Main Street Lending Program Comments, Beginning with Opposition to the Exclusion of Nonprofits, Institutes of Higher Learning and HBCUs
Summary
A set of comments headed Main Street Lending Program Comments, the first of which writes in opposition to the exclusion of nonprofits, institutes of higher learning, and HBCUs from the Main Street New & Expanded Loan Facilities. The comment states that the nonprofit sector is just as critical to economic stability and recovery as for-profit business and that Georgia alone is home to over 300 nonprofit organizations with 500 or more staff members. It argues that HBCUs are critically important. The document is long, and only its opening comment was read.
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, Beginning with Opposition to the Exclusion of Nonprofits, Institutes of Higher Learning and HBCUs.”
Original at www.federalreserve.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/federal-reserve-public-comments-3-pdf-www-federalreserve-gov-29c6219ea-899b852769/
, SHA-256 c412e785b37f6d8516c42d5cdfd8985a530e1746f1e4cafe21ca7ca14aa7cfdd.Full text
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.
Kcoats@hop Children's
4/16/2020 1:08:00 eandhealingg Center for Hope 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 Coats Kara a.org and Healing this unprecedented crisis depends on the success of our nation's nonprofits.
I am writing 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.
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 1:09:00 Email Interfaith 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 Newton Lynn Address Outreach Home this unprecedented crisis depends on the success of our nation's nonprofits.
Elwyn provides services to those with intellectual and developmental disabilities in PA, NJ and CA. We have 5000 employees and could not
access the Paycheck Protection Program due to our size. We have approximately 1000 beds for fragile adults, and our system is under
stress. We urge you to adapt the Main Street Loan program so it is accessible to providers like Elwyn as we continue our essential services.
4/16/2020 1:09:00 rex_carney@ Specifically, we urge you to consider a .5 interest rate with a 5 year amortization, delayed payments for 2 years, a retention baseline pegged
PM PIO (Email from Carney Rex elwyn.org Elwyn to date of loan approval, and defining a workforce as FTEs. Thank you.
jule@mancop Is this loan program taking applications now?
4/16/2020 1:10:00 ropertyservic ManCo Property
PM PIO (Email from Rastikis Julius es.com Services
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
M.E.N.S. Wear, uniquely endangered, and must be included in any and all relief packages available.
Inc. (Making
4/16/2020 1:11:00 aoneal@men Employment the 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 O'Neal Angelia swearinc.org Next Step) this unprecedented crisis depends on the success of our nation's nonprofits.
Consider including loan forgiveness provisions similar to those included in the Paycheck Protection Program in this program. Unlike normal
times when debt is used to fund positive ROI projects, these loans will most likely be used to fund deficits from simply continuing payroll and
operations while experiencing significantly decreased revenue. As we emerge from this pandemic, many businesses will not have the
4/16/2020 1:14:00 carlsonr@csg Community increased profitability normally expected from investment or cash reserves to afford the increased debt payments from additional loans.
PM PIO (Email from Carlson Rejean online.org Services Group
Page 201 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
By excluding nonprofits during this time, you are essentially closing our doors forever. It will be almost impossible for most of us to recover
from this, and we have employees who deserve the assistance just as much as any other American.
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 1:15:00 Email Act3 Productions 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 Peck Michelle Address LLC this unprecedented crisis depends on the success of our nation's nonprofits.
The term sheets for the Main Street New Loan and Expanded Loan Facility incorporate section 4003(c)(3)(A)(ii) of the CARES Act that
imposes the following restriction: "until the date 12 months after the date on which the direct loan is no longer outstanding, not to pay
dividends.with respect to the common stock of the eligible business". Companies that have elected to be treated as S corporations
chris.fraser@ make distributions to their owners who are obligated to pay taxes on income of the eligible business. We would like to confirm that S
4/16/2020 1:16:00 chesterton.co A.W. Chesterton corporations will continue to be allowed to use the cash generated from their operations to make distributions to their owners to cover their tax
PM PIO (Email from Fraser Chris m Inc. obligations relating to that business.
Please consider including non-profits in the Main Street New and Expanded Load Facilities program. Non-profits are critical to economic
Personal stability and well being of the less fortunate in every community. This economic recovery period maybe long and the viability of non-profits will
4/16/2020 1:16:00 Email Address Safe Harbor be more important than ever in providing a safety net for those who need it most.
PM PIO (Email from Feininger Peter Center, Inc. Thank you for your consideration.
Dear Main Street Staff,
Please include nonprofits as part of this funding. Nonprofits provide essential services to our communities from providing food and resources
to families in need to making arts accessible to all. Nonprofits should not be excluded from funding, especially now, as most operate on razor
Director@mo thin margins. Please reconsider this decision.
4/16/2020 1:17:00 tionpacific.co Motion Pacific
PM PIO (Email from Tabone Collette m Dance Thank you.
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
4/16/2020 1:18:00 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 Pawlish Steve 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
dedward@m hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/16/2020 1:20:00 omentummh. Momentum for eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
PM PIO (Email from Edward Donna org Health
Page 202 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.
Sandy@autis
4/16/2020 1:21:00 mimprovised. Autism 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 Bruce Sandra org Improvised, Inc. this unprecedented crisis depends on the success of our nation's nonprofits.
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
Silicon Valley action threatens the viability of larger nonprofits who provide aid to hundreds of thousands of children and families. Please include nonprofits
4/16/2020 1:24:00 wendyh@svc Council of that employ over 500 employees in the Main Street Program to protect the critical safety net.
PM PIO (Email from Ho Wendy n.org Nonprofits
We opened an educationally oriented themepark for elementary aged school children in Frisco TX in November, 2019. COVID-19 imposes a
greg.stevens threat that we may not be able to re-open. MSLP won't work for us as we do not have a full year of operating history....strongly suggest
4/16/2020 1:26:00 @kidzaniaus that the EBITDA requirement is modified for companies with less than one year existence. Perhaps in these circumstances it is based on pro-
PM PIO (Email from stevens greg a.com KidZania USA forma EBITDA?
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.
bob.schlich@
4/16/2020 1:27:00 incommunity InCommunity of 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 Schlich Bob ga.org Georgia this unprecedented crisis depends on the success of our nation's nonprofits.
I write in opposition to the exclusion of nonprofits from the Main Street New & Expanded Loan Facilities. The nonprofit sector is just as
critical to economic stability and recovery as for-profit business. Our particular mission includes overnight guest room and meeting space for
nonprofit organizations, much like a hospitality business. We have been severely impacted by COVID-19 and will be closed for 90 days in
support of prevention measures.
Georgia's nonprofits supply critical services at a scale that would be impossible to replace; support an array of small businesses (print
shops, web firms, food vendors, and more); and serve as economic anchors for their communities.
tlabouff@ign Ignatius House I urge the Federal Reserve to make all nonprofits eligible for the Main Street Loan program. Donations from individuals (who no longer benefit
4/16/2020 1:27:00 atiushouse.or Jesuit Retreat from itemized charitable deductions or must take required minimum distributions in 2020) will not be sufficient for our recovery.
PM PIO (Email from La Bouff Tara g Center
As part of the bipartisan CARES Act, the Federal Reserve recently announced its new "Main Street" lending facility. This facility
will support up to $600 billion in bank lending to small and mid-sized businesses, including two lending options: new loans of $1 million to $25
million, or expansion of a business's existing loan with a bank to up to $150 million. Unfortunately, the Administration and the Fed, as of
today, are excluding nonprofits, many institutions of higher learning and Minority-Serving Institutions. This is a significant blow in particular to
4/16/2020 1:31:00 mbakko@umi University of entities that are also ineligible for the Paycheck Protection Program. Please include nonprofits in this facility, which are critical for sustaining
PM PIO (Email from Bakko Matthew ch.edu Michigan our communities, especially at this time.
Page 203 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 Sir/Madam,
This is regarding Main Street New Loan facility under Section 13(3) of the FR Act. When can we start applying for this loan and through whom
should we apply.
An immediate response will be appreciated. Thank you.
4/16/2020 1:32:00 cfo@talentlog With Regards,
PM PIO (Email from Penukonda Aswin ic.com Talent Logic Inc Aswin
As a Board Member for the Museum of Design Atlanta, 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.
The Museum of Design Atlanta (MODA) has been working tirelessly to bring needed enrichment activities to children and relief to their parents
by providing valuable learning from trusted providers. That work continues even though MODA is strapped for cash. On premises revenue
has been eliminated, donors have lost jobs and contributors, who are concerned about their business's future, are holding funds. We
need help and OUR COMMUNITY NEEDS US, today and tomorrow.
As large employers alone, non-profits like MODA 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 1:33:00 Address Museum of With local community leadership, nonprofits have held the country together through these days of hardship and unity. Please make it possible
PM PIO (Email from Edmisten Teresa Design Atlanta for our communities to emerge from this crisis whole by including nonprofits in the Main Street Loan program.
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. This sector cannot be
ignored if we are to recover our economy.
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. That's over 150,000 people who will be left out of the recovery.
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 I urge the Federal Reserve to make nonprofits eligible for the Main Street Loan program. The success of our nation's recovery from this
4/16/2020 1:35:00 Email unprecedented crisis depends on the success of our nation's nonprofits.
PM PIO (Email from Blue Jackalie Address Karna, LLC
Cornerstones of Care is a community-based nonprofit human services organization whose 760 employees provided trauma-informed
behavioral healthcare to 13,357 children and families in 2019. Because of COVID-19 we will lose over $1.4 million through May, not including
costs for needed Personal Protective Equipment.
As a nonprofit of more than 500 employees, we have been locked out of existing stimulus relief, including the Paycheck Protection Program;
its loan forgiveness provisions can ensure we provide services during the crisis and assist in its recovery.
As the Treasury Department creates a program as directed under the CARES Act section 4003(c)(3)(D) to provide financing to lenders for
nonprofits and other mid-size business between 500-10,000 employees, we request it:
include 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;
defer payments for two years after a direct loan is made;
begin employee retention provisions on the date loan funding is received; and,
carol.grimaldi define "workforce" as full-time employees or full-time equivalents in workforce restoration and retention provisions.
4/16/2020 1:35:00 @cornerston Cornerstones of Charitable nonprofits are the nation's third largest employer and solely focused on making communities stronger. These
PM PIO (Email from Grimaldi Carol esofcare.org Care recommendations will help keep us financially strong to meet communities' needs now and in the future.
Page 204 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
Evelyn.fernan hospital emergency departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility
4/16/2020 1:36:00 dez@upliftfs. Uplift Family eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
PM PIO (Email from Fernandez Evelyn org Services
I am writing to implore you to include nonprofits in future expanded funding. Nonprofits, from cradle to grave, offering essential services to
Americans. These are not services that exist in the marketplace and they are not services government has the proficiency and capacity to
offer.
The nonprofit I lead is on the ground providing emergency support to workers in the arts and entertainment sector. We responded within a
week of local quarantine by providing immediate cash assistance to freelance, "gig" workers who lost months worth of contracted
work. Like other nonprofits, we are hyper local, non-partisan, and well regarded by community members who trust our efforts.
We are in a position of life and death, surviving vs. thriving, scenarios for over half the people whom we serve. We absorb the extra staff
hours it takes to quickly and nimbly respond to crisis. We are your first wave of ground, first responders. Please include nonprofits in
expanded funding. You need us and we need your support.
Respectfully,
Jessyca Holland
Executive Director
4/16/2020 1:38:00 jessyca@c4a C4 Atlanta
PM PIO (Email from Holland Jessyca tlanta.org C4 Atlanta Inc
cgrundner@ Please add nonprofits and universities to this! They need this support too!
4/16/2020 1:42:00 welfarefound Welfare
PM PIO (Email from Grundner Chris ationde.org Foundation, Inc.
4/16/2020 1:43:00 nia.443k@nia Please include non-profits in your expanded lending program, honoring funds that were committed for the current FY20 fiscal year.
PM PIO (Email from Porchia Aaron bklyn.org
Please do not exclude 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. Georgia is home to over 300 nonprofit organizations
with 500 or more staff members, each set to be left behind by this relief effort. Yet each is contributing to the survival of our communities and
our nation during these challenging times.
Environmental We urge the Federal Reserve to make nonprofits eligible for the Main Street Loan program. The success of our nation's recovery from
4/16/2020 1:44:00 KWood@EE Education this unprecedented crisis is inseparably related to the success of our nation's nonprofits. Thanks for your careful consideration of this
PM PIO (Email from Wood Karan Alliance.org Alliance of GA matter.
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.
artistic@outfr Out Front
4/16/2020 1:45:00 onttheatre.co Theatre 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 Conroy Paul m company this unprecedented crisis depends on the success of our nation's nonprofits.
Page 205 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 President/CEO of a nonprofit providing vital services to individuals and families, it was disheartening to receive notice that the Federal
Reserve Bank has chosen to exclude nonprofits from seeking financial relief through the Main Street Lending Program. Just as for-profit
businesses, nonprofits urgently require additional financial aid at this time as they, too, are facing profound hardships.
Nonprofits employ upwards of 12 million workers and contribute 10% of the U.S. GDP. Our payrolls exceed that of U.S. industries, including
for-profit construction, transportation, and finance. As significant employers, it is critical that nonprofits are recognized along with for-profit
employers and be given equitable relief to ensure that nonprofits can continue to provide services to our most vulnerable populations.
History has proven, when a crisis hits, nonprofits are our economy's shock absorber and safety-net for Americans. Nonprofits in the
weeks and months to come will undoubtedly need to provide services in a manner never seen before in our lifetime. The assistance that
Habitat for nonprofits provide to those in need must be safeguarded. I respectfully urge you to equitably treat and include nonprofits just as you do the
dspencer@m Humanity of for-profit sector in the Main Street Lending Program during the COVID-19 pandemic that is ravaging our country and creating enormous
4/16/2020 1:46:00 emphishabita Greater uncertainty among our citizens about what the new normal will look like for them and their families.
PM PIO (Email from Spencer Dwayne t.org Memphis
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 1:48:00 rob@atlblp.or Atlanta BeltLine 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 Brawner Rob g Partnership unprecedented crisis depends on the success of our nation's nonprofits. Thank you.
On behalf of Fordham University, we write to request 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, we ask that guidance be updated so that student workers are
exempted for the purpose of the employee threshold.
Private, not-for-profit colleges and universities like Fordham University are major employers with significant economic impact in our
communities. We are facing a major cash flow crisis caused by reduce revenue and increased spending resulting from the COVID-19
pandemic. Fordham University has an economic impact of more than $1.4B in the New York metropolitan area and we support more than
8,000 direct and indirect jobs.
Low-cost loans like the Main Street Lending program would help Fordham University address the financial impact of the COVID-19 crisis. We
ask that the Federal Reserve update the guidance to clarify that public and private non-profit colleges and universities, with direct borrowing
authority, are eligible for the Main Street Lending program and we also ask that student workers be exempted for the purpose of the employee
threshold for eligibility (businesses with under 10,000 employees).
Sincerely,
4/16/2020 1:49:00 wcolona@for Fordham Lesley A. Massiah-Arthur, AVP and Special Assistant to the President for Government Relations
PM PIO (Email from Colona Bill dham.edu University Bill Colona, Director of Government Relations
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 1:49:00 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 Prophitt David this unprecedented crisis depends on the success of our nation's nonprofits.
Page 206 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
Please include nonprofit organizations in the Main Street Loan programs.
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 1:51:00 jordan@scien 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 Rose Jordan ceatl.org Science ATL this unprecedented crisis depends on the success of our nation's nonprofits.
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 vulnerable, high risk 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
Casa Pacifica nation's safety net are not eligible for the Paycheck Protections Program (PPP) (Sections, 1102, 1106) or the Economic Injury Disaster
mcollins@ca Centers for Loans (EIDL) (Section 1110) or other federal relief. This proposed action threatens the viability of larger nonprofits who provide aid to
4/16/2020 1:53:00 sapacifica.or Children & hundreds of thousands of children and families. Please include non-profits that employ over 500 employees in the Main Street Program to
PM PIO (Email from Collins Marika g Families protect the critical safety net. Thank you.
Institutions of higher education, often the largest or one of the largest employers in their local communities, are facing a major cash flow crisis
in light of the reduced revenue and increased expenses imposed by the COVID-19 pandemic. Institutions expect to refund nearly $8 billion in
room and board charges alone. Some schools have also refunded tuition payments. Anticipated sources of auxiliary revenue have dried up as
campus events have been canceled. Summer programs that provide revenue to many institutions also have been canceled.
Many of our colleges and universities are seeking low cost loans to help address the financial impact of the COVID-19 crisis and are
interested in accessing the credit and loans available under the Main Street Lending program, recently announced by the Federal Reserve.
4/16/2020 1:53:00 kreddick@nc National Credit
PM PIO (Email from Reddick Karen mstl.com Management
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
Rally Foundation uniquely endangered, and must be included in any and all relief packages available.
for Childhood
4/16/2020 1:54:00 adam@rallyf Cancer 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 Cohen Adam oundation.org Research this unprecedented crisis depends on the success of our nation's nonprofits.
Page 207 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
Community Health Centers (CHCs) are non-profit businesses experiencing huge financial losses because of COVID-19. On average CHCs
are seeing a drop in primary care visits of 50%. While the situation continues to evolve on the ground, data projections for California's
CHCs suggests a shortfall of at least $1 billion in revenue over the next three months. If such a reality were to come to pass, the ability to
provide access to 7.2 million Californians will be at risk. Nationally, CHCs are the Health Homes for 29 million patients; we were at the
frontline in the U.S. health care delivery system before COVID-19 and will remain at the frontline after it is gone. It is imperative that CHCs
maintain their operations and staffing levels, both to keep our patients healthy, and 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
Health Center only will they suffer the greatest revenue losses, ranging from $5M-9M per entity, per month; they are also forced to endure this pandemic
Partners of without the financial support that their smaller counterparts have access to, through SBA loans. We respectfully request CHCs with 500 or
4/16/2020 1:55:00 dflaker@hcps Southern more employees be included to receive direct financial support via the Main Street Lending Program.
PM PIO (Email from Flaker Douglas ocal.org California
To Whom It May Concern,
On behalf of Staff Pro LLC dba as Staff Pro Workforce Solutions, I would like to receive more guidance on the application process for the
Main Street Loan Facility program. Where I can find the website to apply for this program.
Thanks for your support.
Cordially, JFA.
jfaguilar@staf
4/16/2020 fproworkforce J. Fernando Aguilar
Cell Phone Number
12:00:00 AM PIO (Email from Aguilar Jose .com Staff Pro
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 1:58:00 reid@rallyfou 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 Crowe Reid ndation.org Rally Foundation this unprecedented crisis depends on the success of our nation's nonprofits.
Ocean Casino Resort ("OCR") is the largest independently-owned casino and resort in Atlantic City, NJ. OCR employs nearly
3,000 workers. The term in the Main Street New Loan Facility (MSNLF) limiting the maximum loan size to 4x 2019 EBITDA arbitrarily
precludes creditworthy businesses like OCR from participating in the MSNLF. JPMorganChase and other Eligible Lenders lend to OCR
against the appraised value of its real estate (RE), and not its annual EBITDA. Lenders to companies that own RE, such as casinos, hotels,
office buildings, retail centers, multifamily dwellings and other similar businesses, typically use appraised RE values to measure borrowing
capacity. Typical leverage in commercial RE asset classes ranges between 65% and 75% of appraised value. Because of the stability and
limited volatility of EBITDA in most commercial RE, leverage levels in companies that own and operate world-class RE like OCR tend to be
higher than more volatile industries. The EBITDA leverage test arbitrarily harm owner-operators of high-quality RE who responsibly carry
leverage above 4x while maintaining credit performance. The 4x test results in aid failing to reach a large portion of the commercial RE
terry.glebocki market. We urge the FRB to add an alternative leverage test of 65-75% of appraised value (calculated by an Eligible Lender using its
4/16/2020 1:58:00 @theoceana customary practices) for industries that customarily use appraised RE values as the primary metric of borrowing capacity.
PM PIO (Email from Glebocki Terry c.com AC Ocean Walk
I write in opposition to the exclusion of nonprofits from the Main Street New & Expanded Loan Facilities. In short: The nonprofit sector is
just as critical to economic stability and recovery as a for-profit business. The nonprofit sector is filling critical roles in the community and will
molly@welco be essential to EVERY communities' recovery. Again, please consider supporting the critical infrastructure of the non-profit ecosystem in
4/16/2020 1:58:00 mingamerica. Welcoming this presented time.
PM PIO (Email from Hilligoss Molly org America Thank you.
Page 208 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 1:59:00 We urge the Federal Reserve to make nonprofits eligible for the Main Street Loan program. The success of our nation's recovery from
Address
PM PIO (Email from Gillespie Liz MODA this unprecedented crisis depends on the success of our nation's nonprofits.
I am 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. My nonprofit supports
business development of for-profit arts business. So, I know how important it is to have a nonprofit like ours in the community. Whether it is
through professional education, resiliency resources or serving as a training ground for future entrepreneurs/employees, we are not separate
business ecologies. Taking out this critical link will cripple us and also provide fewer long-term recovery resources for the for-profit sector as
well. 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. 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
4/16/2020 1:59:00 audrey@c4at nation's recovery from this unprecedented crisis depends on the success of our nation's nonprofits.
PM PIO (Email from Gamez Audrey lanta.org C4 Atlanta
I write to urge you to include nonprofits, institutes of higher learning, and HBCUs in 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.
Greenbriar I urge the Federal Reserve to make nonprofits eligible for the Main Street Loan program. The success of our nation's recovery from this
Personal
4/16/2020 2:00:00 Children's unprecedented crisis depends on the success of our nation's nonprofits. We are "Main Street" just as much as any for-profit
Email Address
PM PIO (Email from Emery Melissa Center business.
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
Rally Foundation uniquely endangered, and must be included in any and all relief packages available.
for Childhood
4/16/2020 2:04:00 emily@rallyfo Cancer 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 Kallos Emily undation.org Reserach this unprecedented crisis depends on the success of our nation's nonprofits.
Page 209 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 the Association of Zoos and Aquariums (AZA), I urge you to ensure that all AZA-accredited facilities are eligible for loans through
the Main Street Lending Program.
Founded in 1924, the Association of Zoos and Aquariums is a 501(c)3 non-profit organization dedicated to the advancement of zoos and
aquariums in the areas of conservation, education, science, and recreation. AZA's 217 U.S.-based members collectively generate more
than $22 billion in annual economic activity and support more than 198,000 jobs. Approximately 54% of AZA-accredited facilities are non-
profit, 35% are public, and 11% are for-profit. All of them are under tremendous economic stress because of the COVID-19 pandemic. These
facilities face a unique challenge of needing to retain sufficient staff and supplies to care for animals while visitors are no longer coming
through the gate. They cannot simply shut the gates and secure the facility, meaning that they continue incurring 40% or more of their
operational costs, even when closed.
Our nation's zoos and aquariums are community icons, businesses, and employers, and are facing an existential threat in facing this
crisis. I strongly urge you to ensure that these facilities have the opportunity to obtain much-needed funds through this critical lending
program.
Sincerely,
Association of Dan Ashe
4/16/2020 2:05:00 dashe@aza. Zoos and President and CEO
PM PIO (Email from Ashe Dan org Aquariums Association of Zoos and Aquariums
Dear Colleagues,
I am writing to urge you to include nonprofit organizations in the Main Street Lending program. Nonprofits employ about 10 percent of the
workforce in the United States and provide many of the services that we have come to count on, from education to medical care, to shelter
and food, nonprofits provide for essential societal needs. They will be especially hard hit by the pandemic as they are likely to suffer a
reduction in philanthropic dollars and an increase in needs among their clients. I'm happy to provide further data on the importance of
nonprofit organizations and urge you to include them in your Mainstreet lending program.
Personal
4/16/2020 2:05:00 Columbia
Email Address
PM PIO (Email from Witkowski Greg University Best,
Non-profits, including higher education organizations, employ millions of American workers, have a huge economic impact, and have a
massive impact generally on their local communities. Right now, they are providing essential services in those communities. Non-profits
should be eligible for loans through the proposed Main Street Lending program. To illustrate the point, I work for an arts and culture non-profit
in Providence, RI. Data compiled by the National Endowment of the Arts in 2018 found that the arts contribute $763.6 billion to the U.S.
economy, more than agriculture, transportation, or warehousing. The arts employ 4.9 million workers across the country with earnings of
more than $370 billion. Despite some temporary programmatic suspensions, my organization is still providing essential services such as
housing to low income resident artists and much needed stipends to youth in our community, including incarcerated and formerly incarcerated
youth, those who are pregnant and parenting, youth in foster care, and youth at high risk of school dropout and disconnection. Our services
are needed more than ever during the COVID-19 pandemic. There is no valid reason not to include non-profit businesses such as ours in the
4/16/2020 2:06:00 ruth.harvey@ Main Street Lending program, and not doing so potentially creates further financial burden on already chronically underfunded service
PM PIO (Email from Harvey Ruth as220.org AS220 providers.
Page 210 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 a Board Member for the Museum of Design Atlanta, 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.
The Museum of Design Atlanta (MODA) has been working tirelessly to bring needed enrichment activities to children and relief to their parents
by providing valuable learning from trusted providers. That work continues even though MODA is strapped for cash. On premises revenue
has been eliminated, donors have lost jobs and contributors, who are concerned about their business's future, are holding funds. We
need help and OUR COMMUNITY NEEDS US, today and tomorrow.
As large employers alone, non-profits like MODA 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 2:06:00 ebru@design Museum of With local community leadership, nonprofits have held the country together through these days of hardship and unity. Please make it possible
PM PIO (Email from Ercan Ebru withe3.com Design Atlanta for our communities to emerge from this crisis whole by including nonprofits in the Main Street Loan program.
Hello:
For 132 years the YMCA of Northwest North Carolina has provided valuable services and resources to the community. In 2019, we served
152,000 people in 7 counties. Prior to the pandemic and subsequent social distancing measures, our Y employed 1912 people (520 FTE),
and has since laid-off 91% of its workforce. Between March 15th and June 30th, we are projecting a $2.5M loss in revenue. There is the
potential for additional losses due to the uncertainty of continued social distancing requirements when we are able to reopen. Despite these
losses, the Y is committed to serving the community through the crisis. Over the past month we have offered emergency child care to
essential workers, food distribution (over 5000 meals served so far), made thousands of wellness calls to seniors, and transitioned multiple
branches for weekly blood drives. 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 for those with 500+ FTE
employees. Without additional resources, many nonprofit organizations will be lost to their communities, including larger non-profits, like the
YMCA Of YMCA. Your support would ensure that we can continue to provide urgently needed services for our communities and continue to support our
4/16/2020 2:06:00 s.law@ymca Northwest North staff as one of the larger employers in the region. We thank you for your service and your consideration.
PM PIO (Email from Law Stan nwnc.org Carolina.
Non-profits, including higher education organizations, employ millions of American workers, have a huge economic impact, and have a
massive impact generally on their local communities. Right now, they are providing essential services in those communities. Non-profits
should be eligible for loans through the proposed Main Street Lending program. To illustrate the point, I work for an arts and culture non-profit
in Providence, RI. Data compiled by the National Endowment of the Arts in 2018 found that the arts contribute $763.6 billion to the U.S.
economy, more than agriculture, transportation, or warehousing. The arts employ 4.9 million workers across the country with earnings of
more than $370 billion. Despite some temporary programmatic suspensions, my organization is still providing essential services such as
housing to low income resident artists and much needed stipends to youth in our community, including incarcerated and formerly incarcerated
youth, those who are pregnant and parenting, youth in foster care, and youth at high risk of school dropout and disconnection. Our services
are needed more than ever during the COVID-19 pandemic. There is no valid reason not to include non-profit businesses such as ours in the
4/16/2020 2:07:00 shauna.duffy Main Street Lending program, and not doing so potentially creates further financial burden on already chronically underfunded service
PM PIO (Email from Duffy Shauna @as220.org AS220 providers.
Page 211 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 Sir or Ma'am:
Comerica Bank appreciates the opportunity to provide some feedback on the Federal Reserve's Main Street New Loan Facility and Main
Street Expanded Loan Facility. We believe these lending programs have the potential to provide significant and rapid relief to a large number
of small and medium businesses and other eligible borrowers and their employees.
Terms and Conditions of Program. We request that consideration be given to striking the 2019 EBITDA multiples as part of the definition for
an Eligible Loan and simply apply the proposed dollar amounts as the limits. This would permit banks to take into account not only pre COVID-
19 financial performance but also would allow the banks to evaluate post COVID-19 conditions and provide more flexibility around EBITDA
multiples.
Program roll-out. Overall, the lending programs should avoid unnecessary complexity. This could include promoting the development of
standard documents where applicable. If possible, FAQs should be vetted by the participating banks before distributed publicly.
Interest rate. The proposed term sheets for the program considers SOFR as the applicable rate. However, many banks may have operational
difficulties using SOFR. Moreover, SOFR may not be acceptable to small and middle market borrowers. Nevertheless, if SOFR is used, other
4/16/2020 2:07:00 gjhudson@co versions of SOFR may be more palatable, e.g., overnight, simple SOFR, weighted average in advance or in arrears.
PM PIO (Email from Hudson Gregory merica.com Comerica Bank
Non-profits, including higher education organizations, employ millions of American workers, have a huge economic impact, and have a
massive impact generally on their local communities. Right now, they are providing essential services in those communities. Non-profits
should be eligible for loans through the proposed Main Street Lending program. To illustrate the point, I work for an arts and culture non-profit
in Providence, RI. Data compiled by the National Endowment of the Arts in 2018 found that the arts contribute $763.6 billion to the U.S.
economy, more than agriculture, transportation, or warehousing. The arts employ 4.9 million workers across the country with earnings of
more than $370 billion. Despite some temporary programmatic suspensions, my organization is still providing essential services such as
housing to low income resident artists and much needed stipends to youth in our community, including incarcerated and formerly incarcerated
youth, those who are pregnant and parenting, youth in foster care, and youth at high risk of school dropout and disconnection. Our services
are needed more than ever during the COVID-19 pandemic. There is no valid reason not to include non-profit businesses such as ours in the
4/16/2020 2:07:00 marina.balko Main Street Lending program, and not doing so potentially creates further financial burden on already chronically underfunded service
PM PIO (Email from Balko Marina @as220.org AS220 providers.
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 2:07:00 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 Smith Lara this unprecedented crisis depends on the success of our nation's nonprofits.
Page 212 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
The Chamber supports the PMCCF, but encourages the Federal Reserve to address:
Is the 130% test applicable only while the issuer has bonds/loans held by the PMCCF? Is it a maintenance or incurrence test? Is it based on
notional or balance sheet value?
What are the repercussions of breaching the 130% limit?
Can affiliate issuers with the same parent access the PMCCF if they meet the criteria?
If the holding company is assumed to be the issuer, how does the issuer account for bonds and loans issued to third parties via subsidiaries?
For split-rated issuers, should the higher or lower rating be referenced?
Are U.S. subsidiaries of foreign parents, with operations primarily in U.S., eligible?
Is eligibility impacted if an issuer is (i) owned by a foreign parent or (ii) receives a guarantee from a foreign parent of a U.S. issuer?
Do secured forms of debt/loans qualify? Do subordinated bonds/loans qualify?
Will the Federal Reserve consider amending ratings eligibility to include additional issuers?
