states the program is now closed. Many nonprofits have lost over
4/15/2020 dmonte@ins Inspire Arts 75% of their revenue, ours included. Non profits need the opportunity to apply - please do not shut us out.
11:22:00 PM PIO (Email from Monte Donna pirearts.org & Music
Personal So you're not going to support Non-Profits, many (if not most) of which are in place to help support those who are in need of help,
Email Address can't support themselves, or have fallen through the cracks - but you have no problem bailing out Airline companies who spent the last
4/15/2020 10 years buying back their own stocks and inflating their value rather than keeping that money in case of emergency? It's an atrocious
11:22:00 PM PIO (Email from Urcan Jason Mr. double standard that's absolutely sickening.
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
Personal Email hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/15/2020 Address eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
11:23:00 PM PIO (Email from Arendsen Kathy AIG
We strongly urge the Federal Reserve to reconsider whether 2019 EBITDA is the appropriate reference point for all businesses for the Main
Street Lending Program. For purposes of determining the maximum loan amount, the proposed EBITDA definition is the borrower's
2019 earnings before interest, taxes, depreciation and amortization. Prior to the crisis, certain businesses that have historically performed
well were adversely affected by recently adopted U.S. trade policies. As a result, EBITDA for these businesses have been relatively lower in
2019 than in prior years. Specifically, we propose that with respect to businesses that can document the adverse impact resulting from these
trade policies, either (i) adjustments giving effect to these adverse impacts are taken into account in determining 2019 EBITDA, or (ii) the
measurement period is the average EBITDA for the last three fiscal years. We believe either of these calculations will reflect more accurately
4/15/2020 jdanner@gor The Gores how these businesses have historically performed when determining the maximum amount of the loan.
11:24:00 PM PIO (Email from Danner John es.com Group
Page 162 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
Personal access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
Email Address hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/15/2020 eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
11:34:00 PM PIO (Email from Phipps Adrina
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am writing
to advocate for restoration of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without
increased access to lending programs intended to sustain payroll and retain employees, many mental health and substance use service
providers are at risk, a circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment
and care. A lack of access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-
Personal crowding community hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main
4/15/2020 Email Address Street New Loan Facility eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5
11:42:00 PM PIO (Email from Mery Pamela billion.
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
Personal hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/15/2020 Email Address Momentum for eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
11:43:00 PM PIO (Email from ARBALLO james Mental Health
Duke University Please include HBCU, community health, small business in care act
4/15/2020 anne.derouin School Of
11:45:00 PM PIO (Email from Derouin Anne @duke.edu Nursing
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
Personal hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/15/2020 Email Address
eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
11:47:00 PM PIO (Email from Wright Paul VA VRC
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/15/2020 speil@ewingf Ewing-Foley, eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
11:49:00 PM PIO (Email from Peil Stephanie oley.com INC.
nsharma@ar Is this program open to apply for and funding?
4/15/2020 yahospitality. How do I apply and find the form?
11:54:00 PM PIO (Email from Sharma Neil com
Page 163 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
Dear Main Street Lending Staff,
The April 9th draft of the Main Street Lending Program excludes many middle-market growth companies that are vital to economic growth,
innovation and job creation. These companies are high-growth, often capital intensive and were viewed as emerging leaders by the broader
investor community before the COVID-19 impact.
Specifically, we have concerns with condition 5(ii): "(ii) an amount that, when added to the Eligible Borrower's existing outstanding
and committed but undrawn debt, does not exceed four times the Eligible Borrower's 2019 earnings before interest, taxes, depreciation,
and amortization ("EBITDA")". The 2019 EBITDA metric precludes companies that are in growth stage while potentially
rewarding established companies in decline. For that reason, the EBITDA requirement should be appended.
We request a third provision is added such that total invested capital is also considered. Total invested capital represents the market's
conviction in a company's growth potential and future prospects. 5(ii) can be rewritten to include total invested capital as such:
"(ii) an amount that, when added to the Eligible Borrower's existing outstanding and committed but undrawn debt, does not exceed
the greater of either total invested capital or four times the Eligible Borrower's 2019 earnings before interest, taxes, depreciation, and
amortization ("EBITDA")"
samuel.meeh We appreciate your consideration of these proposed changes.
4/15/2020 an@view.co
11:59:00 PM PIO (Email from Meehan Samuel m View Inc
You must include medium and large nonprofits in the Main Street Lending Program as they are needed to help communities such as mine in
4/16/2020 Personal Email
Mt. Vernon, New York survive and recovery from the Covid-19 pandemic.
Address
12:09:00 AM PIO (Email from collier ms Thanks for all you do!
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
Personal Email access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
Address hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/16/2020 eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
12:15:00 AM PIO (Email from Mery Pamela
I am writing to encourage the expansion of the CARES Act/Main Street Lending facility to include nonprofit organizations. Nonprofit
organizations provide services to millions of people in communities around the country. Not only do they provide needed services, they also
employ a significant portion of the American workforce. According to a 2019 report by the Center for Civil Society Studies at Johns Hopkins
University, "nonprofits account for roughly one in 10 jobs in the U.S. private workforce, with total employees numbering 12.3 million in
Personal 2016." Since many of these organizations may not be otherwise eligible for the Paycheck Protection Program, it is especially important
Email Address these organizations have other sources of support. We cannot make a significant portion of employers (and their employees) ineligible to
4/16/2020 receive aid, just because they are not "for profit" businesses. I urge you to consider expanding the eligibility of the Main Street
12:26:00 AM PIO (Email from Johnson-Fox Susan Lending facility to include nonprofit organizations.
4/16/2020 pbains39@sb This program will be a god send to farmers as we are not eligible to apply for the economic injury disaster loan. Farmers are facing a crisis
12:30:00 AM PIO (Email from Bains Parvee cglobal.ney situation and any and all loan options will be of great help.
Can you please look into providing additional funds for the EIDL program? I was told by an SBA representative that the loans are capped at
Personal $15,000. This is substantially lower than what most businesses need in order to overcome this tragic time in our country and economy. Our
4/16/2020 Email Amar Sohal business along with other businesses are counting on this funding to help us get through this time. If we are unable to access funds in a timely
12:36:00 AM PIO (Email from Sohal Amar Address Company manner we will jeopardizing the viability of our business.
4/16/2020 hmarinc@opt You must include medium and large nonprofits in the Main Street Lending Program as they are needed to help communities such as mine in
12:45:00 AM PIO (Email from Horowitz Jennifer online.net New Rochelle, New York survive and recovery from the Covid-19 pandemic.
Page 164 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
Personal hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/16/2020 Email Address eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
12:57:00 AM PIO (Email from Lee Theresa
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
Saratoga access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
Speech- hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
Personal Email
4/16/2020 1:00:00 Language eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
Address
AM PIO (Email from Soder Tracie Therapy Center
I am writing to encourage the expansion of the CARES Act/Main Street Lending facility to include nonprofit organizations. Nonprofit
organizations provide services to millions of people in communities around the country. Not only do they provide needed services, they also
employ a significant portion of the American workforce. According to a 2019 report by the Center for Civil Society Studies at Johns Hopkins
University, "nonprofits account for roughly one in 10 jobs in the U.S. private workforce, with total employees numbering 12.3 million in
2016." Since many of these organizations may not be otherwise eligible for the Paycheck Protection Program, it is especially important
these organizations have other sources of support. We cannot make a significant portion of employers (and their employees) ineligible to
4/16/2020 1:13:00 liam@monke receive aid, just because they are not "for profit" businesses. I urge you to consider expanding the eligibility of the Main Street
AM PIO (Email from Fox Liam yhouse.net Lending facility to include nonprofit organizations.
Los Angeles Please amend the Main Street Lending program to include nonprofit organizations. Many of us are doing the work that is essential to
4/16/2020 1:27:00 Franci@lani. Neighborhood communities everywhere, and if we are forced to close our doors, vital human and social needs will go unmet. Thank you for your
AM PIO (Email from Levine-Grater Franci org Initiative consideration.
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
emalynn.cam hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/16/2020 1:35:00 pbell@upliftfs Uplift Family eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
AM PIO (Email from Campbell Emalynn .org Services
I was eligible for the PPP loan as a small business with under 500 employees (about 30). As I bank with JP Morgan Chase, it appears as
Personal though banks' bigger customers are getting preferential treatment, and I likely don't stand a chance at getting financial assistance.
Email Address The It's my understanding that large companies with much more than 500 employees are applying for these "Small Business"
4/16/2020 1:36:00 Gourmandise loans and getting them, and that true "Main Street" businesses don't appear to be getting the assistance, which is what the
AM PIO (Email from Ironside Sabrina School CARES Act was intended to do.
Can you please look into providing additional funds for the EIDL program? I was told by an SBA representative that the loans are capped at
Personal $15,000. This is substantially lower than what most businesses need in order to overcome this tragic time in our country and economy. Our
4/16/2020 1:52:00 Email Address Amar Sohal business along with other businesses are counting on this funding to help us get through this time. If we are unable to access funds in a timely
AM PIO (Email from Sohal Amar Company manner we will jeopardizing the viability of our business.
Page 165 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
Personal hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/16/2020 1:55:00 Email Address eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
AM PIO (Email from Krajnovich Douglas
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/16/2020 2:04:00 jlockman@st eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
AM PIO (Email from Lockman Juliana anford.edu
It seems unclear whether S Corp distributions are allowed during the term of the loan. I would encourage you to allow owner distributions to
continue to occur for S Corps since this is a common form of income for S Corp owners. Otherwise it could force owners to increase their
payroll payouts to themselves, unnecessarily incurring additional payroll costs by doing so. Also, while I completely understand the reasoning
behind prohibiting increased pay to employees during this time, what about employees who work on commission? It would be good to have
4/16/2020 3:14:00 ksitz@cydio.c some reasonable exceptions to this, for those employees who legitimately might earn more in the 4 years during the loan term. Thank you.
AM PIO (Email from Sitz Kimberly om
The Main Street lending program needs to be more inclusive. Nonprofit organizations and institutions of higher learning are the frontline
safety net across America and the COVID-19 pandemic has threatened our economic survival. We need to be included in the Main Street
lending program. Furthermore, we need and an interim emergency response package followed by a CARES 2 package that will deliver more
desperately-needed resources to all suffering from the crisis including the most vulnerable member of our communities and the neighborhood-
4/16/2020 4:07:00 jfarber@hyci Helpline Youth based non-profit organizations that serve them as well as desperate hospitals and state and local governments.
AM PIO (Email from Farber Jeff nc.org Counseling
I am the executive director of the South Memphis Alliance, Inc. (SMA). We have been serving a distressed community with a poverty rate of
57.2% for the past twenty years. We have survived by creatively stretching the limited funding we are able to garner. Recently we purchased
a 57,000 sq.ft. warehouse to bring social services closer to the community. We were in line for a loan from a local bank to upgrade the facility
but due to the economic downturn the bank pulled out. When we heard of the Federal Reserve's Main Street Lending Program it was a
ray of hope. That hope was dashed when it was reported that nonprofits are excluded from these loans. As a Minority-Serving Institutions this
is the wrong decision. Few businesses would invest in our area. If it were not for the nonprofit agencies such as SMA there would be little
4/16/2020 5:05:00 milton@sma hope for these residents. I ask you to visit our website (smaweb.org) and see the work we do and reconsider your decision to exclude
AM PIO (Email from Milton Reginald web.org SMA, Inc. agencies such as ours. Thank you.
I am affiliated with a non-profit behavioral health organization in California, and I am writing to advocate for the inclusion of non-profits as part
of the Main Street Lending Program. Non-profit behavioral health agencies provide critical services to hundreds of thousands of Californians,
yet have been left out of the Main Street Lending Program. Without the vital aid provided by the program, these agencies will have to make
Personal cuts to staff and services which impacts their ability to serve some of the most vulnerable clients in California. PLEASE INCLUDE THESE
4/16/2020 6:28:00 Email Momentum for NON-PROFIT BUSINESSES AND IN TURN INCREASE THE CAPACITY OF THE SAFETY NET SYSTEM.
AM PIO (Email from Johns Beth Address Mental Health
Opportunity Critical to extend program to include charitable (non-profit) organizations.
4/16/2020 6:49:00 jmartin@ocel Center for the
AM PIO (Email from Martin John paso.org Homeless
Please consider including community based non-profits like the YMCA in this new program. These organizations fill vital roles holding the
Personal
4/16/2020 6:55:00 community together and employ thousands of people in some cases. Hopefully the employee count can include non profits with 500 to 5,000
Email Address
AM PIO (Email from Dragon Victor 1974 employees. Thank you.
Page 166 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
MAINSTREET LENDING- Please ensure that nonprofit employers with between 500 and 10,000 employees are able to access the loan. The
Personal YMCA and it's staff was instrumental in finding fellowship and physical fitness within our community when my son was just starting out
Email Address with sports and I was beginning my fitness journey. Excluding such an organization due to the higher amount of employees doesn't
4/16/2020 7:09:00 seem right because they have the ability to utilize those employees to positively impact so many more lives!
AM PIO (Email from Coarse Kimberly
mbrill@theco I am interested in finding a bank in Richmond, Va that is participating in the program.
4/16/2020 7:20:00 mpassschool. Compass
AM PIO (Email from Brill Martin com Enterprises, Inc.
As you work to establish the Main Street Lending Program, aimed at ensuring credit flows to small and mid-sized businesses, Michigan's
community of philanthropy asks that you provide priority to 501(c)(3) tax-exempt entities to prevent the crowding out that is being seen in the
Paycheck Protection Program (PPP). Specifically, the program should:
make loans to nonprofits and other employers with up to 10,000 employees
Provide $60 billion in emergency loans to 501(c)(3) nonprofit organizations
set a date certain for when employee retention provisions should begin
We also ask that Treasury and the Fed utilize all authority to establish protocols to convert loans under this program into grants, similar to the
terms established for PPP.
Council of Michigan Foundation members have been working around the clock to support nonprofits serving on the frontlines of the COVID-19
response working to ensure the public's safety, and leading recovery efforts.
Michigan's charitable sector is an economic engine, working yet starved of resources, as they employ nearly 470,000 people who
provide critical services and economic benefit across our state and leverage more than one million volunteers. The financial hardships
rbell@michig Council of experienced by these organizations have as great of an impact on our state's workforce and economy as any business. Nonprofits
4/16/2020 8:08:00 anfoundation Michigan matter and need your support. Support for our workforce will ensure Michigan communities can endure and recover.
AM PIO (Email from Bell Regina s.org Foundations
4/16/2020 8:19:00 jcooner@thei Can you please send me info on participating banks so I can apply as a Borrower? I contacted 3 divisions of my primary bank, and they
AM PIO (Email from Cooner Jason tmo.com The ITMO, Inc. don't know anything about the Main Street New Loan Facility or how to instruct me to apply. Thanks.
The YMCA of Greater Louisville employed 2100 staff prior to the COVID-19 pandemic and have had to furlough 95% of our staff. We were not
able to apply for the Paycheck Protection Program because of our size. Without access to support, our Y will not be able to resume
4/16/2020 8:36:00 rbeard@ymc YMCA of Greater operations as we knew it or retain our staff. Please ensure nonprofits are explicitly named as eligible recipients of the Main Street Lending
AM PIO (Email from Beard Robyn alouisville.org Louisville program and that nonprofit employers with between 500 and 10,000 employees are able to access the loan.
Personal Please support and fund small business/small non-profit
4/16/2020 8:37:00 Email Address
AM PIO (Email from Hughes Rebecca WIH
Dear Chairman Powell and Federal Reserve Board of Governors,
On behalf of the Community Foundation for Greater Atlanta, I urge the Federal Reserve to include nonprofits and higher education institutions
(including HBCU's) as qualifying for the Main Street New Loan Facility and the Main Street Expanded Loan Facility, which are critical to
supporting and serving individuals and families in the greater Atlanta region during this unprecedented and uncertain time of COVID-19. For
almost 70 years, the Foundation has connected donors to nonprofits and community need within to make a difference in our 23-county region.
As one of the largest community foundations in the U.S. with ~$1.2 billion in assets, we provide philanthropic leadership for 1,000 donors and
4,000+ nonprofits and donate an estimated $100 million annually.
In Georgia, 300 nonprofits - like Goodwill, the Boys & Girls Clubs of Metro Atlanta, Morehouse College, Sheltering Arms (child care), Fox
Theater, and YMCA do not qualify for PPP relief or Main Street Programs because they each employ 500+ Georgians. Yet, these large
institutions support small businesses and provide critical health, employment, and education services to otherwise underserved individuals at
APhilipp@cfg Community a scale impossible to replace. HBCU's are important and must be included in all relief packages. Nonprofits should not be excluded
4/16/2020 8:40:00 reateratlanta. Foundation for from relief packages provided to businesses, they are just as critical to economic stability and recovery.
