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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.

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

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.




                                                                                                                                             Page 106 of 363
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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?




                                                                                                                                             Page 107 of 363
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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
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 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
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                                                                                                                              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
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                                                                                                                              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
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
                                                                                                                           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.




                                                                                                                                             Page 115 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
                                                                                                                              Main Street Lending Program Comments


                                                                                                                           Please expand the 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




                                                                                                                                             Page 116 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.
                                                                                                                           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
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
                                                                                                                              Main Street Lending Program Comments


                                                                                                                           As one of 4,000 employees of a regional non-profit health and human services agency that provides programs and services to nearly 10,000
                                                                                                                           people with intellectual and developmental disabilities, special needs, their families and older adults throughout numerous counties in Western
                                                                                                                           New York and the Greater Rochester region, I am writing today to inform you that our agency, People Inc., is fully engaged in dealing with the
                                                                                                                           COVID-19 crisis. We must ensure that our homes and services for people with disabilities remain as safe as possible and are staffed 24/7.
                                                                                                                           The vulnerable people that depend on us deserve no less. However, because we are providing essential services during the crisis, People
                                                                                                                           Inc. has incurred highly unusual increased costs in staffing, PPE, and cleaning services.

                                                                                                                           Since we are not eligible for the Payroll Protection Program (PPP) due to our size and we must remain fully operational, we request that the
                                                                                                                           Mid-Size Loan Program have provisions to convert to a forgivable loan for nonprofits that face staggering losses due to COVID-19. This would
                                                                                                                           grant us the same protections as PPP.
                                                                                     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
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 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




                                                                                                                                             Page 121 of 363
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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
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
                                                                                                                              Main Street Lending Program Comments


                                                                                                                           As one of 4,000 employees of a regional non-profit health and human services agency that provides programs and services to nearly 10,000
                                                                                                                           people with intellectual and developmental disabilities, special needs, their families and older adults throughout numerous counties in Western
                                                                                                                           New York and the Greater Rochester region, I am writing today to inform you that our agency, People Inc., is fully engaged in dealing with the
                                                                                                                           COVID-19 crisis. We must ensure that our homes and services for people with disabilities remain as safe as possible and are staffed 24/7.
                                                                                                                           The vulnerable people that depend on us deserve no less. However, because we are providing essential services during the crisis, People
                                                                                                                           Inc. has incurred highly unusual increased costs in staffing, PPE, and cleaning services.

                                                                                                                           Since we are not eligible for the Payroll Protection Program (PPP) due to our size and we must remain fully operational, we request that the
                                                                                                                           Mid-Size Loan Program have provisions to convert to a forgivable loan for nonprofits that face staggering losses due to COVID-19. This would
                                                                                                                           grant us the same protections as PPP.

                                                                                                                           Thank you in advance for your support of direct care staff, the people we support and our agency, People Inc.

                                                                                                                           In Appreciation,
                                                                                                                           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



                                                                                                                                             Page 125 of 363
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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




                                                                                                                                             Page 131 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
    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




                                                                                                                                             Page 133 of 363
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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.




                                                                                                                                             Page 134 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:

                                                                                                                           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




                                                                                                                                             Page 136 of 363
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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.



                                                                                                                                                   Page 137 of 363
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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




                                                                                                                                             Page 138 of 363
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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




                                                                                                                                             Page 139 of 363
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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




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                                                                                                                              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.




                                                                                                                                             Page 143 of 363
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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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                                                                                                                              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




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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. 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



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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
                                                                                                                           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




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                                                                                                                               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




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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
                                                                                                                           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.




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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
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.
                                                                                     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
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
                                                                                                                              Main Street Lending Program Comments


                                                                                                                           I am 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.




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                                                                                                                              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



                                                                                                                                             Page 170 of 363
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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




                                                                                                                                             Page 171 of 363
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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




                                                                                                                                             Page 172 of 363
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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.




                                                                                                                                             Page 173 of 363
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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




                                                                                                                                             Page 174 of 363
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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
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                                                                                                                              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
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 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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