Who is responsible for setting/approving the list of participants?
What documentation, disclosures, other readiness must be undertaken?
Is there a date participants need to sign up by to access the PMCCF?
tquaadman@ Is the PMCCF available to participants during an issuer's blackout periods?
4/16/2020 2:07:00 uschamber.c U.S. Chamber of Does the PMCCF intend on lending out the securities at a future date?
PM PIO (Email from Quaadman Tom om Commerce
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.
As the Executive Director of a counseling center, and a therapist who provides emotional support for members of the community, our practice
(amongst many others) is vitally important to the emotional well being of individuals, couples and families dealing with the fall out of this
pandemic.
I 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.
LifeGate
4/16/2020 2:08:00 ryan@lifegat Counseling Thank you for your time and work,
PM PIO (Email from Jackson Ryan egroup.org Center Ryan Jackson, LMFT
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 a 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 essential and
uniquely endangered and must be included in any relief packages available.
Personal
4/16/2020 2:08:00 Email Address 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
PM PIO (Email from Lopez Gianelli Design Atlanta this unprecedented crisis depends on the success of our nation's nonprofits.
Page 213 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
I am writing to express my strong opposition to exclusion of nonprofits, nonprofit institutes of higher learning, and HBCUs from the Main Street
Loan Program.
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 2:09:00 katie@cfmatl. Community 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 Hayes Katie org Farmers Markets 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
Personal uniquely endangered, and must be included in any and all relief packages available.
Email Out Front
4/16/2020 2:11:00 Address Theatre 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 Doss Jonathan company this unprecedented crisis depends on the success of our nation's nonprofits.
Non-profits, including higher education organizations, employ millions of American workers, have a huge economic impact, and have a
massive impact generally on their local communities. Right now, they are providing essential services in those communities. Non-profits
should be eligible for loans through the proposed Main Street Lending program. To illustrate the point, I work for an arts and culture non-profit
in Providence, RI. Data compiled by the National Endowment of the Arts in 2018 found that the arts contribute $763.6 billion to the U.S.
economy, more than agriculture, transportation, or warehousing. The arts employ 4.9 million workers across the country with earnings of
more than $370 billion. Despite some temporary programmatic suspensions, my organization is still providing essential services such as
housing to low income resident artists and much needed stipends to youth in our community, including incarcerated and formerly incarcerated
youth, those who are pregnant and parenting, youth in foster care, and youth at high risk of school dropout and disconnection. Our services
are needed more than ever during the COVID-19 pandemic. There is no valid reason not to include non-profit businesses such as ours in the
4/16/2020 2:12:00 Josh.cormier Main Street Lending program, and not doing so potentially creates further financial burden on already chronically underfunded service
PM PIO (Email from Cormier Joshua @as220.org AS220 providers.
Non-profits, including higher education organizations, employ millions of American workers, have a huge economic impact, and have a
massive impact generally on their local communities. Right now, they are providing essential services in those communities. Non-profits
should be eligible for loans through the proposed Main Street Lending program. To illustrate the point, I work for an arts and culture non-profit
in Providence, RI. Data compiled by the National Endowment of the Arts in 2018 found that the arts contribute $763.6 billion to the U.S.
economy, more than agriculture, transportation, or warehousing. The arts employ 4.9 million workers across the country with earnings of
more than $370 billion. Despite some temporary programmatic suspensions, my organization is still providing essential services such as
housing to low income resident artists and much needed stipends to youth in our community, including incarcerated and formerly incarcerated
youth, those who are pregnant and parenting, youth in foster care, and youth at high risk of school dropout and disconnection. Our services
are needed more than ever during the COVID-19 pandemic. There is no valid reason not to include non-profit businesses such as ours in the
4/16/2020 2:12:00 olivia.watson Main Street Lending program, and not doing so potentially creates further financial burden on already chronically underfunded service
PM PIO (Email from Watson Olivia @as220.org AS220 providers.
Page 214 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
The Chamber supports the SMCCF, but encourages the Federal Reserve to address:
We are concerned that given the terms and conditions of the facility only a small portion of the market that requires assistance will actually be
able to avail themselves of the SMCCF. To ensure that the facility is as impactful as intended, we recommend increasing (i) from 5 to 10 years
the final maturity of eligible bonds to expand the reach of the program and (ii) from 1.5% to 2.0% the per issuer cap of the total program size
to accommodate issuers with larger debt footprints in the market.
Who is responsible for setting and approving the list of participants?
Are U.S. investors with a foreign parent considered eligible sellers?
How will "fair market value" pricing be determined?
Could issuers sell their own debt to the facility that have been purchased in the secondary markets through the ordinary course of market-
making?
How will the Fed allocate the capacity firms could utilize by issuer or seller?
The eligibility of a branch/agency of a foreign bank should be clarified.
What documentation, disclosures, other readiness must be undertaken?
tquaadman@ Is there a date participants need to sign up by to access the SMCCF?
4/16/2020 2:13:00 uschamber.c U.S. Chamber of Does the SMCCF intend on lending out the securities at a future date?
PM PIO (Email from Quaadman Tom om Commerce Does the Fed intend on holding purchased assets to maturity?
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 2:13:00 bmcmast@e 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 McMaster Belle mory.edu Retired this unprecedented crisis depends on the success of our nation's nonprofits.
As one of the largest doctor-owned group practices and Dental Services Organizations in the country, Mortenson Dental Partners (MDP)
would first like to express its gratitude and acknowledge the promising nature of the Main Street Program. It will provide ciritical funding for
companies like ours who have been impacted by COVID-19 and, in particular, government restrictions on operations. These restrictions have
resulted in around 90% reduction in productivity. MDP is concerned, however, about proposed restrictions and contingencies regarding
qualification or default provisions. For example, while MDP intends to continue to employ 100% of its workforce, it cannot predict local
governmental restrictions, the timing of their lift, or future patient demand. As such, and given that the loan is not designed to be forgiven, we
respectfuly request that much deference be given to companies with regard to its obligation to retain workers by acklowedging that, through
christopher.n no fault of the employer, it might not have the demand to justify its current workforce. Given that fact, any provision restricting funds or
4/16/2020 2:14:00 ewman@md Mortenson causing a default realted to worker retention, shoud be excluded.
PM PIO (Email from Newman C pweb.net Dental Partners
Non-profits, including higher education organizations, employ millions of American workers, have a huge economic impact, and have a
massive impact generally on their local communities. Right now, they are providing essential services in those communities. Non-profits
should be eligible for loans through the proposed Main Street Lending program. To illustrate the point, I work for an arts and culture non-profit
in Providence, RI. Data compiled by the National Endowment of the Arts in 2018 found that the arts contribute $763.6 billion to the U.S.
economy, more than agriculture, transportation, or warehousing. The arts employ 4.9 million workers across the country with earnings of
more than $370 billion. Despite some temporary programmatic suspensions, my organization is still providing essential services such as
housing to low income resident artists and much needed stipends to youth in our community, including incarcerated and formerly incarcerated
youth, those who are pregnant and parenting, youth in foster care, and youth at high risk of school dropout and disconnection. Our services
are needed more than ever during the COVID-19 pandemic. There is no valid reason not to include non-profit businesses such as ours in the
4/16/2020 2:16:00 susan@as22 Main Street Lending program, and not doing so potentially creates further financial burden on already chronically underfunded service
PM PIO (Email from Clausen Susan 0.org AS220 providers.
Page 215 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
Diveplane is a leader in natively-explainable artificial intelligence, and like so many early stage companies we reinvest all the money we bring
in to make our products better, and expand the reach of where our technology can help companies and people. (For example, we are
currently working with a top hospital to create a statistical "twin" of medical data restricted by HIPAA in order to help them unlock
further research using the statistical "twin" data.). As such, we request that alternative metrics other than EBITDA be used for
determining loan minimums and eligibility, such as (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 5% risk) in applying reasonable
underwriting criteria relevant to growth-stage companies, such as cash on hand, existing debt, operating costs, gross margins, etc. Use of
alternatives to EDITDA could allow Diveplane to qualify for the Main Street Lending Program. Further, our receipt and reinvestment of these
mjmeehan@ funds will allow for employee retention, and perhaps even job creation, two things that are needed now more than ever.
4/16/2020 2:19:00 diveplane.co Thank you
PM PIO (Email from Meehan Michael m Diveplane
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 uniquely endangered, and must be included in any and all relief packages available.
Email Address
4/16/2020 2:19:00 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 Madden Grace unprecedented crisis depends on the success of our nation's nonprofits.
Non-profits, including higher education organizations, employ millions of American workers, have a huge economic impact, and have a
massive impact generally on their local communities. Right now, they are providing essential services in those communities. Non-profits
should be eligible for loans through the proposed Main Street Lending program. To illustrate the point, I work for an arts and culture non-profit
in Providence, RI. Data compiled by the National Endowment of the Arts in 2018 found that the arts contribute $763.6 billion to the U.S.
economy, more than agriculture, transportation, or warehousing. The arts employ 4.9 million workers across the country with earnings of
more than $370 billion. Despite some temporary programmatic suspensions, my organization is still providing essential services such as
housing to low income resident artists and much needed stipends to youth in our community, including incarcerated and formerly incarcerated
youth, those who are pregnant and parenting, youth in foster care, and youth at high risk of school dropout and disconnection. Our services
David.dvorch are needed more than ever during the COVID-19 pandemic. There is no valid reason not to include non-profit businesses such as ours in the
4/16/2020 2:19:00 ak@as220.or Main Street Lending program, and not doing so potentially creates further financial burden on already chronically underfunded service
PM PIO (Email from Dvorchak David g AS220 providers.
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
Southeastern uniquely endangered, and must be included in any and all relief packages available.
4/16/2020 2:20:00 tiffany@secf. Council of 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 Friesen Tiffany org Foundations this unprecedented crisis depends on the success of our nation's nonprofits.
Page 216 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, please consider 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; and
In implementing any workforce restoration and retention provisions, "workforce" should be defined as full-time employees or full-
time equivalents.
As you may know, many nonprofits employ more than 500 employees and have not been able to access the Paycheck Protection Program,
which contains loan forgiveness provisions that are critical to these organizations, and necessary to help ensure they will be able to continue
barry.simon to provide services during the crisis and assist with our nation's recovery efforts when the crisis is over.
4/16/2020 2:20:00 @oakhillct.or Thank you;
PM PIO (Email from Simon Barry g Oak Hill Barry Simon
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
virginia@sus Susannah uniquely endangered, and must be included in any and all relief packages available.
4/16/2020 2:20:00 annahdarrow. Darrow 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 Nugent Virginia com Consulting 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 Email
4/16/2020 2:22:00 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 Parker Adam this unprecedented crisis depends on the success of our nation's nonprofits.
Please include nonprofits in your program for Main Street lending. They are a critical part not only of our economy, but also of our society,
and are actually hurting more than most other businesses right now.
Thanks for your consideration.
Sincerely,
Personal Email Norm Richie
4/16/2020 2:23:00 Address Citizen
PM PIO (Email from Richie Norman 404-218-9222
Page 217 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.
mandy@hom
4/16/2020 2:23:00 eaidatlanta.or 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 Crater Amanda g HomeAid Atlanta this unprecedented crisis depends on the success of our nation's nonprofits.
As an individual who has been working in the arts & cultural museum sector in Georgia for the past five years, I am writing in opposition
to the exclusion of nonprofits, institutes of higher learning, and HBCUs from the Main Street Loan Program. In short: The nonprofit sector is
just as critical to economic stability and recovery as the for-profit sector.
Georgia's museum sector has a financial impact of $1.6 billion on the state's economy (American Alliance of Museum and Oxford
Economics, 2017). Georgia's museums and 300+ nonprofit organizations, with 500 or more staff members, each doing vital work during
this unprecedented time, are currently excluded from the Main Street Loan Program.
As large employers, nonprofits, institutes of higher learning, and HBCUs deserve federal support. These organizations also support an array
of small businesses, serve as economic anchors in their communities, and supply critical services at a scale that would be impossible to
replace. In particular, HBCUs are critically essential and uniquely endangered and must be included in any and all relief packages available.
jminiter@mus I urge the Federal Reserve to make nonprofits eligible for the Main Street Loan program. The success of our nation's recovery from this
4/16/2020 2:24:00 eumofdesign. Museum of unprecedented crisis also depends on the success of our nation's nonprofits.
PM PIO (Email from Miniter Janelle org Design Atlanta
I submit the following comments in regards to the Main Street Lending program. Specifically, we ask that the Federal Reserve update the
guidance to clarify that non-profit private and public institutions are eligible for the Main Street Lending program.
Institutions of higher education, often the largest or one of the largest employers in their local communities, are facing a major cash flow crisis
in light of the reduced revenue and increased expenses imposed by the COVID-19 pandemic. Institutions expect to refund nearly $8 billion in
room and board charges alone. My institution refunded almost 10% of our usual revenue to students for room and other refunds.
Institutions of higher education are often the largest, or one of the largest, employers within their community and larger region. Please make
Minneapolis not non-profits IHE eligible. It is vital to provide this access to low-interest loans to non-profit colleges and universities financially devastated
4/16/2020 2:25:00 jbrathwaite@ College for Art by the pandemic.
PM PIO (Email from Brathwaite Joy mcad.edu and Design
On behalf of Río Hondo College, I am writing to request that eligibility guidelines for the "Main Street" lending program be
modified to include non-profits and institutions of higher learning. While it is laudable for the Federal Reserve to provide loans to businesses,
it is critical that non-profit organizations and higher education institutions also have an opportunity to apply for these loans. Rio Hondo
College, like so many other higher education institutions, is facing myriad challenges. In our effort to ensure that our College is receiving the
funding needed to provide quality education, while still addressing basic needs of students, our campus faces multiple demands. Our staff are
working on how to meet mandated faculty obligation numbers, while attempting to adjust to a new student-centered funding formula.
Furthermore, our College is nearing the end of a 15-year construction bond, but still has numerous facilities infrastructure needs.Being able to
apply for new loans of $1 million to $25 million will help our College to meet hiring obligations, cover costs of instructional technology, invest in
professional development activities, and bolster student services for our diverse student body. Thank you for your consideration of this
request.
rcastaneda-
4/16/2020 2:25:00 calleros@rioh Rio Hondo Sincerely,
PM PIO (Email from Reyes Arturo ondo.edu College Dr. Arturo Reyes
San Diego Please extend the Main St. Lending Program to NONPROFIT organizations with budgets under $20 Million. Small to medium size nonprofits
4/16/2020 2:26:00 Martin.Furey American Indian are enormously strained at the moment, and they provide a large portion of our national safety net's service delivery. Thanks for your
PM PIO (Email from Furey Martin @sdaihc.org Health Center consideration of this change.
Page 218 of 363
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Main Street Lending Program Comments
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.
We urge the Federal Reserve to make nonprofits eligible for the Main Street Loan program. The success of our nation's recovery from
Rally Foundation this unprecedented crisis depends on the success of our nation's nonprofits.
kimberly@rall for Childhood
4/16/2020 2:28:00 yfoundation.o Cancer Thank you,
PM PIO (Email from walther kimberly rg Research Kimberly Walther
The Fed is taking unprecedented action to stabilize our economy, and that comes with unprecedented responsibility to inform and engage the
public. First, our officials need access to timely and detailed information on all money lent & spent in order to ensure the public's
best interest is being served. The Fed must frequently disclose to the Congressional Oversight Commission what firms are receiving loans
and on what terms as described by Bharat Ramamurti in a letter to Chairman Powell earlier this week. Second, the Fed must then make that
information available online for the public. The situation demands riskier action than the Fed has ever taken, using taxpayer dollars as a
backstop, and that means taxpayers should be able to see who is benefiting from Fed assistance. With so many Americans struggling to meet
4/16/2020 their most crucial needs, we must guarantee all funds are being used as effectively as possible, and true transparency is essential for
12:00:00 AM PIO (Email from Cross R.J. rj@pirg.org U.S. PIRG ensuring that happens.
We are a small business in the Midwest with over 180 employees, and believe we would be able to utilize this program to not only keep our
Personal payroll intact, but to grow new jobs. The three banks we contacted in Fargo, ND, Sioux Falls, SD and Sioux City, IA were not familiar with the
4/16/2020 2:29:00 Email Address Silverstar Car Main Street program. Any resources you may have of participating banks in the North Dakota, South Dakota or Iowa area would be
PM PIO (Email from Nelson Jillian Wash appreciated.
4/16/2020 2:31:00 keithcp@gbc. Goldey-Beacom I encourage you to include non-profits and the college/university community in this lending program. As the president of a college whose
PM PIO (Email from Keith Colleen edu College majority student body are members of minority communities, having this opportunity would be a welcome one.
Thank you for the opportunity to provide comments on the Main Street New Loan Facility, authorized by the Federal Reserve Act. Our
organization includes 14 of California's largest counties, which work collaboratively with nonprofit behavioral health organizations 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
4/16/2020 2:34:00 jkh@hbeadvo Urban Counties employees or with 2019 annual revenue up to $2.5 billion.
PM PIO (Email from Hurst Jean cacy.com of California
Can you please provide me more information regarding the launch of this program? Is the minimum loan amount 1MM?
Personal
4/16/2020 2:36:00 BPD Support
Email Address
PM PIO (Email from Naselli Mike Services LLC Thank you
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; and
In implementing any workforce restoration and retention provisions, "workforce" should be defined as full-time employees or full-
4/16/2020 2:36:00 kfarry@wood time equivalents.
PM PIO (Email from Farry Kristen s.org Woods Services
Page 219 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.
kkaresh@nas
4/16/2020 2:36:00 hvilleliteracy. Nashville Adult 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 Karesh Kim org Literacy Council 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.
lcolbert@heal
4/16/2020 2:39:00 thyfuturega.o Georgians for a 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 Colbert Laura rg Healthy Future this unprecedented crisis depends on the success of our nation's nonprofits.
We write in opposition to the exclusion of Arts nonprofits, institutes of higher learning, and HBCUs from the Main Street New &
Expannded 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 Email
Address Robert SW. Sincerely,
4/16/2020 2:39:00 Woodruff Arts
PM PIO (Email from Leventhal Max Center, Inc. Max Leventhal
Brooklyn Nonprofits in New York account for 18% of the private workforce, and contribute $800 billion in wages. We have experienced severe financial
4/16/2020 2:39:00 jfarris@wear Community losses and layoffs due to COVID-19. Please include Non-profits in eligibility requirements for the Main Street Lending program.
PM PIO (Email from Farris Janelle ebcs.org Services
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.
patty@bluebi Bluebird
4/16/2020 2:39:00 rdconsultants Communications 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 Gregory Patty .com Consultants this unprecedented crisis depends on the success of our nation's nonprofits.
Page 220 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
Seneca is the largest provider of children's behavioral health in the state of California and serve thousands of children and their families
across a continuum of service settings during the most difficult times of their lives. As this pandemic continues to create new funding
challenges for nonprofits such as Seneca, I ask that you consider the below priorities when forming the next stimulus opportunity. 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, I 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
I urge you to consider the above provisions so that together, we can ensure that the public health crisis of COVID-19 does not becomes a
hope_kamer mental health crisis as well.
4/16/2020 2:41:00 @senecacent Seneca Family Thank you for your dedicated leadership and extreme care during this time.
PM PIO (Email from Berrick Ken er.org of Agencies
As the CEO of Atlanta Georgia's largest homeless resource center, 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 the for-profit business sector.
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 they deserve federal support. These non-profit institutions 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
4/16/2020 2:42:00 rholloway@g this unprecedented crisis is dependent on the success of our nation's nonprofits to remain in-tact and supporting the citizens in their
PM PIO (Email from Holloway Raphael atewayctr.org Gateway Center communities as a service provider and employer.
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.
director@hea
4/16/2020 2:42:00 lingbridgeclini Healing Bridge 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 Conaway Mike c.org Clinic this unprecedented crisis depends on the success of our nation's nonprofits.
Good Afternoon,
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. As a Children's Home, it is imperative to
the safety and security of the children we serve to remain open. If the PPP loan runs out before we are funded, I am not sure how we will be
able to continue providing our current level of services.
4/16/2020 2:43:00 rachel@advo Advocates for 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 Castillo Rachel child.org Children this unprecedented crisis depends on the success of our nation's nonprofits.
Page 221 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
RSM US LLP has submitted a more expansive version of the following comments via email to Fed Sec. Misback.
Passthrough Exemptions: Clarity needed re ability for private businesses and flow through businesses (Partnerships, S Corps, LLCs) to make
tax distributions without violating rules.
Loan Restrictions: Confirmation needed re CARES Act restrictions under 4003(c)(3)(D)(i) on outsourcing/collective bargaining/union
organizing not required under 4003(c)(3)(A)(ii)).
EBITDA Clarity: Consideration should be given to basing EBITDA restrictions on an average of 3 prior years to avoid unintended exclusion of
companies that experienced one-time issues.
Loan Timing: Clarification needed re at what point/on what date is the undrawn portion under the expanded loan facility measured, specifically
the 30% limitation.
Compensation: Allowance should be considered for commissions or other variable items previously committed to in employment
arrangements that might result in an employee receiving over $425k annually.
Affiliation Rules: Confirm no limitation preventing portfolio-backed companies from MS program access.
Foreign Entities: Confirm access for foreign-owned companies with many US based employees.
Small Company Access: Allow for smaller businesses and the 72 NAICS code businesses to obtain PPP and MS loans.
4/16/2020 2:45:00 dan.ginsburg Attestation: Clarify attestations/certifications received from borrowers are sufficient for lenders. Potential CPA firm involvement is unclear.
PM PIO (Email from Ginsburg Dan @rsmus.com RSM US LLP
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.
Email Address
4/16/2020 2:46:00 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 de Wilde Richard this unprecedented crisis depends on the success of our nation's nonprofits. Sincerely, Richard de Wilde
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
Personal
4/16/2020 2:47:00 Latin American this unprecedented crisis depends on the success of our nation's nonprofits.
Email Address
PM PIO (Email from Pascual Aixa Association Thank you for your consideration.
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Main Street Lending Program Comments
This comment is being submitted by Matthew Bornfreund, an attorney at Venable LLP, Washington, DC.
Venable LLP has the country's largest nonprofit practice, and on behalf our nonprofit clients, we respectfully request that the Board of
Governors of the Federal Reserve System ("Board") make two clarifications regarding the Main Street Lending Program and its
associated term sheets.
First, we request the Board confirm our understanding that "Eligible Borrowers" include nonprofit organizations that are exempt
from federal income tax under section 501(a) of the Internal Revenue Code of 1986 and that meet all other requirements to be an Eligible
Borrower.
Second, with respect to calculating the maximum loan size for an Eligible Loan, we request the Board clarify that nonprofit organizations may
use revenue less expenses (as reported on Part I, Line 19 of IRS Form 990 or Part I, Line 27a of Form 990-PF, or in a financial statement)
instead of EBITDA. Many nonprofit organizations do not calculate EBITDA, and revenue less expenses, which is more commonly used by
matthew.born nonprofits, is substantially the same as EBITDA.
4/16/2020 2:47:00 freund@vena
PM PIO (Email from Bornfreund Matthew ble.com Venable LLP Thank you for your consideration.
Hello,
I'm very concerned about how various stimulus packages including the Main Street Lending program do not allow for non-profits,
specifically, 501c6 organizations such as mine. This exclusion ignores the very significant impact such organizations have on community
growth and stability. In my instance, Tourism is one of the top drivers of the economy in Monterey County and top provider of jobs. Yet we are
funded by the very thing this such down prevents - travel. We must have access to favorable grants and loans to survive. Your consideration
4/16/2020 2:47:00 Rob@SeeMo Monterey County is appreciated.
PM PIO (Email from OKeefe Rob nterey.com CVB Rob O'Keefe
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, Community Resources for
Justice requests 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; and
Community + In implementing any workforce restoration and retention provisions, "workforce" should be defined as full-time employees or full-
4/16/2020 2:47:00 jjlarivee@crj. Resources for time equivalents.
PM PIO (Email from Larivee John org Justice Thank you for your consideration.
As a Board Member for the Museum of Design Atlanta, 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.
The Museum of Design Atlanta (MODA) has been working tirelessly to bring needed enrichment activities to children and relief to their parents
by providing valuable learning from trusted providers. That work continues even though MODA is strapped for cash. On premises revenue
has been eliminated, donors have lost jobs and contributors, who are concerned about their business's future, are holding funds. We
need help and OUR COMMUNITY NEEDS US, today and tomorrow.
As large employers alone, non-profits like MODA 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 2:48:00 Email With local community leadership, nonprofits have held the country together through these days of hardship and unity. Please make it possible
PM PIO (Email from Moody Kara Address MODA for our communities to emerge from this crisis whole by including nonprofits in the Main Street Loan program.
Page 223 of 363
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Main Street Lending Program Comments
Blue Dolphin Capital Comment:
1. Under the MSNLF, loans are available up to the greater of:
(i) $25 million; or
(ii) An amount that, when added to the eligible borrower's existing outstanding and committed but undrawn debt, does not exceed ten
times the eligible borrower's 2019 EBITDA.*
2. Under the MSELF, loans are available up to the of:
(i) $150 million;
(ii) Fifty percent of greater eligible borrower's existing outstanding and committed but undrawn bank debt; or
(iii) An amount that, when added to the eligible borrower's existing outstanding and committed but undrawn debt, does not exceed
twelve times the eligible borrower's 2019 EBITDA.*
3. The Main Street SPV on a recourse basis, providing leverage that is expected to result in up to $600 billion in new or expanded bank loans
to eligible borrowers. We recommend of the 600 Billion program to earmark 25 percent of the program specifically for Black Borrowers who
are at an disadvantage. Black owned firms need a special loan program without recourse. If Treasury does not implement this comment as
apart of its guidance's more than fifty percent of Black owned firms will close and never return to the marketplace.
4. Add CDFI as a options to receive funding for Black Owned firms.
Best Regards,
Sam Harris III
Blue Dolphin Capital
4/16/2020 2:49:00 sam@bluedol Blue Dolphin President and CEO
PM PIO (Email from Harris III Sam phincap.com Capital, Inc
I have been with People Inc for almost 30yrs and am one of 4,000 employees. We are 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 various 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 ensure that our homes and services for people with
disabilities remain as safe as possible and are staffed round the clock. The vulnerable people that depend on us deserve this care. However,
because we are providing essential services during the crisis, People Inc. has incurred highly unusual increased costs in staffing, PPE, and
cleaning services.
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 2:51:00 tszuflita@peo
PM PIO (Email from Szuflita Terri ple-inc.org People Inc Thank you in advance for your support of direct care staff, the people we support and our agency, People Inc
Personal It appears that the MSNLF and MSELF would disproportionately help businesses that lease versus companies that own large amounts of real
4/16/2020 2:52:00 Email estate. For Medium Sized companies, like the Fitness industry that were excluded from the PPP, using a metric like EBITDARM would make
PM PIO (Email from Bruner Kyle Address much more sense. This is especially true for hospitals!
I believe it is important to include the nonprofit organization and universities in the lending opportunities due to the COVID-19 Pandemic.
Simply because these entities provide services to the public and employ personnel as well. Due the mandatory shutdown to mitigate the
Erica.Dixon- spread of the coronavirus, they have encountered losses as well: so many scheduled initiatives that would have incurred funding and revenue
4/16/2020 2:53:00 Billups@mia Miami-Dade has been impacted. I feel the support is needed to sustain the services that are provide to help develop our leaders of tomorrow.
PM PIO (Email from Dixon-Billups Erica midade.gov County
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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
As part of the bipartisan CARES Act, the Federal Reserve recently announced its new "Main Street" lending facility. This facility
will support up to $600 billion in bank lending to small and mid-sized businesses, including two lending options: new loans of $1 million to $25
million, or expansion of a business's existing loan with a bank to up to $150 million. Unfortunately, the Administration and the Federal
Reserve, as of today, are considering the exclusion of nonprofits, many institutions of higher learning and Minority-Serving Institutions. This is
a significant negative blow in particular to entities that are also ineligible for the Paycheck Protection Program.
Illinois Academy Associations are non-profit organizations helping our members to cope with the COVID19 crisis. As our members suffer, so do our
4/16/2020 2:53:00 vkeenan@iaf of Family organizations. Please include associations in the Main Street Lending opportunity
PM PIO (Email from Keenan Vincent p.com Physicians
The MSELP requires an applicant to have a prior term loan. This provision, not required by The CARES Act, has largely made the MSELP
unusable for companies utilizing special purpose entities ("SPE") to finance projects. Many companies that sponsor development
projects do not have term loans. These companies use an SPE, which (i) owns the project's assets, (ii) is the project contracting entity,
and (iii) arranges funding from the SPE's owners and lenders through asset-based financing. Usual sources of asset-based financings
are unavailable, even for shovel-ready projects. Without MSELP funding, projects will be abandoned, with a devastating effect on employees
and community. Favoring companies with prior term loans over companies with no term debt but a proven record of project execution is
neither fair nor required.
We also request clarification that the term sheet provisions that prohibit dividends, stock buybacks, or compensation increases will not be
imposed on SPE owners.
tom.leonhard Using EBITDA to determine the maximum borrowing amount does not work for an SPE without a prior history. We recommend relying on the
4/16/2020 2:57:00 @hripropertie lender's underwriting expertise that will focus on assessing project viability, collateral value, and ability to repay. Asset-based financings
PM PIO (Email from Leonhard Tom s.com HRI Properties are not unusual and underwriting factors utilized by lenders for these loans should be satisfactory.
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 2:57:00 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 Folio Patricia Act3 Productions this unprecedented crisis depends on the success of our nation's nonprofits.
Non-profits, including higher education organizations, employ millions of American workers, have a huge economic impact, and have a
massive impact generally on their local communities. Right now, they are providing essential services in those communities. Non-profits
should be eligible for loans through the proposed Main Street Lending program. To illustrate the point, I work for an arts and culture non-profit
in Providence, RI. Data compiled by the National Endowment of the Arts in 2018 found that the arts contribute $763.6 billion to the U.S.
economy, more than agriculture, transportation, or warehousing. The arts employ 4.9 million workers across the country with earnings of
more than $370 billion. Despite some temporary programmatic suspensions, my organization is still providing essential services such as
housing to low income resident artists and much needed stipends to youth in our community, including incarcerated and formerly incarcerated
youth, those who are pregnant and parenting, youth in foster care, and youth at high risk of school dropout and disconnection. Our services
are needed more than ever during the COVID-19 pandemic. There is no valid reason not to include non-profit businesses such as ours in the
4/16/2020 2:59:00 neal@as220. Main Street Lending program, and not doing so potentially creates further financial burden on already chronically underfunded service
PM PIO (Email from Walsh Neal org AS220 providers.
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Main Street Lending Program Comments
I am affiliated with a non-profit organization that provides behavioral health, child welfare services, housing support to individuals in
California.
I ask the Federal Reserve and Treasury Department to immediately issue guidance on a program, as directed under the CARES Act, to
provide financing to banks and other lenders to make loans to non-profits and other mid-size businesses (between 500-10,000 employees).