AM PIO (Email from Philpp Alicia org Greater Atlanta
Please ensure nonprofits are explicitly named as eligible recipients of the Main Street Lending program. The YMCA of Greater Louisville
JGOINS@Y employed 2100 staff prior to the COVID-19 pandemic and have had to furlough 95% of our staff. Please also consider loan forgiveness for
4/16/2020 8:42:00 MCALOUISV YMCA of Greater nonprofits, similar to the Paycheck Protection Program, to eliminate the burden of repayment in these uncertain times. Thank you
AM PIO (Email from GOINS JODY ILLE.ORG Louisville
lmorrison@br Requesting the Federal Reserve include nonprofits in the "Main Street" lending facility program. This facility will support up to $600
4/16/2020 8:58:00 andywinecou billion in bank lending to small and mid-sized businesses, including two lending options: new loans of $1 million to $25 million, or expansion of
AM PIO (Email from Morrison Lynn nseling.org BCCS a business's existing loan with a bank to up to $150 million.
Page 167 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
On behalf of Cazenovia College, I write to ask that the Federal Reserve update guidance to clarify that private, not-for-profit colleges and
universities are eligible for the Main Street Lending program. In addition, I ask that guidance be updated so that student workers are
4/16/2020 8:59:00 jepalmer@ca Cazenovia exempted for the purpose of the employee threshold (under 10,000 employees). I have submitted an email with additional information.
AM PIO (Email from Palmer Julia zenovia.edu College
cwelber@neu The Administration and the Federal Reserve, as of today, are considering the exclusion of nonprofits, many institutions of higher learning and
4/16/2020 9:01:00 romodulation. Minority-Serving Institutions.This is a significant negative blow in particular to entities that are also ineligible for the Paycheck Protection
AM PIO (Email from Welber Chris org NANS Program. Please reconsider
Please ensure nonprofits are explicitly named as eligible recipients of the Main Street Lending program. Please also ensure that nonprofit
employers with between 500 and 10,000 employees are able to access the loan. Also consider loan forgiveness for nonprofits, similar to the
Personal
4/16/2020 9:04:00 Paycheck Protection Program, to eliminate the burden of repayment in these uncertain times. Our communities need nonprofits like the
Email
AM PIO (Email from Cappy Jay YMCA YMCA now more than ever.
Address
My name is Jim Kelly - I operate businesses in New Hampshire.
I would like to know which lenders and in which states will be first in line to be able to process the Main Street New Loan Facility. Can you
make the application process an online streamlined process and can you make it available to businesses regardless of any owner's
credit score.
4/16/2020 9:14:00 jim@kellylaw Thank you
AM PIO (Email from Kelly James nh.com Philia Group LLC Jim
Personal Please include non profit companies in the main street lending program.
4/16/2020 9:15:00 Email Address Food banks etc.deserve to have government help for the vital work they do. !
AM PIO (Email from MacPherson Kelly 1951
Thank you to the Federal Reserve for working hard to deliver relief to non-profits and businesses all over the country. As we all fight the
coronavirus, it is important the businesses and organizations that are the lifeblood of this dynamic economy have the resources to make it
through this unprecedented pandemic. No set of organizations are more important than independent colleges and universities, especially in
small states and rural communities. In Kentucky, independent colleges account for over 56,000 students, 7,000 employees, and over $700
million dollars in economic activity. Right now, it is unclear whether or not independent higher education institutions can apply for this
Kentucky desperately needed financial lifeline. My comment is to explicitly open this loan up for independent colleges and universities. They are non-
4/16/2020 9:18:00 tom.mitzel@k Wesleyan profits and need the resources to remain an affordable and accessible postsecondary opportunity for all students, particularly those from a low
AM PIO (Email from Mitzel Thomas wc.edu College socioeconomic background.
As an private higher education institution of 2,300 students and a total headcount of 569 faculty/staff, we are ineligible for many of the benefits
of the SBA programs recently announced as a part of the CARES program. We are a 501(c)(3) organization and encourage the Federal
Reserve to consider non-profit organizations, and especially those in higher education who are "small-medium" sized
organizations to participate in the Main Street Lending Program. Thank you for your consideration.
Personal Sincerely,
4/16/2020 9:19:00 Email University of Patrick D. Heddleston
AM PIO (Email from Heddleston Patrick Address Mount Union Chief Financial Officer, University of Mount Union, Alliance, OH 44601
I am a supporter of a nonprofit healthcare organization in California, and I am writing to advocate for the inclusion of nonprofit organizations as
part of the Main Street Lending Program. The exclusion of nonprofits from this program leaves medium-size nonprofits - which are also not
eligible to participate in the Paycheck Protection Program - in precarious financial standing without any way to mitigate economic injury while
preserving workforce and continuing critical services to hundreds of thousands of Californians. Without the vital aid provided by the program,
organizations like ours are at risk of making cuts to staff and services which impacts our ability to serve some of the most vulnerable people in
Personal California. PLEASE INCLUDE NONPROFIT ORGANIZATIONS OR EXPAND THE PAYCHECK PROTECTION PROGRAM TO INCLUDE
4/16/2020 9:22:00 Email ALL NONPROFITS WHICH WILL INCREASE THE CAPACITY OF THE SAFETY NET SYSTEM.
AM PIO (Email from Alicia Daly Address
4/16/2020 9:29:00 Personal Email Lacking financial resources the YMCA of Greater Louisville may not be able to continue providing operation. The YMCA provides essential
AM PIO (Email from Clark Robert & Dia Address Advocate services to the Louisville Community. It is imperative that the YMVA be included in the Main Street Loan Program!
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Main Street Lending Program Comments
It is my understanding that nonprofit organizations are to be precluded from applying for loans through the Main Street lending facility.
Nonprofit organizations pay nearly $635 billion in annual wages to approximately 14.4 million workersa. This accounts for nearly 10% of all
wages and salaries paid in the United States. In fact, nonprofits are the third largest workforce in the country behind only manufacturing and
retail.
Please do not exclude such a significant portion of the American workforce by not allowing nonprofits to applpy for loans through the Main
Street lending program.
Thank you.
Elementary
4/16/2020 9:32:00 jstone@eisca Institute of James D. Stone
AM PIO (Email from Stone Jim .org Science Executive Director, Elementary Institute of Science
The International Council of Shopping Centers appreciates the opportunity to comment and is supportive of these programs. ICSC's
70,000 member network represents the entire retail real estate industry, from small entrepreneurs to large public companies.
ICSC requests a waiver of the dividend restriction that applies to direct loan programs under Section 4003(c)(3)(A)(ii) of the CARES Act so
REITs can participate in either MSLP facility. REITs are required by law to annually distribute their taxable income to shareholders.
ICSC recommends MSELF be available to all Eligible Borrowers with an existing loan originated before April 8, 2020, regardless if (i) the loan
is a term loan or (ii) the applicable lender is an Eligible Lender. In the alternative, the maximum loan size available for MSNLF and MSELF
should be the same.
ICSC suggests that Treasury and the Federal Reserve specify that Eligible Loans under the MSNLF should be subordinated, in addition to
being unsecured.
ICSC seeks clarification that any LLP and LLC recognized under state law be an "eligible borrower" for the lending facilities,
regardless of employees.
ICSC urges the creation of a program for retail property owners holding $135.8 billion in CMBS debt. Borrowers need financial help to meet
International existing obligations and avoid default. Such assistance could be through MSLP or another emergency lending program utilizing the remaining
Council of funds allocated to Treasury under Title IV of the CARES Act.
4/16/2020 9:32:00 blaird@ICSC. Shopping
AM PIO (Email from Laird Betsy com Centers
The Human Services Council of NY, HSC, would like to submit these comments in response to the Main Street Lending Program. HSC fosters
a diverse network of human service organizations. We discuss ideas and take collective action on issues that impact the entire sector and
those they serve. Through advocacy and collaboration, we support member organizations and their leaders in addressing their concerns of
public policy, economic trends, and the regulatory environment. The human services workforce encapsulates 200,000+ employees in
subsectors including: housing access, childcare, elder care, shelters, food pantries, and disaster response. We believe it is crucial that the
Main Street Lending Program support nonprofit providers of supports and services for all New Yorkers. Many of our agencies are larger than
500 employees and sorely need the type of loan facility the Main Street Lending Program offers in order to maintain payroll and retain our
workforce during this pandemic. Nonprofits continue to serve communities through the pandemic and face serious challenges as they
encounter increase in costs, reduction in revenue, and delay in cash receipts. The failure of large nonprofits will have devastating
kimg@huma consequences for communities leaving New Yorkers like the elderly, the homeless, and at-risk youth without services. It is vital that the Main
4/16/2020 9:33:00 nservicescou Human Services Street Lending Program and any federal stimulus include all nonprofits, big or small, and access to credit and forgivable loans.
AM PIO (Email from Kim Gloria ncil.org Council
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
bphillips@mo hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/16/2020 9:33:00 mentummh.o Momentum for eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
AM PIO (Email from Phillips Brenda rg Mental Health
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Main Street Lending Program Comments
a- Please clarify the language to make it clear that nonprofits are eligible for the Main Street Lending program. Thank you.
4/16/2020 9:33:00 blaz@bethel.
AM PIO (Email from Blaz Amy edu Bethel University
1. Ability to manage line of credit, i.e. cannot paydown other debt - makes no sense
2. Define "reasonable efforts" to maintain payroll...
3. Does SPV have voting rights?
4. Fully amortized in 4 years?
5. Handling of existing covenants...will they include this debt if indeed subordinate
6. Appears to have very little flexibility in how we manage the customer in another downturn within the 4 year period i.e. cannot lower line of
credit...
7. What if the bank is not using SOFR yet?
8. Does not appear to be designed for CRE, Professional Firms, PE Firms.
9. "No changes to existing credit facilities" unnecessarily limits the bank's ability to manage a credit during turbulent times.
10. Does SPV have voting rights in event of default?
11. What happens when borrower moves their banking relationship? Does SPV note move also?
There are many other questions, but these are can be deal killers as to whether a bank will participate in the Main Street Lending Program.
4/16/2020 9:37:00 thomas.terry
AM PIO (Email from Terry Tom @umb.com UMB Bank, n.a.
We strongly urge you to include nonprofits as eligible applications under the Main Street Lending program. Many of these institutions,
including larger nonprofits that do not qualify for the Payment Protection Program or the EIDL due to having more than 500 staff, are in
precarious financial positions due to COVID-19 and desperately need access to loan programs to ensure their sustainability in both the short
4/16/2020 9:38:00 bratner@edal Educational and long term. Including them in the Main Street Lending program, as well as raising the 500 staff limit cap in the Payment Protection
AM PIO (Email from Ratner Bret liance.org Alliance Program, would provide them with a critical lifeline during these very difficult times.
While appropriate for a number of industries, the proposed debt-to-EBITDA metrics mean that many finance companies will fail to qualify for
the MSLP.
Many financial services companies raise the majority of their debt via securitization. Issuers can essentially choose to account for
securitizations as on-balance sheet debt or as a sale in which the assets leave the balance sheet and so no debt appears on the balance
sheet. Finance companies generally ensure that they account for securitization as debt so as to avoid gain-on-sale accounting.
For finance companies that account for their securitizations as on-balance sheet transactions, debt-to-EBITDA measures are typically quite
high. Lenders are leveraged entities and the amount of leverage suitable for lenders is generally higher than the amount of leverage in other
sectors. EBITDA is not a metric used by bankers who cover the lending sector. Money is a lender's primary raw material, so talking
about earnings before interest (the cost of that raw material) is rather like talking about a chair manufacturer's earnings before cost of
wood, fabric, and nails.
We ask that the Federal Reserve either: (1) recognize that securitization debt is non-recourse to the issuer and does not need to be counted
in the calculation, or (2) require an alternative leverage metric that is more suitable for the financial services sector.
4/16/2020 9:39:00 cwinslow@af We also request that the Federal Reserve issue an FAQ to provide additional clarity.
AM PIO (Email from Winslow Celia samail.org AFSA
Please ensure that larger non profits can benefit from federal financial support. Most of them, such as the YMCA/YWCA provide essential
Personal
community support and, in their own right, are large employers who have likely had to furlough or lay off thousands of employees
Email
4/16/2020 9:40:00 compounding the economic impact of this disaster.
Address
AM PIO (Email from Radu Mike Mr.
As the Treasury Department works to create a program as directed under the CARES Act section 4003(c)(3)(D) to provide financing to banks
and other lenders to make loans to nonprofits and other mid-size business of between 500-10,000 employees, we request that the program:
Include a 0.50% interest rate (50 basis points) for 501(c)(3) charitable nonprofits at a 5 year amortization
Provide priority to 501(c)(3) charitable nonprofits responding to COVID-19 relief efforts
Payments shall not be due until two years after a direct loan is made
Employee retention provisions should begin on the date that loan funding is received by the borrower
Public Health In implementing any workforce restoration and retention provisions, "workforce" should be defined as full-time employees or full-
4/16/2020 9:43:00 jschulson@p Management time equivalents
AM PIO (Email from Schulson Jill hmc.org Corporation
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Main Street Lending Program Comments
I would like more information about Main Street lending program. Where and when can I put in an application this program.
4/16/2020 Personal
Email Address
12:00:00 AM PIO (Email from Lembo Kathie
On behalf of the Peabody Area Chamber of Commerce and our 350+ business and non-profit members i would like to advocate for more
financial relief for non-profit organizations. We partnered with the City of Peabody and recently surveyed the community and the
overwhelming response was the need for additional forgivable funding for rent, payroll, utilities, in order to survey through the end of May.
director@pea Peabody Area Many said their business cannot survive that long with existing conditions. If our Chamber does not qualify for funding soon we will have to
4/16/2020 9:44:00 bodychamber Chamber of stop operating and assisting hundreds of businesses with the resources they need. I have already furloughed my two part time employees; I
AM PIO (Email from Daigle Julie .com Commerce am the only employee left trying my best to assist every business who need us more than ever.
As the Treasury Department works to create a program under the CARES Act to provide financing to banks and other lenders to make loans
to nonprofits and other mid-size business of between 500-10,000 employees, we request that the program:
Include a 0.50% interest rate (50 basis points) for 501(c)(3) charitable nonprofits at a 5 year amortization
Provide priority to 501(c)(3) charitable nonprofits responding to COVID-19 relief efforts
Payments shall not be due until two years after a direct loan is made
Employee retention provisions should begin on the date that loan funding is received by the borrower
In implementing any workforce restoration and retention provisions, "workforce" should be defined as full-time employees or full-
time equivalents
Many nonprofits employ more than 500 employees and have not been able to access the Paycheck Protection Program, which contains loan
forgiveness provisions which are critical to these organizations and necessary to help ensure their sustainability in order to meet their mission.
Charitable nonprofits play the third largest employer in our nation's economy and as valued problem solvers. Nonprofit organizations are
Stephen.Chri our country's only institutions solely focused on making communities stronger. In the toughest times, we do the toughest work. When
stian- it's time to restore and repair our well being, these community based institutions need to be equipped to do that as well and their unique
4/16/2020 9:46:00 Michaels@wf Family Services needs should not be overlooked.
AM PIO (Email from Christian-Mich Stephen spa.org of Western P
For the PPP and other SBA loans, there were too many exclusions for certain types of businesses. Please make clear that the standard
exclusions under 13 CFR 120.110 (which were applied for the other SBA/PPP loans) do not apply.
Please also be aware that the eligibility requirements regarding EBIDTA may hinder businesses who have their own loans to operate the
business under normal circumstances. It cannot be the case that a business has to choose between risking default under one funding source
awarriner@bl (a loan taken in the normal course of business) vs. desperately needed stimulus funds.
4/16/2020 9:49:00 uebridgefinan Blue Bridge Allow for non-bank lenders to be lenders under the program. These lenders have already performed due diligence on customers and have
AM PIO (Email from Warriner Amanda cial.com Financial access to smaller businesses nationwide.
-Please ensure nonprofits are explicitly named as eligible recipients of the Main Street Lending program
-The YMCA of Greater Louisville employed 2100 staff prior to the COVID-19 pandemic and have had to furlough 95% of our staff
-Closure of Y facilities and the suspension of programs has created a serious impact on finances and services, reducing revenues by $3 -
$3.5 million per month.
-Despite our facilities being closed, our Y is providing child care for Health, Emergency and other essential services as outlined by the
Governor's Office; Teen Shelter for homeless and neglected/abused youth; Shelter for homeless men; Making hundreds of welfare calls;
Personal Offering thousands of virtual experiences for activity, engagement, and connectedness.
4/16/2020 9:52:00 Email Address -Our Y, along with others, are committed to serving our communities throughout this pandemic and beyond. Our large delivery system serve
AM PIO (Email from Vittitow Melanie UPS many people from vulnerable situations and reduces the burden of government.
The YMCA of Greater Kansas City was not able to apply for the Paycheck Protection Program because of our size. Please also consider loan
forgiveness for nonprofits, similar to the Paycheck Protection Program, to eliminate the burden of repayment in these uncertain times.
Without additional resources, many nonprofit organizations will be lost to their communities, including YMCAs. Our communities need
sallred@prim nonprofits like the Y now more than ever. Despite our facilities being closed, the Y has been providing essential child care services for
4/16/2020 9:58:00 ehealthcare.c YMCA Board healthcare workers, first responders and other essential services. Without access to support, our Y will not be able to resume operations as
AM PIO (Email from Allred Sam om Member we knew it or retain our staff.