We request that the program include the following:
oInclude a 0.50% interest rate (50 basis points) for 501(c)(3) charitable nonprofits at a 5-year amortization
oProvide priority to 501(c)(3) charitable nonprofits responding to COVID-19 relief efforts
Hathaway- oPayments should not be due until two years after a direct loan is made
jchandleroch Sycamores Child oEmployee retention provisions should begin on the date that loan funding is received by the borrower
4/16/2020 3:00:00 oa@hscfs.or and Family oIn any workforce restoration and retention provisions, "workforce" should be defined as full-time employees or full-time
PM PIO (Email from Chandler-Och Jerriann g Services equivalents
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 3:02:00 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 Gump Warren this unprecedented crisis depends on the success of our nation's nonprofits.
4/16/2020 3:02:00 kmattson@sy San Ysidro Very disappointed that this program is not available to nonprofit organizations. To date there is no program for a nonprofit organization with
PM PIO (Email from Mattson Kevin health.org Health over 500 employees and we are being hit very hard by the impact of COVID-19
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 3:04:00 gsimon@mac Metro Atlanta 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 Simon Gregg oc.com Chamber this unprecedented crisis depends on the success of our nation's nonprofits.
We write to provide feedback sought by the Federal Reserve in its announcement of additional actions on April 9, 2020 to address the
significant unmet needs of mid-sized companies, many of which will suffer catastrophic effects from the COVID-19 crises.
Mid-sized companies frequently cannot obtain credit from banks, which often seek to minimize their risk profile by lending only to established
organizations or entities not engaged in activities that many mid-sized entities engage in. As a result, many mid-sized companies need to
obtain credit from non-bank specialty finance companies that have emerged to meet the unmet demand for credit. Limiting participation in the
Main Street programs to only banks fails to address the financial needs of many mid-size companies.
Similarly, given that the terms of the facilities require a bank to retain a 5% participation in any loan it originates, banks with credit policies that
preclude lending to mid-sized companies or those engaged in specific industries will not be willing to originate loans under the program, failing
to address the financial needs of mid-sized companies.
Accordingly, we request the Federal Reserve modify the Main Street Facilities to (i) allow non-banks to participate; and (ii) eliminate the need
lawrencekapl for originating lenders to retain 5% of any loan originated under the program. Both modifications will preserve mid-sized companies and their
4/16/2020 3:04:00 an@paulhasti Paul Hastings. employees.
PM PIO (Email from Kaplan Lawrence ngs.com LLP
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Main Street Lending Program Comments
Nonprofits are critical to the economic well being of our communities. They are working over capacity to provide nutrition and support due to
the economic slowdown and food scarcity caused by COVID-19.
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 3:05:00 Email the Wylde 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 Leach Mary Address Center 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 3:06:00 mary.benton Alston & 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 Benton Mary @alston.com Bird this unprecedented crisis depends on the success of our nation's nonprofits.
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.
kschillace@r
4/16/2020 3:06:00 oadrunner.co Thank you in advance for your support of direct care staff, the people they support and People Inc.
PM PIO (Email from Schillace Kim m People Inc.
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, I 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; and
In implementing any workforce restoration and retention provisions, "workforce" should be defined as full-time employees or full-
time equivalents.
Thank you for your consideration
4/16/2020 3:06:00 kwilliams@ad Karen Williams
PM PIO (Email from Williams Karen vocates.org Advocates
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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
4/16/2020 3:07:00 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 Biddy Darlene Address
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 Email Offering thousands of virtual experiences for activity, engagement, and connectedness.
4/16/2020 3:08:00 Address
PM PIO (Email from Conely Whitney It is so important to our community to keep the YMCA's of Greater Louisville going!
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 3:09:00 Email 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 Suguitan-Lee Heather
Nonprofits have substantial leverage in terms of both employment of workers and service to those greatly affected by COVID-19 and the
related economic downturn. As a result, nonprofits should be prioritized in any further action taken in response to COVID-19 and its impact to
create forgivable loan opportunities. The short and long-term health of our communities and economy are dependent upon more robust
4/16/2020 3:12:00 tcook@prokid action to support the work and employees of nonprofits, during these incredibly challenging and pivotal times.
PM PIO (Email from Cook Tracy s.org ProKids
4/16/2020 3:13:00 Personal Email Save our Not for Profits, they are assisting families during this pandemic.
PM PIO (Email from Ward Calvin Address
4/16/2020 3:13:00 Ejh@rh- Please include non-profit Organizations as eligible under the Main Street Loan. These large employers, poverty fighting and educational
PM PIO (Email from Hardin Edward j law.com Multiple institutions are essential to our economy and their survival is critical to their employees.
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 a for-profit business.
Nonprofit institutions serve thousands of people in every community: feeding the hungry, offering help for the disenfranchised, and raising the
spirit of humanity through art, dance, and song - the very things many people are relying on to get through this pandemic.
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 Atlanta Ballet,
4/16/2020 3:14:00 Address Out Front 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 Cooper Kelly Tonina Theatre this unprecedented crisis depends on the success of our nation's nonprofits.
Please ensure nonprofits are explicitly named as eligible recipients of the Main Street Lending Program. Despite being closed, our Y is
providing child care for Health, Emergency and other essential workers as requested by our Governor. Our Teen Shelter for homeless and
abused youth has remained open, as well as our shelter for homeless men. Volunteers have made wellness calls to our more delicate
4/16/2020 3:15:00 arohleder@t members and we are holding virtual classes on line so our members can have the experience to stay healthy and fit. Please help our Y to be
PM PIO (Email from Rohleder Mary wc.com Ms. able to respond the the needs of our members and community. Thank You!
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Main Street Lending Program Comments
These programs should not discriminate against well-run businesses experiencing hardship (e.g., negative EBITDA) before COVID-19 where
the outbreak has severely impacted their business leading to further decline in demand as individuals adhere to strict social
distancing.Treasury should amend the guidance under these programs as follows: Specific Main Street Program Suggested Changes (Based
on Term Sheet Headings): 1.Eligible Borrowers: Change the qualifying standards to $5.0 billion for commodity-based firms 2.Eligible Loans:
a.Make the maximum amount of money available under either program equal (e.g., $150 million), thereby not preferential to companies that
were already levered
b.Change the language under the maximum loan (Section 5 of both programs) to read as follows: "Maximum loan size that is the lesser
of (i) $150 million or (ii) 5% of Eligible Borrower's 2019 revenues." c.Eliminate the EBITDA language under MSNLF (Section 5(ii)
and under MNSELF (Section 5(iii) for those that can provide # 3.Loan Participations: a.Insure non-discriminatory lending by financial
devin.mogler institutions to make funds available to all businesses that meet qualifications 4.Required Attestations: Allow for use of proceeds to repay
4/16/2020 3:15:00 @gpreinc.co certain debt or otherwise provide for cures under existing lender covenant requirements
PM PIO (Email from Mogler Devin m Green Plains Inc.
I am seeking guidance as to how the various limitations associated with the Main Street Lending Program will be applied to flow through
entities. There should be an exception to the limit on capital distributions to allow partnerships to distribute cash to partners to enable the
partners to pay the tax liability associated with the income that is allocated to the partners on their Schedule K-1. Not allowing for income tax
4/16/2020 3:18:00 jfinnerty@nrp distributions to cover federal, state and sometimes local tax liabilities will be a hardship on partners who may not be otherwise able to satisfy
PM PIO (Email from Finnerty Jim group.com The NRP Group their tax obligations.
I am writing as a representative of over 500 small businesses employing more than 13,000 workers to provide feedback on the proposed Main
Street Lending Program.
Hundreds of business owners in Charleston and across South Carolina are currently unable to pay rent on the storefront their business
occupies. A town that sees thousands of visitors each year and has seen lease rates climbing by 26% in one year are now shuddering their
doors due to COVID19. We know that a strong economic recovery will be based on how many of these small businesses that we are able to
preserve. But in these unprecedented times, tenants can't pay rent, and landlords may find it difficult to make mortgage payments.
In cases where the bank providing Main Street Lending 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 now expended 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.
jamee@lowc Whatever the method, the need to prevent the eviction of Main Street businesses that will be the lifeline of recovery should require banks
4/16/2020 3:18:00 ountrylocalfir Lowcountry providing federal loans to relieve these mortgages, which are imperative to keep healthy Main Streets everywhere.
PM PIO (Email from Haley Jamee st.org Local First
The economic shutdown related to Covid-19 has been devastating to a number of our clients, who need CARES Act relief. Given their size
and the loan amounts they need, the only program available to many is the Expanded Loan Facility (MSELF). However, as currently
described in the Term Sheet, several cannot participate in the MSELF because they do not have a term loan outstanding with an eligible
lender. They do, however, have other forms of credit, such as lines of credit or credit facilities, with eligible lenders. The term loan qualification
to participate in the MSELF unnecessarily restricts the program's ability to assist businesses that are in need during this time of crisis.
Letters of credit, credit facilities, credit lines and other forms of lending with an eligible lender should also allow an eligible borrower to borrow
under the MSELF. The principles underlying know-your-customer policies and traditional credit evaluation favor higher caps or limitations on
available loans to borrowers who have existing relationships with federally insured depository institutions. But, these same principles apply to
Nelson Mullins all types of credit, not just term loans. Therefore, by requiring the existence of a term loan, rather than any other form of credit, the MSELF
jon.talcott@n Riley & unnecessarily limits the amount of support that will be given to businesses, a direct contradiction to its stated goal to "enhance support
4/16/2020 3:18:00 elsonmullins. Scarborough for small and mid-sized businesses" and help "businesses keep their workers on payroll."
PM PIO (Email from Talcott Jonathan com LLP
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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
Personal uniquely endangered, and must be included in any and all relief packages available.
Email Address
4/16/2020 3:19:00 Tri-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 Holmes Pamela CASA, Inc. this unprecedented crisis depends on the success of our nation's nonprofits.
Non-profits, including higher education organizations, employ millions of American workers, have a huge economic impact, and have a
massive impact generally on their local communities. Right now, they are providing essential services in those communities. Non-profits
should be eligible for loans through the proposed Main Street Lending program. To illustrate the point, I work for an arts and culture non-profit
in Providence, RI. Data compiled by the National Endowment of the Arts in 2018 found that the arts contribute $763.6 billion to the U.S.
economy, more than agriculture, transportation, or warehousing. The arts employ 4.9 million workers across the country with earnings of
more than $370 billion. Despite some temporary programmatic suspensions, my organization is still providing essential services such as
housing to low income resident artists and much needed stipends to youth in our community, including incarcerated and formerly incarcerated
youth, those who are pregnant and parenting, youth in foster care, and youth at high risk of school dropout and disconnection. Our services
are needed more than ever during the COVID-19 pandemic. There is no valid reason not to include non-profit businesses such as ours in the
Personal
4/16/2020 3:21:00 AS220 Youth Main Street Lending program, and not doing so potentially creates further financial burden on already chronically underfunded service
Email
PM PIO (Email from Davis Simcha Address Studio providers.
We are an American company headquartered in Palm Beach Gardens, Florida, with 9,727 employees based in the U.S. and 982 based
internationally. Since 2018, we have been jointly owned by two foreign entities. Under the Main Street Lending Program's proposed
eligibility criteria, it is unclear whether our operations outside the U.S. or our foreign parents are included in the analysis of whether we are
eligible for a loan under the Program. We would be eligible under the Program if considered as a standalone U.S. entity; however, we would
not be eligible under the Program if considered together with our foreign parents and employees.
We believe we should be evaluated for a loan under traditional banking underwriting procedures as a standalone U.S. entity. Evaluating our
eligibility as a standalone entity would be consistent with long-standing bank underwriting practices and the procedures adopted by the
SBA's Paycheck Protection Program. Under the PPP, an applicant's foreign-based employees are not counted against eligibility.
Both the Program and PPP were established to help "businesses keep their workers on payroll." The Program was established
"to enhance support for small and mid-sized businesses" and businesses may participate in both the Program and PPP. Therefore
the Program should adopt a similar rule to broaden the eligibility of prospective domestic companies to achieve its goal.
4/16/2020 3:21:00 eolsen@tbcc
PM PIO (Email from Olsen Erik orp.com TBC Corporation
I am seeking guidance as to how the various limitations associated with the Main Street Lending Program will be applied to flow through
entities. Guidance is needed to understand how the compensation limitations will apply to a partner in a partnership. Guaranteed payments
for services could reasonably be included in determining compensation paid to a partner. However, for partnerships that do not pay
guaranteed payments (and for amounts of partnership income that are in excess of guaranteed payments), it would not be appropriate to treat
4/16/2020 3:22:00 jfinnerty@nrp a partner's share of distributable income as compensation as there is no way to apply a limit to this income allocation under current
PM PIO (Email from Finnerty Jim group.com The NRP Group partnership law.
I am on the board of Out Front Theatre, a regional 503(c) production company. There is concern that small non profits like ours may be
excluded from COVID -19 relief packages. While we are not a large employer, we employee a full time staff and many contract set designers,
lighting and production professionals, marketing and PR firms, printers, and actors for our productions. When we were shut down by the CIty
Personal
4/16/2020 3:22:00 Diane Haymes of Atlanta over the virus all of these contract people lost their income from us. We count, the arts matter, please make sure that small non-
Email Address
PM PIO (Email from Haymes Diane Photography profits are included in the relief efforts.
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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
I write in opposition to the exclusion of nonprofits, institutes of higher learning, and especially HBCUs from the Main Street New &
Expanded Loan Facilities. The nonprofit sector is just as critical to economic stability and recovery as for-profit businesses.
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. It is also home to the Atlanta University Center where the nation's
top-tier HBCU institutions are located.
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.
I 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 3:22:00 jrgarre@emo
PM PIO (Email from Garrett Jamila ry.edu Thank you for your consideration.
As part of the bipartisan CARES Act, we were thrilled to hear that the Federal Reserve recently announced its new "Main Street"
lending facility. Unfortunately, our understanding is that currently as the proposal has been written, the lending facility is excluding nonprofits,
many institutions of higher learning and Minority-Serving Institutions. We are a mid-size higher education institution and were in good
financial standing prior to the COVID-19 crisis. We are one of the organizations that are also ineligible for the Paycheck Protection Program.
4/16/2020 3:22:00 tnawabi@pra As a result of not extending the lending program to all higher education institutions would be a significant blow to our organization and many
PM PIO (Email from Nawabi Tom tt.edu Pratt Institute other higher education institutions across the country.
Non-profits, including higher education organizations, employ millions of American workers, have a huge economic impact, and have a
massive impact generally on their local communities. Right now, they are providing essential services in those communities. Non-profits
should be eligible for loans through the proposed Main Street Lending program. To illustrate the point, I work for an arts and culture non-profit
in Providence, RI. Data compiled by the National Endowment of the Arts in 2018 found that the arts contribute $763.6 billion to the U.S.
economy, more than agriculture, transportation, or warehousing. The arts employ 4.9 million workers across the country with earnings of
more than $370 billion. Despite some temporary programmatic suspensions, my organization is still providing essential services such as
housing to low income resident artists and much needed stipends to youth in our community, including incarcerated and formerly incarcerated
Personal youth, those who are pregnant and parenting, youth in foster care, and youth at high risk of school dropout and disconnection. Our services
Email are needed more than ever during the COVID-19 pandemic. There is no valid reason not to include non-profit businesses such as ours in the
4/16/2020 3:26:00 Address Main Street Lending program, and not doing so potentially creates further financial burden on already chronically underfunded service
PM PIO (Email from MacDonald Kate Citizens Bank providers.
*Full text of comments submitted via email*
The term sheet for the Main Street Lending Programs (MSLP) states that "The Eligible Borrower must attest that it will follow.capital
distribution restrictions that apply to direct loan program under section 4003(c)(3)(A)(ii) of the CARES Act."
This language is designed to prevent corporate entities from returning loan proceeds to stockholders through dividends. However, the
language can be construed as prohibiting all cash distributions by eligible borrowers, including distributions made by partnerships.
Partnership entities, including master limited partnerships (MLPs), operate differently than corporations and must be able to make regular
distributions as an inherent component of their unique business model. This model allows MLPs to attract the dollars needed to provide our
nation's critical energy infrastructure. Prohibiting such distributions would be incompatible with the operation of these partnerships, and
would preclude MLPs from utilizing the MSLP, unnecessarily restricting access to the MSLP from a crucial sector of our economy and
nation's energy infrastructure.
The Federal Reserve should provide guidance making it clear that MSLP dividend restrictions, including the term sheet language related to
Joshua.Zive "other capital distributions," do not prohibit partnerships from making regular cash distributions in the ordinary course of business.
4/16/2020 3:26:00 @bracewell.c
PM PIO (Email from Zive Joshua om Bracewell LLP
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Main Street Lending Program Comments
I am writing to 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. 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.
Personal
4/16/2020 3:27:00 Email 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 White Eugene Address unprecedented crisis depends on the success of our nation's nonprofits.
As a nonprofit with a mission of creating vibrant commercial districts, small businesses are the fabric of our community and the core focus of
our technical assistance efforts. Approximately 35.7 million Americans employed by small businesses appear to be at risk of unemployment.
Beyond low-interest loans, business owners primarily need financial assistance and penalty-free extensions on expenses.
It is imperative that the Main Street Lending Program account for two things: the dire need for terms that allow our small business community
to fully rebound and to allow nonprofits - particularly those supporting small, lifestyle businesses - to be included in these provisions.
The stimulus package provided loan forbearance for SBA loans, which is a great first step, but we must ensure that small businesses with
other forms of debt are supported. Please consider allowing nonprofits the opportunity to receive funding under this legislation as a boots-on-
the-ground resource to advocate for and implement policies and programs to help our small business community rebound. Furthermore,
implement provisions that extend beyond favorable loan terms and earmark a portion as forgivable as our small business desperately need
financial assistance that will not further impact their bottom line through the accrual of more debt.
4/16/2020 3:28:00 taylor@revbir
PM PIO (Email from Clark Taylor mingham.org REV Birmingham
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.
Out Front
Personal Email
4/16/2020 3:28:00 Address Theatre 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 Silvestri Nick company 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 3:28:00 gregory.hesto 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 Heston Greg n@ey.com EY this unprecedented crisis depends on the success of our nation's nonprofits.
Page 232 of 363
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Main Street Lending Program Comments
We are writing with STRONG 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.
People and communities now more than ever are needing non-profits to help meet basic needs for food, shelter, healthcare, safety, and
mental health and well-being issues. Nonprofits are meeting the needs of those most vulnerable in communities across GA. They are
pivoting with the times, as they always do, to ensure those least able to protect themselves have the means to do so. They MUST be
included in new legislation or regulations that address and bolster GA's businesses - as they ARE businesses. Georgia nonprofits have
hundreds of staff each doing vital work during this unprecedented time, and each set to be left behind by this (and previous) relief efforts.
stephanie.wa Building We urge the Federal Reserve to make nonprofits eligible for the Main Street Loan program. The success of our nation's recovery from
4/16/2020 3:28:00 tson@pobox. Connections, this unprecedented crisis depends on the success of our nation's nonprofits.
PM PIO (Email from Watson Stephanie com LLS
APLA Health is deeply concerned to learn that nonprofits are ineligible for the Federal Reserve's new "Main Street" lending
facility, despite the fact that nonprofits are leading the effort to respond to this pandemic. APLA Health is a federally qualified health center,
with a focus on LGBT and other low-income marginalized populations, and people living with and at risk for HIV. All the populations APLA
Health serves are disproportionately impacted by COVID-19. Our clinics continue to see all who present at our doors, including when
appropriate patients presenting with suspected COVID-19 symptoms. However, our revenues are currently diminished by fewer patient visits
during the COVID crisis. Nonprofits like ours need access to these government backed revenue streams and loan programs. This is a
particularly devastating blow for larger nonprofits who are currently ineligible for the Paycheck Protection Program. Given the current financial
crisis and loss of revenue, nonprofits may be forced to shrink their services or even close, meaning tens of thousands could go without care.
4/16/2020 3:29:00 PCurtis@apl We urge the Federal Reserve to expand the eligibility of this program to explicitly include nonprofits.
PM PIO (Email from Curtis Philip a.org APLA Health
I'd like to offer my support of the American Council of Education's (ACE's) comments sent to you on April 16, 2020 regarding
the MSNLF.
I applaud the Federal Reserve's efforts in establishing the MSNLF to enhance support for small and mid-sized businesses affected by
the COVID-19 pandemic, but I think public universities should have access to MSNLF loans should we need them. Our states are not able to
absorb one-time losses that could exceed $100 million per university.
First, UConn has a $1.3 billion annual operating budget, two-thirds of which we generate ourselves through tuition, fees, and our business
auxiliaries (e.g., housing, dining, parking, sporting events, etc.). Our state contributes about a third of our revenues. Thus, we effectively
operate as a mid-size business delivering educational and research and development services.
Second, if social distancing runs into the fall semester of 2020, it could lead to a $74 million loss in tuition revenues from international and out-
of-state students alone, and $58 million in lost housing and dining revenues. Access to short-term lending at favorable rates would help us
bridge the gap between normal operations.
Finally, our 31,000 students rely strongly on our ability to sustain our academic, research, and public service operations that helps them begin
4/16/2020 3:32:00 scott.jordan University of their careers. Access to MSNLF loans will help us continue and complete their college experience on-time. Thank you for your leadership
PM PIO (Email from Jordan Scott @uconn.edu Connecticut during this unprecedented time.
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 3:33:00 jamie@rallyfo 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 Mitchell Jamie undation.org Rally Foundation this unprecedented crisis depends on the success of our nation's nonprofits.
Page 233 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;
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; and
In implementing any workforce restoration and retention provisions, "workforce" should be defined as full-time employees or full-
4/16/2020 3:33:00 bowdenk@fc Friendship time equivalents.
PM PIO (Email from Bowden Karla care.org Community Care
We ask the Fed to address two issues:
Provide clarification that exec comp does not include vesting or exercise of previously granted stock options, particularly when those stock
options may be illiquid or the fair market value may be based on a prior valuation that has likely dropped as a result of COVID, cannot be
valued easily at the time of vesting, and cannot be disposed of or sold. If stock or options are included, this would disadvantage private
companies whose founders often receive substantial stock in trade off for many years at low salaries while the company is built. Private
companies need this facility to continue to meet the needs of customers, but would not be able to meet the compensation change cap if stock
that vests over the subsequent 12 months is counted as compensation. We ask that you include only cash compensation and liquid stock in
the definition of exec comp and not include any periodic vesting of previously granted stock as an "increase" in total compensation.
The maximum loan amounts in the term sheet are based on an EBITDA multiplier. However, many early-stage companies that provide
valuable services to small businesses have a negative EBIDTA, and would be ineligible even though they regularly verify solvency with
lenders, investors, and counterparties using other metrics. We suggest the Fed evaluate companies' needs based on a percentage of
4/16/2020 3:36:00 legal@gusto. valuation or commonly accepted debt/equity metrics on a per industry basis.
PM PIO (Email from Quick Jeanette com
The Humane I do not think non profits should be excluded from this lending program. I volunteer with the Humane Society of Statesboro and Bulloch
Society of County. Non profits serve a vital function in the United States and it is important to keep them strong.
4/16/2020 3:36:00 Personal Email Statesboro and
PM PIO (Email from Mitchell Carrie Address Bulloch County
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.
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.
I have been employed by a non-profit and now serve on the board of this same non-profit and have personally seen the positive impact it has
Personal Email
4/16/2020 3:37:00 South Georgia had on our small community. We are blessed with several non-profits in our small town and each one contributes immeasurably to this
Address
PM PIO (Email from Arline Helen Ballet community. Thank you
Please include nonprofits in any additional funding made available through the PPP.
4/16/2020 3:37:00 Personal Best,
PM Email Address
PIO (Email from Aker Anthony Anthony
Page 234 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 a nonprofit in Massachusetts that shelters and houses homeless men and women, 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, such as
ours, 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.
aimee.coolid
4/16/2020 3:37:00 ge@pinestre Thank you for your consideration.
PM PIO (Email from Coolidge Aimee etinn.org Pine Street Inn
Regarding The Main Street Loan Facility.
Point #5, the term "undrawn debt" should be eliminated. In the wholesale industry, this term
brett.schneid would make many companies ineligible.
4/16/2020 3:37:00 er@madison
PM PIO (Email from Schneider Brett electric.com Thank you
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; and
Friendship In implementing any workforce restoration and retention provisions, "workforce" should be defined as full-time employees or full-
4/16/2020 3:38:00 reevess@fcc Community time equivalents.
PM PIO (Email from Reeves Sara are.org Care, Inc.
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; and
Friendship In implementing any workforce restoration and retention provisions, "workforce" should be defined as full-time employees or full-
4/16/2020 3:38:00 brownm@fcc Community time equivalents.
PM PIO (Email from Brown Marcia are.org Care, Inc.
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; and
In implementing any workforce restoration and retention provisions, "workforce" should be defined as full-time employees or full-
4/16/2020 3:39:00 tackettc@fcc Friendship time equivalents.
PM PIO (Email from Tackett Caitlin are.org Community Care
Page 235 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 3:39:00 mark@theHol Gateway Center 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 Holzberg Mark zbergs.com for Homeless this unprecedented crisis depends on the success of our nation's nonprofits.
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; and
In implementing any workforce restoration and retention provisions, "workforce" should be defined as full-time employees or full-
4/16/2020 3:39:00 goodmana@f time equivalents.
PM PIO (Email from Goodman Amy ccare.org
We write in opposition to the exclusion of nonprofits from 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.
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
12:00:00 AM PIO (Email from popper kirstin this unprecedented crisis depends on the success of our nation's nonprofits.
Address
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; and
Friendship In implementing any workforce restoration and retention provisions, "workforce" should be defined as full-time employees or full-
4/16/2020 3:42:00 schaubroeck Community time equivalents.
PM PIO (Email from Schaubroeck Antonia a@fccare.org Care, 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,
Personal Email we request that the Mid-Size Loan Program have provisions to convert to a forgivable loan for nonprofits that face staggering losses due to
4/16/2020 3:43:00 Address COVID-19. This would grant them the same protections as PPP.
PM PIO (Email from Regan Teresa
Bogard My Company is interested in participating in the Main Street Lending Program. We own a significant dollar amount of mortgage backed
Agricultural property that seems to fit this program. We provide Groundwater Preservation relief for a large area designated as a critical Groundwater
4/16/2020 Personal Email Consultancy Depletion area and need help.
Address
12:00:00 AM PIO (Email from Bogard Jerry Group inc
Page 236 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 finding that banks still do not have any information about this Main Street Loan Program. Would you please advise which banks will be
4/16/2020 rybarra@asc Ascent Foods, elegible on this program?
12:00:00 AM PIO (Email from Ybarra Ricardo entfoods.com LLC
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; and
Friendship -In implementing any workforce restoration and retention provisions, "workforce" should be defined as full-time employees or full-
4/16/2020 3:44:00 millera@fccar Community time equivalents.
PM PIO (Email from Miller Amy e.org Care, Inc.
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
mcressler@ig uniquely endangered, and must be included in any and all relief packages available.
4/16/2020 3:45:00 natiushouse. 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 Cressler Maria org Ignatius House this unprecedented crisis depends on the success of our nation's nonprofits.
MAINSTREET LENDING- Please ensure that nonprofit employers with between 500 and 10,000 employees are able to access the loan. The
YMCA and it's staff was instrumental in finding fellowship and physical fitness within our community when my son was just starting out
Personal 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 3:45:00 Email Address
seem right because they have the ability to utilize those employees to positively impact so many more lives!
PM PIO (Email from Coarse Kimberly
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; and
Friendship In implementing any workforce restoration and retention provisions, "workforce" should be defined as full-time employees or full-
4/16/2020 3:45:00 caldwellc@fc Community time equivalents.
PM PIO (Email from Caldwell Connie care.org Care, Inc.
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; and
In implementing any workforce restoration and retention provisions, "workforce" should be defined as full-time employees or full-
4/16/2020 3:46:00 philpotr@fcca Friendship time equivalents.
PM PIO (Email from Philpot Renee re.org Community Care
Page 237 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;
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; and
In implementing any workforce restoration and retention provisions, "workforce" should be defined as full-time employees or full-
time equivalents.
As you have shared with us, many nonprofits employ more than 500 employees and have not been able to access the Paycheck Protection
Program, which contains loan forgiveness provisions that 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.
4/16/2020 3:46:00 ktefelski@va
PM PIO (Email from Tefelski Karen accses.org vaACCSES
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 3:46:00 info@aysc.or Atlanta Young 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 Thompson Virginia g Singers this unprecedented crisis depends on the success of our nation's nonprofits.
The operations and finances of 501(c)(3) charitable nonprofits are particularly stressed and such organizations do not have the same
capability to ramp-up revenue generation as quickly as business organizations. We therefore recommend enhanced loan terms for such
nonprofits as long as they are capable of submitting credit-worthy applications. Such terms should include a 0.50% interest rate for a 5-year
term and with a 20-year amortization.
Among 501(c)(3) charitable nonprofits, priority should be provided to applicants certifying that they are directly engaged in providing COVID-
19 relief. Such priority should include the following practices.
oSuch applications should be considered before other nonprofit applications.
oSuch applications should be prioritized for maximum feasible funding. If there is insufficient funding to grant all nonprofit loans in the full
amounts applied-for, applicants of charitable nonprofits providing COVID-19 relief should receive a higher percentage of funds applied-for
than those nonprofits not providing COVID-19 relief.
Payments on loans made to 501(c)(3) charitable nonprofits should not be due until two years after a direct loan is received.
4/16/2020 3:50:00 cburkhardt@ Barnes & To distinguish between sets of loans and to reserve funds for social service organizations to apply to, we suggest a set aside of funds within
PM PIO (Email from Burkhardt Craig btlaw.com Thornburg LLP the MSBLP.
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
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.
Children's Home Charitable nonprofits play the third largest employer in our nation's economy. The recommendations above will help to keep non-profits
4/16/2020 3:51:00 andry.sweet Society of financially strong and allow them to continue to meet the immediate needs of their communities.
PM PIO (Email from Sweet Andry @chsfl.org Florida
Page 238 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
Non-profits, including higher education organizations, employ millions of American workers, have a huge economic impact, and have a
massive impact generally on their local communities. Right now, they are providing essential services in those communities. Non-profits
should be eligible for loans through the proposed Main Street Lending program. To illustrate the point, I work for an arts and culture non-profit
in Providence, RI. Data compiled by the National Endowment of the Arts in 2018 found that the arts contribute $763.6 billion to the U.S.
economy, more than agriculture, transportation, or warehousing. The arts employ 4.9 million workers across the country with earnings of
more than $370 billion. Despite some temporary programmatic suspensions, my organization is still providing essential services such as
housing to low income resident artists and much needed stipends to youth in our community, including incarcerated and formerly incarcerated
youth, those who are pregnant and parenting, youth in foster care, and youth at high risk of school dropout and disconnection. Our services
are needed more than ever during the COVID-19 pandemic. There is no valid reason not to include non-profit businesses such as ours in the
Personal
4/16/2020 3:51:00 Main Street Lending program, and not doing so potentially creates further financial burden on already chronically underfunded service
Email Address
PM PIO (Email from Basile Catherine AS220 providers.
In support of the 4,000 employees of a regional non-profit health and human services agency that provides programs and services to nearly
10,000 people with intellectual and developmental disabilities, special needs, their families and older adults throughout numerous counties in
Western New York and the Greater Rochester region, I am writing today to inform you that People Inc. is fully engaged in dealing with the
COVID-19 crisis. They must ensure that more than 150 community-based homes and services for people with disabilities remain as safe as
possible and are staffed 24/7. The vulnerable people that depend on People Inc. deserve no less. However, because they are providing
essential services during the crisis, People Inc. has incurred highly unusual increased costs in staffing, PPE, and cleaning services.