What is the availability of this program? All of the banks that are around me in Delaware have not heard of the program, not being able to give
4/16/2020 9:59:00 kirby@midso me more details on it. Is there a list of banks that are taking part?
AM PIO (Email from Wilson Kirby uthaudio.com Mid South Audio
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Main Street Lending Program Comments
Our business is live family entertainment. The live entertainment industry has been severely impacted and will face unprecedented challenges
in responding to the COVID-19 crisis. As abruptly as the bans on mass gatherings were implemented, it will take much longer for arenas,
stadiums, production companies and event promoters to ramp back up once the public health emergency has passed, particularly if the
reopening is piecemeal. Productions and tours need to be re-built and that takes time. That, along with necessary operational changes in
venues and the economic and other impacts of this crisis on our customers, means it is not possible to require live entertainment entities to
quickly return to prior operational levels. That is why we propose targeted relief for the live entertainment industry tied to loans to mid-size
businesses by exempting NACIS Sector 71 entities from the requirement to return to 90% of prior workforce within four months. In addition,
eligibility under the Main Street Expanded Loan Facility should not be limited to borrowers with pre-existing term loans but should also apply
to those with pre-existing revolving credit facilities. Excluding revolving credit facilities unfairly penalizes existing low leveraged borrowers
4/16/2020 9:59:00 spayne@feldi Feld (who have no term debt) for their conservative overall debt levels prior to the effects of COVID-19.
AM PIO (Email from Payne Stephen nc.com Entertainment
Please ensure nonprofits are explicitly named as eligible recipients of the Main Street Lending program. Our communities need nonprofits like
the Y now more than ever.
Without additional resources, many nonprofit organizations will be lost to their communities, including YMCAs. The YMCA of Greater
Louisville employed 2100 staff prior to the COVID-19 pandemic and have had to furlough 95% of our staff. Despite our facilities being closed,
our Y is providing child care for Health, Emergency and other essential services as outlined by the Governor's Office; Teen Shelter for
homeless and neglected/abused youth; Shelter for homeless men; Making hundreds of welfare calls; Offering thousands of virtual
experiences for activity, engagement, and connectedness. Our Y, along with others, are committed to serving our communities throughout
egallagher@ this pandemic and beyond. Our large delivery system serve many people from vulnerable situations and reduces the burden of government.
4/16/2020 9:59:00 ymcalouisvill YMCA of Greater Please help us ensure that we have the resources necessary to support our neighbors and our staff.
AM PIO (Email from Gallagher Beth e.org Louisville
As the Treasury Department works to create a program under the CARES Act to provide financing to banks and other lenders to make loans
to nonprofits and other mid-size business of between 500-10,000 employees, we request that the program:
Include a 0.50% interest rate (50 basis points) for 501(c)(3) charitable nonprofits at a 5 year amortization
Provide priority to 501(c)(3) charitable nonprofits responding to COVID-19 relief efforts
Payments shall not be due until two years after a direct loan is made
Employee retention provisions should begin on the date that loan funding is received by the borrower
In implementing any workforce restoration and retention provisions, "workforce" should be defined as full-time employees or full-
time equivalents
Many nonprofits employ more than 500 employees and have not been able to access the Paycheck Protection Program, which contains loan
forgiveness provisions which are critical to these organizations and necessary in helping to ensure their sustainability in meeting their mission.
Charitable nonprofits are the third largest employer in our nation's economy and are valued problem solvers. Nonprofit organizations are
our country's only institutions solely focused on making communities stronger. In the toughest times, we do the hardest work. When
it's time to restore and repair the nation's wellbeing, these community-based institutions must be equipped to succeed, and their
4/16/2020 wstennett@vf Voices for unique needs should not be overlooked.
10:02:00 AM PIO (Email from Stennett Will icil.org Independence
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Main Street Lending Program Comments
April 16, 2020
To whom it may concern:
Subject: Main Street Lending Program Comments
On behalf of Habitat for Humanity International, thank you for the opportunity to comment on the Main Street Lending Program.
Habitat for Humanity International requests a program designed specifically for larger nonprofits who have been left out of the Paycheck
Protection Program. A new program should be as similar as possible to the Paycheck Protection Program to provide financing to banks and
other lenders to make forgivable loans to nonprofits with over 500 employees. Any facility the Reserve Bank creates needs to expressly
include 501 (c)(3) nonprofits and be highly concessionary, preferably 0% interest, for these nonprofits, many of whom are at the front lines of
serving at-risk communities and populations.
The creation of a Paycheck Protection Program for nonprofits with over 500 employees will help keep Habitat for Humanity International and
other critical nonprofits financially strong and enable us to continue to support our network of 1,200 local affiliates working in every state
across the country providing strength, stability, and self-reliance through shelter.
Chris Vincent
4/16/2020 cvincent@ha Habitat for Vice-President, Government Relations and Advocacy
10:04:00 AM PIO (Email from Vincent Christopher bitat.org Humanity Habitat for Humanity International
We are strongly encouraging that nonprofits be included in the Federal Reserve's Main Street lending program. Small and mid-sized
organizations make up the vast majority of nonprofits, and they are critical to the social safety net because of the relationships and trust
they've built within the communities they serve. Because of their intense commitment to their communities, they do the work regardless
of whether they are paid a fair and equitable rate, relying on in-kind donations and unpaid labor in the form of sweat equity and volunteer
support. As such, many organizations do not have a financial reserve, and without help, they may have to lay off or furlough staff, or risk
shutting down permanently. While the CARES Act made the Paycheck Protection Program's small business loans available to
nonprofits, it soon became clear that it was difficult for nonprofits to access those loans due partially to the SBA's unfamiliarity with
lending to nonprofit organizations. It is absolutely crucial that nonprofits have access to the Main Street lending program if they are to survive
4/16/2020 abugglevine Nonprofit the COVID-19 crisis and continue to provide critical services to populations in dire need of them.
10:05:00 AM PIO (Email from Bugg-Levine Antony @nff.org Finance Fund
Please consider clarifying that non-profits and institutions of higher education will be eligible for the Main Street Lending. Both are critically
amandabelm Trinity Bible important and help to make communities better.
4/16/2020 ont@trinitybib College &
10:06:00 AM PIO (Email from Belmont Amanda lecollege.edu Graduate School Thank you for your time!
On behalf of its 140 member hospitals, the Missouri Hospital Association urges Treasury and the Federal Reserve to explicitly make not-for
profit and local governmental hospitals eligible for the Main Street New Loan Facility initiative.
Hospitals are experiencing daunting financial challenges as they ramp up expenditures to prepare for treating a surge of patients while
concurrently losing revenue from a significant reduction in outpatient and elective procedures. With a loss of approximately half of their
revenues from those reductions, Missouri hospitals are facing significant cash flow problems.
MHA appreciates Congress' enactment of the Coronavirus Aid, Relief, and Economic Security Act. It provides valuable support to
Missouri hospitals. Section 4003(c)(4)(D) directs the Treasury and the Federal Reserve to implement a nonexclusive emergency loan
program under Section 4003 (b)(4) for businesses with up to 10,000 employees. This is the New Loan Facility program. The term sheet
posted by the Federal Reserve on April 9, 2020, does not distinguish between for-profit and not-for-profit businesses. The term sheet also
4/16/2020 dlandon@mh Missouri Hospital does not mention county, district or city owned organizations. MHA urges Treasury and the Federal Reserve to explicitly acknowledge the
10:06:00 AM PIO (Email from Landon Daniel anet.com Association eligibility of not-for-profit, county, district and city owned hospitals.
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Main Street Lending Program Comments
As you work to establish the Main Street Lending Program, aimed at ensuring credit flows to small and mid-sized businesses, Michigan's
nonprofit community asks that you provide priority to 501(c)(3) tax-exempt entities to prevent the crowding out that is being seen in the
Paycheck Protection Program (PPP). Specifically, the program should:
make loans to nonprofits and other employers with up to 10,000 employees
Provide $60 billion in emergency loans to 501(c)(3) nonprofit organizations
set a date certain for when employee retention provisions should begin
We also ask that Treasury and the Fed utilize all authority to establish protocols to convert loans under this program into grants, similar to the
terms established for PPP.
Michigan Nonprofit Association members have been working around the clock on the frontlines of the COVID-19 to ensure the public's
safety, and leading recovery efforts.
Michigan's charitable sector is an economic engine, working yet starved of resources, as they employ nearly 470,000 people who
provide critical services and economic benefit across our state and leverage more than one million volunteers. The financial hardships
jgustafson@ Michigan experienced by these organizations have as great of an impact on our state's workforce and economy as any business. Nonprofits
4/16/2020 mnaonline.or Nonprofit matter and need your support. Support for our workforce will ensure Michigan communities can endure and recover.
10:07:00 AM PIO (Email from Murray-Brown Donna g Association
Hello! It is my understanding that the "Main Street" lending program does not support non-profits, institutions of higher learning
and minority-serving institutions. This blind spot could prevent a significant sector of our community from surviving the COVID-19 outbreak. In
Chicago alone, the association community is a $14B annual enterprise that provides a livlihood for industry ranging from printing, hospitality,
Starkweather information technology, restaurants and more. These institutions provide education and support for growing segments of our community.
4/16/2020 joe@starkwe Association Think of them as community gardeners for growing small and medium-sized businesses. They are typically service-oriented and run at narrow
10:09:00 AM PIO (Email from Plasterer Joseph ather.us Services LLC margins. Please don't leave them out.
I write to ask that the Federal Reserve update guidance to clarify that private, not-for-profit colleges and universities are eligible for the Main
Street Lending program. In addition, I ask that guidance also be updated so that student workers are exempted for the purpose of the
employee threshold (under 10,000 employees).
Private, not-for-profit colleges and universities are major employers with significant economic impact in their communities. The COVID-19
pandemic has caused a major cash flow crisis due to reduced revenue and increased spending. In New York, private not-for-profit colleges
and universities have a nearly $90 billion economic impact and support more than 415,600 jobs.
Campuses across the country expect to refund nearly $8 billion in room and board charges alone. Additionally, we have seen our auxiliary
sources of revenue dry up as events and summer programs are cancelled.
Meanwhile, costs related to the pandemic are rising. Our move to remote instruction required an unexpected investment in technology and we
also face costs including deep cleaning buildings and increased security expenses.
Commission on
Independent Low-interest loans will provide vital support to private, not-for-profit colleges and universities that are working to fulfill their educational
4/16/2020 tschnurr@cic Colleges and missions and support their communities despite the severe impacts of the pandemic. We look forward to working with you as the Federal
10:15:00 AM PIO (Email from Schnurr Tom u.org Universities Reserve responds to the COVID-19 crisis.
Large nonprofit organizations have a big impact on communities. The services they provide fill many gaps that neither for-profit business nor
government can offer. For that reason, I urge you to consider allowing nonprofit organizations with 500-plus employees like the YMCA to
access Main Street Lending Program, so that it may further support its employees and our community. This would allow us to continue
responding to people's needs during this time. Along with fitness facilities and classes, we are the largest childcare provider in the
region, and support a runaway youth program and transitional homeless shelter. The Y supports immigrant youth and children with
incarcerated parents. We respond where needed and will continue to do that as we recover from this pandemic. Including large nonprofits
which make up a key part of many communities' foundations would go a long way in bringing hope to our citizens. Furthermore, we also
support loan forgiveness as a way to help us all stay strong as our economies and our people rebuild. Just like businesses, when we close
our revenue dries up. We have had to lay off about 95 percent of our staff - from childcare and social workers, to trainers and office
Personal
employees. A strong safety net is what will help our communities heal in a healthy way and get back to business. We will strive to stay strong
Email
4/16/2020 Greater for our people. We appreciate your consideration of our request.
Address
10:18:00 AM PIO (Email from Wesslund Debbie Louisville YMCA
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Main Street Lending Program Comments
Hi,
Would you please send me a list of banks that are approved to provide Main Street New Loan Facility (MSNLF) and Main Street Expanded
nick.deldeo@ Loan Facility (MSELF) loans.
4/16/2020 principiscapit Thank so much!
10:20:00 AM PIO (Email from Del Deo Nick al.com Principis Capital Nick
The new Main Street lending facility program, as currently designed, excludes some of the nation's most pivotal organizations --
nonprofits. Nonprofits are responsible for educating, providing health services, creating and maintaining arts and culture, and helping to
preserve our planet. Among many other responsibilities, nonprofits employ millions of Americans and help to meet the needs of millions more.
Given the current crisis, many small to mid-size nonprofits providing crucial services are struggling to keep their doors open. Many nonprofits
amber@coas are ineligible for current incentives like the Paycheck Protection Program and are forced to consider adding their employees to the
talcommunity Coastal unemployed list. A program like the Main Street lending program could prevent millions of Americans from needing to apply for unemployment
4/16/2020 foundation.or Community benefits. I strongly urge that you make the Main Street lending program more inclusive overall to help relieve the burden on our social
10:21:00 AM PIO (Email from Brown Amber g Foundation programs.
4/16/2020 jpiatak@uncc Nonprofits should be included as they provide as vital of services to communities as businesses.
10:22:00 AM PIO (Email from Piatak Jaclyn .edu UNC Charlotte
I am chief of staff for Ascentria Care Alliance, one of the largest human services agencies in New England. We employ 1800 people
throughout the region, and a significant portion of our staff are client facing, putting themselves at daily risk to exposure of the COVID-19
virus.
As the Treasury Department works to create a program as directed under the CARES Act section 4003(c)(3)(D) to provide financing to banks
and other lenders to make loans to nonprofits and other mid-size business of between 500-10,000 employees, we request that the program:
Include a 0.50% interest rate (50 basis points) for 501(c)(3) charitable nonprofits at a 5 year amortization
Provide priority to 501(c)(3) charitable nonprofits responding to COVID-19 relief efforts
Payments shall not be due until two years after a direct loan is made
Employee retention provisions should begin on the date that loan funding is received by the borrower
In implementing any workforce restoration and retention provisions, "workforce" should be defined as full-time employees or full-
time equivalents
Because of our size, we have not been able to access the Paycheck Protection Program and this program is the only remaining lifeline for
4/16/2020 JKinney@asc Ascentria Care organizations like ours.
10:26:00 AM PIO (Email from Kinney Jeffrey entria.org Alliance
If a company did not have positive EBITDA in '19, can they still receive funding?
What is the test for indicating that the company "requires financing due to the exigent circumstances presented by the coronavirus
disease 2019 ("COVID-19") pandemic"?
What is the test for indicating that the company has made "reasonable efforts to maintain its payroll and retain its employees during
the term of the Eligible Loan"?
Is there collateral required for this loan?
Is this senior to existing credit?
Will there be affiliation tests that relate to qualifying for these loans?
wsimmons@ Will EBITDA calculations be under GAAP or subject to definition by the company and/or the administering bank?
4/16/2020 scfpartners.c When will final guidance be issued?
10:27:00 AM PIO (Email from Simmons William om SCF Partners When will loan applications begin?
Page 175 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
As the Treasury Department works to create a program as directed under the CARES Act section 4003(c)(3)(D) to provide financing to banks
and other lenders to make loans to nonprofits and other mid-size business of between 500-10,000 employees, we request that the program:
Include a 0.50% interest rate (50 basis points) for 501(c)(3) charitable nonprofits at a 5 year amortization, with payments not due for two
years
Provide priority to 501(c)(3) charitable nonprofits retaining employees and responding to COVID-19 relief efforts
Many nonprofits employ more than 500 employees and have not been able to access the Paycheck Protection Program, which contains loan
forgiveness provisions which are critical to these organizations and necessary to help ensure they will be able to continue to provide services
during the crisis and assist with our nation's recovery efforts when the crisis is over. Charitable nonprofits are the third largest employer
in our nation's economy and are our country's only institutions solely focused on making communities stronger. The
recommendations above will help to keep these organizations financially strong and allow them to continue to meet the immediate needs of
their communities while planning for the future when many of their services will be needed most. When it's time to restore and repair our
agruenewald well-being, these community based institutions need to be equipped to do that as well and their unique needs should not be overlooked.
4/16/2020 @fouroaks.or
10:32:00 AM PIO (Email from Gruenewald Anne g Four Oaks
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
Personal hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/16/2020 Email eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
10:33:00 AM PIO (Email from Hawes Tonya Address
Please include nonprofits and universities in the Main Street Lending Program. Nonprofits are suffering great economic harm and many will
close due to increased operating costs from COVID-19 and decreased donations due to the economic downturn. NGOs are on the frontline of
fighting this disease in every state and abroad.
4/16/2020 lpena@law.g Thank you for your consideration.
10:35:00 AM PIO (Email from Pena Lisa wu.edu self employed Lisa Pena
Confidential Business
4/16/2020 Personal Email Please allow me to finance my short term loans into long term. Information
10:40:00 AM PIO (Email from Chapin Jim Address Sand Dollar One
4/16/2020 carl.lin@whet Whetron Hello, does it new loading program also applies to foreign companies operating in the US? if it does, what are the complete requirement for
10:42:00 AM PIO (Email from Lin Carl ron-us.com Electronics such entity?
You must include medium and large nonprofits in the Main Street Lending Program as they are needed to help communities such as mine in
Personal Yorktown, New York survive and recovery from the Covid-19 pandemic. Non-profits in New York already suffered when the deductions for
4/16/2020 Email Address Indivisible charitable contributions were severely limited by the current administration. Fewer people were donating to non-profits even before the
10:42:00 AM PIO (Email from Stone Marcia Yorktown current crisis. Now, it is a horror for everyone. Please help.
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
Personal Email hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/16/2020 Address eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
10:43:00 AM PIO (Email from Romine Briana
Page 176 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
Personal access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
Email hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/16/2020 Address eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
10:46:00 AM PIO (Email from Templeton Alan
We are a small community college in Ohio looking for resources to replace reduced revenue and increased expenses imposed by the
COVID-19 pandemic. IHE's are dealing with refunds to students, cancelled programs, and additional expenses at our facility due to
cleaning. We also have refunded tuition and fees for students at our schools. It is vital to provide this access to low-interest loans to non-profit
4/16/2020 sandreani@s colleges and universities financially devastated by the pandemic and struggling to continue to educate and assist students and employ the
10:48:00 AM PIO (Email from Andreani scott tarkstate.edu millions of faculty and staff who work on campuses around the country.
The American Association for Dental Research (AADR) requests that the Administration deem non-profit and other tax-exempt associations
among those groups eligible for the "Main Street" lending facility.
Many associations are experiencing financial stress resulting from the COVID-19 pandemic-namely from the necessary cancellation of major
meetings and events, which support and finance associations' operations throughout the rest of the year. Many of the associations that
canceled their meetings in March and April, including AADR, chose to act in the interest of community public health over their own financial
stability; our own meeting cancellation will result in nearly $1.4 million in lost revenue.
As eligibility requirements for this lending facility are considered, AADR implores the Administration to acknowledge the integral role
associations have in our society-both from a public service and economic perspective. Not only do meetings convened by non-profit
associations contribute nearly half a trillion dollars to U.S. gross domestic product and directly support 5.9 million jobs nationwide, but they
American also contribute to the betterment of our society by serving as resources and as links between research and public health professionals as well
4/16/2020 cfox@aadr.or Association for as state and federal policymakers. We hope their value will be recognized in federal policies, such as this one, moving forward.
10:57:00 AM PIO (Email from Fox Christopher g Dental Research
The International Association for Dental Research (IADR) requests that the Administration deem non-profit and other tax-exempt associations
among those groups eligible for the "Main Street" lending facility.
Many associations are experiencing financial stress resulting from the COVID-19 pandemic-namely from the necessary cancellation of major
meetings and events, which support and finance associations' operations throughout the rest of the year. Many of the associations that
canceled their meetings in March and April, including IADR, chose to act in the interest of community public health over their own financial
stability; our own meeting cancellation will result in nearly $1.5 million in lost revenue.
As eligibility requirements for this lending facility are considered, IADR implores the Administration to acknowledge the integral role
associations have in our society-both from a public service and economic perspective. Not only do meetings convened by non-profit
associations contribute nearly half a trillion dollars to U.S. gross domestic product and directly support 5.9 million jobs nationwide, but they
International also contribute to the betterment of our society by serving as resources and as links between research and public health professionals as well
4/16/2020 dwalsh@iadr. Association for as state and federal policymakers. We hope their value will be recognized in federal policies, such as this one, moving forward.
11:01:00 AM PIO (Email from Walsh Darin org Dental Research
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/16/2020 Lynette.ruiz Uplift Family eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
11:02:00 AM PIO (Email from Ruiz Lynette @upliftfs.org Services
4/16/2020 Personal Email Please include nonprofits, many institutions of higher learning and minority-serving Institutions in the CARES act. These areas are as
11:07:00 AM PIO (Email from Rooney Mary Address important as small businesses to our economy and the well-being of the American people. Thank you.
Page 177 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
amiller@mo hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/16/2020 mentummh.o Momentum for eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
11:24:00 AM PIO (Email from miller anthony rg Mental Health
4/16/2020 Personal Please include nonprofits in this lending group. Nonprofits are on the frontlines providing services and support that the government is unable
11:26:00 AM PIO (Email from Krug Kate Email Address to provide. Leaving them out of this is leaving vulnerable populations of citizens out on the streets.
christian.gos The Federal Reserve needs to clarify that nonprofits should also be eligible for these loans in the CARES Act.
4/16/2020 alvez@caltec
11:30:00 AM PIO (Email from gosalvez christian h.edu Caltech
I am writing on behalf of Centre College, an independent college in Danville, Kentucky, which plays a major role in our local, rural economy.
Our student body is made up of a diverse group of talented individuals, many of whom are first generation college students from Kentucky.
Thank you to the Federal Reserve for working hard to deliver relief to non-profits and businesses all over the country. As we all fight the
coronavirus, it is important the businesses and organizations that are the lifeblood of this dynamic economy have the resources to make it
through this unprecedented pandemic. No set of organizations are more important than independent colleges and universities, especially in
small states and rural communities. In Kentucky, independent colleges account for over 56,000 students, 7,000 employees, and over $700
million dollars in economic activity. Right now, it is unclear whether or not independent higher education institutions can apply for this
desperately needed financial lifeline. My comment is to explicitly open this loan up for independent colleges and universities. They are non-
katherine.and profits and need the resources to remain an affordable and accessible postsecondary opportunity for all students, particularly those from a low
4/16/2020 rews@centre Centre College - socioeconomic background. Thank you for your attention to this important issue.
11:33:00 AM PIO (Email from Andrews Katherine .edu Danville, KY
Nonprofit organizations must be included in eligibility for the Main Street Lending Program. The enabling legislation (CARES Act, Section
4003) expressly includes larger nonprofit organizations, those with between 500 and 10,000 employees. These nonprofit organizations are
not eligible for the U.S. Small Business Administration's Paycheck Protection Program, but must have federal relief so they can continue
to provide vital services, treatment, and care to hundreds of thousands of individuals and families.
Without access to federal lending programs, nonprofit service providers will be unable to retain employees and continue services. Without
access to behavioral health and other essential services these larger nonprofits provide, Americans will turn to emergency services in
hospitals that are already overcrowded, increasing health care costs overall.
California To manage health care costs during and after the COVID-19 crisis, to ensure access to vital services, and to keep employees of large
4/16/2020 lucyc@calno Association of nonprofits on the payroll to provide those services, nonprofit organizations with up to 10,000 employees or an annual revenue under $2.5
11:35:00 AM PIO (Email from Carter Lucy Salcido nprofits.org Nonprofits billion must be included in eligibility for the Main Street Lending Program.
Kpurcell@wil Please do not exclude nonprofits and many institutions of higher learning and Minority-Serving Institution from the Main Street Lending
4/16/2020 mingtonsenio Wilmington program. Nonprofit organizations provide critical services to their communities, thus people are not dependent on the government for support!
11:36:00 AM PIO (Email from Purcell Kathleen rcenter.org Senior Center
Pl saw include the YMCA organization in all efforts to help small business. They are a key organization for children and teenagers who have
mental health needs and psychosocial determinants of health that can positively impact medical and mental health outcomes.
Thank you
Dr. Nicholas Abid
Medical Director
Personal
4/16/2020 Centene Centene/Wellcare
Email Address
11:37:00 AM PIO (Email from Abid Nicholas Healthplan
Please ensure nonprofits are explicitly named as eligible recipients of the Main Street Lending program. Please also consider loan
Personal Email
4/16/2020 forgiveness for nonprofits, similar to the Paycheck Protection Program, to eliminate the burden of repayment in these uncertain times.
Address
11:38:00 AM PIO (Email from Ingram Luther
Page 179 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
Excluding colleges and universities from access to funds via the CARES Main Street lending program will be problematic for schools in need
of liquidity. The US college population is largely served by small to mid-size regional colleges. Lack of funding will make it very difficult for
these schools to absorb the impact of enrollment declines and systematically reduced revenue streams sure to result from this crisis. Per
Moody's April 7, 2020 report: "Over the next year, the coronavirus will negatively affect universities across the world as they
grapple with lower student demand, lost income due to ongoing campus closures, higher expenses, and balance sheet erosion. Globally, we
expect greater uncertainty surrounding the next recruitment cycle and lower domestic and international student enrollment for the next
academic year."
If universities do not have access to capital for bridge funding until students return, the worst will be a reality; that being fewer college options
for all students. This will disproportionately affect underrepresented students, as they are primarily served by small to mid-sized institutions.
Not having access to the lending program will give universities no option but to turn to raising tuition to stay afloat, further disadvantaging
4/16/2020 lemarbe@oa Oakland underrepresented students. Smaller schools will risk pricing themselves out of the market and driving away existing students and
11:41:00 AM PIO (Email from LeMarbe Thomas kland.edu University unnecessarily increasing the cost of higher education on those students who remain.
As one of 4,000 employees of a regional non-profit health and human services agency that provides programs and services to nearly 10,000
people with intellectual and developmental disabilities, special needs, their families and older adults throughout numerous counties in Western
New York and the Greater Rochester region, I am writing today to inform you that our agency, People Inc., is fully engaged in dealing with the
COVID-19 crisis. We must ensure that our homes and services for people with disabilities remain as safe as possible and are staffed 24/7.
The vulnerable people that depend on us deserve no less. However, because we are providing essential services during the crisis, People
Inc. has incurred highly unusual increased costs in staffing, PPE, and cleaning services.
Since we are not eligible for the Payroll Protection Program (PPP) due to our size and we must remain fully operational, we request that the
Mid-Size Loan Program have provisions to convert to a forgivable loan for nonprofits that face staggering losses due to COVID-19. This would
grant us the same protections as PPP.
4/16/2020 pking@peopl Thank you in advance for your support of direct care staff, the people we support and our agency, People Inc. Pamela King
11:49:00 AM PIO (Email from King Pamela e-inc.org People Inc
Just as any business Not-For-Profits are suffering. As a company of over 500 staff we need the same assistance as for-profit businesses. We
for example employ approximately 800 people who all have families and need their jobs. We provide essential healthcare and behavioral
Lorrie.hender Jewish Family health services to approximately 50,000 of the most needy individuals in the community that rely on those services to survive. Without these
4/16/2020 son@jfcsaz.o and Children's essential services hospitals and emergency services would be inundated. This program could be the difference in saving many of these lives.
11:50:00 AM PIO (Email from Henderson Lorrie rg Service Thank you
Our communities need nonprofits like the Y now more than ever. Please reconsider adding non-profits with more than 500 employees to be
eligible to receive financial assistance. Our non-profits are operating at less than 10% to still offer needed services to the community such as:
continue to provide urgently needed services to the community.
Despite YMCA facilities being closed, they are still providing child care for Health, Emergency and other essential services as outlined by
the Governor's Office; Teen Shelter for homeless and neglected/abused youth; Shelter for homeless men; Making hundreds of welfare
Personal calls; Offering thousands of virtual experiences for activity, engagement, and connectedness.
4/16/2020 Email These are services a community need to strive.
11:50:00 AM PIO (Email from Goatley Verna Address
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
carolsontag hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/16/2020 @sbcglobal.n eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
11:51:00 AM PIO (Email from Sontag Carol et
Page 180 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
Substitute "available" for "committed" in item 5. (Both terms are universally understood terms in asset-based lending,
but they mean two very different things).
Add the following clarifying language: "For purposes of determining the eligible loan amount (or, for purposes of this provision), an
Theresa.shea eligible borrower's existing outstanding and committed but undrawn bank debt does not include any amount that is not currently
4/16/2020 @truevalue.c True Value available under the terms of the facility, nor does it include any amount that, if drawn, would cause the Borrower to suffer fees, penalties,
11:57:00 AM PIO (Email from Shea Theresa om Company restrictions, or limitations on its operations. Lease financing obligations are also excluded.
The Main Street Lending Program is an important step to providing much needed support to small and mid-sized businesses and their millions
of workers.
In the last few weeks unemployment has skyrocketed. To address this, the Program should only purchase loans from businesses that commit
to retain their workforce and their payroll in line with CARES Act Section 4003(c)(3)(D).
There has been considerable attention regarding the private equity industry's lobbying to access low-interest CARES Act loans. The
goal of the Program should be to save businesses and jobs, not to prop up private equity firms' returns. As of the end of 2019 the private
funds industry had $2.3 trillion in available capital. The Facilities should not purchase loans made to companies owned by financial sponsors
that have capital available to invest, or at the very least should only purchase loans where the sponsor has invested additional capital
equivalent to the loan amount.
In recent years, private equity sponsors have utilized more leverage to acquire companies and have increasingly added debt to pay
themselves dividends. Adding further leverage creates moral hazard, incentivizing PE firms to take greater risks expecting government
bailouts. The Program's 6x EBITDA leverage cap is too high. Instead, the facility should prioritize acquiring loans to companies with
jim.baker@P Private Equity lower current leverage.
4/16/2020 Estakeholder. Stakeholder
12:01:00 PM PIO (Email from Baker Jim org Project In addition, the identity of recipients and the terms of assistance should be quickly made public.
We write in opposition to the exclusion of nonprofits, institutes of higher learning, and HBCUs from the Main Street New & Expanded
Loan Facilities. In short: The nonprofit sector is just as critical to economic stability and recovery as for-profit business.
Georgia alone is home to over 300 nonprofit organizations with 500 or more staff members, each doing vital work during this unprecedented
time, and each set to be left behind by this (and previous) relief efforts.
As large employers alone, they deserve federal support - but they also supply critical services at a scale that would be impossible to replace;
support an array of small businesses; and serve as economic anchors for their communities. In particular, HBCUs are critically important and
International uniquely endangered, and must be included in any and all relief packages available.
4/16/2020 j.d.mccrary@ Rescue We urge the Federal Reserve to make nonprofits eligible for the Main Street Loan program. The success of our nation's recovery from
12:02:00 PM PIO (Email from McCrary J.D. rescue.org Committee this unprecedented crisis depends on the success of our nation's nonprofits.
As an alternative to the proposed ebitda requirements the facility should also consider lenders who have security interests in real world assets
4/16/2020 dacree@acre that would similarly act as collateral for the loans. Any ebitda requirement is suspect in this environment and there should be alternatives to
12:02:00 PM PIO (Email from Acree Derek elawfirm.com this requirement to qualify for the loans.
We write in opposition to the exclusion of nonprofits, institutes of higher learning, and HBCUs from the Main Street New & Expanded
Loan Facilities. In short: The nonprofit sector is just as critical to economic stability and recovery as for-profit business.
Georgia alone is home to over 300 nonprofit organizations with 500 or more staff members, each doing vital work during this unprecedented
time, and each set to be left behind by this (and previous) relief efforts.
As large employers alone, they deserve federal support - but they also supply critical services at a scale that would be impossible to replace;
support an array of small businesses; and serve as economic anchors for their communities. In particular, HBCUs are critically important and
uniquely endangered, and must be included in any and all relief packages available.
We urge the Federal Reserve to make nonprofits eligible for the Main Street Loan program. The success of our nation's recovery from
this unprecedented crisis depends on the success of our nation's nonprofits.
4/16/2020 arease@star- Audrea Rease
12:03:00 PM PIO (Email from Rease Audrea c.org Executive Director, Star-C
Page 181 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
We write in opposition to the exclusion of nonprofits, institutes of higher learning, and HBCUs from the Main Street New & Expanded
Loan Facilities. In short: The nonprofit sector is just as critical to economic stability and recovery as for-profit business.
Georgia alone is home to over 300 nonprofit organizations with 500 or more staff members, each doing vital work during this unprecedented
time, and each set to be left behind by this (and previous) relief efforts.
As large employers alone, they deserve federal support - but they also supply critical services at a scale that would be impossible to replace;
support an array of small businesses; and serve as economic anchors for their communities. In particular, HBCUs are critically important and
uniquely endangered, and must be included in any and all relief packages available.
Personal Email
4/16/2020 Address We urge the Federal Reserve to make nonprofits eligible for the Main Street Loan program. The success of our nation's recovery from
12:03:00 PM PIO (Email from Brown Nikonie this unprecedented crisis depends on the success of our nation's nonprofits.
I write in opposition to the exclusion of nonprofits, institutes of higher learning, and HBCUs from the Main Street New & Expanded Loan
Facilities. In short: The nonprofit sector is just as critical to economic stability and recovery as for-profit business.
As large employers alone, they deserve federal support - but they also supply critical services at a scale that would be impossible to replace;
support an array of small businesses; and serve as economic anchors for their communities. In particular, HBCUs are critically important and
uniquely endangered, and must be included in any and all relief packages available.
meghan@alt
4/16/2020 ernativebreak We urge the Federal Reserve to make nonprofits eligible for the Main Street Loan program. The success of our nation's recovery from
12:03:00 PM PIO (Email from Foley Meghan s.org this unprecedented crisis depends on the success of our nation's nonprofits.
We write in opposition to the exclusion of nonprofits, institutes of higher learning, and HBCUs from the Main Street New & Expanded
Loan Facilities. In short: The nonprofit sector is just as critical to economic stability and recovery as for-profit business.