Since People Inc. is not eligible for the Payroll Protection Program (PPP) due to their size and the fact that they must remain fully operational,
we request that the Mid-Size Loan Program have provisions to convert to a forgivable loan for nonprofits that face staggering losses due to
COVID-19. This would grant them the same protections as PPP.
4/16/2020 3:51:00 Personal Email Thank you in advance for your support of direct care staff, the people they support and People Inc.
Address
PM PIO (Email from AbuSitta Mary
Please extend this legislation to include non-profits
4/16/2020 3:54:00 janice@edrcs Eating Disorders
PM PIO (Email from Bremis Janice v.org Resource Center
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 Email
4/16/2020 3:54:00 Address Thank you in advance for your support of direct care staff, the people they support and People Inc.
PM PIO (Email from Regan Darcy
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. Furthermore, my organization provides trauma
counseling to an underserved and often overlooked population, both children and minorities. Also, we provide services to youth offenders in
hopes to prevent future reoffending behavior.
tlawrence@h Children's We urge the Federal Reserve to make nonprofits eligible for the Main Street Loan program. The success of our nation's recovery from
4/16/2020 3:56:00 opeandhealin Center for Hope this unprecedented crisis depends on the success of our nation's nonprofits. Thank you for taking time to consider the contributions of
PM PIO (Email from Lawrence Tewan gga.org and Healing all non-profits and their importance in the community.
Page 239 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
In support of the 4,000 employees of a regional non-profit health and human services agency that provides programs and services to nearly
10,000 people with intellectual and developmental disabilities, special needs, their families and older adults throughout numerous counties in
Western New York and the Greater Rochester region, I am writing today to inform you that People Inc. is fully engaged in dealing with the
COVID-19 crisis. They must ensure that more than 150 community-based homes and services for people with disabilities remain as safe as
possible and are staffed 24/7. The vulnerable people that depend on People Inc. deserve no less. However, because they are providing
essential services during the crisis, People Inc. has incurred highly unusual increased costs in staffing, PPE, and cleaning services.
Since People Inc. is not eligible for the Payroll Protection Program (PPP) due to their size and the fact that they must remain fully operational,
we request that the Mid-Size Loan Program have provisions to convert to a forgivable loan for nonprofits that face staggering losses due to
COVID-19. This would grant them the same protections as PPP.
Personal
4/16/2020 3:57:00 Thank you in advance for your support of direct care staff, the people they support and People Inc.
Email Address
PM PIO (Email from Regan Mary
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; and
Developmental In implementing any workforce restoration and retention provisions, "workforce" should be defined as full-time employees or full-
4/16/2020 3:58:00 sophia.samu Disabilities time equivalents.
PM PIO (Email from Samuel Sophia el@ddiny.org Insitute, 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.
dhowland@ki
4/16/2020 3:58:00 ppmetroatlant KIPP Metro 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 Howland David a.org Atlanta Schools this unprecedented crisis depends on the success of our nation's nonprofits.
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
organizations, by mandate of their non-profit status and their oversight governance are the MOST efficiently run organizations that perennially
4/16/2020 3:59:00 naya@ywcaa 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 Diaz Naya ustin.org MOST needed by the communities they serve.
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; and
In implementing any workforce restoration and retention provisions, "workforce" should be defined as full-time employees or full-
4/16/2020 3:59:00 Lapointea@f Friendship time equivalents.
PM PIO (Email from LaPointe Andrea ccare.org Community Care
Page 240 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 ask the Federal Reserve and Treasury Department to immediately issue guidance on a program, as directed under the CARES Act, to
provide financing to banks and other lenders to make loans to non-profits and other mid-size businesses. 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; Prioritize 501(c)(3) charitable
nonprofits responding to COVID-19 relief efforts; Payments should not be due until two years after a loan is made;Employee retention
provisions should begin on the date that loan funding is received by the borrower. Many non-profit organizations are not able to access the
Paycheck Protection Program, which is critical to ensure the continued provision of essential services during this crisis.Without increased
access to loan programs intended to sustain payroll and retain employees, these mid-sized non-profit organizations are at financial risk, a
circumstance that could leave thousands of individuals without timely access to needed care. This lack of access to care will lead many
Americans to utilize more emergency services, over-crowding community hospital emergency departments. This will drive up health care
4/16/2020 4:00:00 wwang@hscf Hathaway costs at a time when the health system is already strained caring for COVID-19 patients
PM PIO (Email from Wang Wendy s.org Sycamores
I am affiliated with a non-profit organization that provides behavioral health, child welfare services and housing support to individuals in
California. I ask the Federal Reserve and Treasury Department to immediately issue guidance on a program, as directed under the CARES
Act, to provide financing to banks and other lenders to make loans to non-profits and other mid-size businesses (between 500-10,000
employees). We request that the program include the following:
oInclude a 0.50% interest rate (50 basis points) for 501(c)(3) charitable nonprofits at a 5-year amortization
oProvide priority to 501(c)(3) charitable nonprofits responding to COVID-19 relief efforts
oPayments should not be due until two years after a direct loan is made
oEmployee retention provisions should begin on the date that loan funding is received by the borrower
oIn any workforce restoration and retention provisions, "workforce" should be defined as full-time employees or full-time
equivalents
Hathaway- Many non-profit organizations are not able to access the Paycheck Protection Program , which is critical to ensure the continued provision of
Sycamores Child essential services during this crisis. Without increased access to loan programs intended to sustain payroll and retain employees, these mid-
4/16/2020 4:00:00 khopkins@hs and Family sized non-profit organizations are at financial risk, a circumstance that could leave thousands of individuals without timely access to needed
PM PIO (Email from Hopkins Karen cfs.org Services care.
The Main Street Lending Program's (MSLP) reliance on EBITDA as the only financial metric to determine eligibility and loan size
operates to exclude employers of millions of people in the life sciences, technology, media, start-ups and high-growth industries. Companies
in industries such as these are focused on rapid growth or product development and frequently do not have annual EBITDA as they typically
reinvest revenue into employees and other human capital, R&D, product development and customer/product acquisition efforts.
To open up the MSLP to a wider range of companies, Eligible Lenders should be authorized to apply EBITDA add-backs for growth-oriented
companies on a case-by-case basis. These adjustments to EBITDA could include: 1) human capital costs, including payroll costs to the extent
they are intended to grow the business, 2) R&D/software/technology costs that do not fulfill requirements to be capitalized but are
necessary in these industries, such as human capital costs which decrease EBITDA, 3) production and development costs, content
amortization costs and human capital costs related to building IP libraries, 4) goodwill impairments resulting from the economic downturn, and
5) share-based compensation expense, non-cash expenses and one-time or non-recurring cash expenses. Alternatively, Eligible Lenders
could use revenue-based tests for companies with a proven revenue-track record, but whose liquidity is suffering from the pandemic crisis.
4/16/2020 4:01:00 lucinda.treat Vice Group
PM PIO (Email from Treat Lucinda @vice.com Holding, Inc.
On behalf of over 200 members and partners, InterAction requests that non-profits be included in the Main Street Lending Program. As the
largest alliance of U.S.-based NGOs that implement and advocate for U.S. humanitarian, health, development, and democracy programs, we
know that nonprofits need access to this vital economic relief in order to keep staff employed and operations running - including operations
that are directly responding to the impacts of covid-19 at home and overseas. As nonprofits, we seek the funding as grants or at the lowest
possible interest rate. The nonprofit sector - the third largest workforce in our nation that contributes over five percent to the national GDP - is
especially vulnerable because of what we expect to be precipitous declines in charitable giving and earned revenues as a result of the COVID-
4/16/2020 4:02:00 jmarron@inte 19 pandemic. We are, therefore, extraordinarily dependent upon equitable access to the financial assistance provisions of the CARES Act.
PM PIO (Email from Marron Jennifer raction.org InterAction
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Main Street Lending Program Comments
I am a Program Director in a non-profit agency with a 100 year history of helping families in Massachusetts. I have been an Early Intervention
Director for 42 years serving thousands of children with disabilities, many living in homeless shelters, many babies born prematurely and
numerous other conditions. Services are provided by nurses, physical and speech therapists, special educators and social workers . Because
there are more than 10 such programs in our agency there are more than 500 employees. We do not have support for sick leave, paycheck
protection, and forgivable loans. We are held to different criteria for the employee retention credit. We are left out of the economic stimulus
that is essential for our organization's survival.
The lack of cash flow to our agency, and others like ours, is leading to job loss. Without revenue from service delivery, we cannot pay staff.
The longer term impact is that families and our service sector will suffer for decades. Across the country, programs like ours are closing,
furloughing staff, and stopping services to children who need our help.
Thom Child With access to favorable lending terms and with the same stimulus funding that was offered to smaller non-profits, we can continue to employ
4/16/2020 4:03:00 lsanik@thom & Family our staff of skilled specialists. We can continue to support children and families. We need immediate action. Non-profit agencies of our size
PM PIO (Email from Sanik Lorraine child.org Services must be included in the Main Street Lending Program and any subsequent mid-size loan programs
scott.odonnel How will EBITDA be calculated for purposes of determining the maximum loan amount?
4/16/2020 4:05:00 l@liquidityser Liquidity
PM PIO (Email from ODonnell Scott vices.com Services If a company has negative EBITDA for the 2019 year, will it be ineligible for a loan?
I am writing in opposition to the exclusion of nonprofits 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 4:05:00 Email 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 Friedman Royceann Address this unprecedented crisis depends on the success of our nation's nonprofits.
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
organizations, by mandate of their non-profit status and their oversight governance are the MOST efficiently run organizations that perennially
4/16/2020 4:05:00 bri@ywcaaus YWCA Greater 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 Hamlyn Bri tin.org Austin MOST needed by the communities they serve.
I run a FQHC that has over 500 employees. We were excluded from the Payroll Protection Loan and now are excluded from this program
because we are a non-profit. We have already been forced to make significant changes to mitigate on-going losses. We play a critical role in
providing health care to un/under insured population. Furthermore, we have been instrumental in reducing ER usage by providing the care our
4/16/2020 4:05:00 rakeshp@nh Neighborhood patients need in a manner which works for them. We ask that large health centers be allowed to participate in this program given our
PM PIO (Email from Patel Rakesh care.org Healthcare exclusion from the other programs to date.
Hello, I have two businesses that were in good standing at the end of 2019, and am Confidential Business Information
I wasn't able to participate in the PPP program, so your new MSNLF is
the only option I have to get my businesses back up and running. I contacted the bank I have a business relationship with, Regions Bank,
and they have no idea on how to assist or even if they will be participating in the MSNLF. Can you please have someone assist me in
applying for and successfully participating in your new loan program for my two businesses? I am afraid I won't receive any assistance
from my bank, and the SBA hasn't been of any assistance either. I really need your assistance as I can't find anyone else that has
any idea on how to help. Please advise.
Thanks for any assistance,
4/16/2020 4:05:00 jcooner@thei
PM PIO (Email from Cooner Jason tmo.com The ITMO, Inc. Jason
Personal We are against the Federal Government excluding Non-profit from the lending program
4/16/2020 4:05:00 Email New Horizon
PM PIO (Email from Johnson Ronald Address Ministries
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Main Street Lending Program Comments
We write in opposition to the exclusion of nonprofit organizations and institutes of higher learning from the Main Street New & Expanded
Loan Facilities. In short: The nonprofit sector is just as critical, if not more so, to economic stability and recovery as for-profit business.
Georgia 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 they should qualify for federal support - they 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.
J. Bulow We urge the Federal Reserve to make nonprofits eligible for the Main Street Loan program. The success of our nation's recovery from
4/16/2020 4:06:00 jwstephenson Campbell this unprecedented crisis depends on the success of our nation's nonprofits.
PM PIO (Email from Stephenson John @jbcf.org Foundation
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; and
In implementing any workforce restoration and retention provisions, "workforce" should be defined as full-time employees or full-
4/16/2020 4:08:00 lisamf@eed- time equivalents.
PM PIO (Email from Meyer Fertal Lisa a.org EEDA
The International Cemetery, Cremation and Funeral Association urges the Fed to include entities registered as tax-exempt under 501(c)(13),
which applies solely to not for profit cemeteries, as eligible borrowers under the Main Street Lending Program. The Paycheck Protection
Program excludes 501(c)(13)s, preventing nearly 10,000 cemeteries, according to the most recent IRS data, from accessing that program.
Some cemeteries are structured as 501(c)(3)s or for-profit businesses so are eligible for the PPP. This has caused a disparity in the industry
among those receiving financial assistance. Cemeteries, typically small businesses, have been adversely impacted by the COVID- 19 crisis
since most states have limited burials to only immediate family. Cemeteries are being forced to cut back on staffing because of the limited
services they are providing under social distancing orders. Family counselors are not meeting with families, which produces lower sales,
International forcing many cemeteries to lay off or furlough numerous dedicated employees because of the lower revenue. ICCFA requests that as the Fed
Cemetery, and Treasury finalize the Program infrastructure they consider allowing cemeteries registered as 501(c)(13) organizations to be included as
Cremation and eligible borrowers. Founded in 1887, ICCFA has over 9,300 members, primarily in the United States, representing non-profit, religious and
4/16/2020 4:08:00 mmcgowan@ Funeral municipal cemeteries, funeral homes, crematories, monument builders, for-profit cemeteries and third-party retailers.
PM PIO (Email from McGowan Mary Beth dykema.com Association
We write in opposition to the exclusion of nonprofit organizations and institutes of higher learning from the Main Street New & Expanded
Loan Facilities. In short: The nonprofit sector is just as critical, if not more so, to economic stability and recovery as for-profit business.
Georgia 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 they should qualify for federal support - they 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.
bverner@fras We urge the Federal Reserve to make nonprofits eligible for the Main Street Loan program. The success of our nation's recovery from
4/16/2020 4:08:00 erparkerfoun Fraser-Parker this unprecedented crisis depends on the success of our nation's nonprofits.
PM PIO (Email from Verner Betsy dation.org Foundation
CONTEXT: Dispatch is a profitable, modestly-leveraged construction services operating company, organized as a passthrough entity.
1)TAX DISTRIBUTIONS PERMISSIBLE: Please confirm that to the extent tax distributions (A) are set forth prior to April 8, 2020 (unless they
are for newly formed entities) in governing documents (e.g., LLC Operating Agreements) and (B) not prohibited under any credit agreements,
they shall be permissible for passthrough entities (i.e., they are not otherwise restricted by the "no dividends" rule.) Otherwise, the
Main Street Lending Program would give rise to phantom income for the owners of borrowers, like Dispatch, organized as pass-through
entities.
2)ADJUST FOR SEASONAL FLUCTUATIONS IN DEBT: For the purpose of calculating debt in seasonal businesses (such as in retail and
construction industries), please allow for factoring in the timing of the loan application within the calendar year. We propose an alternative
calculation of "debt" in such seasonal businesses affected by consumer/retail, weather, construction, etc. Namely, replace the
debt calculation with the:
(i) average debt balance over the last 12 month ends +/-
(ii) the change in the applicant's net working capital the borrower vs 12 months prior to the application date.
jsullivan@dis This would prevent distortions where leverage ratios may vary dramatically depending on whether an application is filed in May vs. in
4/16/2020 4:08:00 patchtrans.co Dispatch September.
PM PIO (Email from Sullivan John m Transportation
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Main Street Lending Program Comments
I applaud your efforts to establish the Main Street Lending Program and would like to advocate the Main Street New Loan Facility allow for
loan proceeds to fund mergers and acquisitions of small and medium-sized businesses. Permitting the use of the MSNLF for mergers and
acquisitions would provide immediate and sustained assistance to business owners who are seeking strategic paths to continue the next
rmartin@stab chapter of their business and provide on-going employment to their workforce. Similarly, qualified business purchasers would be provided
4/16/2020 4:10:00 lesidecapital. access to capital markets that are currently operating at less than ideal conditions due to the COVID-19 impact. Thank you for your
PM PIO (Email from Martin Robert com consideration.
We write in opposition to the exclusion of nonprofit organizations and institutes of higher learning from the Main Street New & Expanded
Loan Facilities. In short: The nonprofit sector is just as critical, if not more so, to economic stability and recovery as for-profit business.
Georgia 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 they should qualify for federal support - they 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.
We urge the Federal Reserve to make nonprofits eligible for the Main Street Loan program. The success of our nation's recovery from
4/16/2020 4:10:00 bjarrard@jbcf Georgia Health this unprecedented crisis depends on the success of our nation's nonprofits.
PM PIO (Email from Jarrard Beth .org Foundation
The 35 members of the MLA applaud the Main Street Lending Program to support mid-sized companies during the Covid-19 pandemic.
These programs can provide relief for our members, but to do so, the following terms should be clarified: The Main Street Extended Loan
Facility (MSELF) loan size test in 5(ii) is designed so borrowers do not take on more than 30% in additional debt. The test in 5(iii) of the
MSELF and 5(ii) of the Main Street New Loan Facility should make clear that "bank debt" as defined in these tests should permit,
at the borrower's election, inclusion of all lending facilities, including asset-based warehouse facilities, and should be consistently
applied to the calculations in 5(ii) and 5(iii).
Our members often have existing bank loan facilities, including revolving and warehouse facilities, that are integral to financing their
businesses and they may have drawn these facilities in anticipation of the pandemic's impacts and to house loans while access to
capital markets is limited. The ability to extend or refinance these facilities is constrained at this time. Without relief from the Main Street
Lending Program, our members may need to take more severe actions that will further restrict consumer lending in order to repay bank debts
when due.
nat.hoopes@
marketplacel Marketplace If the above clarification is made, eligible MLA members will be able to utilize the Main Street facilities and keep credit flowing to consumers
4/16/2020 4:11:00 endingassoci Lending and small businesses.
PM PIO (Email from Hoopes Nathaniel L. ation.org Association
4/16/2020 4:11:00 Wardgv@sbc Veale Please declare that oil and gas have been severely affected by the pandemic. The payback terms could be made more helpful by increasing
PM PIO (Email from Veale Ward global.net Companies the no debt service period from a year and lengthening the term from 4 years.
As an active Association Board member with the YMCA of Greater Louisville, I ask that you ensure nonprofits are explicitly named as eligible
recipients of the Main Street Lending program. It is critical that nonprofit employers with between 500 and 10,000 employees are able to
access the loan. The YMCA of Greater Louisville employed 2100 staff prior to the COVID-19 pandemic and have had to furlough 95% of our
staff. Without access to support, our Y will not be able to resume operations as we knew it or retain 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;
Offering thousands of virtual experiences for activity, engagement, and connectedness.
Personal
Email Address I am depending on you to ensure that we have the resources necessary to support our neighbors and our staff. Thank you. Stay healthy in
4/16/2020 4:11:00 these unusual times.
PM PIO (Email from Burke Patricia The RCF Group
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Main Street Lending Program Comments
I am writing to oppose the exclusion of nonprofits, institutes of higher learning, and HBCUs from the Main Street New & Expanded Loan
Facilities program. The nonprofit sector is just as critical to economic stability and recovery as for-profit business.
For example, Georgia is home to over 300 nonprofit organizations with 500 or more staff members. All of them are doing vital work during this
unprecedented time. Please do leave them behind in this relief effort.
Jewish As large employers alone, they deserve federal support - but they also supply critical services at a scale that would be impossible to replace.
Community They support an array of small businesses and serve as economic anchors for their communities.
Relations
Personal
4/16/2020 4:12:00 Council of We urge the Federal Reserve to make all nonprofits eligible for the Main Street Loan program. The success of our nation's recovery
Email
PM PIO (Email from Kirtz Harold / Atlanta from this unprecedented crisis depends on the success of our nation's nonprofits.
Address
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
organizations, by mandate of their non-profit status and their oversight governance are the MOST efficiently run organizations that perennially
Personal
4/16/2020 4:13:00 DO THE MOST with the operating dollars they have. To EXCLUDE these essential organizations is a grave misstep at a time when they are
Email Address
PM PIO (Email from nicoll heather MOST needed by the communities they serve.
I write in opposition to the exclusion of non-profits, institutes of higher learning, and HBCUs from the Main Street New & Expanded Loan
Facilities.
In short: The non-profit sector is every bit as critical to economic stability and recovery as for-profit business.
Georgia alone is home to over 300 non-profit 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 non-profits 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 non-profits.
llmckinnon@
4/16/2020 4:13:00 employability Non-profits are expected to address community issues and solve our society's problems, but we need adequate support ourselves to do
PM PIO (Email from McKinnon Laura Lane ga.org EmployAbility Inc so. Thank you.
I am writing to express 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 Email
4/16/2020 4:14:00 Address Thank you for your consideration
PM PIO (Email from Bozard Colleen
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Main Street Lending Program Comments
Mooyah is a profitable, unlevered restaurant franchisor and operator, organized as a passthrough entity.
1)TAX DISTRIBUTIONS PERMISSIBLE: Please confirm that to the extent tax distributions (A) are set forth prior to April 8, 2020 (unless they
are for newly formed entities) in governing documents (e.g., LLC Operating Agreements) and (B) not prohibited under any credit agreements,
they shall be permissible for passthrough entities (i.e., they are not otherwise restricted by the "no dividends" rule.) Otherwise, the
4/16/2020 4:15:00 agala@mooy Mooyah Main Street Lending Program would give rise to phantom income for the owners of borrowers, like KPA, organized as pass-through entities.
PM PIO (Email from Gala Anand ah.com Franchising, LLC
As a leader at the YMCA of Greater Seattle, I am writing to urge that nonprofits, especially those with more than 500 employees be eligible for
the Main Street Loan Program. Nonprofits like ours have depleted our cash reserves addressing COVID-related community needs, and need
financial support to return to regular operations during COVID recovery.Nonprofit organizations should be explicitly named as eligible for the
Main Street Lending program. While the CARES Act was an important step in relief, more support is needed especially for organizations like
ours with over 500 employees that are not eligible for the Paycheck Protection Program. We were forced to move 2,200 of our employees
4/16/2020 4:15:00 nphillips@se YMCA of Greater (70%) to standby status until we can return to regular operations, and we are facing millions of dollars in losses this year.
PM PIO (Email from Phillips Nathan attleymca.org Seattle
Good afternoon,
I'm writing to express my strong opposition to the exclusion of nonprofits from the Main Street Loan Program. The nonprofit sector is just
as critical to economic stability and recovery as for-profit business and it isn't logical to leave it out of the package.
Personal Thank you,
4/16/2020 4:16:00 Email Address Sarah Duffy
PM PIO (Email from Duffy Sarah
Please confirm that to the extent tax distributions (A) are set forth prior to April 8, 2020 (unless they are for newly formed entities) in governing
documents (e.g., LLC Operating Agreements) and (B) not prohibited under any credit agreements, they shall be permissible for passthrough
entities (i.e., they are not otherwise restricted by the "no dividends" rule.) Otherwise, the Main Street Lending Program would give
4/16/2020 4:16:00 jason@lifepor rise to phantom income for the owners of borrowers, like LifePort, organized as pass-through entities.
PM PIO (Email from Darley Jason t.com LifePort, LLC.
(1) Priority access for food distributors to the credit facility; (2) Loan forgiveness opportunities like with SBA loans; and (3) Loan interest
deductions without regard to typical limitations OR 50% business interest limitation remains in effect.
Shamrock Foods Company is a family-owned food distributor that provides transportation and logistics support to ensure food reaches any
place where people consume away from home (e.g., hospitals, restaurants, schools, military bases, hotels). Before the pandemic,
approximately 50 percent of the food in America was consumed outside the home. Given our customer base, we are experiencing significant
revenue declines with a direct impact on jobs. Priority access to short term loan money, coupled with favorable terms, assists food distributors
by helping to preserve jobs and provide direct support to food away from home sources.
Food distributors are uniquely positioned to support food away from home sources in weathering this crisis. We are supporting the industry
by essentially providing loans through deferred balances to help restaurants continue to obtain food to supply families. We are using our
carrie_ryerso resources to develop education and tools to support restaurants as their business model shifts. We are working with restaurant associations
4/16/2020 4:16:00 n@shamrock Shamrock Foods to stimulate takeout business. We are partnering with grocers and food banks to help them overcome supply chain gaps and providing
PM PIO (Email from Ryerson Carrie foods.com Company donated goods to assist the food insecure.
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Main Street Lending Program Comments
Girl Scouts of the USA (GSUSA) and our 111 councils have been hit hard by COVID-19. Social distancing has derailed troop meetings,
council events, and plans for summer camp. GSUSA and councils have quickly launched virtual activities for girls and their families, but the
pandemic has interrupted Girl Scout Cookie sales as well as fundraising and sponsorships. Without greater access to capital, GSUSA and
councils will?be forced to slash programming, staff, and scholarships just as communities need Girl Scouts the most.
Many nonprofits have been unable to access the Paycheck Protection Program. Further, as the full impact of the pandemic is realized,
nonprofit borrowers will need more flexibility and coverage than the Paycheck Protection Program provides. As the Treasury Department
works to make loans available under section 4003(c)(3)(D) of the CARES Act, we respectfully request the following:
Eliminate the 500-employee minimum for 501(c)(3) organizations seeking mid-sized business loans;
Open the Main Street Lending Program to 501(c)(3) organizations contributing to COVID-19 relief efforts;
Include a 0.50% interest rate for 501(c)(3) organizations with a minimum 5-year amortization;
Defer payments until at least two years after a direct loan is made; and
Base employee retention on the date of the loan's origination.
These steps will allow nonprofits to meet the immediate needs of our communities as well as plan for the future when our services will be
needed most.
4/16/2020 4:16:00 ssanta@girls Girl Scouts of the
PM PIO (Email from Santa Sue couts.org USA
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; and
Friendship In implementing any workforce restoration and retention provisions, "workforce" should be defined as full-time employees or full-
4/16/2020 4:17:00 whiffenk@fcc Community time equivalents.
PM PIO (Email from Whiffen Karla are.org Care, Inc.
Loma Linda University Health, a nonprofit organization in California including 8 professional schools, 6 hospitals and over 900 faculty
physicians, offers these comments on the Main Street Lending Program (Program) to support inclusion of nonprofit organizations as
'eligible businesses' under the Program.
Nonprofits employed 10.2% of the private workforce in 2016. Excluding nonprofit organizations undermines the CARES Act (Act) goal to
preserve employment.
The Act contemplates nonprofit organizations as 'eligible borrowers.' The Program is authorized under Act Section 4003(b)(4).
Conditions for loans are set forth in Section 4003(c). Section 4003(c)(3)(D) (Assistance for Mid-Sized Businesses) states 'eligible
businesses' include 'to the extent practicable nonprofit organizations.' Section 4003(c)(3)(D)(i). The Program is described in
subpart (ii) of that section: 'Nothing in this subparagraph shall limit the discretion of the Board of Governors of the Federal Reserve
System to establish a Main Street Lending Program or other similar program or facility that supports lending to small and midsized businesses
on such terms and conditions as the Board may set . including any such program in which the Secretary makes a loan, loan guarantee, or
other investment under subsection (b)(4).' Thus, the reference to eligible 'nonprofit organizations' applies to loans made
4/16/2020 4:18:00 flapallo@man pursuant to Section 4003(b)(4). No references in the Act call for exclusion of nonprofits.
PM PIO (Email from LaPallo Francis att.com Manatt
I believe there is a great need 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 we serve, providing essential services to the most vulnerable people in a community.
Additionally, non-profits, such as the over 200 affiliates of YWCA USA are in turn employers in the markets in which we operate. Social
service non-profit organizations, by mandate of our non-profit status and our oversight governance are the MOST efficiently run organizations
that perennially DO THE MOST with the operating dollars we have. To EXCLUDE these essential organizations is a grave misstep at a time
when we are MOST needed by the communities we serve. YWCA Greater Austin provides mental health counseling, care coordination,
educational, and other services. In the last month, we have seen an increase in the mental health needs of our community. People are in
isolation, uncertain and presented with emotions and situations they have never before fathomed, much less lived. The work that
vticoordinator organizations like mine provide in the community is essential to the overall health and wellness of our people. We cannot be excluded from
4/16/2020 4:18:00 @ywcaaustin YWCA Greater opportunities like those proposed in the Main Street Covid-19 relief package.
PM PIO (Email from Campbell Haleigh .org Austin
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Main Street Lending Program Comments
As a Board Member for the Museum of Design Atlanta, 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.
The Museum of Design Atlanta (MODA) has been working tirelessly to bring needed enrichment activities to children and relief to their parents
by providing valuable learning from trusted providers. That work continues even though MODA is strapped for cash. On premises revenue
has been eliminated, donors have lost jobs and contributors, who are concerned about their business's future, are holding funds. We
need help and OUR COMMUNITY NEEDS US, today and tomorrow.
As large employers alone, non-profits like MODA 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.
salshut@stud
4/16/2020 4:19:00 ioa2- Museum of With local community leadership, nonprofits have held the country together through these days of hardship and unity. Please make it possible
PM PIO (Email from Alshut Shawn design.com Design Atlanta for our communities to emerge from this crisis whole by including nonprofits in the Main Street Loan program.
CONTEXT: Mooyah a profitable, unlevered restaurant franchisor and operator, organized as a passthrough entity.
TAX DISTRIBUTIONS PERMISSIBLE: Please confirm that to the extent tax distributions (A) are set forth prior to April 8, 2020 (unless they
are for newly formed entities) in governing documents (e.g., LLC Operating Agreements) and (B) not prohibited under any credit agreements,
they shall be permissible for passthrough entities (i.e., they are not otherwise restricted by the "no dividends" rule.) Otherwise, the
4/16/2020 4:19:00 agala@mooy Mooyah Main Street Lending Program would give rise to phantom income for the owners of borrowers, like Mooyah, organized as pass-through
PM PIO (Email from Gala Anand ah.com Franchising, LLC entities.
Non-profits, including higher education organizations, employ millions of American workers, have a huge economic impact, and have a
massive impact generally on their local communities. Right now, they are providing essential services in those communities. Non-profits
should be eligible for loans through the proposed Main Street Lending program. To illustrate the point, I work for an arts and culture non-profit
in Providence, RI. Data compiled by the National Endowment of the Arts in 2018 found that the arts contribute $763.6 billion to the U.S.
economy, more than agriculture, transportation, or warehousing. The arts employ 4.9 million workers across the country with earnings of
more than $370 billion. Despite some temporary programmatic suspensions, my organization is still providing essential services such as
housing to low income resident artists and much needed stipends to youth in our community, including incarcerated and formerly incarcerated
youth, those who are pregnant and parenting, youth in foster care, and youth at high risk of school dropout and disconnection. Our services
are needed more than ever during the COVID-19 pandemic. There is no valid reason not to include non-profit businesses such as ours in the
4/16/2020 4:19:00 Michele.fonte Main Street Lending program, and not doing so potentially creates further financial burden on already chronically underfunded service
PM PIO (Email from Fontes Michele s@as220.org AS220 providers.
The Association for Psychological Science encourages the inclusion of nonprofits as eligible for loans through the Main Street Lending
program. Nonprofits support functions of significant benefit to the public, particularly during the current public health and economic crisis, such
as ensuring the quality and timeliness of research that is disseminated to the public and providing access to science-based information that
can help individuals, families, communities, government, and businesses cope. COVID-19 has negatively affected the ability of nonprofits to
fill these important roles. Lending through the Main Street program would provide vital support to organizations in dire need of financial help
during this crisis.