Georgia alone is home to over 300 nonprofit organizations with 500 or more staff members, each doing vital work during this unprecedented
time, and each set to be left behind by this (and previous) relief efforts.
Lupus As large employers alone, they deserve federal support - but they also supply critical services at a scale that would be impossible to replace;
Foundation of support an array of small businesses; and serve as economic anchors for their communities. In particular, HBCUs are critically important and
America, uniquely endangered, and must be included in any and all relief packages available.
4/16/2020 temond@lfag Georgia Chapter We urge the Federal Reserve to make nonprofits eligible for the Main Street Loan program. The success of our nation's recovery from
12:04:00 PM PIO (Email from Emond Teri a.org Inc this unprecedented crisis depends on the success of our nation's nonprofits.
We write in opposition to the exclusion of nonprofits, institutes of higher learning, and HBCUs from the Main Street New & Expanded
Loan Facilities. In short: The nonprofit sector is just as critical to economic stability and recovery as for-profit business.
Georgia alone is home to over 300 nonprofit organizations with 500 or more staff members, each doing vital work during this unprecedented
time, and each set to be left behind by this (and previous) relief efforts.
As large employers alone, they deserve federal support - but they also supply critical services at a scale that would be impossible to replace;
support an array of small businesses; and serve as economic anchors for their communities. In particular, HBCUs are critically important and
uniquely endangered, and must be included in any and all relief packages available.
pmontgomery
4/16/2020 @pawshuma Paws Humane We urge the Federal Reserve to make nonprofits eligible for the Main Street Loan program. The success of our nation's recovery from
12:04:00 PM PIO (Email from Montgomery Tricia ne.org Inc this unprecedented crisis depends on the success of our nation's nonprofits.
We write in opposition to the exclusion of nonprofits, institutes of higher learning, and HBCUs from the Main Street New & Expanded
Loan Facilities. In short: The nonprofit sector is just as critical to economic stability and recovery as for-profit business.
Georgia alone is home to over 300 nonprofit organizations with 500 or more staff members, each doing vital work during this unprecedented
time, and each set to be left behind by this (and previous) relief efforts.
As large employers alone, they deserve federal support - but they also supply critical services at a scale that would be impossible to replace;
support an array of small businesses; and serve as economic anchors for their communities. In particular, HBCUs are critically important and
uniquely endangered, and must be included in any and all relief packages available.
lpatterson@g Georgia
4/16/2020 atransplant.or Transplant We urge the Federal Reserve to make nonprofits eligible for the Main Street Loan program. The success of our nation's recovery from
12:04:00 PM PIO (Email from Patterson LaTonia L g Foundation this unprecedented crisis depends on the success of our nation's nonprofits.
Page 182 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
We are looking to find out more information on the main street lending program being rolled out by the federal govt. we understand thru our
banking associates that this is to help large companies with over 500 employees. We are very interested in being in the loop for information
vsinha@trime Trimed Home on how to file for this govt help once it becomes available.
4/16/2020 dhomecare.c Care Services Thank you,
12:04:00 PM PIO (Email from sinha vinod om Inc Mr. Vinod Sinha
When can we start applying for the Main Street lending program?
Where do we apply?
4/16/2020 mark@lotusg
12:06:00 PM PIO (Email from patel mihir roupinc.com What documentation will be needed for approval?
We write in opposition to the exclusion of nonprofits, institutes of higher learning, and HBCUs from the Main Street New & Expanded
Loan Facilities. In short: The nonprofit sector is just as critical to economic stability and recovery as for-profit business.
Georgia alone is home to over 300 nonprofit organizations with 500 or more staff members, each doing vital work during this unprecedented
time, and each set to be left behind by this (and previous) relief efforts.
As large employers alone, they deserve federal support - but they also supply critical services at a scale that would be impossible to replace;
support an array of small businesses; and serve as economic anchors for their communities. In particular, HBCUs are critically important and
uniquely endangered, and must be included in any and all relief packages available.
4/16/2020 emily@savan Savannah We urge the Federal Reserve to make nonprofits eligible for the Main Street Loan program. The success of our nation's recovery from
12:06:00 PM PIO (Email from Salzer Emily nahchoir.org Children's Choir this unprecedented crisis depends on the success of our nation's nonprofits.
We write in opposition to the exclusion of nonprofits, institutes of higher learning, and HBCUs from the Main Street New & Expanded
Loan Facilities. In short: The nonprofit sector is just as critical to economic stability and recovery as for-profit business.
Georgia alone is home to over 300 nonprofit organizations with 500 or more staff members, each doing vital work during this unprecedented
time, and each set to be left behind by this (and previous) relief efforts.
As large employers alone, they deserve federal support - but they also supply critical services at a scale that would be impossible to replace;
support an array of small businesses; and serve as economic anchors for their communities. In particular, HBCUs are critically important and
uniquely endangered, and must be included in any and all relief packages available.
rachel@welc
4/16/2020 omingameric Welcoming We urge the Federal Reserve to make nonprofits eligible for the Main Street Loan program. The success of our nation's recovery from
12:06:00 PM PIO (Email from Peric Rachel a.org America this unprecedented crisis depends on the success of our nation's nonprofits.
We write in opposition to the exclusion of nonprofits, institutes of higher learning, and HBCUs from the Main Street New & Expanded
Loan Facilities. In short: The nonprofit sector is just as critical to economic stability and recovery as for-profit business.
Georgia alone is home to over 300 nonprofit organizations with 500 or more staff members, each doing vital work during this unprecedented
time, and each set to be left behind by this (and previous) relief efforts.
As large employers alone, they deserve federal support - but they also supply critical services at a scale that would be impossible to replace;
support an array of small businesses; and serve as economic anchors for their communities. In particular, HBCUs are critically important and
Madeline@e uniquely endangered, and must be included in any and all relief packages available.
4/16/2020 arthsharega. EarthShare We urge the Federal Reserve to make nonprofits eligible for the Main Street Loan program. The success of our nation's recovery from
12:07:00 PM PIO (Email from Reamy Madeline org Georgia this unprecedented crisis depends on the success of our nation's nonprofits.
I write in opposition to the exclusion of nonprofits, institutes of higher learning, and HBCUs from the Main Street New & Expanded Loan
Facilities. In short: The nonprofit sector is just as critical to economic stability and recovery as for-profit business.
Georgia alone is home to over 300 nonprofit organizations with 500 or more staff members, each doing vital work during this unprecedented
time, and each set to be left behind by this (and previous) relief efforts.
As large employers alone, they deserve federal support - but they also supply critical services at a scale that would be impossible to replace;
support an array of small businesses; and serve as economic anchors for their communities. In particular, HBCUs are critically important and
uniquely endangered, and must be included in any and all relief packages available.
4/16/2020 pax@august Greater Augusta I urge the Federal Reserve to make nonprofits eligible for the Main Street Loan program. The success of our nation's recovery from this
12:07:00 PM PIO (Email from Bobrow Pax aarts.com Arts Council unprecedented crisis depends on the success of our nation's nonprofits.
Page 183 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
I write in opposition to the exclusion of nonprofits, institutes of higher learning, and HBCUs from the Main Street New & Expanded Loan
Facilities. In short: The nonprofit sector is just as critical to economic stability and recovery as for-profit business.
Georgia alone is home to over 300 nonprofit organizations with 500 or more staff members, each doing vital work during this unprecedented
time, and each set to be left behind by this (and previous) relief efforts.
As large employers alone, they deserve federal support - but they also supply critical services at a scale that would be impossible to replace;
support an array of small businesses; and serve as economic anchors for their communities. In particular, HBCUs are critically important and
Personal uniquely endangered, and must be included in any and all relief packages available.
4/16/2020 Email Address We urge the Federal Reserve to make nonprofits eligible for the Main Street Loan program. The success of our nation's recovery from
12:08:00 PM PIO (Email from ZVIKAS ANDREA this unprecedented crisis depends on the success of our nation's nonprofits.
I write in opposition to the exclusion of nonprofits, institutes of higher learning, and HBCUs from the Main Street New & Expanded Loan
Facilities. In short: The nonprofit sector is just as critical to economic stability and recovery as for-profit business.
Georgia alone is home to over 300 nonprofit organizations with 500 or more staff members, each doing vital work during this unprecedented
time, and each set to be left behind by this (and previous) relief efforts.
As large employers alone, they deserve federal support - but they also supply critical services at a scale that would be impossible to replace;
support an array of small businesses; and serve as economic anchors for their communities. In particular, HBCUs are critically important and
uniquely endangered, and must be included in any and all relief packages available.
4/16/2020 kfarr@cau.ed Clark Atlanta I urge the Federal Reserve to make nonprofits eligible for the Main Street Loan program. The success of our nation's recovery from this
12:08:00 PM PIO (Email from Farr Kim u University unprecedented crisis depends on the success of our nation's nonprofits.
Loans through the Payment Protection Program should not limited to non-profits with the distinction of 501(c)(3) or 501(c)(19) and that all non-
dylan@sdbus North San Diego profits should be eligible. Without PPP assistance we hare seeing many non-profits cut hours, furlough, or worse lay off employees.As a non-
4/16/2020 inesschambe Business profit ourselves it is imperative that we are able to apply for this loan so we can continue to support the business community by connecting our
12:09:00 PM PIO (Email from Fisher Dylan r.com Chmaber members with the resources they need to survive this pandemic.
We write in opposition to the exclusion of nonprofits, institutes of higher learning, and HBCUs from the Main Street New & Expanded
Loan Facilities. In short: The nonprofit sector is just as critical to economic stability and recovery as for-profit business.
Georgia alone is home to over 300 nonprofit organizations with 500 or more staff members, each doing vital work during this unprecedented
time, and each set to be left behind by this (and previous) relief efforts.
As large employers alone, they deserve federal support - but they also supply critical services at a scale that would be impossible to replace;
support an array of small businesses; and serve as economic anchors for their communities. In particular, HBCUs are critically important and
uniquely endangered, and must be included in any and all relief packages available.
Personal
4/16/2020 We urge the Federal Reserve to make nonprofits eligible for the Main Street Loan program. The success of our nation's recovery from
Email
12:10:00 PM PIO (Email from Nowell Lee this unprecedented crisis depends on the success of our nation's nonprofits.
Address
We write in opposition to the exclusion of nonprofits, institutes of higher learning, and HBCUs from the Main Street New & Expanded
Loan Facilities. In short: The nonprofit sector is just as critical to economic stability and recovery as for-profit business.
Georgia alone is home to over 300 nonprofit organizations with 500 or more staff members, each doing vital work during this unprecedented
time, and each set to be left behind by this (and previous) relief efforts.
As large employers alone, they deserve federal support - but they also supply critical services at a scale that would be impossible to replace;
Personal support an array of small businesses; and serve as economic anchors for their communities. In particular, HBCUs are critically important and
Email Address Historic Rural uniquely endangered, and must be included in any and all relief packages available.
4/16/2020 Churches of We urge the Federal Reserve to make nonprofits eligible for the Main Street Loan program. The success of our nation's recovery from
12:11:00 PM PIO (Email from Carter Susan Georgia this unprecedented crisis depends on the success of our nation's nonprofits.
Page 184 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
I write in opposition to the exclusion of nonprofits, institutes of higher learning, and HBCUs from the Main Street New & Expanded Loan
Facilities. In short: The nonprofit sector is just as critical to economic stability and recovery as for-profit business.
Georgia alone is home to over 300 nonprofit organizations with 500 or more staff members, each doing vital work during this unprecedented
time, and each set to be left behind by this (and previous) relief efforts.
As large employers alone, they deserve federal support - but they also supply critical services at a scale that would be impossible to replace;
support an array of small businesses; and serve as economic anchors for their communities. In particular, HBCUs are critically important and
uniquely endangered, and must be included in any and all relief packages available.
Personal
4/16/2020 Email Acadia I urge the Federal Reserve to make nonprofits eligible for the Main Street Loan program. The success of our nation's recovery from this
12:11:00 PM PIO (Email from Shartar Edward Address Associates unprecedented crisis depends on the success of our nation's nonprofits.
To whom it may concern:
We would like to urge you to please expand eligibility criteria for the Federal Reserve "Main Street" Lending Facility to include non-
profits and higher education institutions. Like many businesses these entities are suffering losses from the current crisis and require additional
resources to be able to cover those losses. Many of them are ineligible for the Paycheck Protection Program.
Personal These institutions employ more than 5 million dedicated professionals/workers and educate more than 19.9 million students across the United
4/16/2020 Email Address States. Many universities are a main employer in their communities and some oversee major health systems that are responding to the
12:13:00 PM PIO (Email from Campbell James pandemic. Their ineligibility to participate may mean some of these institutions may have to close.
Sample script:
We write in opposition to the exclusion of nonprofits, institutes of higher learning, and HBCUs from the Main Street New & Expanded
Loan Facilities. In short: The nonprofit sector is just as critical to economic stability and recovery as for-profit business.
Georgia alone is home to over 300 nonprofit organizations with 500 or more staff members, each doing vital work during this unprecedented
time, and each set to be left behind by this (and previous) relief efforts.
As large employers alone, they deserve federal support - but they also supply critical services at a scale that would be impossible to replace;
support an array of small businesses; and serve as economic anchors for their communities. In particular, HBCUs are critically important and
uniquely endangered, and must be included in any and all relief packages available.
mpierrette@p
4/16/2020 aintedpink.or We urge the Federal Reserve to make nonprofits eligible for the Main Street Loan program. The success of our nation's recovery from
12:14:00 PM PIO (Email from Pierrette Manica g Painted Pink, Inc this unprecedented crisis depends on the success of our nation's nonprofits.
We write in opposition to the exclusion of nonprofits, institutes of higher learning, and HBCUs from the Main Street New & Expanded
Loan Facilities. In short: The nonprofit sector is just as critical to economic stability and recovery as for-profit business.
Georgia alone is home to over 300 nonprofit organizations with 500 or more staff members, each doing vital work during this unprecedented
time, and each set to be left behind by this (and previous) relief efforts.
As large employers alone, they deserve federal support - but they also supply critical services at a scale that would be impossible to replace;
support an array of small businesses; and serve as economic anchors for their communities. In particular, HBCUs are critically important and
teresa@side Side by Side uniquely endangered, and must be included in any and all relief packages available.
4/16/2020 bysideclubho Brain Injury We urge the Federal Reserve to make nonprofits eligible for the Main Street Loan program. The success of our nation's recovery from
12:14:00 PM PIO (Email from Little Teresa use.org Clubhouse this unprecedented crisis depends on the success of our nation's nonprofits.
Page 185 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
We write in opposition to the exclusion of nonprofits, institutes of higher learning, and HBCUs from the Main Street New & Expanded
Loan Facilities. In short: The nonprofit sector is just as critical to economic stability and recovery as for-profit business.Georgia alone is home
to over 300 nonprofit organizations with 500 or more staff members, each doing vital work during this unprecedented time, and each set to be
left behind by this (and previous) relief efforts.
As large employers alone, they deserve federal support - but they also supply critical services at a scale that would be impossible to replace;
support an array of small businesses; and serve as economic anchors for their communities. In particular, HBCUs are critically important and
uniquely endangered, and must be included in any and all relief packages available.
We urge the Federal Reserve to make nonprofits eligible for the Main Street Loan program. The success of our nation's recovery from
Kcoleman@d DeKalb this unprecedented crisis depends on the success of our nation's nonprofits.
4/16/2020 ekalbchambe Chamber of
12:15:00 PM PIO (Email from Coleman Kenneth r.org Commerce Kenneth Coleman
National Down I strongly oppose the proposal to exclude non profit organizations from the "Main Street Lending Program". These organizations
4/16/2020 david@ndscc Syndrome not only employee U.S. citizens, they often provide support for underserved, overlooked populations, often those in poverty. In our case, we
12:16:00 PM PIO (Email from Tolleson David enter.org Congress serve individuals with Down syndrome and their families. Thank you for your consideration.
I write in opposition to the exclusion of nonprofits, institutes of higher learning, and HBCUs from the Main Street New & Expanded Loan
Facilities. In short: The nonprofit sector is just as critical to economic stability and recovery as for-profit business.
Georgia alone is home to over 300 nonprofit organizations with 500 or more staff members, each doing vital work during this unprecedented
time, and each set to be left behind by this (and previous) relief efforts.
As large employers alone, they deserve federal support - but they also supply critical services at a scale that would be impossible to replace;
support an array of small businesses; and serve as economic anchors for their communities. In particular, HBCUs are critically important and
uniquely endangered, and must be included in any and all relief packages available.
Personal
Email Address
4/16/2020 I urge the Federal Reserve to make nonprofits eligible for the Main Street Loan program. The success of our nation's recovery from this
12:17:00 PM PIO (Email from Howard Mary Kay unprecedented crisis depends on the success of our nation's nonprofits.
To whom it may concern:
We would like to urge you to please expand eligibility criteria for the Federal Reserve Main Street Lending Facility to include non-profits and
higher education institutions. Like many businesses these entities are suffering losses from the current crisis and require additional
resources to be able to cover those losses. Many of them are ineligible for the Paycheck Protection Program. 
These institutions employ more than 5 million dedicated professionals/workers and educate more than 19.9 million students across the United
States. Many universities are a main employer in their communities and some oversee major health systems that are responding to the
pandemic. Their ineligibility to participate may mean some of these institutions may have to close. 
Personal Thanks
4/16/2020 Email Lindsley Juste
12:17:00 PM PIO (Email from Juste Lindsley Address
We write in opposition to the exclusion of nonprofits, institutes of higher learning, and HBCUs from the Main Street New & Expanded
Loan Facilities. In short: The nonprofit sector is just as critical to economic stability and recovery as for-profit business.
Georgia alone is home to over 300 nonprofit organizations with 500 or more staff members, each doing vital work during this unprecedented
time, and each set to be left behind by this (and previous) relief efforts.
As large employers alone, they deserve federal support - but they also supply critical services at a scale that would be impossible to replace;
support an array of small businesses; and serve as economic anchors for their communities. In particular, HBCUs are critically important and
uniquely endangered, and must be included in any and all relief packages available.
laura@peach
4/16/2020 statecollectiv Peach State We urge the Federal Reserve to make nonprofits eligible for the Main Street Loan program. The success of our nation's recovery from
12:17:00 PM PIO (Email from Moody Laura e.com Collective this unprecedented crisis depends on the success of our nation's nonprofits.
Page 186 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
joel.berman Please fund
4/16/2020 @mulesoft.co
12:18:00 PM PIO (Email from Berman Joel m Mulesoft, Inc.
As a director of a non-profit agency for victims of domestic violence, we too are being economically hurt. We have been forced to close our
second store and cancel fundraising events that are essential in maintaining services for clients. In fact, the need for services has gone up as
domestic violence is increasing. Also, many of our working poor clients have been laid off and we are struggling to help them keep a roof over
executivedire Northeast Ga. their heads and food on the table so they will not be forced to return to their abuser. We are an essential service and have not closed our
4/16/2020 ctor@negacd Council on doors to those in need of our services We are doing this with diminishing funds. Please help.
12:20:00 PM PIO (Email from Reusing Dr. Katherine v.org Domes
I write in opposition to the exclusion of nonprofits, institutes of higher learning, and HBCUs from the Main Street New & Expanded Loan
Facilities. In short: The nonprofit sector is just as critical to economic stability and recovery as for-profit business.
Georgia alone is home to over 300 nonprofit organizations with 500 or more staff members, each doing vital work during this unprecedented
time, and each set to be left behind by this (and previous) relief efforts.
As large employers alone, they deserve federal support - but they also supply critical services at a scale that would be impossible to replace;
support an array of small businesses; and serve as economic anchors for their communities. In particular, HBCUs are critically important and
uniquely endangered, and must be included in any and all relief packages available.
Personal
4/16/2020 Email Address I urge the Federal Reserve to make nonprofits eligible for the Main Street Loan program. The success of our nation's recovery from this
12:21:00 PM PIO (Email from Buoy Barbra unprecedented crisis depends on the success of our nation's nonprofits.
Personal Email THE BOX LOOKING FOR WORKING CAPITAL FINANCING
4/16/2020 Address HOUSE HOTEL
12:21:00 PM PIO (Email from WHITLEY SIMON GROUP
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
jennifer.pang hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/16/2020 aniban@sale eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
12:21:00 PM PIO (Email from Panganiban Jennifer sforce.com Salesforce
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
Personal access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
Email hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/16/2020 Address eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
12:21:00 PM PIO (Email from Gomez Tatiana
Page 187 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
To whom it may concern:
I am writing to express concern that nonprofits, nonprofit institutes of higher learning, and HBCUs will be excluded from the Main Street Loan
Program. I am a former educator at the college level and a current writer for one non-profit (Georgia Health News) and a volunteer with
several others, including a local choir. I am concerned that these important parts of our community are being left out.
Moreover, I have many friends that studied at or work at HBCUs here in Atlanta like Spelman, Morehouse, and Clark Atlanta, and I am
concerned that their important contributions and needs are being left out. For example, my friend teaches Chinese at Morehouse and his
summer program has already been canceled, representing a loss for the students, the college, and his personal finances.
All of these groups provide big benefits to our communities that can not always be captured in profit numbers and they deserve our support
just like private companies do during this time.
Personal Thank you for your consideration,
4/16/2020 Email Rebecca Grapevine
12:21:00 PM PIO (Email from Grapevine Rebecca Address Atlanta, GA
We write in opposition to the exclusion of nonprofits, institutes of higher learning, and HBCUs from the Main Street New & Expanded
Loan Facilities. In short: The nonprofit sector is just as critical to economic stability and recovery as for-profit business.
Georgia alone is home to over 300 nonprofit organizations with 500 or more staff members, each doing vital work during this unprecedented
time, and each set to be left behind by this (and previous) relief efforts.
Personal
Email Address
4/16/2020 Act 3 We urge the Federal Reserve to make nonprofits eligible for the Main Street Loan program. The success of our nation's recovery from
12:22:00 PM PIO (Email from Anderson Susan Productions, Inc this unprecedented crisis depends on the success of our nation's nonprofits.
Please support lending to Non-Profits with this program. Many are suffering dramatic reductions in charitable donations due to economic
Prophet Elias hardship. Our country would be a diminished by the loss of compassion toward groups that support emotional well-being of their supporters
4/16/2020 robin@sirakid Greek Orthodox and the broader community they serve. This includes places of worship, health care providers to lower income and arts organizations that
12:23:00 PM PIO (Email from Festival Santa Cruz es.com Church make our communities the special places they are both now and in the future.
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
awoolsey@s hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/16/2020 alesforce.co eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
12:23:00 PM PIO (Email from Woolsey Allison m
4/16/2020 Personal Gunkler & Non-Profits like the YMCA help and assist so many underprivileged kids, homeless people, cancer victims that they need to be part of this
12:24:00 PM PIO (Email from Gunkler Andrew Email Address Associates bailout!!
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
Personal Email access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
Address hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/16/2020 eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
12:24:00 PM PIO (Email from LEDUC STEPHANIE
Page 188 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
Personal hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/16/2020 Email Address eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
12:24:00 PM PIO (Email from Riley Ellen
We write in opposition to the exclusion of nonprofits, institutes of higher learning, and HBCUs from the Main Street New & Expanded
Loan Facilities. In short: The nonprofit sector is just as critical to economic stability and recovery as for-profit business.
Georgia alone is home to over 300 nonprofit organizations with 500 or more staff members, each doing vital work during this unprecedented
time, and each set to be left behind by this (and previous) relief efforts.
As large employers alone, they deserve federal support - but they also supply critical services at a scale that would be impossible to replace;
support an array of small businesses; and serve as economic anchors for their communities. In particular, HBCUs are critically important and
uniquely endangered, and must be included in any and all relief packages available.
lflusche@mu
4/16/2020 seumofdesig We urge the Federal Reserve to make nonprofits eligible for the Main Street Loan program. The success of our nation's recovery from
12:25:00 PM PIO (Email from Flusche Laura n.org MODA this unprecedented crisis depends on the success of our nation's nonprofits.
We write in opposition to the exclusion of nonprofits, institutes of higher learning, and HBCUs from the Main Street New & Expanded
Loan Facilities. In short: The nonprofit sector is just as critical to economic stability and recovery as for-profit business.
Georgia alone is home to over 300 nonprofit organizations with 500 or more staff members, each doing vital work during this unprecedented
time, and each set to be left behind by this (and previous) relief efforts.
As large employers alone, they deserve federal support - but they also supply critical services at a scale that would be impossible to replace;
support an array of small businesses; and serve as economic anchors for their communities. In particular, HBCUs are critically important and
uniquely endangered, and must be included in any and all relief packages available.
4/16/2020 exec.office@ We urge the Federal Reserve to make nonprofits eligible for the Main Street Loan program. The success of our nation's recovery from
12:25:00 PM PIO (Email from Webber Ebony manrrs.org MANRRS this unprecedented crisis depends on the success of our nation's nonprofits.
mariah@char Hello,
4/16/2020 lieschalkdust.
12:26:00 PM PIO (Email from Corbett Mariah com I cannot find any banks that are familiar with the main street lending program. We would like to apply ASAP, any guidance here?
Suggested modifications in reference to Main Street Expanded Loan Facility:
Substitute "available" for "committed" in item 5. (Both terms are universally understood terms in asset-based lending,
but they mean two very different things.)
Add the following clarifying language: "For purposes of determining the eligible loan amount (or, for purposes of this provision), an
eligible borrower's existing outstanding and available but undrawn bank debt does not include any amount that, if drawn, would cause
4/16/2020 rbarthel@par the Borrower to suffer fees, penalties, restrictions, or limitations on its operations. Lease financing obligations are also excluded."
12:29:00 PM PIO (Email from Barthel Ronald ksite.com Parksite Inc.
Personal Please do not exclude our nation'snonprofit organizations from the Main Street Loan Program
4/16/2020 Email Address
12:30:00 PM PIO (Email from De la Vega Jennifer
The draft maximum debt and leverage thresholds that borrowers must satisfy to obtain loans under the proposed Main Street Program, should
include alternative criteria for qualification. As currently drafted, businesses that exceed those debt leverage levels and any business with
zero or negative EBITDA will be unable to obtain loans under the Main Street Program, which will significantly limit the ability of this program
gregory.keou to help small and medium sized businesses. As one proposed alternative to the proposed EBITDA and leverage requirements the facility
gh@blockcha should also consider businesses who have first-lien security interests in real world physical assets that would act as collateral for the loans
4/16/2020 increditpartne above and beyond any EBITDA only criteria. Any EBITDA only requirement is suspect in this environment and there should be alternatives to
12:30:00 PM PIO (Email from keough greg rs.com BCP this criteria to qualify for the Main Street Program.
Page 189 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
We write in opposition to the exclusion of nonprofits, institutes of higher learning, and HBCUs from the Main Street New & Expanded
Loan Facilities. In short: The nonprofit sector is just as critical to economic stability and recovery as for-profit business.
Georgia alone is home to over 300 nonprofit organizations with 500 or more staff members, each doing vital work during this unprecedented
time, and each set to be left behind by this (and previous) relief efforts.
As large employers alone, they deserve federal support - but they also supply critical services at a scale that would be impossible to replace;
support an array of small businesses; and serve as economic anchors for their communities. In particular, HBCUs are critically important and
shanice@geo uniquely endangered, and must be included in any and all relief packages available.
4/16/2020 rgiaorganics. Georgia We urge the Federal Reserve to make nonprofits eligible for the Main Street Loan program. The success of our nation's recovery from
12:31:00 PM PIO (Email from Chesney Shanice org Organics this unprecedented crisis depends on the success of our nation's nonprofits.
We write in opposition to the exclusion of nonprofits, institutes of higher learning, and HBCUs from the Main Street New & Expanded
Loan Facilities. In short: The nonprofit sector is just as critical to economic stability and recovery as for-profit business.
Georgia alone is home to over 300 nonprofit organizations with 500 or more staff members, each doing vital work during this unprecedented
time, and each set to be left behind by this (and previous) relief efforts.
As large employers alone, they deserve federal support - but they also supply critical services at a scale that would be impossible to replace;
support an array of small businesses; and serve as economic anchors for their communities. In particular, HBCUs are critically important and
uniquely endangered, and must be included in any and all relief packages available.
Personal Tifton Museum
4/16/2020 Email of Arts and We urge the Federal Reserve to make nonprofits eligible for the Main Street Loan program. The success of our nation's recovery from
12:32:00 PM PIO (Email from Yost Joy Address Heritage this unprecedented crisis depends on the success of our nation's nonprofits.
We write in opposition to the exclusion of nonprofits, institutes of higher learning, and HBCUs from the Main Street New & Expanded
Loan Facilities. In short: The nonprofit sector is just as critical to economic stability and recovery as for-profit business.
Georgia alone is home to over 300 nonprofit organizations with 500 or more staff members, each doing vital work during this unprecedented
time, and each set to be left behind by this (and previous) relief efforts.
As large employers alone, they deserve federal support - but they also supply critical services at a scale that would be impossible to replace;
support an array of small businesses; and serve as economic anchors for their communities. In particular, HBCUs are critically important and
uniquely endangered and must be included in any and all relief packages available.
ebest@muse
4/16/2020 umofdesign.o Museum of We urge the Federal Reserve to make nonprofits eligible for the Main Street Loan program. The success of our nation's recovery from
12:32:00 PM PIO (Email from Best Elena rg Design Atlanta this unprecedented crisis depends on the success of our nation's nonprofits.
To Whom It May Concern,
Expressing my concern that the nations non-profits are under consideration to be excluded from the federal financial support. I am strongly
against their being excluding from federal funding at this critical juncture in our nation's history while the COVID-19 Pandemic is now at
its peak.
Mel Stowers
4/16/2020 mstowers@st President of the Board,
12:32:00 PM PIO (Email from Stowers Melvin owersco.com Mountain Top Boys Home, Inc.
Thank you to the Federal Reserve for working hard to deliver relief to non-profits and businesses all over the country. As we all fight the
coronavirus, it is important the businesses and organizations that are the lifeblood of this dynamic economy have the resources to make it
through this unprecedented pandemic. No set of organizations are more important than independent colleges and universities, especially in
small states and rural communities. In Kentucky, independent colleges account for over 56,000 students, 7,000 employees, and over $700
million dollars in economic activity. Right now, it is unclear whether or not independent higher education institutions can apply for this
meredith.bru Centre College desperately needed financial lifeline. My comment is to explicitly open this loan up for independent colleges and universities. They are non-
4/16/2020 ner@centre.e & Greater profits and need the resources to remain an affordable and accessible postsecondary opportunity for all students, particularly those from a low
12:32:00 PM PIO (Email from Bruner Meredith du Kentucky HERC socioeconomic background.
Page 190 of 363
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Main Street Lending Program Comments
The Alzheimer's Association respectfully requests that any facility the Reserve Bank creates expressly include 501(c)(3) nonprofits and
be highly concessionary, preferably 0% interest. Many are serving at-risk populations during the COVID-19 crisis. The Reserve Bank should
include these eligibility changes in the Main Street Lending Program and Treasury should consider for nonprofits under Sec. 4003 for mid-size
loans:
· While we strongly prefer 0% interest since nonprofits are structurally different than for-profits and on the front lines of the crisis, we at
least would recommend a 0.50% interest rate (50 basis points) for 501(c)(3) charitable nonprofits at a 5-year amortization
· Prioritize 501(c)(3) charitable nonprofits responding to COVID-19 relief efforts
· Payments not be due until two years after a direct loan is made
· Employee retention provisions begin on the date loan funding is received by the borrower
· "Workforce" should be defined as full-time employees or full-time equivalents for workforce restoration and retention
provisions
· Nonprofits make good faith certification that they require funding due to the pandemic and that they will make reasonable efforts to
maintain payroll during the term of the loan
Economic recovery will take years and nonprofits will need more time to begin repayment, especially those reliant on charitable donations,
4/16/2020 lthornhill@alz- Alzheimer's which are also likely to be negatively affected for months or years to come.
12:33:00 PM PIO (Email from Thornhill Laura aim.org Association
We write in opposition to the exclusion of nonprofits, institutes of higher learning, and HBCUs from the Main Street New & Expanded
Loan Facilities. In short: The nonprofit sector is just as critical to economic stability and recovery as for-profit business.
Georgia alone is home to over 300 nonprofit organizations with 500 or more staff members, each doing vital work during this unprecedented
time, and each set to be left behind by this (and previous) relief efforts.
As large employers alone, they deserve federal support - but they also supply critical services at a scale that would be impossible to replace;
support an array of small businesses; and serve as economic anchors for their communities. In particular, HBCUs are critically important and
bruce.mcevo uniquely endangered, and must be included in any and all relief packages available.
4/16/2020 y@perkinswill MODA Board We urge the Federal Reserve to make nonprofits eligible for the Main Street Loan program. The success of our nation's recovery from
12:34:00 PM PIO (Email from McEvoy Bruce .com Chair this unprecedented crisis depends on the success of our nation's nonprofits.
4/16/2020 Personal Please help fund Momentum! Our friends and family are working their hearts out to help their clients during this pandemic, while others
12:35:00 PM PIO (Email from Holmquist Lin Email Address shelter at home. Funding is absolutely necessary!!!
I write in opposition to the exclusion of nonprofits, institutes of higher learning, and HBCUs from the Main Street New & Expanded Loan
Facilities. In short: The nonprofit sector is just as critical to economic stability and recovery as for-profit business.
Georgia alone is home to over 300 nonprofit organizations with 500 or more staff members, each doing vital work during this unprecedented
time, and each set to be left behind by this (and previous) relief efforts.