As an example, APS is a nonprofit scientific association that promotes awareness and understanding of psychological science. It supports
research psychologists working towards solving society's most difficult problems. As a result of COVID-19, APS had to cancel its annual
sarah.brookh scientific convention, which is one of APS's key scientific activities and also generates significant revenue for the association. Main
art@psycholo Association for Street Lending support would help APS recover from this cancellation and position the organization to prepare for other threats such as
4/16/2020 4:20:00 gicalscience. Psychological reduced membership and membership revenue resulting from COVID-19. APS will be directly affected by the likely downturn in federal
PM PIO (Email from Brookhart Sarah org Science research funding and the other negative effects being experienced by universities.
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Main Street Lending Program Comments
CONTEXT: iGPS is a profitable, modestly-leveraged operating company organized as a passthrough entity. Its debt structure includes ABL
debt, a senior term loan, capital leases and convertible debt.
1)TAX DISTRIBUTIONS PERMISSIBLE: Please confirm that to the extent tax distributions (A) are set forth prior to April 8, 2020 (unless they
are for newly formed entities) in governing documents (e.g., LLC Operating Agreements) and (B) not prohibited under any credit agreements,
they shall be permissible for passthrough entities (i.e., they are not otherwise restricted by the "no dividends" rule.) Otherwise, the
Main Street Lending Program would give rise to phantom income for the owners of borrowers organized as pass-through entities.
2)LEASES: Please confirm whether capital and/or operating leases would count in the definition of "debt."
3)OTHER DEBTS CAN CONVERT INTO EQUITY: Please confirm that the program would not prohibit or in any way be affected by a
conversion of some convertible debt into equity at any time post-closing, regardless of the seniority or juniority of the convertible debt. A
4/16/2020 4:20:00 JPepperwort conversion of any debts to equity will enhance the credit quality of the borrower and Main Street loan outstanding.
PM PIO (Email from Pepperworth Jeff h@igps.net
To The Board of Governors,
The Main Street Lending Facility has a clause that says the borrower must calculate and deduct from its maximum loan amount of its
committed but undrawn debt facilities. In asset based lending such as secured by finished goods as wood products the maximum amount is
an absolute that comes with ranges of safeguards levels that when tapped require more fees and more stringent collateral reporting
requirements. This is used throughout the wood products industry from wood dealers (buyers of standing timber), manufacturers, wholesalers,
distributors, and retailers. Using the maximum and not the amount of debt incured at the point of applying for the MSLF. I would suggest to
remove the "committed but undrawn debt" from the language.
Thank you for the opportunity to comment.
Respectfully submitted,
gskipper@sc Gray Skipper
4/16/2020 4:21:00 otchplywood. Scotch Plywood Vice President
PM PIO (Email from Skipper Gray com Company, Inc. Scotch Plywood Company, Inc.
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; and
In implementing any workforce restoration and retention provisions, "workforce" should be defined as full-time employees or full-
4/16/2020 4:21:00 cottinghama Friendship time equivalents.
PM PIO (Email from Cottingham Audrey @fccare.org Community Care
The current eligibility requirements for CARES Act Main Street, Corporate Credit Facility and National Security Loan programs exclude an
entire critical infrastructure sector - independent American oil & gas producers who generate 83% of domestic crude oil. The California
Independent Petroleum Association represents hundreds of producers who are designated as critical to national defense in the Defense
Production Act. Producers have been severely impacted by COVID-19, a situation exacerbated by foreign commodity price manipulation by
Saudi Arabia and others threatening American energy independence. This has significantly impacted short-term liquidity and credit ratings of
American producers. The Federal Reserve and Secretary of the Treasury could enable producers to access CARES Act loans by making the
following changes:
Main Street Programs: Apply the EBTIDA leverage ratio to senior bank debt only, rather than total debt since the Fed can acquire a senior
position.
Corporate Credit Facilities: Remove the rating requirement since the CARES Act seeks to bolster short-term liquidity and already requires that
California the borrower must not be in bankruptcy proceedings.
Independent National Security Program: Expand the definition of "businesses critical to maintaining national security" beyond specific weapons
4/16/2020 4:22:00 sabrina@cipa Petroleum systems to include independent oil & gas producers who supply needed energy and feedstocks for national defense as recognized by
PM PIO (Email from Officer Rock Zierman CIP .org Association the Defense Production Act.
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Main Street Lending Program Comments
I am providing this comment 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 and
such organizations should have access to these loan facilities.
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.
I ask that the Federal Reserve 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 Email Thank you.
4/16/2020 4:23:00 Address
PM PIO (Email from Johnson Scott Scott Johnson
The YMCA of Northwest North Carolina has been a cornerstone of the community for many years. Despite recent layoffs and facility closures
due to the COVID-19 pandemic, we are working tirelessly to support those in need in our community. Over the past month we have offered
emergency child care to essential workers, food distribution (over 5000 meals served so far), made thousands of wellness calls to seniors,
and transitioned multiple branches for weekly blood drives In 2019, we served 152,000 people in 7 counties with the support of 1912
dedicated employees. Our organization has had to lay-off 91% of our workforce, 1740 people, and are projecting a $2.5M loss in revenue
between March 15th and June 30th, with the potential for additional losses due to the uncertainty of continued social distancing requirements
when we are able to reopen. Our communities need nonprofits like the Y now more than ever but more help is needed for non-profit
organizations with more than 500 FTE employees. We were not able to apply for the Paycheck Protection Program because of our size and
without access to support our Y, and other larger non-profits, will not be able to resume operations as we knew it or retain our staff. Your
YMCA of support would ensure that we can continue to provide urgently needed services for our communities and continue to support our staff as one
4/16/2020 4:23:00 c.collins@ym Northwest North of the larger employers in the region. Thank you for looking into this matter and for your service to our nation in this time of crisis.
PM PIO (Email from Collins Carrie canwnc.org Carolina
WAB is concerned the Programs do not provide meaningful financial support to businesses for two primary reasons: 1. Limiting loan size to a
multiple of EBITDA eliminates a significant numbers of borrowers. Borrowers in our bank's Tech and Hotel loan portfolios would not be
able to participate even though they were in good financial standing prior to the crisis. 2. The broad restrictions on use of loan proceeds
constrain borrowers' abilities to steady themselves financially, are too restrictive for most borrowers, and hamstring our ability to work
with borrowers in good faith.
We also have the following questions:
Terms and Conditions: Can fees be financed in the loan? Do leveraged lending rules apply (i.e. deleveraging)? Will CRE loans be allowed to
upsize based on LTV? What is the definition of EBITDA (i.e. TTM, projected, or addbacks)? What is the amortization schedule after deferral?
What is the expectation at maturity? Is SOFR the only rate available? Will it require compounding, lock-ins, or lookbacks? Does the FRB get
the benefit of existing recourse agreements? Will loans have delayed draw features?
Attestations: What due diligence is expected by the bank? Do PPP loan payoffs trigger prohibition on paying debt? Do banks monitor
jjarvi@wester borrowers' ongoing compliance with attestations?
4/16/2020 4:24:00 nalliancebank Western Alliance Participations: What pre-approval is required? What happens if a borrower certification is temporarily untrue (i.e. curable)? Can syndicated
PM PIO (Email from Jarvi Jessica .com Bank facilities be participated?
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 4:24:00 TEST@TEST eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
PM PIO (Email from Hobbs Elisabeth .com
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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 4:25:00 Purpose Built We urge the Federal Reserve to make nonprofits eligible for the Main Street Loan program. The success of our nation's recovery from
Email Address
PM PIO (Email from Davidson Ethan Communities this unprecedented crisis depends on the success of our nation's nonprofits.
On behalf of Western Union, a leader in global money movement and payment services with a 170 year track record of innovation and
success, I write today regarding lender eligibility requirements under the Main Street Lending Facility.
Western Union operates in the US through approximately 10,000 agents that offer our money transfer services, and we estimate that at least
8000 of those are small and medium-sized businesses. Through our Western Union Business Solutions affiliate we also support the
commercial needs of 4000 businesses in the US, many of whom may qualify for the Main Street Lending program. Many of these businesses
have been seriously impacted by COVID-19 and need government assistance during this unprecedented time.
To broaden the scope of the Main Street Lending program to as many small and medium-sized businesses as possible, we respectfully
recommend expanding lender eligibility under the program to include non-depository institutions, similar to what is allowed under the
Paycheck Protection Program.
We appreciate your consideration of this request, and we appreciate your efforts to bolster our economy during this unprecedented time.
Respectfully,
Tim Daly
tim.daly@we Head of Global Public Policy
4/16/2020 4:25:00 sternunion.co Western Union
PM PIO (Email from Daly Tim m Western Union
As a Board member of Thom Child and Family Services, I 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, I 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.
agillis@nonpr Institute for Sincerely,
4/16/2020 4:25:00 ofitpractice.or Nonprofit
PM PIO (Email from Gillis Audrey g Practice Audrey Gillis
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Main Street Lending Program Comments
We are developing a framework that will measure pandemic payment risk on a 100 point scale, based on 2 variables:
transmission risk - how likely is the functioning of a business to spread the virus, from 0-10. With 10 being the most likely.
Essential service - how essential is the business. With 10 being the least essential.
Pandemic payment risk = transmission risk x essential service.
Using work like the Moody's index to measure the essential nature of different industries, and Christos Makridis work to measure the
economic impact of the virus (which can be adapted to approximate transmission risk by industry), one could develop an exogenous measure
of pandemic payment risk for any particular cash flow stream, and isolate the types of businesses and loans that this program needs to
support.
By making these loans to both borrowers and tenants, you prevent gaming the system, and by having specific public health measures in place
around their servicing, you help ensure that non-essential operations that are likely to transmit disease stay closed for as long as necessary,
by paying them to do so.
Tulane
will@greenco University, This will also help ensure that businesses least able to function don't sink the loans or loan portfolios of businesses, and it provides an
4/16/2020 4:26:00 astenterprise Green Coast indirect support for businesses that couldn't otherwise sustain their operating costs through this time, by removing their rent obligation
PM PIO (Email from Bradshaw William s.com Enterprises for an extended period.
Nonprofits across the country are the number-one driver of tourists to our cities and providers of programming to our communities. At Lincoln
Center, we are therefore disappointed that the Main Street Lending Program does not include opportunities for nonprofits of all sizes to
access robust stimulus funding. We are asking the federal government to include cultural organizations in provisions helping businesses
survive this crisis.
The CARES Act provides some relief but it is insufficient to our needs. We request that the Main Street program be revised to benefit
nonprofits, including the following:
A favorable interest rate for 501(c)(3) charitable nonprofits
Loan forgiveness provisions to help ensure nonprofits, including cultural organizations, will be able to continue to provide services during the
crisis (such as our online performances) and assist with our nation's recovery.
Lincoln Center Arts and culture revived New York City's downtown after 9/11. Following the 2008 economic crisis, New York's rich culture brought
4/16/2020 4:27:00 lklein@lincoln for the tourism back to New York. Now is the time for our cultural institutions to play a critical role in our recovery, both economically and socially.
PM PIO (Email from Timms Henry center.org Performing Arts
We have submitted by separate email with attachments
4/16/2020 4:28:00 tony.armlin@
PM PIO (Email from Armlin Tony triplefive.com Triple Five
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Main Street Lending Program Comments
Since the Fed's Main Street New Loan and Expanded Loan Facility programs were announced on April 9, several of TechNet's
smaller member companies have raised concerns that need to be addressed, including the requirement that applicants need to have been
"EBITDA-positive" in 2019 in order to qualify. This would indiscriminately exclude many promising, high-quality, and credit-worthy
businesses, including fast growing startups.
To illustrate the problem, here are a few examples of why the "EBITDA-positive in 2019" requirement would leave out many worthy
businesses that are now being challenged by the coronavirus' impact:
A company that had been profitable from 2015-2018 but decided to expand into new work in 2019 and was intentionally EBITDA negative in
2019.
A new business that required significant investment at the start of 2019 but grew to profitability by the end may not have been EBITDA
positive for all of 2019.
An investor-backed start-up that decided 2019 was a year to invest in growth and may not have been EBITDA positive in 2019.
Via a separate email, we are submitting additional comments and suggestions from TechNet elaborating on this and other concerns raised by
4/16/2020 4:28:00 aburgos@tec our member companies, who are trying to save jobs, continue innovating, and keep their businesses open - in addition to stepping up to do
PM PIO (Email from Burgos Alex hnet.org TechNet their part to help our nation overcome this unprecedented challenge.
Valley Community Healthcare is a private non-profit 501(c)(3) agency that provides free and low-cost medical care and mental health services
to over 26,000 low-income men, women, and children in the San Fernando Valley region of Los Angeles County. We are deeply concerned to
learn that nonprofits are ineligible for the Federal Reserve's new "Main Street" lending facility, despite the fact that nonprofits
are leading the effort to respond to this pandemic. In order to meet the needs of our patients while still keeping them safe, we were forced to
completely re-organize our business model. Currently 90% of our care is being provided remotely, significantly reducing revenue, along with
reducing exposure to the virus for thousands of vulnerable patients and staff. Nonprofits like ours urgently need access to these government
backed revenue streams and loan programs. Given the current financial crisis and loss of revenue, nonprofits, including critical health care
Valley entities, may be forced to shrink their services, meaning tens of thousands could go without care. We urge the Federal Reserve to expand the
4/16/2020 4:29:00 jrose@vchcar Community eligibility of this program to explicitly include nonprofits.
PM PIO (Email from Rose Judi e.org Healthcare
The Jewish Board of Family and Children's Services serves more than 43,000 New Yorkers with programming related to mental health
counseling, foster care, domestic violence, supportive housing, and early childhood education. As an organization, we employ more than
2,500 staff members. The charitable nonprofit community appreciates that several key relief programs in the CARES Act were modified to
include nonprofit eligibility. This approach recognizes the significant role that charitable nonprofits play as the third largest employer in our
nation's economy and as valued problem solvers. We urge the administration to support the following: Expand Nonprofit Access to
Credit by designating funding exclusively for nonprofits within the two principal loan programs established in the CARES Act to ensure that the
organizations dedicated to addressing immediate pandemic-related problems are included in relief efforts and not excluded.
Paycheck Protection Program: Provide incentives to private lenders and expand the eligibility for nonprofits to participate in the Paycheck
Protection Program by modifying the current 500-employee cap.
The Jewish Mid-Size Business Loan Program: Adjust CARES Act Section 4003(c)(3)(D) to implement a program to support nonprofit employers with
Personal Email Board of Family between 500 and 10,000 employees, including loan-forgiveness and other provisions. The legislation should direct the Treasury Department
4/16/2020 4:31:00 Address & Children's to have this program operational no later than 15 days after enactment.
PM PIO (Email from McBrien Bridget Services
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Main Street Lending Program Comments
Enesco is a 62-year-old, profitable, gift wholesaler.Confidential Business Information
In 2019, Enesco's subsidiary acquired a 53-year-old retailer of engraved gifts Things Remembered (TR) out of BK. The transaction
saved 1000+ jobs (email attachment to come). Enesco capitalized TR with no debt of its own. TR lost money in 2019, the year it emerged
from BK.
1)DECONSOLIDATE A SUBSIDIARY THAT INCURRED STARTUP LOSSES IN 2019: Please confirm ability of a Parent (Enesco) to
exclude a subsidiary (TR) or sister, which incurred startup losses in 2019, from the EBITDA/leverage analysis (as opposed to requiring
Enesco + TR to submit one application on a consolidated basis.) If TR is consolidated with its parent, startup losses would disqualify Enesco
from receiving a loan. Please confirm ability to add back TR's losses.
2)SEASONAL FLUCTUATIONS IN DEBT: For the purpose of calculating debt in seasonal businesses, please allow consideration of the
loan application's calendar timing. We propose businesses affected by consumer/retail, weather, etc replace the debt calculation with
4/16/2020 4:31:00 mmyren@en the (i) average debt balance over the last 12 month ends +/- (ii) the change in the applicant's net working capital vs 12 months prior to
PM PIO (Email from Myren Matt esco.com Enesco, LLC the application date. This would prevent distortions in leverage ratios due to seasonality.
A new 13(3) facility is required to assist non-bank financial firms (NBFFs) in continuing to extend credit to millions of Americans. The terms of
the MSLP effectively prevent NBFFs from accessing the liquidity they desperately need, and none of the other current 13(3) facilities meet
Squire Patton NBFFs' unique liquidity needs.
brandon.rom Boggs (on behalf
4/16/2020 4:31:00 an@squirepb of non-bank By way of follow-up to this submission, we are e-mailing an attachment to regs.comments@federalreserve.gov with additional information.
PM PIO (Email from Roman Brandon .com financial firms)
Related to COVID 19-
I am affiliated with a non-profit organization that provides behavioral health, child welfare services, housing support to individuals in California.
I ask the Federal Reserve and Treasury Department to immediately issue guidance on a program, as directed under the CARES Act, to
provide financing to banks and other lenders to make loans to non-profits and other mid-size businesses (between 500-10,000 employees).
We request that the program include the following:
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 should 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 any workforce restoration and retention provisions, "workforce" should be defined as full-time employees or full-time equivalents
4/16/2020 4:31:00 jquintero@hs Hathaway-
PM PIO (Email from Quintero Janine cfs.org Sycamores
A new 13(3) facility is required to assist non-bank financial firms (NBFFs) in continuing to extend credit to millions of Americans. The terms of
the MSLP effectively prevent NBFFs from accessing the liquidity they desperately need, and none of the other current 13(3) facilities meet
NBFFs' unique liquidity needs.
rohit.kirpalani Atlanticus
4/16/2020 4:31:00 @atlanticus.c Holdings By way of follow-up to this submission, we are e-mailing an attachment to regs.comments@federalreserve.gov with additional information.
PM PIO (Email from Kirpalani Rohit om Corporation
CRUIZ@AM Regarding Main Street Lending and proposed financial CARES 2 legislation: It is critical that all 501's have access to relief as small
ERICANORN American employers. Without access to relief funds, all employers, including 501's will be forced to make difficult staffing and operating decisions.
4/16/2020 4:33:00 ITHOLOGY. Ornithological
PM PIO (Email from Ruiz Crystal ORG Society
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 Out Front
4/16/2020 4:34:00 Email Address Theatre
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 Mikell Kayleigh company this unprecedented crisis depends on the success of our nation's nonprofits.
Page 254 of 363
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Main Street Lending Program Comments
I am against the exclusion of nonprofits from the Main Street New & Expanded Loan Facilities.The nonprofit sector is critical to
maintaining our society, economic stability and recovery as for-profit business.
Georgia has 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
4/16/2020 4:34:00 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
PM PIO (Email from Cuttler Sandra Ms. unprecedented crisis depends on the success of our nation's nonprofits.
On behalf of our employees and families, I write to you today asking for your help as North Pacific Paper Company (NORPAC) tries to keep
operating during the unprecedented COVID-19 pandemic. Today, NORPAC remains one of the largest employers and economic drivers in
Southwest Washington and Northern Oregon. We employ 450 people with an annual payroll of over $40 million.
As is the case with many other small rural manufacturing businesses, Confidential Business Information
. We were hopeful that we would be able to secure a Payroll Protection Plan loan to enable us
to keep paying our employees during this period but appear to be roadblocked because of the Small Business Administration's affiliation
rule, since our company is owned by a private equity firm, One Rock Capital.
It does not seem right that NORPAC, a rural manufacturing company, should be denied access to PPP or Main Street funds simply because
Confidential Business
thomas.rozw North Pacific One Rock was willing to invest in NORPAC when Weyerhaeuser was looking to exit the business we're in. Information
4/16/2020 4:34:00 od@norpacp Paper Company, I ask for your support in removing the barriers to loan
PM PIO (Email from Rozwod Thomas aper.com LLC access for small companies who happen to be owned by private equity firms.
The YMCA of Northwest North Carolina has a long standing history of responding and meeting community needs. Impacting the lives of over
150,000 people in 7 counties, we have adapted our services to support our neighbors through the COVID-19 pandemic. Our Y is currently
providing emergency child care to essential workers, distributing meals in at risk neighborhoods (over 5000 meals served so far), making
thousands of wellness calls to seniors, and transitioning multiple branches for weekly blood drives. As a large non-profit, our dedicated staff
are our most valuable resource. Prior to the pandemic and subsequent facility closures due to social distancing measures, our Y employed
1912 people (520 FTE), making us one of the largest employers in the region. We have since had to lay off 91% of our workforce, 1740
people. We are committed to serving northwest North Carolina and will continue working tirelessly to support those in need in our community
despite recent layoffs and facility closures The CARES Act was a first step toward supporting nonprofits through the economic crisis, however
we were not able to apply for the Paycheck Protection Program because of our size. We are projecting a $2.5M loss in revenue between
YMCA of March 15th and June 30th and your support would ensure that the Y and other large non-profits can continue to provide urgently needed
4/16/2020 4:35:00 j.lagesse@y Northwest North services for our communities. Thank you for looking into this matter and for your service to our nation in this time of crisis.
PM PIO (Email from Lagesse Jason mcanwnc.org Carolina
CONTEXT: ThingsRemembered (TR) is a 53-year-old retailer of engraved gifts, acquired out of bankruptcy, in a transaction that saved 1000+
Confidential Business
jobs (email attachment forthcoming), by Enesco, a 62-year-old, profitable, gift wholesaler. While Enesco (the parent) made Information
; it too has been decimated by Covid-19. Confidential Business Information
REQUEST RE JOB-SAVING TURNAROUNDS: We respectfully request that applicants be permitted to either:
1) use "3 x ( 2019 avg mo. payroll + 2019 avg mo. rent )" instead of 2019 EBITDA or
2) add back "6 x 2019 avg mo. payroll" to its EBITDA to account for the social benefit of the jobs it has saved.
We propose this alternative only in the limited cases where 2 conditions are met:
A) Company was a bona fide purchaser of third-party assets in a bankruptcy that can be demonstrated to have saved 500+ jobs in 2019 and
incurred startup losses in so doing and/or
B) Majority of the company's operations have been substantially shut down in March through May 2020 due to a stay at home orders
Enesco (e.g., retail cannot open).
cibold@thing Properties, LLC We also request that Parent companies be permitted to deconsolidate subsidiaries or sister companies from the EBITDA/leverage analysis,
4/16/2020 4:36:00 sremembere d/b/a Things but only where conditions (A) and (B) above are met.
PM PIO (Email from Ibold Charles d.com Remembered
Page 255 of 363
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Main Street Lending Program Comments
Non-profits, including higher education organizations, employ millions of American workers, have a huge economic impact, and have a
massive impact generally on their local communities. Right now, they are providing essential services in those communities. Non-profits
should be eligible for loans through the proposed Main Street Lending program. To illustrate the point, I work for an arts and culture non-profit
in Providence, RI. Data compiled by the National Endowment of the Arts in 2018 found that the arts contribute $763.6 billion to the U.S.
economy, more than agriculture, transportation, or warehousing. The arts employ 4.9 million workers across the country with earnings of
more than $370 billion. Despite some temporary programmatic suspensions, my organization is still providing essential services such as
housing to low income resident artists and much needed stipends to youth in our community, including incarcerated and formerly incarcerated
youth, those who are pregnant and parenting, youth in foster care, and youth at high risk of school dropout and disconnection. Our services
are needed more than ever during the COVID-19 pandemic. There is no valid reason not to include non-profit businesses such as ours in the
4/16/2020 4:36:00 seth.tourjee Main Street Lending program, and not doing so potentially creates further financial burden on already chronically underfunded service
PM PIO (Email from Tourjee Seth @as220.org AS220 providers.
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.
jjude@truecol True Colors
4/16/2020 4:38:00 orstheatre.or Theatre 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 Jude Jamil g Company this unprecedented crisis depends on the success of our nation's nonprofits.
I am affiliated with a non-profit organization that provides behavioral health, child welfare services, housing support to individuals in
California.
I ask the Federal Reserve and Treasury Department to immediately issue guidance on a program, as directed under the CARES Act, to
4/16/2020 4:41:00 mgomez@hs Hathaway- provide financing to banks and other lenders to make loans to non-profits and other mid-size businesses (between 500-10,000)
PM PIO (Email from Gomez Minerva cfs.org Sycamores
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 4:42:00 Personal Email 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 moebes michael Address this unprecedented crisis depends on the success of our nation's nonprofits.
Related to COVID19: I am affiliated with a non-profit organization that provides behavioral health, child welfare services, housing support to
individuals in California. I ask the Federal Reserve and Treasury Department to immediately issue guidance on a program, as directed under
the CARES Act, to provide financing to banks and other lenders to make loans to non-profits and other mid-size businesses (between 500-
10,000 employees). We request that the program include the following:
oInclude a 0.50% interest rate (50 basis points) for 501(c)(3) charitable nonprofits at a 5-year amortization
oProvide priority to 501(c)(3) charitable nonprofits responding to COVID-19 relief efforts
oPayments should not be due until two years after a direct loan is made
oEmployee retention provisions should begin on the date that loan funding is received by the borrower
oIn any workforce restoration and retention provisions, "workforce" should be defined as full-time employees or full-time
equivalents
4/16/2020 4:42:00 mlhommedie
PM PIO (Email from L'Hommedieu Michelle u@hscfs.org Thank you.
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Main Street Lending Program Comments
Numerous businesses and government entities are utilizing the staffing industry to supply temporary employees throughout the COVID-19
pandemic. These temporary and contract employees have aided our country by producing and delivering necessities, supplying critically
needed health care services, and helping state and local governments manage the influx of unemployment and financial assistance
caseloads.
However, delivering these vital services only accounts for a small portion of staffing firms' pre-crisis revenue, and many still face
Squire Patton catastrophic declines in work orders because temporary workers are usually the first to be laid off during an economic downturn.
Boggs (on behalf
brandon.rom of the American In an effort to enable staffing firms to continue providing essential services and survive the current economic downturn, it is critical that the
4/16/2020 4:43:00 an@squirepb Staffing Main Street Lending Program ensure that funds be set aside - or, at a minimum, prioritized - to provide business assistance for staffing firms.
PM PIO (Email from Roman Brandon .com Association)
CONTEXT: Vesta is a profitable, modestly-leveraged modular construction and mobile-module leasing operating company, organized as a
passthrough entity.
1)TAX DISTRIBUTIONS PERMISSIBLE: Please confirm that tax distributions are not otherwise restricted by the "no dividends"
rule. Otherwise, the Main Street Lending Program would give rise to phantom income for the owners of borrowers, like Vesta, organized as
pass-through entities.
2)ADJUST FOR SEASONAL FLUCTUATIONS IN DEBT: For the purpose of calculating debt in seasonal businesses, we propose the
following alternative calculation of "debt" in businesses affected by seasonality of consumer/retail, weather, construction, etc.:
(i) average debt balance over the last 12 month ends +/-
(ii) the change in the applicant's net working capital the borrower vs 12 months prior to the application date.
This would prevent distortions where leverage ratios may vary dramatically depending on whether an application is filed in May vs. in
September.
3)Please confirm the parameters for using its cash profits or new debt proceeds (other than proceeds from the Main Street Lending
Program) to retire any of its outstanding debts and/or preferred equity. This would allow Vesta to retire higher cost fixed obligations - provided
that such repayment is not financed by the Main Street loan proceeds.
cmattina@ve 4)PREFERRED DEBT: Please confirm that retirement of preferred equity is not considered a "dividend" for purposes of the
4/16/2020 4:45:00 stamodular.c Vesta Housing CARES Act.
PM PIO (Email from Mattina Christopher om Solutions, LLC
4/16/2020 4:45:00 ngallardo@h I am affiliated with a non-profit organization that provides behavioral health, child welfare services, housing support to individuals in California.
PM PIO (Email from Gallardo Natalie scfs.org
NVCA (Charts via email)
EBITDA
Prob.-MSLF requires EBITDA, excluding growth companies which do not have EBITDA but are creditworthy
Sol.-Alternate test using independent valuations or $ preferred investment
Capital distribution in M&A or IPO
Prob.-Even if MSLF loan retired, equity holders cannot receive proceeds for a year
Sol.-Proceeds of liquidity event distributable to equity holders if MSLF loan is paid off prior to distributions
Access for companies fighting COVID-19
Prob.-Exclusion of companies fighting COVID-19
Sol.-Exigent COVID-19 circumstances include fighting COVID-19 and its effects
Preexisting equity awards and compensation
Prob.-if included in comp calculation, equity awards vesting under previous agreements can disqualify growth companies, even though illiquid
Sol.-Compensation excludes value of equity awards that vest under agreements prior to 3/27/20
Requirement of existing lenders to agree to MSLF loan
Prob.-Borrowers must obtain consent from current lenders before taking MSLF loan
Sol.-Lenders may restructure other debt so long as not senior to MSLF, and MSLF loan is not used to pay down other debt
Limitations on reductions in debt/existing lines of credit
Prob.-Lenders would lose ability to restructure credit lines/reduce debt during MSLF loan, creating credit and asset management dangers for
National Venture banks
4/16/2020 4:45:00 jfield@nvca.o Capital Sol.-Limitations on reductions in debt and existing lines of credit by lender only for the first year of MSLF loan
PM PIO (Email from Field Justin rg Association
Page 257 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
The non-profit agency I work for as a Director in Early Intervention has a 100 year history of helping families in Massachusetts. Last year, we
delivered home visiting services to over 15,000 infants and toddlers. Our skilled staff of 864 professionals made this possible. And yet,
because there are more than 500 of us, we were left without support for sick leave, paycheck protection, and forgivable loans. We are held to
different criteria for the employee retention credit. We are left out of the economic stimulus that is essential for our organization's
survival.
The lack of cash flow to our agency, and others like ours, is leading to job loss. Without revenue from service delivery, we cannot pay staff.
The longer term impact is that families and our service sector will suffer for decades. Across the country, programs like ours are closing,
furloughing staff, and stopping services to children who need our help.
With access to favorable lending terms and with the same stimulus funding that was offered to smaller non-profits, we can continue to employ
our staff of nurses, therapists, speech-language pathologists, educators, and other skilled specialists. We can continue to support children
4/16/2020 4:47:00 djaworek@th Thom Child and and families. We can avoid an erosion of our social service sector. We need immediate action. Non-profit agencies of our size must be
PM PIO (Email from Jaworek Donna omchild.org Family Services included in the Main Street Lending Program and any subsequent mid-size loan programs
As a nurse who has worked in early intervention for many years I cannot imagine what some families would do without our support. These
are children with genetic,neurological and neurodegenerative, metabolic and muscular skeletal disorders. We work with children with
speech delays and disorders as well as behavioral, social emotional and children at risk for delay due to family conditions. We are essential to
families who rely on help with their developing families. Children in our program are not developing normally and we need to support them
more than ever now due to this pandemic. These are everyone's children and they are our future. We need to support the staff and
programs behind them. We need access to more favorable lending terms and to the same stimulus funding that was offered to smaller non-
cgeoghegan Thom Pentucket profits. We must be included in the Main Street Lending Program and any subsequent mid-sized loan program.
4/16/2020 4:47:00 @thomchild.o Early Thank you
PM PIO (Email from Geoghegan Christine rg Intervention
Program structure looks good. I think it's very important to include residential and commercial development as an eligible activity.
These projects are having a difficult time accessing capital due to COVID uncertainty. We're seeing a significant amount of labor
sidelined as good projects are delayed.
National What will be the process for an eligible lending entity to access funds?
4/16/2020 4:47:00 Scott@NSG Development
PM PIO (Email from Keller Scott DC.com Group What will be the process for an eligible borrower to initiate contact with an eligible lender? How quickly can funding occur?
In a normal year, CAMBA serves more than 65,000 New Yorkers by taking a comprehensive approach to address poverty across six program
areas: Economic Development, Education/Youth Development, Family Support, Health, Housing, and Legal Services.
The number of New Yorkers in need of our services has grown significantly with the pandemic. Before COVID-19 hit, CAMBA employed
approximately 2,000 individuals. To meet demand for services, we will need to hire 500 more.
We respectfully ask that you:
Allow loan forgiveness for nonprofits or offer these organizations a 0% interest rate at a 5 year amortization;
Ensure payments are not due until two years after a direct loan is made;
Allow nonprofits maximum flexibility regarding the labor and collective bargaining-related certifications outlined for the program;
Ensure employee retention provisions begin on the date the borrower receives loan funding and, in implementing workforce
restoration/retention provisions, define workforce as full-time employees; and
Give priority to 501(c)(3) nonprofits responding to COVID-19 relief efforts.
Personal CAMBA and CAMBA has served New York City for more than 40 years. Our model has been, and remains, to identify emerging needs and to quickly scale
4/16/2020 4:47:00 Email Address CAMBA Housing programs to tackle those problems. We are working every hour to ensure the health, safety, and security of thousands of Americans and we
PM PIO (Email from Oplustil Joanne M. Ventures appreciate your thoughtful consideration of our request.
Page 258 of 363
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Main Street Lending Program Comments
I am affiliated with a non-profit organization that provides behavioral health, child welfare services, housing support to individuals in
California.
I ask the Federal Reserve and Treasury Department to immediately issue guidance on a program, as directed under the CARES Act, to
provide financing to banks and other lenders to make loans to non-profits and other mid-size businesses (between 500-10,000 employees).
We request that the program include the following:
oInclude a 0.50% interest rate (50 basis points) for 501(c)(3) charitable nonprofits at a 5-year amortization
oProvide priority to 501(c)(3) charitable nonprofits responding to COVID-19 relief efforts
oPayments should not be due until two years after a direct loan is made
oEmployee retention provisions should begin on the date that loan funding is received by the borrower
Hathaway- oIn any workforce restoration and retention provisions, "workforce" should be defined as full-time employees or full-time
Sycamores Child equivalents
4/16/2020 4:47:00 krivas@hscfs & Family Many non-profit organizations are not able to access the Paycheck Protection Program , which is critical to ensure the continued provision of
PM PIO (Email from Rivas Karla .org Services essential services during this crisis
Children's Home & Aid is a large social service organization headquartered in Chicago, IL. While most of our sites are closed, we
continue to serve 100% of our client population of nearly 20,000 vulnerable children and families during this critical moment in time.
As the Treasury Department works to create a program as directed under the CARES Act (section 4003(c)(3)(D)) to provide financing directly
to banks and other lenders for loans to nonprofits and other mid-size business sized between 500-10,000 employees, we request the
following program components:
1. Include a 0.50% interest rate (50 basis points) for 501(c)(3) charitable nonprofits at a 5 year amortization
2. Provide priority to 501(c)(3) charitable nonprofits responding to COVID-19 relief efforts
3. Ensure payments not to be due until two years after a direct loan is made
4. Employee retention provisions should begin on the date that loan funding is received by the borrower
5. In implementing any workforce restoration and retention provisions, "workforce" should be defined as full-time employees or full-
time equivalents
Many nonprofits like the one I lead employ more than 500 employees and have been unable to access the Paycheck Protection Program.The
mshaver@chi recommendations above will help to keep these organizations financially strong and allow them to continue to meet the immediate needs of
4/16/2020 4:48:00 ldrenshomea Children's Home their communities.
PM PIO (Email from Shaver Michael ndaid.org & Aid
YWCA and nonprofits across the country are on the front lines in our communities during the COVID-19 pandemic, working tirelessly to serve
the most vulnerable people who need services. Nonprofits that serve in the social service sector MUST be included in the Main Street Covid-
4/16/2020 4:48:00 Personal Email 19 relief package. Nonprofits need financial support to keep their doors open to continue providing the desperately needed services for
PM Address
PIO (Email from Cannon Mashariki individuals and families across the country.
I am affiliated with a non-profit organization that provides behavioral health, child welfare services, housing support to individuals in Ca. I ask
the Federal Reserve and Treasury Department to immediately issue guidance on a program, as directed under the CARES Act, to provide
financing to banks and other lenders to make loans to non-profits and other mid-size businesses (between 500-10,000 employees). Many non-
profit organizations aren't able to access the Paycheck Protection Program, this is critical to ensure the continued provision of essential
services during this crisis Without increased access to loan programs intended to sustain payroll and retain employees, these mid-sized non-
Hathaway- profit organizations are at financial risk, a circumstance that could leave thousands of individuals without timely access to needed care. This
Sycamores Child lack of access to care will lead many Americans to utilize more emergency services, over-crowding community hospital emergency
4/16/2020 4:49:00 ssanpedro@ and Family departments. This will drive up health care costs at a time when the health system is already strained caring for COVID-19 patients
PM PIO (Email from San Pedro Shannon hscfs.org Services
In regards to the term of the program, I am concerned regarding the language that is placed on restricting dividend / distribution payments.
For S-Corporations, this is used to pay the income tax liability by the individual owners of the S-Corporation. I am wondering if this is an
unintended consequence of the legislation.
kevin.mullins Addiction I understand how this would apply to a C-Corporation, but it appears that "Corporation" is used too broadly. Please clarify the
4/16/2020 4:50:00 @arccenters. Recovery Care, intent and the potential impact of this provision on S-Corporations. In closing, there are other "pass through" entities that will be
PM PIO (Email from Mullins Kevin com LLC impacted as well since distributions are made for tax liabilities for the company.
Page 259 of 363
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Main Street Lending Program Comments
April 16, 2020
Re:Main Street Lending
Dear Sir or Madam:
We respectfully provide below certain comments for consideration by the Federal Reserve System ("Federal Reserve") and U.S.
Department of the Treasury ("Treasury") regarding the term sheets ("Term Sheets") released by the Federal Reserve
on April 9, 2020 for the Main Street New Loan Facility (the "Main Street Program") and the Main Street Expanded Loan Facility
(the "Main Street Expanded Program" and, with the Main Street Program, the "Programs") to support lending to small
and medium-sized businesses ("Purpose"). Capitalized terms used but not defined in this letter have the meanings given in the
Term Sheets.
Required Attestations.
With exception for the attestations regarding the use of proceeds to repay or refinance pre-existing loans or lines of credit, to repay certain
other loan balances, and to make reasonable efforts to maintain its payroll and retain its employees, the Term Sheets do not restrict the use of
proceeds by Eligible Borrowers.
Many small and medium-sized businesses could be excluded from access to the Programs if required to make onerous or impracticable
restrictions on the use of proceeds. Please confirm that, to support the Purpose, there will not be additional restrictions on the use of
michael.winte Dentons Cohen proceeds beyond those contained in the Term Sheets.
4/16/2020 4:51:00 rhalter@dent & Grigsby Very truly yours,
PM PIO (Email from Winterhalter Michael ons.com P.C. Michael Winterhalter, Dentons Cohen & Grigsby P.C.
The non-profit agency I work for has a 100 year history of helping families in Massachusetts. Last year, we delivered home visiting services to
over 15,000 infants and toddlers. Our skilled staff of 864 professionals made this possible. And yet, because there are more than 500
of us, we were left without support for sick leave, paycheck protection, and forgivable loans. We are held to different criteria for the employee
retention credit. We are left out of the economic stimulus that is essential for our organization's survival.
The lack of cash flow to our agency, and others like ours, is leading to job loss. Without revenue from service delivery, we cannot pay staff.
The longer term impact is that families and our service sector will suffer for decades. Across the country, programs like ours are
closing, furloughing staff, and stopping services to children who need our help.
With access to favorable lending terms and with the same stimulus funding that was offered to smaller non-profits, we can continue to employ
our staff of nurses, therapists, speech-language pathologists, educators, and other skilled specialists. We can continue to support
Personal Email
children and families. We can avoid an erosion of our social service sector. We need immediate action. Non-profit agencies of our size must
Address
4/16/2020 4:51:00 Thom Child and be included in the Main Street Lending Program and any subsequent mid-size loan programs
PM PIO (Email from Lavoie Kim Family Services
Non-profits, including higher education organizations, employ millions of American workers, have a huge economic impact, and have a
massive impact generally on their local communities. Right now, they are providing essential services in those communities. Non-profits
should be eligible for loans through the proposed Main Street Lending program. To illustrate the point, I work for an arts and culture non-profit
in Providence, RI. Data compiled by the National Endowment of the Arts in 2018 found that the arts contribute $763.6 billion to the U.S.
economy, more than agriculture, transportation, or warehousing. The arts employ 4.9 million workers across the country with earnings of
more than $370 billion. Despite some temporary programmatic suspensions, my organization is still providing essential services such as
housing to low income resident artists and much needed stipends to youth in our community, including incarcerated and formerly incarcerated
youth, those who are pregnant and parenting, youth in foster care, and youth at high risk of school dropout and disconnection. Our services
are needed more than ever during the COVID-19 pandemic. There is no valid reason not to include non-profit businesses such as ours in the
4/16/2020 4:53:00 Jason.colon Main Street Lending program, and not doing so potentially creates further financial burden on already chronically underfunded service
PM PIO (Email from Colon Jason @as220.org AS220 providers.
Page 260 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 urge you to recognize mid-size nonprofits as eligible entities of the Main Street Lending Program and to consider forgivable loan options.
Catholic Charities of St. Paul and Minneapolis has 580 employees and serves nearly 23,000 men, women, children and families. Nonprofits
like ours comprise our nation's safety net, providing shelter, food, medical and other essential services to those most in need.
COVID19 is creating a greater demand for social services. At the same time, the economic downturn is reducing revenues, and charitable
contributions are likely to decrease, putting extreme financial stress on nonprofits as we seek to maintain critical safety net services for
vulnerable populations.
Federal relief has largely failed to recognize mid-sized charitable nonprofits (those with 500 or more employees). We are ineligible for the
paycheck protection program, COVID19 tax credit and others, despite being significant employers. We do not qualify for other federal aid -
such as that offered by FEMA, HUD and CDBG - which goes directly to state or local governments.
Mid-sized nonprofits are key to a healthy economy and healthy communities. They need immediate access to forgivable and zero interest
loans to respond to the increasing demands caused by the pandemic and to stabilize operations as we move toward recovery. Without it,
Catholic many will be forced to significantly reduce services or close their doors at a time when services are needed most.
lorna.schmidt Charities of St.
4/16/2020 4:53:00 @cctwincities Paul and
PM PIO (Email from Schmidt Lorna .org Minneapolis
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 4:53:00 Email 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 Lee Bryant
Heating, Air- Heating, Air-conditioning, & Refrigeration Distributors International (HARDI) is deeply concerned with the limitation put on companies
conditioning, using the Main Street Lending Program. Part of the attestations required to receive loans includes the limits on distributions of capital stock
& from Section 4003 of the CARES Act. Many businesses organized as S-corporations use distributions to pass-through tax payments to the
Refrigeration individual owners to file through their 1040 forms. Without the ability to distribute these payments S-corps are effectively barred from
4/16/2020 4:54:00 aayers@hard Distributors participating in the Main Street Lending Program.
PM PIO (Email from Ayers Alex inet.org International
Dear Board of Governors of the Federal Reserve,
Novita Nutrition is in the business of producing high quality protein for the dairy industry and have a Confidential Business Information
Would it be possible to add a Debt to Asset metric of 60% after adding the Mainstreet financing as another method
to determine the eligible amount? We appreciate your consideration and hope you would consider our request. With additional capital we are
confident we can stay in operation and return to profitability after business returns to a more normal operating environment.
We have tried to apply for the PPP program but the affiliation rule prevents our business from being eligible to receive financing. I would
welcome the opportunity to answer additional questions and look forward to hearing back from you.
Best regards,
Don Endres
4/16/2020 4:55:00 don@novitan CEO Novita Nutrition
PM PIO (Email from Endres Don utrition.com Novita Nutrition
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Main Street Lending Program Comments
As a privately-funded, regional economic organization (501c6) in a county with 70,000 businesses 98% of which are small enterprises, our
team of 23 professionals are on the front line of the COVID crisis. In a typical year, we assist 150+/- companies expand their footprint in our
county. In the last four weeks, we have triaged the needs of more than 400 small businesses, seemingly with no end in sight. Many do not
have strong advisors in banking, legal and accounting. They need information, guidance and resources. We cannot reduce our ranks when
companies so desperately need help to access complex systems. As a 501c6, we are not eligible for the Paycheck Protection Program. Our
base of members has been hit hard by the crisis. We have already heard from many who cannot contribute funding this year. We are fighting
Economic to stay afloat. We applaud a CARES 2 package to provide desperately-needed resources and ask that it includes PPP eligibility for economic
Development development nonprofits classified as a 501c6. Our services are vital to the survival of the most vulnerable small businesses and we will be a
4/16/2020 4:56:00 ls@sandiego Corp of San significant leader in developing and executing the recovery plan for San Diego County alongside state and local governments.
PM PIO (Email from Sahba Lauree business.org Diego County
We urge you to approve the Main Street Lending program. Pathlight is a 501(c)3 non-profit that has provided services to people with
developmental disabilities and autism since 1952. We have 650 employees in Western Massachusetts. We do not qualify for the PPP. Since
Ruth.Banta@ 80% of our expense are staffing, this is a significant issue for us. The COVID-19 pandemic has significantly increased our expenses as we
4/16/2020 4:56:00 PathlightGrou need to staff our group homes 24/7 with incentive payments for staff. The cut off 500 employees for many of federal programs leaves out
PM PIO (Email from Banta Ruth p.org Pathlight, Inc. non-profits like Pathlight which put us, our staff and our services in fiscal peril.
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; and
In implementing any workforce restoration and retention provisions, "workforce" should be defined as full-time employees or full-
4/16/2020 4:56:00 mitchelb@fcc Friendship time equivalents.
PM PIO (Email from Mitchel Brandy are.org Community Care
April 16, 2020
Re:Main Street Lending
Dear Sir or Madam:
We respectfully provide below certain comments for consideration by the Federal Reserve System ("Federal Reserve") and U.S.
Department of the Treasury ("Treasury") regarding the term sheets ("Term Sheets") released by the Federal Reserve
on April 9, 2020 for the Main Street New Loan Facility (the "Main Street Program") and the Main Street Expanded Loan Facility
(the "Main Street Expanded Program" and, with the Main Street Program, the "Programs") to support lending to small
and medium-sized businesses ("Purpose"). Capitalized terms used but not defined in this letter have the meanings given in the
Term Sheets.
Eligible Loans.
The Term Sheets include loan size limitations based on leverage conditions and the EBITDA of an Eligible Borrower.
A.Many small and medium-sized businesses that are subject to increased leverage conditions could be excluded from access to the
Programs based on these loan size limitations. To support the Purpose, these leverage conditions should be revised or qualified to permit
such businesses that are subject to increased leverage conditions to have access to Eligible Loans.
B.Many small and medium-sized businesses require adjustments to EBITDA. To support the Purpose, the Main Street Program and Main
adrian.stewar Street Extended Program should permit adjustments to EBITDA for purposes of determining the maximum loan amount.
4/16/2020 4:56:00 t@dentons.c Very truly yours,
PM PIO (Email from Stewart Adrian om Dentons US LLP Adrian Stewart, Dentons US LLP
Personal I strongly object to the exclusion of nonprofits from the Main Street Lending Program. Nonprofits are desperately needed right now, and the
4/16/2020 4:57:00 Email Address current economic conditions have hit them especially hard.
PM PIO (Email from Williams Cassandra
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Main Street Lending Program Comments
These comments are submitted on behalf of Venable LLP with regard to the MSELF:
1.Definition of Eligible Borrowers. Amend the definition to clarify that only one of the two requirements stated need be met to be an eligible
borrower. This can be accomplished either by inserting:
a.The word "either" after the word "businesses" in the first sentence of the definition, or
b. An additional sentence confirming that meeting either requirement (up to 10,000 employees or less than $2.5 billion 2019 revenue) allows
a borrower to qualify as an "Eligible Borrower."
Potential participants in this program have expressed doubt that the eligibility test is in the disjunctive. Unless clarified now, this issue will
cause needless delay in the review process and potential rejection of applications from otherwise qualifying borrowers.
2.EBITDA Test in Para. 5(iii). Amend paragraph 5(iii) in the Eligible Loan section. The current test is based, in part, on the applicant's
2019 EBITDA. We suggest using an average of the applicant's EBITDA over the three prior years (2017-19). This would give the lender
a better view of the applicant's business performance and credit capacity. This change could be a replacement calculation or an
alternative one, in which case the higher of the two numbers (2019 EBITDA or 2017-19 average EBITDA) would be used.
Thank you for your consideration. Please do not hesitate to contact us with questions.
4/16/2020 4:57:00 dwilson@ven D. E. (Ed) Wilson, Jr. & Laura R. Biddle
PM PIO (Email from Wilson, Jr. D. E. (Ed) able.com Venable LLP
The maximum loan size limitations of 4x MSNLF and 6x MSELF EBITDA minus outstanding debt and committed, undrawn facilities provide no
incremental capital to NBFFs. NBFFs require significantly more debt for each dollar of equity to fund consumer loans efficiently.
The $25M MSNLF/$150M MSELF maximum loan limitations are inadequate for NBFFs whose primary capital need is for continued funding of
consumer loans.
The requirement that MSELF loans be in place prior to April 8 significantly limits the utility of the program. NBFFs typically fund their business
with receivables-based loans, with limited, or no, corporate indebtedness.
The 5% participation requirement for MSLP eligible lenders limits expansion of borrowing capacity. Most companies will have fully drawn on
existing credit capacity in anticipation of a business disruption, and lenders are unlikely to increase their exposure to facilitate new loans.
Including undrawn lines of credit in the maximum loan size calculation further limits NBFFs total borrowing capacity and ignores that these
lines are at significant risk of being terminated.
The term loan structure requires companies to draw funds today without regard to the timing of the need for capital. This increases the
Squire Patton borrowing cost and limits the ability of the facility to meet future needs as they arise.
brandon.rom Boggs (on behalf Consumer loan funding is NBFFs' principal need for capital and is inadequately addressed by the MSLP.
4/16/2020 4:57:00 an@squirepb of non-bank
PM PIO (Email from Roman Brandon .com financial firms)
To whom it may concern:
Thank you for your work to provide support for our crucial small and mid-sized businesses during this time. The "Main Street"
program will provide much needed relief and additional options for aid for struggling businesses that need help to stay afloat and support our
economy.
We ask that relief be extended to all of our crucial businesses and organizations, including non-profits, both 501(c)(3)s and 501(c)(6)s;
institutions of higher learning; and minority-serving institutions.
If these organizations are unable to survive, the path to recovery for our hard-hit Main Street economy will be even more difficult.
epaul@birmi
nghambusine Birmingham Sincerely,
4/16/2020 4:57:00 ssalliance.co Business
PM PIO (Email from Paul Elizabeth m Alliance The Birmingham Business Alliance
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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 Email
4/16/2020 4:59:00 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 Phan M
Please consider minimum loan amounts below 1 million dollars. If you are truly looking to help small businesses you must consider setting a
lower minimum loan amount.
As you can see, the EIDL and PPP may not stay funded long enough to help most of Main Street. Lending to true small businesses (with
annual revenue averaging $400,000 or more) is the best way to ensure that your investment in the future of American enterprise is dispersed
in a way that minimizes risk to taxpayers while maximizing the potential of our great entrepreneurs and community leaders.
Please consider lending minimums appropriate for the majority of America's small businesses. Most of us will not qualify for $1 Million.
4/16/2020 sean@theblo
12:00:00 AM PIO (Email from Bucher Sean ck.me
Saint Francis Ministries is a national and international organization that is headquartered in Salina, Kansas. Rooted in the Episcopal tradition,
Saint Francis is an independent not-for-profit with a mission to provide hope and healing through a multi-faceted child and family services
ministry in six states and around the globe. We provide child welfare case management, foster care homes, youth residential programs, and
mental health and substance use treatment services.
We request that the Main Street Loan Program (MSLP):
*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;
*Defer payments up to two years after a direct loan is made;
*Begin employee retention provisions on the date that loan funding is received by the borrower;
*Define "workforce as full-time employees or full-time equivalents in workforce restoration and retention provisions.
Nonprofits are the third largest employer in our nation's economy. Many are essential partners to public agencies in providing the vital
human services that keep people and communities safe and stable. Our recommendations to the MSLP will help keep nonprofits financially
4/16/2020 5:00:00 marlo.nash@ Saint Francis strong so we can meet today's needs and still be there in the future when many of our services will be needed even more. In the
PM PIO (Email from Nash Marlo st-francis.org Ministries toughest times, we do the toughest work.
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Main Street Lending Program Comments
Dear Secretary Mnuchin and Chairman Powell,
Cumulus Media is the second largest radio broadcaster in the US by number of stations and the third largest by revenue; as well, we operate
the country's largest radio network, Westwood One, which represents 8,000 affiliate stations in addition to our own, and we own and
manage a number of digital properties. We also employ over 4,500 full-time and part-time personnel who work tirelessly to deliver essential
news and information and entertainment content across all our platforms to serve the public interest and reach over 250 million listeners every
month who depend on us for that content.
As you are no doubt aware, the radio industry has been drastically impacted by the COVID-19 crisis given the crisis-induced reduction in
advertising spend, which makes up more than 90% of our revenue, and, specific to radio, the dramatic suppression of commuter traffic which
has decimated "drive-time-radio," a key component of radio's listenership base. As a leading radio broadcaster, we are
suffering significantly from these effects.
We have reviewed the requirements published by the Treasury Department for both the Main Street New Loan Facility ("MSNLF")
and the Main Street Expanded Loan Facility ("MSELF"), and we have several comments and suggestions for clarification under
separate cover.
4/16/2020 5:01:00 collin.jones@ Please see the email titled "Main Street Lending - Cumulus Media Comments" - sent on 4/16/20 at approximately 5:00 PM ET.
PM PIO (Email from Jones Collin cumulus.com
We provide here comments regarding the term sheets released by the Federal Reserve on April 9, 2020 for the Main Street New Loan Facility
and the Main Street Expanded Loan Facility to support lending to small and medium-sized businesses ("Purpose").
Required Attestations.
With exception for the attestations regarding compensation, stock repurchase, and capital distributions, the Term Sheets do not require
attestation that an Eligible Borrower would comply with other requirements set forth in Section 4003(c)(3)(A)(ii) of the CARES Act. Many
small and medium-sized businesses could be excluded from access to the Programs if required to make other attestations such as the
certifications required under section 4003(c)(3)(D)(i) of the CARES Act. Please confirm that, to support the Purpose, the certifications
required under section 4003(c)(3)(D)(i) of the CARES Act do not apply to an Eligible Borrower under the Main Street Program and Expanded
Main Street Program.
The Term Sheets provide little guidance as to the covenants (financial and otherwise) and other terms and conditions that would be required
of Eligible Borrowers, and do not clarify important application, approval and documentation issues related to Eligible Loans. Please confirm
that, to support the Purpose, guidance will provide consistent, clear and limited terms and conditions for application, approval, documentation
4/16/2020 5:01:00 john.cleary@ and terms for Eligible Loans.
PM PIO (Email from Cleary John dentons.com Dentons US LLP
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Main Street Lending Program Comments
April 16, 2020
Re: Main Street Lending
Dear Sir or Madam:
We respectfully provide below certain comments for consideration by the Federal Reserve System ("Federal Reserve") and U.S.
Department of the Treasury ("Treasury") regarding the term sheets ("Term Sheets") released by the Federal Reserve
on April 9, 2020 for the Main Street New Loan Facility (the "Main Street Program") and the Main Street Expanded Loan Facility
(the "Main Street Expanded Program" and, with the Main Street Program, the "Programs") to support lending to small
and medium-sized businesses ("Purpose"). Capitalized terms used but not defined in this comment have the meanings given in
the Term Sheets.
The Term Sheets mandate that the limitation on certain employee compensation at section 4004 of the CARES Act apply for the term of the
Eligible Loan and 12 months after the repayment of the Eligible Loan. Total compensation is defined as including salary, bonuses, awards of
stock and other financial benefits provided to an officer or employee.
Many small and medium-sized businesses that utilize incentive equity plans could be excluded from access to the Programs depending on
how incentive equity is valued. To support the Purpose, the compensation conditions should be revised or qualified to permit such
businesses that utilize incentive equity plans to have access to Eligible Loans.
christopher.th Dentons Cohen
4/16/2020 5:03:00 el@dentons.c & Grigsby Very truly yours,
PM PIO (Email from Thel Christopher om P.C. Chris Thel, Dentons Cohen & Grigsby P.C.
I'm associated with a public nonprofit organization in CA providing public resources for many who need them. I'm advocating the
Federal Reserve and Treasury Department to immediately issue guidance on a program, as directed under the CARES Act, to provide
financing to banks and other lenders to provide the following measures:
oInclude a 0.50% interest rate (50 basis points) for 501(c)(3) charitable nonprofits at a 5-year amortization
oProvide priority to 501(c)(3) charitable nonprofits responding to COVID-19 relief efforts
oPayments should not be due until two years after a direct loan is made
oEmployee retention provisions should begin on the date that loan funding is received by the borrower
Hathaway oIn any workforce restoration and retention provisions, "workforce" should be defined as full-time employees or full-time
Sycamores Child equivalents
4/16/2020 5:04:00 hilarydeckard and Family Additionally, we do not have the Paycheck Protection Program that will allow us to retain employees critical in supporting needed services
PM PIO (Email from Deckard Hilary @hscfs.org Services and be able to manage implications for current COVID-19 crisis.
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; and
In implementing any workforce restoration and retention provisions, "workforce" should be defined as full-time employees or full-
4/16/2020 5:04:00 mitchelc@fcc Friendship time equivalents.
PM PIO (Email from Mitchel Benjamin are.org Community Care
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Main Street Lending Program Comments
The CT Community Nonprofit Alliance (The Alliance) is the statewide association of community nonprofit in Connecticut.
I submit the following comments on behalf of the many nonprofit organizations who have been excluded from the critical benefits of the
Paycheck Protection Program, simply because they employ more than 500 in their workforce. The Paycheck Protection Program contains
loan forgiveness provisions that 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.
As you proceed, 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. In addition, please provide priority to 501(c)(3) charitable nonprofits responding to COVID-19 relief efforts. We recommend that
the payments should not be due until two years after a direct loan is made.
As you are likely aware, employee retention has been a critical concern for nonprofit providers. We recommend that the employee retention
gcasa@ctnon CT Community provisions should begin on the date that loan funding is received by the borrower. Finally, we recommend that upon implementing any
4/16/2020 5:05:00 profitalliance. Nonprofit workforce restoration and retention provisions, "workforce" should be defined as full-time employees or full-time equivalents.
PM PIO (Email from Casa Gian-Carl org Alliance
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.
k.hiler@newa
4/16/2020 5:05:00 mericanpath 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 Hiler Kristin ways.org this unprecedented crisis depends on the success of our nation's nonprofits.
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
organizations, by mandate of their non-profit status and their oversight governance are the MOST efficiently run organizations that perennially
4/16/2020 5:06:00 kay@ywcaau 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 Suttle-Field Kay stin.org YWCA MOST needed by the communities they serve.
We provide here certain comments for consideration regarding the term sheets for the Main Street New Loan Facility (the "Main Street
Program") and the Main Street Expanded Loan Facility (the "Main Street Expanded Program"). The Main Street Expanded
Program provides for collateral securing an Eligible Loan, whether pledged under the original terms of the Eligible Loan or at the time of
upsizing, to secure the loan participation on a pro rata basis. If the SPV shares "pro rata" in collateral securing the existing and the
upsized loan, it may dis-incentivize banks from lending under the Main Street Expanded Program. For instance, if an Eligible Lender with
existing secured loans of $100M outstanding to an Eligible Borrower would be required, in connection with an upsized loan of $20M in which
the SPV would have a 95% participation, to permit the SPV to share:
- the existing collateral, it might discourage Eligible Lenders from lending under the Main Street Expanded Program and favor the Main Street
Program if they were permitted to choose what to offer; and/or
- in proceeds of existing collateral, the allocation of such proceeds would need to be limited to the amount of the participation (which we
Elke.rehbock understand the intent of the term sheet to be).
4/16/2020 5:06:00 @dentons.co To support broad participation, this framework should be revised, clarified or qualified to ensure the availability of loans under the Main Street
PM PIO (Email from Rehbock Elke m Dentons US LLP Expanded Program.
Please incude nonprofits in the Main Street lending program. Nonprofits are a vital part of communities and they not only support thier own
4/16/2020 5:07:00 Personal employees but also support community resilience and rebuilding efforts by providing services to those who are the most impacted in
PM PIO (Email from Word Jessica Email Address communities. Leaving these organizations out of this funding will have a large negative impact upon communities.
The Fed should revise the term sheet to conform with the terms of Section 4003(c)(3)(D) of the CARES Act, particularly those terms designed
to protect American workers' jobs, pay and benefits. These include the prohibition on loan recipients offshoring work, and the
Communications requirements that loan recipients use the money to maintain a high percentage of payroll and remain neutral whenever employees consider
4/16/2020 5:08:00 dmauer@cw Workers of whether to engage the employer in collective bargaining for their mutual aid and benefit. The current term sheet ignores one safeguard after
PM PIO (Email from Mauer Dan a-union.org America (CWA) another that Congress enacted to ensure these funds are utilized for the benefit of working people.
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Main Street Lending Program Comments
On behalf of YMCA of the USA, the resource office for the nation's 2,600 YMCAs, I urge you to include nonprofits in the Main Street
lending program. We request that the program:
Model the SBA PPP program approach by forgiving loan amounts that meet certain criteria around employment.
Include a 0.50% interest rate (50 basis points) for 501(c)(3) charitable nonprofits at a 5-year amortization
Give priority to 501(c)(3) charitable nonprofits responding to the COVID-19 crisis.
Provide that payments shall not be due until two years after a direct loan is made
Stipulate that employee retention provisions begin on the date that loan funding is received by the borrower
Define "workforce" as full-time employees or full-time equivalents for the purposes of implementing any workforce restoration
4/16/2020 5:08:00 Neal.Denton YMCA of the and retention provisions
PM PIO (Email from Denton Neal @ymca.net USA [FULL LETTER SUBMITTED TO email address]
Re: Ensuring nonprofits have access to the Main Street Lending Program
Since 1969, the Los Angeles LGBT Center (Center) has cared for, LGBT individuals and families in Los Angeles and beyond. Today the
Center's nearly 800 employees provide services for more LGBT people than any other organization in the world. The Center is one of
the few Federally Qualified Health Centers in the nation with providers who specialize in medical care for the LGBT people and people living
with HIV/AIDS. In addition to our health services, we offer residential services for youth and seniors, drop-in services for homeless persons,
meal services, and so much more. Across all of our programs, we see over a half a million client visits each year. In this time, the need for
our services has never been greater, which is why the Center was deeply concerned to learn that the Federal Reserve's new
"Main Street" lending facility would exclude nonprofits, the very organizations on the front lines responding to this pandemic. This
is a particularly devastating blow for organization likes our who are currently ineligible for the Paycheck Protection Program. Given the
current financial crisis and loss of revenue, the Center, may be forced to shrink our services, meaning thousands could go without care.