As large employers alone, they deserve federal support - but they also supply critical services at a scale that would be impossible to replace;
support an array of small businesses; and serve as economic anchors for their communities. As an African American who works in a nonprofit
these organizations are integral to my community as well as the broader community. Furthermore, these institutions and organizations are
apart of all our lives in many different aspects. By neglecting these organizations you are INTENTIONALLY ignoring the voices and lives of so
many individuals who find support in these institutions.
bbosley@mu
4/16/2020 seumofdesig We urge the Federal Reserve to make nonprofits eligible for the Main Street Loan program. The success of our nation's recovery from
12:38:00 PM PIO (Email from Bosley Blaire n.org MODA this unprecedented crisis depends on the success of our nation's nonprofits.
Please include non-profits in the Main Street Lending Program. NGOs should be included in any economic relief package because as an
international NGO, Food for the Hungry is dedicated to putting ourselves on the frontline of fighting COVID-19 in 20 countries around the
globe. Food for the Hungry provides food to food insecure and vulnerable populations, as well as global health interventions that will help
curtail the spread of COVID-19. Due to economic hardship of our donors because of COVID-19, many of our donors are not able to provide
financial contributions to pay for Food for the Hungry's operations. Assistance will keep Food for the Hungry's staff employed and
4/16/2020 evanzyl@fh.o Food for the our operations running, which will help millions around the globe receive the food and global health services they need. Please include non-
12:38:00 PM PIO (Email from van Zyl Elizabeth rg Hungry profits in the Main Street Lending Program.
Page 191 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
I write in opposition to the exclusion of nonprofits, institutes of higher learning, and HBCUs from the Main Street New & Expanded Loan
Facilities. In short: The nonprofit sector is just as critical to economic stability and recovery as for-profit business.
Georgia alone is home to over 300 nonprofit organizations with 500 or more staff members, each doing vital work during this unprecedented
time, and each set to be left behind by this (and previous) relief efforts.
As large employers alone, they deserve federal support - but they also supply critical services at a scale that would be impossible to replace;
support an array of small businesses; and serve as economic anchors for their communities. In particular, HBCUs are critically important and
uniquely endangered, and must be included in any and all relief packages available.
Info@greaterf
4/16/2020 aithrestore.co Greater Faith I urge the Federal Reserve to make nonprofits eligible for the Main Street Loan program. The success of our nation's recovery from this
12:39:00 PM PIO (Email from Girtmon Paisha m Restoration unprecedented crisis depends on the success of our nation's nonprofits.
I write in opposition to the exclusion of nonprofits, institutes of higher learning, and HBCUs from the Main Street New & Expanded Loan
Facilities. In short: The nonprofit sector is just as critical to economic stability and recovery as for-profit business.
Georgia alone is home to over 300 nonprofit organizations with 500 or more staff members, each doing vital work during this unprecedented
time, and each set to be left behind by this (and previous) relief efforts.
As large employers alone, they deserve federal support - but they also supply critical services at a scale that would be impossible to replace;
support an array of small businesses; and serve as economic anchors for their communities. In particular, HBCUs are critically important and
uniquely endangered, and must be included in any and all relief packages available.
4/16/2020 ellen@warms Warm Springs We urge the Federal Reserve to make nonprofits eligible for the Main Street Loan program. The success of our nation's recovery from
12:40:00 PM PIO (Email from McDuffie Mary Ellen pringsga.com Village Mall this unprecedented crisis depends on the success of our nation's nonprofits.
I strongly oppose the exclusion of nonprofits, institutes of higher learning, and HBCUs from the Main Street New & Expanded Loan
Facilities. The nonprofit sector is just as critical to economic stability and recovery as for-profit business.
We have been acting quickly and diligently to readjust to continue supplying critical services to our community during this time, attempting to
provide services to children, families, and community members during this difficult time from education to personal development to community
building, all of which are crucial to survival and persistence in this time.
We have always been commited to the bolstering of our community and carry that through this time, despite the strain we too are facing
financially. It would be a mistake if the work of these intstitutions is not recognized and supported, and a bigger one if the important work of
nonprofits, educational institutions, and especially HBCUs are forced to cease during this time and beyond as a result.
Personal We are working tirelessly to continue to support our community, which also happen to be your constituents. Please consider revisiting the
4/16/2020 Email Address Museum of inclusion of our organizations in the Main Street Loan Program.
12:42:00 PM PIO (Email from Klucik Veronica Design Atlanta
We write in opposition to the exclusion of nonprofits, institutes of higher learning, and HBCUs from the Main Street New & Expanded
Loan Facilities. In short: The nonprofit sector is just as critical to economic stability and recovery as for-profit business.
As large employers alone, they deserve federal support - but they also supply critical services at a scale that would be impossible to replace;
support an array of small businesses; and serve as economic anchors for their communities.
jroland@foun
4/16/2020 dryministries. We urge the Federal Reserve to make nonprofits eligible for the Main Street Loan program. The success of our nation's recovery from
12:44:00 PM PIO (Email from Roland John com The Foundry this unprecedented crisis depends on the success of our nation's nonprofits.
Page 192 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
On behalf of Pacific Clinics, I am writing to request the inclusion of non-profit organizations in the Main Street Lending Program. As a leading
nonprofit mental health provider serving over 22,000 individuals of all ages, Pacific Clinics recognizes the importance of meeting the growing
demand for treatment and services. Likewise, we offer meaningful employment to over 1,200 people. These individuals offer healthcare
services and stability to the communities we serve.
As currently written, the term sheet for the Main Street New Loan Facility (MNSLF) and the Main Street Expanded Loan Facility (MNSELF) do
not expressly include a provision of eligibility for non-profit entities.
mgamino@p The inclusion of non-profit organizations helps to support the health and economic viability of the nation and ensures that such organizations
4/16/2020 acificclinics.o have access to resources to continue to meet needs without obstruction. Thank you for the opportunity to provide comments on the Main
12:44:00 PM PIO (Email from Balla James rg Pacific Clinics Street New Loan Facility.
On behalf of my Board of Directors and staff, I write in opposition to the exclusion of nonprofits, institutes of higher learning, and HBCUs from
the Main Street New & Expanded Loan Facilities. The nonprofit sector is just as critical to economic stability and recovery as for-profit
business. In fact, many of us are working twice as hard now to assist small businesses with loans, displaced employees with unemployment
claims, county officials with communications to members and citizens, schools with additional activities for students, hospitals with locating
needed supplies and so much more. We are a very important part of the recovery process and yet, we are being overlooked at every level for
necessary funding.
Georgia alone is home to over 300 nonprofit organizations with 500 or more staff members, each doing vital work during this unprecedented
time, and each set to be left behind by this (and previous) relief efforts.
Towns County
4/16/2020 candacelee@ Chamber of We urge the Federal Reserve to make nonprofits eligible for the Main Street Loan program. The success of our nation's recovery from
12:45:00 PM PIO (Email from Lee Candace brmemc.net Commerce this unprecedented crisis depends on the success of our nation's nonprofits.
ChargePoint is the world's largest electric vehicle charging network. ChargePoint designs, develops, and sells EV charging stations to
our customers, who own and operate chargers on their premises. We manufacture charging stations in California and partner with small
businesses around the country to deploy these stations.
In the term sheets for the Main Street New Loan Facility and Main Street Expanded Loan Facility announced on April 9, 2020, the Federal
Reserve included a leverage test to calculate the maximum loan size (4x or 6x 2019 EBITDA, respectively).
For many startups, which drive innovation and growth in our country, this requirement could be difficult to meet, shutting them out of
temporary liquidity that could assist them to get through the pandemic-driven downturn and keep contributing to the economy.
We respectfully urge the addition of an alternative prong to the leverage test in calculating maximum loan size (i.e., an eligible borrower could
either meet the leverage test, or an alternative test consistent with the goals of the leverage test).
Example: If a third party (e.g., a venture capital firm) provides additional funding to the eligible borrower, a percentage of that additional
kevin.miller@ funding (e.g., 25%) could serve as maximum loan size. If a third party is confident enough to provide funding to the borrower, the Federal
4/16/2020 chargepoint.c ChargePoint, Reserve should be willing to match a certain % of that funding in the form of an eligible loan provide by an eligible lender.
12:46:00 PM PIO (Email from Miller Kevin George om Inc.
We write in opposition to the exclusion of nonprofits, institutes of higher learning, and HBCUs from the Main Street New & Expanded
Loan Facilities. In short: The nonprofit sector is just as critical to economic stability and recovery as for-profit business.
Georgia alone is home to over 300 nonprofit organizations with 500 or more staff members, each doing vital work during this unprecedented
time, and each set to be left behind by this (and previous) relief efforts.
As large employers alone, they deserve federal support - but they also supply critical services at a scale that would be impossible to replace;
support an array of small businesses; and serve as economic anchors for their communities. In particular, HBCUs are critically important and
uniquely endangered, and must be included in any and all relief packages available.
laura@susan
4/16/2020 nahdarrow.co We urge the Federal Reserve to make nonprofits eligible for the Main Street Loan program. The success of our nation's recovery from
12:46:00 PM PIO (Email from Hennighausen Laura m this unprecedented crisis depends on the success of our nation's nonprofits.
Page 193 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
We write in opposition to the exclusion of nonprofits, institutes of higher learning, and HBCUs from the Main Street New & Expanded
Loan Facilities. In short: The nonprofit sector is just as critical to economic stability and recovery as for-profit business.
Georgia alone is home to over 300 nonprofit organizations with 500 or more staff members, each doing vital work during this unprecedented
time, and each set to be left behind by this (and previous) relief efforts.
As large employers alone, they deserve federal support - but they also supply critical services at a scale that would be impossible to replace;
support an array of small businesses; and serve as economic anchors for their communities. In particular, HBCUs are critically important and
uniquely endangered, and must be included in any and all relief packages available.
Personal
4/16/2020 Email We urge the Federal Reserve to make nonprofits eligible for the Main Street Loan program. The success of our nation's recovery from
12:47:00 PM PIO (Email from Hall Lucy Address this unprecedented crisis depends on the success of our nation's nonprofits.
I write on behalf of the Southeast Fiber Arts Alliance and in opposition to the exclusion of nonprofits, institutes of higher learning, and HBCUs
from the Main Street New & Expanded Loan Facilities. In short: The nonprofit sector is just as critical to economic stability and recovery
as for-profit business.
Georgia alone is home to over 300 nonprofit organizations with 500 or more staff members, each doing vital work during this unprecedented
time, and each set to be left behind by this (and previous) relief efforts.
As large employers alone, they deserve federal support - but they also supply critical services at a scale that would be impossible to replace;
support an array of small businesses; and serve as economic anchors for their communities. In particular, HBCUs are critically important and
uniquely endangered, and must be included in any and all relief packages available.
We urge the Federal Reserve to make nonprofits eligible for the Main Street Loan program. The success of our nation's recovery from
this unprecedented crisis depends on the success of our nation's nonprofits.
Sincerely,
Suzi Gough
Executive Director
Southeast Fiber Arts Alliance
PS Arts nonprofits without staff also have rent, utility payments, and other bills to pay while our doors are shut. We do not qualify for the PPP
4/16/2020 info@fiberart or the $10,000 EIDL grant because we don't have employees and we are hurting, too. Big or small, nonprofits need your support.
12:47:00 PM PIO (Email from Gough Suzi salliance.org SEFAA Center
Question from City official:
When Federal Reserve uses the term "Main Street businesses" what small business are being targeted in the program that was
recently by the Federal Reserve to support Main Streets? Is there a process in place to help Main Street "small" businesses that
Federal Reserve may need loans smaller then the minimum loan amount listed. If not, is the Federal Reserve creating an opportunity to address the needs of
4/16/2020 peter.dolkart Bank of businesses with less than 20 employees, located in Main Street districts and/or community based businesses?
12:49:00 PM PIO (Email from Dolkart Peter @rich.frb.org Richmond
Page 194 of 363
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Main Street Lending Program Comments
On behalf of Southern California Grantmakers, we respectfully request that the Federal Reserves "Main Street Lending Programs"
include 501(c)(3) nonprofit organizations as eligible applicants.
Charitable organizations are a part of the frontline responders providing healthcare, food, shelter, and other critical services to those in need
in our communities. Absent opportunities to access capital, America's charitable nonprofits and the people our nonprofit partners serve
will face a precipitous decline in mission services at a time when our efforts are needed like never before by our communities.
Nonprofits power California's economy, accounting for more than 1.2 million jobs - the fourth largest employer in the state. According to
Causes Count, which analyzes the economic impact of the sector, nonprofits generate about 15 percent or one-sixth of California's
Gross State Product.
Philanthropy has responded to this crisis. Our membership of foundations, corporate giving programs, and philanthropists have given with
urgency. However, private philanthropy alone cannot address this issue - we simply lack the size, scope, and scale of the Federal Reserve.
Southern California Grantmakers has more than 325 foundation members across the region. We serve as the forum for the exchange of
ideas, improve cooperation among funders, and increase our knowledge of community problems to tackle critical issues and achieve shared
seyron@soca Southern goals.
4/16/2020 lgrantmakers. California
12:50:00 PM PIO (Email from Foo Seyron org Grantmakers
Live2Create We write in opposition to the exclusion of nonprofits, institutes of higher learning, and HBCUs from the Main Street New & Expanded
4/16/2020 iam@live2cre Foundation Loan Facilities. In short: The nonprofit sector is just as critical to economic stability and recovery as for-profit business.
12:51:00 PM PIO (Email from McIntosh Amy ate.org Network
To whom it may concern,
I'm writing in opposition to the exclusion of nonprofits, institutes of higher learning, and HBCUs from the Main Street New &
Expanded Loan Facilities. In short: The nonprofit sector is just as critical to economic stability and recovery as for-profit business.
Georgia alone is home to over 300 nonprofit organizations with 500 or more staff members, each doing vital work during this unprecedented
time, and each set to be left behind by this (and previous) relief efforts.
As large employers alone, they deserve federal support - but they also supply critical services at a scale that would be impossible to replace;
support an array of small businesses; and serve as economic anchors for their communities. In particular, HBCUs are critically important and
uniquely endangered, and must be included in any and all relief packages available.
We urge the Federal Reserve to make nonprofits eligible for the Main Street Loan program. The success of our nation's recovery from
this unprecedented crisis depends on the success of our nation's nonprofits.
Personal
4/16/2020 Email Please reconsider and include nonprofits! Even via online curriculum, they provide sanity and value that no other organization can.
12:53:00 PM PIO (Email from Johnson Kasema Address MODA
We write in opposition to the exclusion of nonprofits, institutes of higher learning, and HBCUs from the Main Street New & Expanded
Loan Facilities. In short: The nonprofit sector is just as critical to economic stability and recovery as for-profit business.
Georgia alone is home to over 300 nonprofit organizations with 500 or more staff members, each doing vital work during this unprecedented
time, and each set to be left behind by this (and previous) relief efforts.
As large employers alone, they deserve federal support - but they also supply critical services at a scale that would be impossible to replace;
support an array of small businesses; and serve as economic anchors for their communities. In particular, HBCUs are critically important and
uniquely endangered, and must be included in any and all relief packages available.
Personal
4/16/2020 Email South Georgia We urge the Federal Reserve to make nonprofits eligible for the Main Street Loan program. The success of our nation's recovery from
12:53:00 PM PIO (Email from Ewing Anna Address Ballet this unprecedented crisis depends on the success of our nation's nonprofits.
Page 195 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
As an executive Director of a non profit that employees 20 staff and serves 15,000 youth per year, I write in opposition to the exclusion of
nonprofits, institutes of higher learning, and HBCUs from the Main Street New & Expanded Loan Facilities. In short: we, the non profit
sector, is just as critical to economic stability and recovery as for-profit business.
Georgia alone is home to over 300 nonprofit organizations with 500 or more staff members, each doing vital work during this unprecedented
time, and each set to be left behind by this (and previous) relief efforts.
4/16/2020 jason@steam Community We urge the Federal Reserve to make nonprofits eligible for the Main Street Loan program. The success of our nation's recovery from
12:53:00 PM PIO (Email from Martin Jason truck.org Guilds this unprecedented crisis depends on the success of our nation's nonprofits.
We write in opposition to the exclusion of nonprofits, institutes of higher learning, and HBCUs from the Main Street New & Expanded
Loan Facilities. In short: The nonprofit sector is just as critical to economic stability and recovery as for-profit business.
Georgia alone is home to over 300 nonprofit organizations with 500 or more staff members, each doing vital work during this unprecedented
time, and each set to be left behind by this (and previous) relief efforts.
As large employers alone, they deserve federal support - but they also supply critical services at a scale that would be impossible to replace;
support an array of small businesses; and serve as economic anchors for their communities. In particular, HBCUs are critically important and
uniquely endangered, and must be included in any and all relief packages available.
maria@raisin
4/16/2020 gexpectation Raising We urge the Federal Reserve to make nonprofits eligible for the Main Street Loan program. The success of our nation's recovery from
12:54:00 PM PIO (Email from Armstrong Maria s.org Expectations Inc. this unprecedented crisis depends on the success of our nation's nonprofits.
Please make sure non-profit employers like the Dallas YMCA with employees over 500 are able to access the loans and are considered for
loan forgiveness.
Prior to the Covid-19 crisis, the Dallas Y employed 2400 staff (90% of whom have been furloughed) serving more than 35,000 thru 22
branches in our community. We were unable to apply for the PPP due to our size. Without access to support, our Y will not be able to
resume operations or retain staff as we knew it before the pandemic.