Nonprofits like ours need access to these government backed revenue streams and loan programs. We urge the Federal Reserve to expand
4/16/2020 5:08:00 tslavin@lalgb Los Angeles the eligibility of this program to explicitly include nonprofits.
PM PIO (Email from Russell-Slavin Terra tcenter.org LGBT Center
I am writing to raise an issue that will impact many of the nation's pass-through businesses, including the majority of over 3,000 family-
owned beer distribution businesses represented by the National Beer Wholesalers Association.
Federal guidance should include and allow for S corporation access to the MSLP loan program during this difficult time. The inclusion of
certain capital distribution limitations or restrictions could prevent S corporations from participation in this much-needed loan program. To
address this concern, NBWA recommends clarifying capital distribution attestation requirements for the loan program by addressing Section
4003(c)(3)(D)(i)(vii) of the CARES Act with an exception for pass-through distributions that are made to finance taxes owed on business
income, in a manner similar to the following:
The Eligible Borrower must attest that it will follow compensation, stock repurchase, and capital distribution restrictions that apply to direct
loan programs under 4003(c)(3)(D)(i)(vii) of the CARES Act. These restrictions do not apply to pass-through entities that make distributions to
pay taxes attributable to income earned by the eligible entity.
National Beer NBWA members are primarily structured as S corporations. Correcting this presumed unintended consequence for pass-throughs will help
4/16/2020 5:09:00 lknight@nbw Wholesaler ensure that these businesses - many of which are family-owned and family-operated - are allowed to participate in the MSLP loan program.
PM PIO (Email from Purser Craig a.org Association
We respectfully provide below certain comments for consideration regarding the term sheets ("Term Sheets") released by the
Federal Reserve on April 9, 2020 for the Main Street New Loan Facility (the "Main Street Program") and the Main Street Expanded
Loan Facility (the "Main Street Expanded Program" and, with the Main Street Program, the "Programs") to support
lending to small and medium-sized businesses ("Purpose"). Capitalized terms used but not defined in this letter have the
meanings given in the Term Sheets.
The Term Sheets would require attestation that an Eligible Borrower must commit to refrain from repaying other debt of equal or lower priority,
with the exception of mandatory prepayments, unless the Eligible Borrower has first repaid the Eligible Loan in full.
Many small and medium-sized businesses have existing commitments related to unsecured third-party debt the terms of which would conflict
with such required attestation, and thus such businesses could be excluded from access to the Programs. To support the Purpose, these
michael.doug Dentons Cohen attestations should be revised or qualified to permit (a) regularly scheduled payments of interest and principal on existing debt, including
4/16/2020 5:10:00 herty@dento & Grigsby payment at maturity (in addition to mandatory prepayments), and (b) the refinancing of such debt in the event that such business determines
PM PIO (Email from Dougherty Michael ns.com P.C. that doing so is in its best interests economically and financially.
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Main Street Lending Program Comments
We respectfully provide below a comment for your consideration regarding the term sheet ("Term Sheet") released by the Federal
Reserve on April 9, 2020 for the Main Street New Loan Facility (the "Program") to support lending to small and medium-sized
businesses ("Purpose"). Capitalized terms used but not defined in this comment have the meanings given in the Term Sheets.
The Term Sheets limit Eligible Business to businesses with up to 10,000 employees or up to $2.5B in 2019 annual revenues, created or
organized in the United States or under the laws of the United States with significant operations in and a majority of its employees based in
the United States.
Many small and medium-sized businesses could be excluded from access to the Program based on affiliation and consolidation issues. To
support the Purpose, eligibility determinations for a business should be made with reference to the entity applying as the Eligible Borrower
and its direct and indirect subsidiaries without affiliation or consideration of its (i) ownership by and/or affiliation with other parent companies
or entities (whether domestic or foreign) and (ii) affiliation with other foreign subsidiary entities, including, but not limited to, for purposes of
scott.graham Dentons Cohen calculating relevant headcount, headcount location, revenue, operational concentration, and jurisdictional status.
4/16/2020 5:11:00 @dentons.co & Grigsby
PM PIO (Email from Graham Scott m P.C.
Ensuring access to capital will be essential in late stage pandemic response and throughout the recovery phase. Nonprofits, institutions of
higher learning and Minority-Serving Institutions are and will continue to play key roles in both. I urge you to include all three groups in the
Whatcom recently announced Main Street Lending program so that they are able to access the capital necessary to fulfill their essential roles and, in the
4/16/2020 5:12:00 mingram@w Community case of the nonprofit sector, public and community serving missions. Thank you for your consideration.
PM PIO (Email from Ingram Mauri hatcomcf.org Foundation
We respectfully provide below certain comments for consideration by the Federal Reserve System and U.S. Department of the Treasury
regarding the term sheets ("Term Sheets") released by the Federal Reserve on April 9, 2020 for the Main Street New Loan Facility
(the "Main Street Program") and the Main Street Expanded Loan Facility (the "Main Street Expanded Program" and,
with the Main Street Program, the "Programs") to support lending to small and medium-sized businesses. Capitalized terms used
but not defined in this letter have the meanings given in the Term Sheets.
Eligible Borrowers.
Please confirm that a Tribal business concern engaged in a trade or business and distinct from the Indian Tribal government that owns it,
with, for example, its own Federal Employer Identification Number and employees, may be an "Eligible Borrower" under either of
the Programs.
Please confirm that a payment from a Tribal business concern to a Tribal government or government instrumentality, for example, for the
reimbursement of public health and safety services provided by a Tribal government or for any of the other five permitted uses of net gaming
heather.sibbi revenues from Tribal gaming under 25 U.S.C. § 2710(b)(2)(B), would not be considered "compensation, stock repurchase and
4/16/2020 5:12:00 son@denton capital distribution" payments or "dividends . or capital distributions with respect to the common stock of the eligible
PM PIO (Email from Sibbison Heather s.com business" which are restricted by Section 4003(c)(3)(A)(ii) of the CARES Act and the Term Sheets.
CONTEXT: KP Aviation & Affiliates is a profitable, modestly-leveraged aftermarket aviation parts operating company organized as a pass-
through entity.
1)TAX DISTRIBUTIONS PERMISSIBLE: Please confirm that to the extent tax distributions (A) are set forth prior to April 8, 2020 (unless they
are for newly formed entities) in governing documents (e.g., LLC Operating Agreements) and (B) not prohibited under any credit agreements,
they shall be permissible for pass-through entities (i.e., they are not otherwise restricted by the "no dividends" rule.) Otherwise,
the Main Street Lending Program would give rise to phantom income for the owners of borrowers, like KPA, organized as pass-through
entities.
2)Please confirm the parameters for using its cash profits or new debt proceeds (other than proceeds from the Main Street Lending
4/16/2020 5:14:00 linn.s@kpavi KP Aviation Program) to retire any of its outstanding debts. This would allow KPA to retire higher cost fixed obligations - provided that such repayment is
PM PIO (Email from Shaw Linn ation.net & Affiliates not financed by the Main Street loan proceeds.
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Main Street Lending Program Comments
Volunteers of America of MN and WI provides a wide range of services deemed essential.
We have a shoestring budget but exceed the 500-employee threshold in the CARES ACT.
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; and
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
julie.manworr Volunteers of forgiveness provisions that are critical to our organizations, and necessary to help ensure we will be able to continue to provide essential
4/16/2020 5:14:00 en@voamn.o America of MN services during the COVID - 19 crisis and assist with our nation's recovery efforts when the crisis is over.
PM PIO (Email from Manworren Julie rg & WI
It is critical that the Main Street Lending Program include colleges & universities. I am a Trustee of Messiah College who already
discounts its tuition more than 40%, and is experiencing a $7 million dollar shortfall this semester related to the COVID-19 crisis. The COVID-
19 crisis has caused our College to furlough approximately 250 people, in addition to other employees who not be able to be employed this
Fall, should dormitories remain empty and other disruptions to campus eliminate the need for their employment. Messiah has been serving
4/16/2020 5:14:00 leremita@bu. students for more than 100 years and desirous of continuing to educate students for the next several hundred years.
PM PIO (Email from Eremita Linda edu Messiah College
We provide here comments on the term sheets ("Term Sheets") released by the Federal Reserve for the Main Street New Loan
Facility and the Main Street Expanded Loan Facility (the "Programs") to support lending to small and medium-sized businesses
("Purpose").
The Term Sheets require attestation that an Eligible Borrower not pay dividends with respect to its common stock until 12 months after the
Eligible Loan is no longer outstanding, as required in section 4003(c)(3)(A)(ii)(II) of the CARES Act.
A.Some companies, such as real estate investment trusts and regulated investment companies, are required by federal law to make annual
distributions of dividends in order to maintain their tax status. The limitation on the payment of dividends would jeopardize the tax status of
these entities (and would therefore make these loans unavailable for these entities). For this reason, these entities should be excluded from
the limitations on the payment of dividends under section 4003(c)(3)(A)(ii)(II) of the CARES Act.
B.Many businesses could be excluded from access to the Programs based on these attestations. To support the Purpose, these
attestations should be qualified to permit dividends and other distributions (a) for designated purposes including (i) tax distributions and
donald.hamm guaranteed payments for flow through entities, and (ii) in connection with a sale of business transaction, and (b) upon or following the time
4/16/2020 5:14:00 ett@dentons. that the Eligible Loan is no longer outstanding.
PM PIO (Email from Hammett Donald com Dentons US LLP
As the Treasury Dept works to create a program under CARES Act section 4003(c)(3)(D) to provide financing to banks & other lenders to
make loans to nonprofits and other mid-size business 500-10,000 employees, we request they: Include 0.50% interest rate (50 basis points)
for 501(c)(3) charitable nonprofits at a 5 yr amortization; Provide priority to 501(c)(3) charitable nonprofits responding to COVID-19 relief
efforts; Payments shall not be due until 2 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 or equivalents. Many nonprofits employ more than 500 employees and have not been able to access the
Paycheck Protection Program, with loan forgiveness provisions which are critical & necessary to help ensure they will be able to
continue to provide services during the crisis & assist with our nation's recovery efforts when the crisis is over. Nonprofits are the
third largest employer in our nation's economy and valued problem solvers. Our members provide essential supports to people with
intellectual and developmental disabilities. The recommendations above will help to keep these organizations financially strong and allow
4/16/2020 5:15:00 smccracken them to continue to meet the immediate needs of their communities while planning for the future when many of their services will be needed
PM PIO (Email from McCracken Shannon @ancor.org ANCOR most.
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Main Street Lending Program Comments
As a nonprofit organization, Urban Pathways urges the Federal Reserve to either include nonprofit organizations in the Main Street Lending
Program, or to create a separate lending program for organizations with more than 500 staff who are ineligible for the CARES Act PPP/SBA
7(a) loan program.
Private nonprofits form a large industry (larger than the airline industry) and employ many people nationwide. Nonprofit social service
organizations are playing a significant role in the current crisis, taking care of society's most vulnerable populations, including the
homeless, the elderly, and people with disabilities. If these organizations were to close, the most vulnerable in our communities would be at
risk. With many nonprofits already in poor financial straits prior to the Covid-19 epidemic and now enduring increased costs associated with
continuing essential services and/or changing their programs to provide a needed essential service, organizations are being pushed to their
brink. The federal government must provide the same level of relief to nonprofit organizations as they are to for-profit businesses, especially in
light of the essential role they are playing.
nmcvinua@u Due to years of chronic under-funding by local governments, many human service organizations have merged or consolidated into
4/16/2020 5:17:00 rbanpathway organizations with well over 500 staff members. For the same reasons above, nonprofits with more than 500 staff members must also be able
PM PIO (Email from McVinua Nicole s.org Urban Pathways to access zero-interest and forgivable loans.
April 16, 2020
Re:Main Street Lending
Dear Sir or Madam:
We respectfully provide below certain comments for consideration by the Federal Reserve System ("Federal Reserve") and U.S.
Department of the Treasury ("Treasury") regarding the term sheets ("Term Sheets") released by the Federal Reserve
on April 9, 2020 for the Main Street New Loan Facility and the Main Street Expanded Loan Facility.
Required Documentation.
The Term Sheets provide little guidance as to role of the Federal Reserve in approving the proposed form of Note, Loan Agreement and
Participation Agreement.
Please indicate: 1) whether the Federal Reserve will require Eligible Lenders to submit their form of Note and Loan Agreement for approval,
and 2) whether the Federal Reserve will specify a form of Participation Agreement, or require Eligible Lenders to submit their form of
Participation Agreement for approval.
SOFR.
The Term Sheets state that the adjustable rate will be based on SOFR, with little further detail. Eligible Lenders may wish to use an average
of SOFR, rather than daily SOFR.
Please indicate that an Eligible Lender may base the rate for an accrual period on an average of SOFR over an observation period (such as
30 days), determined either in advance or in arrears. Also please indicate that an Eligible Lender may use either simple or compound
averaging,
steve.kudenh Very truly yours,
4/16/2020 5:17:00 oldt@denton
PM PIO (Email from Kudenholdt Stephen s.com Dentons US LLP Stephen S. Kudenholdt, Dentons US LLP
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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.
mkollman@m
4/16/2020 5:18:00 useumofdesi 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 Kollman Max gn.org MODA this unprecedented crisis depends on the success of our nation's nonprofits.
I write to submit the following feedback during the comment period for the proposed Main Street Lending Program.
Many business owners are currently unable to pay rent on the storefront their business occupies. These businesses are suffering from forced
closures of all but essential businesses due to the Covid-19 outbreak. These business owners are stalwart tenants who have rarely, if ever,
caused loss for their landlords. But in these unprecedented times, tenants can't pay rent, and landlords may find it difficult to make
mortgage payments. Worse, business tenants worry they will be evicted--adding future relcoation to the rising costs of maintaining a business
which is ceased serving customers during this pandemic.
In cases where the bank providing Main Street Lending 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.
Louisville
jennifer@kee Independent Whatever the method, the need to prevent the market disruption that will be caused by hundreds of thousands of "for rent" signs
4/16/2020 5:19:00 plouisvillewei Business on American main streets is primary and can be prevented by requiring banks which are providing fed loans to relieve these mortgages, which
PM PIO (Email from Rubenstein Jennifer rd.com Alliance are imperative to keep healty Main Streets everywhere.
The maximum loan size limitations of 4x MSNLF and 6x MSELF EBITDA minus outstanding debt and committed, undrawn facilities provide no
incremental capital to NBFFs. NBFFs require significantly more debt for each dollar of equity to fund consumer loans efficiently.
The $25M MSNLF/$150M MSELF maximum loan limitations are inadequate for NBFFs whose primary capital need is for continued funding of
consumer loans.
The requirement that MSELF loans be in place prior to April 8 significantly limits the utility of the program. NBFFs typically fund their business
with receivables-based loans, with limited, or no, corporate indebtedness.
The 5% participation requirement for MSLP eligible lenders limits expansion of borrowing capacity. Most companies will have fully drawn on
existing credit capacity in anticipation of a business disruption, and lenders are unlikely to increase their exposure to facilitate new loans.
Including undrawn lines of credit in the maximum loan size calculation further limits NBFFs total borrowing capacity and ignores that these
lines are at significant risk of being terminated.
The term loan structure requires companies to draw funds today without regard to the timing of the need for capital. This increases the
borrowing cost and limits the ability of the facility to meet future needs as they arise.
Continental Consumer loan funding is NBFFs' principal need for capital and is inadequately addressed by the MSLP.
4/16/2020 5:21:00 tamer@contfi Finance
PM PIO (Email from El-Rayess Tamer nco.com Company, LLC
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Main Street Lending Program Comments
To whom it may concern;
Many nonprofits employ more than 500 employees and have not been able to access the Paycheck Protection Program, which contains loan
forgiveness provisions 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.
In the toughest times, nonprofits like United Cerebral Palsy do the toughest work. As the U.S. Treasury Department works to develop a
program as directed under the CARES Act section 4003(c)(3)(D) to provide financing to banks and other lenders in order to make loans to
nonprofits and other mid-size business with 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 no prepayment penalty.
· Provide priority to 501(c)(3) charitable nonprofits responding to COVID-19 relief efforts
· Ensure that payments shall not be due until two years after a direct loan is made with the loan period last for seven years
· 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
4/16/2020 5:22:00 acontreras@ United Cerebral The recommendations above will help to keep these organizations financially strong.
PM PIO (Email from Contreras Armando ucp.org Palsy
The maximum loan size limitations of 4x MSNLF and 6x MSELF EBITDA minus outstanding debt and committed, undrawn facilities provide
no incremental capital to NBFFs. NBFFs require significantly more debt for each dollar of equity to fund consumer loans efficiently.
The $25M MSNLF/$150M MSELF maximum loan limitations are inadequate for NBFFs whose primary capital need is for continued funding
of consumer loans.
The requirement that MSELF loans be in place prior to April 8 significantly limits the utility of the program. NBFFs typically fund their
business with receivables-based loans, with limited, or no, corporate indebtedness.
The 5% participation requirement for MSLP eligible lenders limits expansion of borrowing capacity. Most companies will have fully drawn on
existing credit capacity in anticipation of a business disruption, and lenders are unlikely to increase their exposure to facilitate new loans.
Including undrawn lines of credit in the maximum loan size calculation further limits NBFFs total borrowing capacity and ignores that these
lines are at significant risk of being terminated.
The term loan structure requires companies to draw funds today without regard to the timing of the need for capital. This increases the
borrowing cost and limits the ability of the facility to meet future needs as they arise.
bruce.weistei Genesis Consumer loan funding is NBFFs' principal need for capital and is inadequately addressed by the MSLP.
4/16/2020 5:23:00 n@genesis- Financial
PM PIO (Email from Weinstein Bruce fs.com Solutions, Inc
Dear Chairman Powell and Board Staff,
I write on behalf of Par Pacific Holdings, Inc. ("PPHI"), an energy company in the
refining, retailing, and logistics spaces. PPHI appreciates the opportunity to submit comments to the Board concerning the Main Street
Lending Program. As
currently contemplated by the term sheets for the Main Street Expanded Loan Facility and the Main Street New Loan Facility the Board
published on April 9, we believe that the terms of these facilities do not optimally account for the ways in which some businesses operate, and
thereby may inadvertently limit borrower access to the Main Street Lending Program and the loan amounts available to those borrowers.
Therefore, we would respectfully suggest making five changes to the terms of these facilities, which we believe would enhance credit
available to eligible businesses and allow lenders to better serve the policy aims for which Congress, the Treasury Department, and the Board
have created the Main Street Lending Program. Our proposed changes and the rationale for them are set forth in a short comment letter that
I am submitting by e-mail today. We appreciate the Board's consideration of our requests.
Regards,
Michael D. Lewis
4/16/2020 5:24:00 michael.lewis Sidley Austin Sidley Austin LLP
PM PIO (Email from Lewis Michael @sidley.com LLP
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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.
4/16/2020 5:25:00 jamie@atlant Atlanta Pride 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 Fergerson Jamie apride.org Committee this unprecedented crisis depends on the success of our nation's nonprofits.
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 5:27:00 Email eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
PM PIO (Email from Smith Theresa 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.
Personal
4/16/2020 5:27:00 Email 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 Davenport Audrey Address Soque St LLC this unprecedented crisis depends on the success of our nation's nonprofits.
As a leader at the YMCA of Greater Seattle, I am writing to urge that nonprofits, especially those with more than 500 employees are eligible
for the Main Street Loan Program. Nonprofits like ours have depleted our cash reserves addressing COVID-related community needs such
as providing daycare services to first responders, and need financial support to return to regular operations during COVID recovery. Nonprofit
organizations should be explicitly named as eligible for the Main Street Lending program. While the CARES Act was an important step in
relief, more support is needed especially for organizations like ours with over 500 employees that are not eligible for the Paycheck Protection
4/16/2020 5:28:00 jlamb@seattl YMCA or Program. We were forced to move 2,200+ of our employees (75%+) to standby status until we can re-open operations, and we are facing
PM PIO (Email from Lamb John eymca.org Greater Seattle millions of dollars in losses this year.
Regarding a borrower's eligibility for Main Street Loans:
oPlease confirm that the borrower's ownership structure will not be relevant (e.g., that having a sole proprietor, disregarded entity
(for tax purposes), special purpose entity, or foreign ownership will not be disqualifying).
oPlease confirm that there will not be any consolidation of the borrower (for purposes of the maximum employee count or revenue
calculation) with parent companies, non-majority owned subsidiaries or sister companies.
oPlease confirm whether and how a borrower should count employees held by or revenue generated by its majority-owned subsidiaries.
ehinds@shep If the Fed contemplates ownership or affiliation requirements, those requirements should be easily understood and applied, and preferably not
4/16/2020 5:29:00 pardmullin.co akin to the restrictive and complex affiliation rules that apply in the SBA context.
PM PIO (Email from Hinds Elliot m Sheppard Mullin
Please include the programs for people with developmental disabilities
4/16/2020 5:29:00 Tross@quee Queens Centers
PM PIO (Email from ross terri nscp.org for Progress
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Main Street Lending Program Comments
The YMCA of Northwest North Carolina has a long standing history of responding and meeting community needs. Impacting the lives of over
150,000 people in 7 counties, we have adapted our services to support our neighbors through the COVID-19 pandemic. Our Y is currently
providing emergency child care to essential workers, distributing meals in at risk neighborhoods (over 5000 meals served so far), making
thousands of wellness calls to seniors, and transitioning multiple branches for weekly blood drives. As a large non-profit, our dedicated staff
are our most valuable resource. Prior to the pandemic and subsequent facility closures due to social distancing measures, our Y employed
1912 people (520 FTE), making us one of the largest employers in the region. We have since had to lay off 91% of our workforce, 1740
people. We are committed to serving northwest North Carolina and will continue working tirelessly to support those in need in our community
despite recent layoffs and facility closures The CARES Act was a first step toward supporting nonprofits through the economic crisis, however
we were not able to apply for the Paycheck Protection Program because of our size. We are projecting a $2.5M loss in revenue between
YMCA of March 15th and June 30th and your support would ensure that the Y and other large non-profits can continue to provide urgently needed
4/16/2020 5:31:00 s.joy@ymcan Northwest North services for our communities. Thank you for looking into this matter and for your service to our nation in this time of crisis.
PM PIO (Email from Joy Susan enc.org Carolina
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 5:31:00 david@gntv.i GNTV Media 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 Wood David nfo Ministry this unprecedented crisis depends on the success of our nation's nonprofits.
Please also ensure that nonprofit employers with between 500 and 10,000 employees are able to access the loan. Please also consider 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.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. We were
not able to apply for the Paycheck Protection Program because of our size. Without access to support, our Y will not be able to resume
operations as we knew it or retain our staff.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 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
Personal others, are committed to serving our communities throughout this pandemic and beyond. Our large delivery system serve many people from
4/16/2020 5:32:00 Email Address vulnerable situations and reduces the burden of government. Our Y has been a big help to our physical and mental health in our community.
PM PIO (Email from Steineker Lee Northeast YMCA Thank you for your consideration!
The SOA is a nonprofit professional organization that educates actuaries and provides objective research to assist our members and the
public in making sound financial decisions. The SOA routinely collaborates with governmental bodies on our research efforts, including
COVID-19 impact studies.
We urge you to include all nonprofits in the Main Street Lending Program. Associations and professional organizations provide a multitude of
community services and benefits to society. Many in the nonprofit community operate on very lean budgets and have felt a significant financial
drain through COVID-19 related losses.
Thank you very much for the consideration of our comments.
4/16/2020 5:32:00 aweber@soa Society of Sincerely, Greg Heidrich
PM PIO (Email from Heidrich Greg .org Actuaries SOA Executive Director
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Main Street Lending Program Comments
At what date is the employee count measured for purposes of determining borrower eligibility? The borrower eligibility employee count test
should have the flexibility to use different measurement dates, including the date of the Main Street loan application (which would meet the
business where it presently stands as a result of the COVID-19 impact it has experienced).
The borrower eligibility revenue test should have the flexibility to use either 2019 annual revenues or the trailing twelve months revenues (as
of the date of its Main Street loan application). This measurement would meet the business where it presently stands as a result of the COVID-
19 impact it has experienced.
Will an eligible borrower under Section 4003(b)(1), (2) or (3) of the CARES Act also be eligible to receive Main Street loans?
ehinds@shep Assuming a borrower meets the other eligibility requirements established, please confirm that an Eligible Borrower can be any type of US
4/16/2020 5:32:00 pardmullin.co entity form such as a trust (e.g., a REIT or a business trust), limited liability company, partnership, joint venture, quasi-governmental entity,
PM PIO (Email from Hinds Elliot m Sheppard Mullin nonprofit entity or tribal entity.
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; and
In implementing any workforce restoration and retention provisions, "workforce" should be defined as full-time employees or full-
4/16/2020 5:32:00 ablesc@fccar Friendship time equivalents.
PM PIO (Email from Ables Cristy e.org Community Care
I write on behalf of TripActions, Inc., a US-based corporate travel management technology company. The coronavirus pandemic is having a
particularly devastating effect on the business travel sector in the United States.
The Main Street Lending Program, which is intended to help support small and midsize businesses through the pandemic, effectively requires
the borrower to have positive EBITDA for its loan to be eligible. However, growth-stage companies like TripActions have negative EBITDA
due to our investment in product development, sales and marketing, and other growth functions ahead of revenue. Unfortunately, this has the
consequence of excluding growth-stage companies from eligibility in the Program.
There are other means of calculating appropriate loan sizes for the Main Street Lending Program while also assessing whether potential
borrowers have the financial standing to ensure that taxpayer funds are protected: (1) Lending banks should apply industry-specific criteria
such as debt/equity ratio, cash on hand, free cash flows over the loan term, and/or an assessment of operating costs and gross margins to
evaluate borrower solvency and ability to service the loan. (2) Similar to the Paycheck Protection Program administered by the SBA,
maximum loan amounts should be calculated based on payroll and other operating costs, instead of EBITDA.
4/16/2020 5:33:00 sjahann@trip Please see our Letter submitted by email for additional information. Thank you for your consideration.
PM PIO (Email from Jahann Sai actions.com TripActions, Inc.
Hello, we have sent our comment letter to regs.comments@federalreserve.gov (it contains graphics). If you would please acknowledge
receipt it would be very helpful. My colleagues and I are standing by to assist with this extremely important matter.
Thank yo for your efforts on behalf of our country and the global financial system.
Sincerely,
Jared M. Carney
4/16/2020 5:34:00 jcarney@light Vice-Chairman
PM PIO (Email from Carney Jared dalellc.com McKinley Capital McKinley Capital Management, LLC
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Main Street Lending Program Comments
The leverage restrictions in the proposed terms sheets unfairly exclude companies that rely solely, or predominantly on asset-based revolving
credit facilities. According to terms, the calculation of Maximum Loan Size for both New Loan facilities and Expanded Loan Facilities must
include "committed but undrawn debt" as a component of leverage.
Undrawn commitments are generally not accessible. They represent surplus collateral, or cushion, and banks impose significant penalties if
this surplus is drawn down. These commitments should not count as debt.
Left as is, the terms would preclude many metals service centers from participating. That obviously was not the intent of Congress.
Our sector may be uniquely impacted by the "committed but undrawn debt" restriction because use of that credit method is widely
used to finance inventory. We ask that you remove that condition in its entirety. Absent that, we urge the Federal Reserve to modify the Loan
Facility Term sheets to allow borrowers to calculate their loan amounts using only the amount of "committed but undrawn debt"
that is available to them without punitive bank responses.
We have outlined two options for doing so in a full letter that was emailed.
4/16/2020 5:34:00 bweidner@m Metals Service Our member companies operate in every state and collectively employ millions of workers. If these facilities cannot provide them with a
PM PIO (Email from Weidner M. Robert sci.org Center Institute lifeline, they are in danger of closing for good.
A significant number of the target businesses for the Main Street Loan program access credit from non-Eligible Lenders. Completely
excluding non-Eligible Lenders from the Main Street Loan program will significantly hamper the program's impact on the target market.
To increase accessibility of the Main Street Loan program in a manner that balances the Fed's other considerations, please consider the
following changes:
oAn otherwise Eligible Loan should not be tainted because some or all of it passes through a non-Eligible Lender. Instead, consider
eliminating or de-emphasizing the identity of the underlying loan originator so long as an Eligible Lender leads the expanded loan (which loan
would be subject to the collateral sharing requirements described in the term sheets). However, if the Fed chooses not to eliminate the
Eligible Lender origination requirement entirely, it should, at a minimum, loosen the requirement by allowing the following loans as Eligible
Loans in the Main Street Expanded Loan Facility:
?*A loan that was originated by a non-Eligible Lender but was assigned in whole or in part to an Eligible Lender.
ehinds@shep ?*A loan that was originated by a syndicate of lenders that includes one or more non-Eligible Lenders and one or more Eligible Lenders.
4/16/2020 5:35:00 pardmullin.co ?*A loan that was originated by an Eligible Lender that syndicated or assigned some or all of that loan to a non-Eligible Lender.
PM PIO (Email from Hinds Elliot m Sheppard Mullin
As a staff leader at the YMCA of Greater Seattle, I am writing to urge that nonprofits, especially those with more than 500 employees become
eligible for the Main Street Loan Program. Nonprofits like ours have depleted our cash reserves addressing COVID-related community needs
such as meal programs and child care for essential employees and require financial support to return to regular operations during COVID
recovery. Nonprofit organizations should be explicitly named as eligible for the Main Street Lending program. While the CARES Act was an
important step in relief, more support is needed especially for organizations like ours with over 500 employees that are not eligible for the
swashburn@ Paycheck Protection Program. We were forced to move 2,200+ of our employees (75%+) to standby status until we can re-open operations,
4/16/2020 5:35:00 seattleymca. YMCA of Greater and we are facing millions of dollars in losses this year. Thank you for your consideration.
PM PIO (Email from Washburn Scott org Seattle
Hi, I am so surprised that you have not included non profits in this stimulus package. Non profits and higher education programs employ
thousands of people and are the heartbeat of their communities. My organization, AS220, are providing services to help to our low income
Personal artists with rent/housing . We also work with youth in foster care, youth at risk, some have been incarcerated, and pregnant moms, to name
4/16/2020 5:36:00 Email some of our work. Now more then ever with Covid -19 pandemic, we need your HELP!!! Please have non profits be a part of Main St stimulus!
PM PIO (Email from Hearn Marie Address AS220 Thank you
Page 277 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.
4/16/2020 5:37:00 Melissa@gnt 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 Niedrauer Melissa v.info this unprecedented crisis depends on the success of our nation's nonprofits.
Under the Main Street Lending Program ("MSLP") currently being proposed, Eligible Borrowers cannot use the proceeds to repay
other loan balances with the exception of mandatory principal payments. The upstream oil and gas industry is currently experiencing historic
distress and retrenchment in the reserve-based loan market that is primarily serviced by banks that are Eligible Lenders under the MSLP.