4/16/2020 Don_bowles
12:55:00 PM PIO (Email from Bowles Donald @mhbt.com MHBT/MMA Our services are needed now more than ever in our 135 years of serving our community! Thank you.
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/16/2020 bob@lessingf Momentum eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
12:56:00 PM PIO (Email from Lessing Robert amily.com Mental Health
We write in opposition to the exclusion of nonprofits, institutes of higher learning, and HBCUs from the Main Street New & Expanded
Loan Facilities. In short: The nonprofit sector is just as critical to economic stability and recovery as for-profit business.
Georgia alone is home to over 300 nonprofit organizations with 500 or more staff members, each doing vital work during this unprecedented
time, and each set to be left behind by this (and previous) relief efforts.
As large employers alone, they deserve federal support - but they also supply critical services at a scale that would be impossible to replace;
support an array of small businesses; and serve as economic anchors for their communities. In particular, HBCUs are critically important and
uniquely endangered, and must be included in any and all relief packages available.
4/16/2020 Erick@histori Historic Augusta We urge the Federal Reserve to make nonprofits eligible for the Main Street Loan program. The success of our nation's recovery from
12:56:00 PM PIO (Email from Montgomery Erick caugusta.org Inc this unprecedented crisis depends on the success of our nation's nonprofits.
Page 196 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. I am
affiliated with a nonprofit behavioral health organization serving children and families in California and I am writing to advocate for restoration
of the applicability of the Main Street Lending Program to nonprofits with more than 500 employees. Without increased access to lending
programs intended to sustain payroll and retain employees, many mental health and substance use service providers are at risk, a
circumstance that could leave hundreds of thousands without access to appropriate and desperately needed treatment and care. A lack of
access to adequate mental and substance use care will lead many Americans to utilization of emergency services, over-crowding community
lisa@thegree hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/16/2020 nwichoffice.c eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
12:56:00 PM PIO (Email from Davies Lisa om
We write in opposition to the exclusion of nonprofits, institutes of higher learning, and HBCUs from the Main Street New & Expanded
Loan Facilities. In short: The nonprofit sector is just as critical to economic stability and recovery as for-profit business.
Georgia alone is home to over 300 nonprofit organizations with 500 or more staff members, each doing vital work during this unprecedented
time, and each set to be left behind by this (and previous) relief efforts.
As large employers alone, they deserve federal support - but they also supply critical services at a scale that would be impossible to replace;
support an array of small businesses; and serve as economic anchors for their communities. In particular, HBCUs are critically important and
uniquely endangered, and must be included in any and all relief packages available.
Personal
4/16/2020 Email Address We urge the Federal Reserve to make nonprofits eligible for the Main Street Loan program. The success of our nation's recovery from
12:56:00 PM PIO (Email from Beskind Marcie this unprecedented crisis depends on the success of our nation's nonprofits.
As the second largest employer in a rural county of less than 20,000 poulation, the economic impact to our community and to the university as
a result of going online has had a significant negative impact. Just to name a few of the costs and lost revenues: the return of room and board
revenues to residential students, lost summer revenues from the cancellation of camps and conferences, revenue lost in the local community
for nearly 2,000 students who are no longer here, the decrease in summer enrollment not to mention the lost productivity for university
employees who are sheltered at home yet still receive paychecks. And looking toward the fall semester the impact is yet to be determined for
revenues from empty or less that full resident halls and for enrollment in classes on campus (if such will be possible). As a further comment,
Workstudy is classified as financial aid for eligible students as determined by their "Estimated Family Contribution" (EFC).
Workstudy positions cannot be used to replace employees. Workstudy is not subject to payroll taxes. Workstudy is assigned on an academic
year by year basis. There is no guarantee of work. Loans under the CARES Act cannot be used to pay Workstudy since most Workstudy is
4/16/2020 mchambers Carson-Newman already partially funded by other federal funds. Therefore, Workstudy should not be included in the count of employees.
12:56:00 PM PIO (Email from Chambers Martha @cn.edu University
I am writing in opposition to the exclusion of nonprofits, institutes of higher learning, and HBCUs from the Main Street New & Expanded
Loan Facilities. In short: The nonprofit sector is just as critical to economic stability and recovery as for-profit business.
Georgia alone is home to over 300 nonprofit organizations with 500 or more staff members, each doing vital work during this unprecedented
time, and each set to be left behind by this (and previous) relief efforts.
As large employers alone, they deserve federal support - but they also supply critical services at a scale that would be impossible to replace;
support an array of small businesses; and serve as economic anchors for their communities. In particular, HBCUs are critically important and
uniquely endangered, and must be included in any and all relief packages available.
4/16/2020 mary@mpres I urge the Federal Reserve to make nonprofits eligible for the Main Street Loan program. The success of our nation's recovery from this
12:58:00 PM PIO (Email from Sorrel Mary sionspr.com Act3 Productions unprecedented crisis depends on the success of our nation's nonprofits.
Page 197 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
I write in opposition to the exclusion of nonprofits, institutes of higher learning, and HBCUs from the Main Street New & Expanded Loan
Facilities. In short: The nonprofit sector is just as critical to economic stability and recovery as for-profit business.
Georgia alone is home to over 300 nonprofit organizations with 500 or more staff members, each doing vital work during this unprecedented
time, and each set to be left behind by this (and previous) relief efforts.
As large employers alone, they deserve federal support - but they also supply critical services at a scale that would be impossible to replace;
support an array of small businesses; and serve as economic anchors for their communities. In particular, HBCUs are critically important and
uniquely endangered, and must be included in any and all relief packages available.
4/16/2020 Julian.ivey@ Beulah Heights We urge the Federal Reserve to make nonprofits eligible for the Main Street Loan program. The success of our nation's recovery from
12:59:00 PM PIO (Email from Ivey Julian beulah.edu University this unprecedented crisis depends on the success of our nation's nonprofits.
I am a volunteer Board member for the Northeast Branch of the YMCA of Greater Louisville.
Please open PPP or a similar program to the larger non-profits, such as the YMCA. Our Y's employ 2100 people and 95% are
furloughed right now due to COVID-19 and our Governor's orders. The YMCA is vital to our community, providing services to our most
vulnerable populations. Our Y's continue to provide service through this time, such as childcare for first responders and medical
Personal personnel. We are also providing Safe Place services to at risk teens. The crisis has caused up to $3.5 million dollar losses to our Y system
4/16/2020 Email Address EACH MONTH WE ARE CLOSED. If we cannot be open, we need help. Please consider helping those that help our neighbors and make
12:59:00 PM PIO (Email from Ross Elizabeth sure larger non-profits are included in the PPP or in similar programs.
On behalf of Mass Audubon, we urge you to ensure that the Main Street Lending Program and any subsequent mid-size loan programs are
fully available to nonprofits, including those with 500 employees or more.
The CARES Act made two loan programs (EIDL, PPP) available to nonprofits with 500 employees or fewer. Those provide important relief but
they are not available to nonprofits that employ more than 500 people. This is a significant barrier to relief for nonprofit institutions with larger
workforces administering critical programs and services.
As Treasury and the Fed work to implement §4003(c)(3)(D), providing financing to lenders to make loans to nonprofits and other
employers with up to 10,000 employees, we urge you to:
· Include an interest rate of 0.50% (50 basis points) for 501(c)(3) charitable nonprofits at a 5 year amortization;
· Provide priority to 501(c)(3) charitable nonprofits and require lenders to make a proportionate number and value of loans to
nonprofits to prevent the crowding out that is being seen in the Paycheck Protection Program;
· Set a date certain for when employee retention provisions should begin; and
· Set forth that payments shall not be due until two years after a direct loan is made.
Thank you for your consideration.
Sincerely,
mcusher@m Mike Cusher
4/16/2020 1:02:00 assaudubon. Legislative Director
PM PIO (Email from Cusher Michael org Mass Audubon Mass Audubon
The YMCA of KC provides childcare and other services to promote health, enhance student learning, and promote leadership in KC. Our
business model is one where we serve 20,000 members through several facilities which are currently closed. Financially our objective is to
break even after debt service. We do not have a profit motive as our objective is to build community and make our services as broadly
available to our community as possible. For many of our members, this means that they utilize our services on scholarship. Due to the
number of employees that work at our facilities, we were not able to apply for the Paycheck Protection Program. We also do not meet the
underwriting criteria of the Mainstreet Lending Facility due to our existing leverage and financial objective noted above. Our appeal is that our
government consider programs that provide loan forgiveness for nonprofits, similar to the PPP. Without additional resources, many nonprofit
organizations will be lost to their communities, including YMCAs in general and our Y. Our communities need nonprofits like the Y now more
than ever. Despite our facilities being closed, the Y has partnered with our community to provide essential child care services for healthcare
workers, first responders and other essential workers. Without financial support, our Y will close and will not be able to continue to provide
4/16/2020 1:04:00 john.passanis Ernst & childcare or other programs that strengthen our community.
PM PIO (Email from Passanisi John i@ey.com Young
Page 198 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
As the Federal Reserve and Treasury Department work to get the MSLP up and running, the Chamber makes the following
recommendations:
1)Lenders should be able to provide flexibility on loan maturities for a period of up to six years, and the minimum loan size should be
reduced significantly.
2)The employee and revenue thresholds used to determine eligible borrowers should be modified so that certain businesses are not
arbitrarily excluded. Eligible lenders should additionally include U.S. branches or affiliates of non-U.S. institutions. Greater clarification is
needed to determine what constitutes "reasonable efforts" by borrowers to maintain payroll during the life of the loan.
3)Since many borrowers - particularly emerging companies and those in the lower middle market - do not calculate earnings before interest,
taxes, depreciation, and amortization (EBITDA) based on generally accepted accounting principles (GAAP), borrowers should be allowed to
use "adjusted" EBITDA when determining their eligibility under the MSLP leverage thresholds.
4)Businesses that participate in the MSLP should not be automatically prohibited from paying dividends to shareholders or engaging in stock
repurchases. The terms of the MSLP should also reflect certain investment structures - such as real estate investment trusts (REITs) and
tquaadman@ regulated investment companies - that are obligated to make distributions to shareholders in order to maintain their regulatory status.
4/16/2020 1:04:00 uschamber.c US Chamber of
PM PIO (Email from Quaadman Tom om Commerce
We write in opposition to the exclusion of nonprofits, institutes of higher learning, and HBCUs from the Main Street New & Expanded
Loan Facilities. In short: The nonprofit sector is just as critical to economic stability and recovery as for-profit business.
Georgia alone is home to over 300 nonprofit organizations with 500 or more staff members, each doing vital work during this unprecedented
time, and each set to be left behind by this (and previous) relief efforts.
As large employers alone, they deserve federal support - but they also supply critical services at a scale that would be impossible to replace;
support an array of small businesses; and serve as economic anchors for their communities. In particular, HBCUs are critically important and
Personal uniquely endangered, and must be included in any and all relief packages available.
4/16/2020 1:04:00 Email Address We urge the Federal Reserve to make nonprofits eligible for the Main Street Loan program. The success of our nation's recovery from
PM PIO (Email from Else Lee Ann Mrs. this unprecedented crisis depends on the success of our nation's nonprofits.
I write in opposition to the exclusion of nonprofits, institutes of higher learning, and HBCUs from the Main Street New & Expanded Loan
Facilities. In short: The nonprofit sector is just as critical to economic stability and recovery as for-profit business. The services provided to the
public are invaluable.
Georgia alone is home to over 300 nonprofit organizations with 500 or more staff members, each doing vital work during this unprecedented
time, and each set to be left behind by this (and previous) relief efforts.
As large employers alone, they deserve federal support - but they also supply critical services at a scale that would be impossible to replace;
support an array of small businesses; and serve as economic anchors for their communities. In particular, HBCUs are critically important and
uniquely endangered, and must be included in any and all relief packages available.
4/16/2020 1:04:00 cking@gwinn Gwinnett County We urge the Federal Reserve to make nonprofits eligible for the Main Street Loan program. The success of our nation's recovery from
PM PIO (Email from King Cynthia ettpl.org Public Library this unprecedented crisis depends on the success of our nation's nonprofits.
I am writing to encourage the expansion of the CARES Act/Main Street Lending facility to include nonprofit organizations. Nonprofit
organizations provide services to millions of people in communities around the country. Not only do they provide needed services, they also
employ a significant portion of the American workforce. According to a 2019 report by the Center for Civil Society Studies at Johns Hopkins
University, "nonprofits account for roughly one in 10 jobs in the U.S. private workforce, with total employees numbering 12.3 million in
2016." Since many of these organizations may not be otherwise eligible for the Paycheck Protection Program, it is especially important
these organizations have other sources of support. We cannot make a significant portion of employers (and their employees) ineligible to
Personal
4/16/2020 1:05:00 receive aid, just because they are not "for profit" businesses. I urge you to consider expanding the eligibility of the Main Street
Email Address
PM PIO (Email from Lorick Connie Lending facility to include nonprofit organizations.
Page 199 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
5)Given the ongoing transition from the London Interbank Offered Rate (LIBOR) to the Secured Overnight Financing Rate (SOFR), the
MSLP should initially utilize LIBOR with a "fallback" approach to SOFR, which is currently a common practice in the syndicated
loan market.
6)To facilitate quick loan disbursement, lenders should be able to rely on representations from borrowers regarding their eligibility, similar to
requirements under the Paycheck Protection Program (PPP).
7)Eligible loans under the MSELF should be expanded so borrowers that do not have term loans are included.
8)The Federal Reserve and Treasury Department should amend the terms of the MSLP so that during the duration of the program, eligible
tquaadman@ lenders would retain their respective category with respect to regulatory tailoring.
4/16/2020 1:05:00 uschamber.c US Chamber of
PM PIO (Email from Quaadman Tom om Commerce 9)Clarity should be provided regarding material terms of the participation agreement for the Special Purpose Vehicle.
I am writing in opposition to the exclusion of nonprofits, institutes of higher learning, and HBCUs from the Main Street New & Expanded
Loan Facilities. In short: The nonprofit sector is just as critical to economic stability and recovery as for-profit business.
Georgia alone is home to over 300 nonprofit organizations with 500 or more staff members, each doing vital work during this unprecedented
time, and each set to be left behind by this (and previous) relief efforts.
As large employers alone, they deserve federal support - but they also supply critical services at a scale that would be impossible to replace;
support an array of small businesses; and serve as economic anchors for their communities. In particular, HBCUs are critically important and
Personal Email uniquely endangered, and must be included in any and all relief packages available.
Address Resurgens
4/16/2020 1:05:00 Impact I urge the Federal Reserve to make nonprofits eligible for the Main Street Loan program. The success of our nation's recovery from this
PM PIO (Email from Barnard Monica Consulting unprecedented crisis depends on the success of our nation's nonprofits.
4/16/2020 1:06:00 rena@gariver Georgia River Don't leave out NGOs please
PM PIO (Email from Peck Rena Ann s.org Network
On behalf of the employees of the Kennedy Krieger Institute in Baltimore, Maryland, I am writing to request that nonprofits be included in the
Federal Reserves "Main Street" lending facility. Kennedy Krieger Institute is the world's premier institution dedicated to
improving the lives of children and young adults with developmental disabilities and disorders of the brain, spinal cord and musculoskeletal
system. Through our pediatric rehabilitation hospital and research center, 85+ outpatient clinical programs, and school and community
programs, we annually serve ~25,000 of the most medically fragile and vulnerable individuals in our state and nation. It is of the utmost
importance that Kennedy Krieger continues to provide services during and after the COVID-19 pandemic, as well as be fiscally sound after it
subsides. The patients for whom they provide care are precisely those most vulnerable to severe outcomes from COVID-19 and whose
Schlaggar@k ongoing intensive outpatient care is critically important. Being eligible to receive funding from the "Main Street" lending program
4/16/2020 1:07:00 ennedykriege Kennedy Krieger would be extremely helpful in continuing to provide services and retaining our employees.
PM PIO (Email from Schlaggar Bradley r.org Institute
We at the Steffen Thomas Museum write in opposition to the exclusion of nonprofits, institutes of higher learning, and HBCUs from the Main
Street New & Expanded Loan Facilities. In short: The nonprofit sector is just as critical to economic stability and recovery as for-profit
business.
Georgia alone is home to over 300 nonprofit organizations with 500 or more staff members, each doing vital work during this unprecedented
time, and each set to be left behind by this (and previous) relief efforts. 
As large employers alone, they deserve federal support - but they also supply critical services at a scale that would be impossible to replace;
support an array of small businesses; and serve as economic anchors for their communities. In particular, HBCUs are critically important and
uniquely endangered, and must be included in any and all relief packages available. 
lconner@stef Steffen Thomas
4/16/2020 1:07:00 fenthomas.or Museum and We urge the Federal Reserve to make nonprofits eligible for the Main Street Loan program. The success of our nation's recovery from
PM PIO (Email from Conner Margaret "Li g Archives, Inc this unprecedented crisis depends on the success of our nation's nonprofits.
Page 200 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
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