The size of a typical reserve-based loan is generally determined by its "borrowing base" or the present value of the estimated
futures cash flows of the assets securing the loan. It is expected that the distress in the oil and gas market due to COVID-19 will lead to
significant decreases in estimated borrowing bases during 2020 forcing borrowers to cure any borrowing base deficiency. The oil and gas
industry lacks sufficient access to capital to cure these expected borrowing base deficiencies. We would recommend that uses of proceeds
from MSLP loans also include curing borrowing base deficiencies in oil and gas reserve-based loans. This will provide the requisite capital
4/16/2020 5:37:00 bcase@eleva Elevation and liquidity to maintain a healthy energy industry, support job preservation and tax revenue, and promote long-term U.S. energy
PM PIO (Email from case blake tionres.com Resources independence.
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 a 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 5:37:00 GNTV Media 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 Bates William bill@gntv.info Ministry this unprecedented crisis depends on the success of our nation's nonprofits.
4/16/2020 5:37:00 tallen@desu. Delaware State Main Street Lending
PM PIO (Email from Allen Tony edu University
Please clarify the rules that apply to lender roles after a Main Street New Loan or Main Street Expanded Loan is funded such as:
?*Allowing either an Eligible Lender or a non-Eligible Lender to acquire an assignment or participation interest in a Main Street New Loan or
Main Street Expanded Loan.
?*Allowing loan servicing responsibilities to be performed only by another Eligible Lender
ehinds@shep ?*Confirming that the SPV's 95% risk participation in each Main Street New Loan or Main Street Expanded Loan is an undivided
4/16/2020 5:37:00 pardmullin.co interest such that an assignment by an Eligible Lender of all or a portion of its loan will include a ratable assignment of the 95% risk
PM PIO (Email from Hinds Elliot m Sheppard Mullin participation.
Page 278 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
1) Will the MSLP lenders agree to sign subordination agreements with existing secured lenders of the borrowers?
2) Will the MSLP lenders be required to use any particular form of loan documentation?
3) Will companies be able to distribute proceeds from sales outside the ordinary course of business, including sales of companies or
divisions?
4) There is no indication that the SBA "affiliation rules" applicable to the PPP apply, or any similar concept applies, to the MSLP
with respect to its headcount, gross revenue or EBIDTA calculations. Rather, in addition to the headcount, gross revenue and EBITDA
requirements, each "Eligible Borrower" under the MSLP "must be a business that is created or organized in the United
States or under the laws of the United States with significant operations in and a majority of its employees based in the United States"
(see (1) the MSLP term sheets and (2) the CARES Act, Section 4003(c)(3)). Do any affiliation rules apply for purposes of determining
eligibility? Do any affiliation rules apply in determining gross revenue, EBITDA and head count? Are the headcount, gross revenue and
EBTIDA calculations made separately for each entity (based on such borrower being a U.S. Business) rather than aggregated among
affiliates?
steven.phillip
4/16/2020 5:38:00 s@us.dlapipe 5) Are existing severance agreements or severance policies exempted from the limitations under the rules with respect to payment of
PM PIO (Email from Phillips Steve r.com DLA Piper severance?
I am looking for some clarity on the Main street lending program. I am a Ceo of a small company that meets the requirements for this
program. I bank with a small regional bank has problems navigating the PPP program. I would like to find out there will be a list of bigger
banks that I can go to to get approved for the loan? Does the bank have to approve the loan first before it goes to the Federal Reserve? And if
so, what will be their requirements to ensure they are making ethical judgments on there end to help facilitate the process. Under some of the
mwilliams@st terms of the loan, there will be a 200 basis point charge over the lending rate. Will this loan be forgiven after the four years are can it be
4/16/2020 reamlinemgm extended past the 4-year point.? Lastly, Inside of the "SPV" if we get the credit, does the small business have access to other
12:00:00 AM PIO (Email from Williams Melvin tno.com Opulence lending facilities directly through the Federal Reserve?
asantini@aca As a non-profit organization that does not meet the size requirements under the Paycheck Protection Program and has more that 500
4/16/2020 5:39:00 cianetwork.or employees, it would be helpful the Main Street Loan Program to have a forgiveness provision - similar to PPP. Additionally, Fees/origination
PM PIO (Email from Santini Angel g Acacia Network points should be waived for qualifying non-profit organizations.
6) Is a borrower permitted to hire a new executive with pay over $425,000 per year?
7) There is no guidance indicating whether the headcount, gross revenue and EBITDA of two companies that form a joint venture would be
aggregated for purposes of the MSLP. Joint ventures and the management companies should be treated as separate businesses, so that
each company can apply for a loan under the MSLP using separate headcount, gross revenue and EBITDA for that U.S. Business. Are joint
ventures that own and operate businesses (seniors housing, nursing homes, etc.) considered separate businesses from the hired
management companies for MSLP purposes?
8) It is noted the new loans will not require collateral, but if an Eligible Borrower has other more senior debt, are the MSLP loans subordinated
to that existing senior debt obligations?
9) The attestations required under the MSLP require an Eligible Lender to attest that the proceeds of an Eligible Loan will not be used to repay
steven.phillip or refinance pre-exiting loans or lines of credit made by the Eligible Lender. In addition, Eligible Borrowers must commit to refrain from using
4/16/2020 5:40:00 s@us.dlapipe MSLP proceeds to repay debt of equal or lower priority (other than mandatory principal payments). Would approval be required by the senior
PM PIO (Email from Phillips Steve r.com DLA Piper lender for the MSLP loan?
Page 279 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
TIAA appreciates the opportunity to comment on the Federal Reserve's Main Street proposal. TIAA is a savings and loan holding
company and parent company of TIAA Bank, FSB. Accordingly, each of TIAA and TIAA Bank are 'eligible lenders' under the
proposal. Our initial comments are set forth below. We would be happy to further discuss these and other concerns in more detail. Please
contact John McCally at john.mccally@nuveen.com or by phone at 202-210-5275.
Eligible Lenders
1. Wholly-owned subsidiaries of SLHCs and IDIs should be permitted to act as eligible lenders.
2. Eligible lenders should be permitted to transfer Main Street loans to their affiliates and entities under common control or management.
Eligible Loans
1. LIBOR loans should be permitted with ARRC fallback language.
2. Floating rate floors should be permitted by mutual agreement.
3. Applicable margin for middle market loans and other asset classes should be set by reference to pre-Covid ranges, which often exceeded
400 bps.
4. Leverage should be able to be increased beyond 6x for loans secured by equipment, inventory or other tangible or high-quality collateral
(e.g. residential mortgages).
Participations
john.mccally 1. Participation terms should ensure 'sale' treatment under applicable accounting principles. Applicable principles should include
4/16/2020 5:40:00 @nuveen.co GAAP and/or statutory principles that apply to SLHCs doing business as insurance companies.
PM PIO (Email from McCally John m TIAA / Nuveen
Long Beach City College (LBCC) strongly supports emergency funding opportunities for small business and we encourage inclusion of non-
profits in any federal lending programs. LBCC is a regional leader in Economic Development, hosting programs such as the Los Angeles
Regional Small Business Development Center Network (LA SBDC) and the Goldman Sachs 10,000 Small Businesses Program. Through the
Long Beach college's small business COVID-19 response work, there has been an incredible demand for financial resources to small businesses,
4/16/2020 5:41:00 mdrinkwine@ Community including a significant number of NGOs seeking assistance. Small businesses and NGOs make up a critical portion of our local economies
PM PIO (Email from Drinkwine Marlene lbcc.edu College District and LBCC encourages our federal leaders to join us in taking action to support them.
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 5:41:00 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 Stewart Nathan this unprecedented crisis depends on the success of our nation's nonprofits.
There has been confusion about the Main Street Lending program and whether non-profits are eligible because the current guidance is silent.
At Delaware State University, we ask that the Federal Reserve update the guidance to clarify that non-profit private and public institutions of
higher education, with direct borrowing authority, are eligible for the Main Street Lending program.
4/16/2020 5:41:00 tallen@desu. Delaware State We look forward to working with you on this and other essential loan programs as the Federal Reserve responds to the COVID-19 crisis.
PM PIO (Email from Allen Tony edu University Thank you in advance for your consideration.
Page 280 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.
4/16/2020 5:41:00 Laura@gntv.i 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 Poarch Laura nfo this unprecedented crisis depends on the success of our nation's nonprofits.
I ask that our legislators reflect on our economic sectors, and ask if growth comes at the expense of stability. By prioritizing our nonprofit
community in this next round of support, we invest in our future as a nation, strengthening our communities. Without this prioritization, interest
groups seeking to profit or deliver products or services that do not increase social value will capture equity and destabilize our health,
education, and social support networks.
Please require banks to prioritize nonprofits in accessing Main Street Lending funds, and make these loans as affordable as possible for all
involved.
4/16/2020 5:41:00 jsears@nwce Northwest
PM PIO (Email from Sears Jason nter.org Center Thank you.
Support for the Main Street lending program to include non-profit organizations over 500 people is vital to our continued existence during this
Personal Email
4/16/2020 5:43:00 Address HeartShare crisis. We serve some of society's most vulnerable individuals -- children and adults with intellectual and developmental disabilities! We
PM PIO (Email from Tempel Linda Human Services need your support!
Please accept respectful commentary in support of the YMCA, by ensuring that nonprofits are explicitly named as eligible recipients of the
Main Street Lending program. To ensure all YMCAs are covered, request consideration for nonprofit employers with between 500 and 10,000
Personal Email
4/16/2020 5:45:00 to be able to access the loan, as many families throughout the nation depend on their services, and are supported regardless of their ability to
Address
PM PIO (Email from Tarver Kenton pay.
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 5:45:00 millie@gntv.i GNTV Media 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 Johnson Millie nfo Ministry this unprecedented crisis depends on the success of our nation's nonprofits.
INARF's 72 member organizations that provide services to people with disabilities are facing skyrocketing costs for staffing, purchasing
Personal Protective Equipment, cleaning and disinfecting homes of individuals served, etc. Unfortunately, they are not receiving additional
funding to offset these costs, and many are nonprofits that employ more than 500 employees and have not been able to access the Paycheck
Protection Program, which contains loan forgiveness. Without funding programs to support them during the pandemic, many will shutter and
therefore be unable to continue to provide services during the crisis and assist with our nation's recovery efforts when the crisis is over.
As the Treasury Department works to create a program as directed 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; and
In implementing any workforce restoration and retention provisions, "workforce" should be defined as full-time employees or full-
4/16/2020 5:45:00 sarah@inarf. time equivalents.
PM PIO (Email from Chestnut Sarah org INARF
Page 281 of 363
Note: At the commenter’s request, we removed the identifying information for commenters who were not notified at the time they made their comments that it was the Federal Reserve Board’s intention to make such comments public.
Main Street Lending Program Comments
I am writing to 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 5:47:00 alexis@fcfox. 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 Marion Alexis org Lending facility to include nonprofit organizations.
karen.marsha HeartShare Please help us!
4/16/2020 5:47:00 ll@heartshar Human Services
PM PIO (Email from Johnson Karen e.org of NY
edgardo.vele Support for the Main Street lending program to include non-profit organizations over 500 people is vital to our continued existence during this
4/16/2020 5:47:00 z@heartshar crisis. We serve some of society's most vulnerable individuals -- children and adults with intellectual and developmental disabilities! We
PM PIO (Email from Velez Edgardo e.org need your support!
Greetings- I am the Chief Human Resources Officer at the YMCA of Greater Seattle. As a professional in the non-profit sector and a
community membe, I urge that nonprofits, especially those with more than 500 employees, like the YMCA of Greater Seattle, are eligible for
the Main Street Loan Program. While YGS and other Nonprofits have continued to meet community needs for homeless youth and the
children of first responders, we and other Nonprofits like ours have depleted our cash reserves addressing COVID-related community needs.
We need financial support to return to regular operations during COVID recovery. Nonprofit organizations must be explicitly named as eligible
for the Main Street Lending program. While the CARES Act was an important step in relief, more support is needed especially for
organizations like ours with over 500 employees that are not eligible for the Paycheck Protection Program. YGS was forced to move 2,200+
of our employees (75%+) to standby status until we can re-open operations, and we are facing millions of dollars in losses this year. This
4/16/2020 5:51:00 mmartin@se YMCA of Greater relief is important in allowing us to continue this important community work in greater Seattle.
PM PIO (Email from Martin Moriah attleymca.org Seattle
rose.jean- Support for the Main Street lending program to include non-profit organizations over 500 people is vital to our continued existence during this
4/16/2020 5:51:00 pierre@heart HeartShare crisis. We serve some of society's most vulnerable individuals -- children and adults with intellectual and developmental disabilities! We
PM PIO (Email from Jean-Pierre Rose share.org Human Sercices need your support!
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 5:51:00 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 Brown Brady 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 5:52:00 nathaniel@g GNTV Media 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 Dauphin Nathaniel ntv.info Ministry this unprecedented crisis depends on the success of our nation's nonprofits.
HeartShare Support for the Main Street lending program to include non-profit organizations over 500 people is vital to our continued existence during this
4/16/2020 5:52:00 Personal Human Services crisis. We serve some of society's most vulnerable individuals -- children and adults with intellectual and developmental disabilities! We
PM PIO (Email from Cordero Maribel Email Address of NY need your support!
Page 282 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 a 26-year veteran of nonprofit sector, I have seen the important work nonprofits play in binding and holding the safety net for so many
people in our society. A number of larger nonprofits play critical roles in building the capacity of our local, state, and federal governments to
reduce long term costs of care, break the cycle of poverty for families, and ensure the next generation of citizens are well prepared to produce
in a thriving society. Nonprofits with an employee base larger than 500 MUST be included in eligibility for the Main Street Lending program or
4/16/2020 5:53:00 gzeno@seattl YMCA of Greater even more smaller nonprofits and businesses that they support will parish and governments will not have the right partners to scale solutions
PM PIO (Email from Zeno George eymca.org Seattle that reduce costs and save lives.
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.
Lesley@umc UM Commission
4/16/2020 5:55:00 ommission.or Higher 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 Baskette Lesley g Education this unprecedented crisis depends on the success of our nation's nonprofits.
I am affiliated with a non-profit organization providing behavioral health, child welfare services, housing support to individuals in California. I
ask the Federal Reserve and Treasury Department to immediately issue guidance on a program, as directed under the CARES Act, to
provide financing to banks and other lenders to make loans to non-profits and other mid-size businesses. We request that the program
include:
-0.50% interest rate (50 basis points) for 501(c)(3) charitable nonprofits at a 5-year amortization
-Priority to 501(c)(3) charitable nonprofits responding to COVID-19 relief efforts
-Payments due at least two years after a direct loan is made
-Employee retention provisions begin on the date that loan funding is received
-"Workforce" should be defined as full-time employees or full-time equivalents
Many non-profit organizations aren't able to access the Paycheck Protection Program , which is critical to ensure the continued provision
of essential services during this crisis. Without increased access to loan programs intended to sustain payroll and retain employees, these
Hathaways mid-sized non-profit organizations are at financial risk, a circumstance that could leave thousands of individuals without timely access to
Sycamores Child needed care.
4/16/2020 5:57:00 hkwon@hscf and Family This lack of access to care will lead many Americans to utilize more emergency services. This will drive up health care costs at a time when
PM PIO (Email from Kwon Hannah s.org Services the health system is already strained caring for COVID-19 patients.
American Hotel has been in business since 1865. We are a key distributor to the hospitality industry which has been negatively impacted to
unprecedented levels as a result of COVID-19. Our sales demand is down 90% versus the prior year and we have been forced to furlough
approximately 80% of our workforce. Industry forecasts suggest that hospitality could be down as much as 50% in 2020, and American
Hotel's sales directly correlate to industry performance. Bridging this financial burden until the industry rebounds is critical to our
ongoing viability. Our feedback is focused around the maximum loan criteria, particularly the EBITDA leverage conditions. One year of
EBITDA performance is not representative of a company's overall financial viability particularly in cases where that year was impacted
by one-time events. In our case, we experienced significant implementation hurdles after investing heavily in a technology platform resulting
in suppressed EBITDA results compared to our historical performance. Leveraging 2019 as a baseline drastically reduces our ability to
benefit from the program. A more representative benchmark would be a 5-year historical average. We made the decision to invest in the
akorompilas American Hotel business because we are critical to the hospitality supply chain and wanted to ensure we had the infrastructure in place to support it for many
4/16/2020 6:00:00 @americanh Register more years to come, and this decision is now impeding us from getting much needed financial relief as we navigate this crisis.
PM PIO (Email from Korompilas Angela otel.com Company
vivian.berrios HeartShare Support for the Main Street lending program to include non-profit organizations over 500 people is vital to our continued existence during this
4/16/2020 6:00:00 @heartshare. Human Svcs of crisis. We serve some of society's most vulnerable individuals -- children and adults with intellectual and developmental disabilities! We
PM PIO (Email from BERRIOS VIVIAN org New York need your support!
Kuumbwa Jazz is a 501 (c) 3 located in downtown Santa Cruz, CA established in 1975.
Due to COVID-19 since March 12th all sources of earned income have come to a halt. I am writing to ask that non-profits be considered for
funding during this health and economic crisis.
Sincerely, Bobbi Todaro
4/16/2020 6:01:00 bobbi@kuum Executive Director
PM PIO (Email from Todaro Bobbi bwajazz.org Kuumbwa Jazz Kuumbwa Jazz
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Main Street Lending Program Comments
On behalf of Northern California Grantmakers, we respectfully request that the Federal Reserve's "Main Street" lending
facility include support for non-profit organizations. The lasting impact of the COVID-19 (Coronavirus) pandemic and its aftermath will have
profound effects on communities throughout Northern California. As Californians continue to shelter in place, the effects of the economic
fallout will be felt long after the order is lifted. Although the philanthropic and non-profit sectors are working together to mitigate the negative
effects of this pandemic, it is not enough. The inclusion of non-profit organizations in the "Main Street" lending facility would
support critical, community-based services that protect the health, safety, and well-being of our communities. Our non-profit partners are
quickly adapting services to meet the emerging needs of our most vulnerable populations during this pandemic. Yet, many non-profit
organizations have lost significant revenue due to canceled fundraising events, and are also incurring new costs by purchasing needed
protective gear and equipment to work remotely. Demand for their services has grown and, with rising unemployment rates, even more
Northern demand is anticipated. The philanthropic sector alone cannot address this issue - we simply lack the size, scope, and scale of the federal
4/16/2020 6:04:00 cdelgado@nc California government. Again, please consider the inclusion of non-profit organizations in the "Main Street" lending facility.
PM PIO (Email from Delgado Crispin g.org Grantmakers
Please ensure nonprofits are explicitly named as eligible recipients of the Main Street Lending program especially those with >500
employees. Please also 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 Louisville serves over 100,000 people annually representing broad demographics and economic capacities and has
served this region for 167 years. With a commitment to health and education equity, we have many partners including school systems,
government entities, law enforcement, and health care.
On Dec 18, 2019, we opened a new facility housing a YMCA and six other partners providing a continuum of health and education in a
disinvested community. A public elementary school is to be added. It is the largest investment in west Louisville in decades and operated only
12 weeks prior to the emergency closing.
Despite our facilities being closed, our Y is providing child care for Health, Emergency and other essential services; A Teen Shelter for
homeless and neglected/abused youth; Housing for homeless men; Making hundreds of welfare calls; And offering thousands of virtual
experiences. Even so, services have been seriously reduced. ~95% of our 2100 staff are furloughed.
4/16/2020 6:04:00 starver@ymc YMCA of Greater
PM PIO (Email from Tarver Steve alouisville.org Louisville(KY) Our Y, and others, are committed to serving our communities throughout this pandemic and beyond. Thank you.
Most governors and mayors across the nation have deemed cannabis dispensaries and cultivation facilities as "essential"
business functions and the economic benefits from these taxes and employment-generating businesses stand to assist in keeping the
economy running in many areas.
However, cannabis businesses as well as ancillary businesses who support them, have been excluded from the original CARES
Act based upon earlier guidance prohibitions from the SBA. Across the country, many industry operators are suffering and
without access to these federal lending programs could be forced to close or lay-off employees. At the same time, the greatest inequity is that
these same companies are required to abide by the regulations stemming from the CARES Act.
The cannabis industry generates billions of dollars in tax revenues, which lawmakers rely on, and almost 300,000 direct and indirect jobs. As
being designated essential services, these operations are in many cases filling the void with tax revenues and employment opportunities while
more traditional businesses are unable to maintain either in many cases. 
Policy Center for Please consider inclusion of the cannabis industry as eligible for Main Street Lending loans. We would also encourage that the
4/16/2020 6:04:00 fn@igsolution Public Health minimum loan size be decreased to $500,000, allowing for a more conservative capital structure for smaller businesses.
PM PIO (Email from Niehaus Fred s.co and Safety
4/16/2020 6:04:00 fsinito@mhml The Millennia Please be advised comments were submitted to the designated email address April 16, 2020.
PM PIO (Email from Sinito Frank td.com Companies
Hazen.Demp Troutman Sanders LLP and Pepper Hamilton LLP have submitted a joint comment letter by email.
4/16/2020 6:05:00 ster@troutma Troutman
PM PIO (Email from Dempster Hazen n.com Sanders LLP
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Main Street Lending Program Comments
Will 1st year deferred interest accrue during the year? If so, when is it collected? Term sheet states "amortization" of P&I is
deferred for 1 year- are all payments deferred for 1 year? Is the loan amortized with outstanding and accrued interest over the remaining
term?
What pricing guidance is there? Many banks aren't yet ready for a SOFR index and have system limits. Is there data to calculate a
suitable spread? Consider a minimum SOFR floor and/or LIBOR with a hardwire fallback.
Full amortization/term of 4 years is quick.
This unsecured debt shouldn't have a repayment schedule ahead of existing bank debt.
Is a balloon payment at maturity on another term loan a permitted mandatory principal payment? What if that debt is with another lender? How
would lender monitor payment of only mandatory principal payments?
If we have a working capital line of credit and Borrower gets one of these loans from another lender, is Borrower prohibited from making
payment on our working capital line?
What diligence is needed to support a claim that financing need is pandemic-related? Will there be a standard Borrower Certification? Can
Lender rely on Borrower representations?
amy.pauls@c How does Borrower document reasonable efforts to maintain payroll and retain staff through the loan life? What if Borrower doesn't?
4/16/2020 6:05:00 ommerceban What are Lender responsibilities to monitor/report noncompliance?
PM PIO (Email from Pauls Amy k.com Must the certifications be covenants in loan docs? How will covenants applying after loan repayment be treated?
EBITDA Loan Sizing Test
Problem - Unclear whether EBITDA is meant to be unadjusted without any addbacks or pro forma impacts included. Calculating EBITDA
without taking into account adjustments and pro forma impact would prevent many companies from meeting the leverage tests as virtually all
loan facilities provide for EBITDA on an adjusted basis. For companies that have made acquisitions or dispositions, this creates uncertainty in
how EBITDA should be calculated.
Solution - For the Expanded Loan Facility (ELF) leverage sizing test, have EBITDA include the same adjustments and pro forma treatment
as under the existing loan facility. For the New Loan Facility (NLF) leverage sizing test, allow the lender and the company to agree on the
addbacks and pro forma treatment to be included in EBITDA.
Problem - Because many growth companies do not have positive EBITDA, without another test, most growth companies will be excluded
from Main Street Loan Facility (MSLF).
Solution - For private growth companies, provide a test that looks to a percentage of the most recent 409(A) valuation or post-money
Association for valuation from the most recent financing round. For public growth companies, provide a test that looks to a percentage of 52-week average
4/16/2020 6:06:00 kcraven@acg Corporate market capitalization with the end date for the period covered by such test being a date before the start of the pandemic.
PM PIO (Email from Bohn Tom .org Growth
Please include nonprofits in the Main Street Lending program.
4/16/2020 6:07:00 Personal
PM PIO (Email from Pei Marianne Email Address
Living Well Disabilities Services serves about 200 people, with disabilities, in 34 group homes. Direct Service Professionals (DSPs) are the
heart of our services. The pay rates for these staff are already below some fast food vendors and retaining them is difficult. The COVID crisis
has added further pressure on our organization.
To ensure that our best DSPs continue to serve the people in our homes, we created a payroll incentive program which rewards them for
working while safe and provides them with pay checks when out of leave. This is creating an unplanned deficit situation for the fiscal year.
We could not benefit from the Paychex Protection plan, because we employer over 500 employees. Given this, we welcome and strongly
support the effort underway to create a loan program for organizations that fit our size. We urge that the program contain the following
features:
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) nonprofits responding to COVID-19 relief efforts.
Make payments two years after a direct loan is made.
ghazi.akailvi Living Well Employee retention provisions should begin on the date that loan funding is received by the borrower; and
4/16/2020 6:09:00 @livingwell.o Disability In implementing any workforce restoration and retention provisions, "workforce" should be defined as full-time employees or full-
PM PIO (Email from Akailvi Syed Ghazi rg Services time equivalents.
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Main Street Lending Program Comments
As you stand up the Main Street Program, Boys Town respectfully requests you do the following to support non-profit organizations on the
front lines:
· Set 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
· Delay payments for two years after a direct loan is made
· Begin employee retention provisions on the date that loan funding is received by the borrower
· Define "workforce" as full-time employees or full-time equivalents when implementing workforce restoration and
retention provisions
Boys Town serves the most vulnerable children and families in the country. Alongside many other large non-profit organizations, we have
targeted our work to respond to the COVID-19 crisis. Yet, we face our own challenges as the COVID-19 outbreak drastically impacts our
bottom lines, and unfortunately, many non-profits that employ more than 500 people have been unable to access the Paycheck Protection
Program.
Father.Boes While we are all facing an unexpected challenge right now, what we can predict is an increased demand for services when this crisis is over
4/16/2020 6:09:00 @boystown.o and the healing begins. Ensuring our organizations can remain solvent is critical to both continued service delivery and retaining a large
PM PIO (Email from Boes Steven rg Boys Town sector of our economy. The main Street Program can provide a lifeline to many critical non-profit organizations.
Meaning of "Bank Debt" in the 30% Size Limiting Test for ELP
Problem - It is unclear what "bank debt" is meant to pick up. If this term is to pick up all debt of any kind with banks, cash
management arrangements could limit borrowing. If this term was to pick up only debt of banks, then companies that only have debt with a
non-bank lender would not be able to take advantage of a MSLF.
Solution - Clarify that this term is meant to include "all loans, notes and loan commitments" with "any lender".
Meaning of "Committed but Undrawn Debt" in the Leverage Size Limiting Test
Problem - The language "committed but undrawn debt" is problematic. It is not typical for undrawn debt to be picked up in a
leverage test. It also sends the signal that the company is required to draw on every last dollar available. If this program is to provide
companies needed liquidity, this would cause the company to put itself in a very vulnerable situation. The term sheets provide that no existing
debt may be reduced or terminated, so even if a company looks to reduce its undrawn commitment to satisfy the leverage test, it cannot do
so. Second, it is unclear what "debt" is meant to pick up.
Association for Solution - First, have such leverage test for availability only pick up amounts outstanding and not amounts that are committed but undrawn.
4/16/2020 6:10:00 kcraven@acg Corporate Second, clarify that such leverage test only includes loans and notes.
PM PIO (Email from Bohn Tom .org Growth
As a non-profit organization, we serve over 500 people; which are some of society's most vulnerable individuals and adults with
4/16/2020 6:10:00 maria.tuitt@h intellectual and developmental disabilities. We are asking that we be included in the Main Street Lending Program. We need your support!
PM PIO (Email from Tuitt Maria eartshare.org Heartshare
Maturity for Expanded Loan Facility
Problem - Most existing credit agreements prevent new loans to mature inside the maturity of existing loans as existing lenders do not want
new loans get paid off before the existing loans.
Solution - Allow for the maturity date of an ELF to be the later of (i) four years and (ii) the latest maturity date of any of the existing loans
under the existing loan facility.
Eligible Lenders
Problem - Limits the lenders eligible to participate in MSLF to only US banks and US SLHCs. With many non-bank lenders and foreign
Association for lenders in the lending market and that are existing lenders under the ELF, this is going to exclude many lenders and overwhelm the US banks
4/16/2020 6:13:00 kcraven@acg Corporate that are eligible.
PM PIO (Email from Bohn Tom .org Growth Solution - Include direct/non-bank lenders and foreign lenders (and clarify that US branches of foreign banks) as eligible lenders.
Page 286 of 363
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Main Street Lending Program Comments
Distribution/Equity Repurchase Issues
Problem - Unclear whether the distribution restriction would block distributions from acquisition or IPO activity for up to 12 months after
repayment of the loan.
Solution - Provide clarity that distributions to equity holders from an acquisition or IPO will be permitted, subject to full repayment of the
MSLF loan prior to distributions.
Problem - The restriction on distributions prohibits public companies to repurchase the equity of officers, directors and estates upon
termination of employment, death, etc., especially with respect to officers and directors that enter into agreements with a company after the
closing of the loan facility.
Solution - Provide a carve-out from the distribution restriction for such equity buybacks.
Association for Problem - The restriction on distributions does not provide for (i) tax distributions or (ii) distributions for fees or expenses that need to be
4/16/2020 6:13:00 kcraven@acg Corporate paid by holding companies.
PM PIO (Email from Bohn Tom .org Growth Solution - Allow for (i) tax distributions and (ii) distributions covering fees and expenses that are to be paid by a holding company.
Issues with Restriction on Ability to Repay "Other Debt of Equal or Lower Priority"
Problem - The restrictions on debt of equal or lower priority creates ambiguity that apparently does not allow for revolving loan repayments.
Also, unclear whether existing mandatory prepayments are permitted.
Solution - Clarify that (i) revolving loans may be repaid at any time and (ii) mandatory prepayments (in addition to scheduled amortization
payments) are permitted.
Problem - Causes issues for any seller notes and other debt in effect prior to the closing of the MSLF that have repayments due during the
term of the MSLF.
Solution - Allow for repayments, including prepayments, required under any agreements that were in effect prior to the closing of the MSLF.
Problem - Does not clarify what is meant by "debt" and whether such term includes items such as earnouts and holdbacks.
Association for Solution - Clarify that the term "debt" in such restriction means only loans and notes.
4/16/2020 6:14:00 kcraven@acg Corporate
PM PIO (Email from Bohn Tom .org Growth
Interest Rate Issues
Problem - NLF and ELF only provides a SOFR interest rate option. Many lenders are still developing SOFR procedures and language to
implement in their loan documents. Also, there is no base rate option, even in a situation where SOFR is unavailable for any reason.
Solution - Allow also for a base rate option to address these issues. In an ELF, permit the reference rate, including alternate rate provisions
related to the end of LIBOR, to be the same as the existing loan.
Foreign Ownership
Problem - Does not provide whether foreign ownership of US companies is permitted or whether non-US subsidiaries may be co-borrowers
or guarantors (e.g., where they are part of a credit group in an existing loan facility).
Association for Solution - Clarify that foreign ownership of US companies is allowed and non-US co-borrowers and guarantors are allowed in an ELF to the
4/16/2020 6:15:00 kcraven@acg Corporate extent that they are obligors under the existing loan.
PM PIO (Email from Bohn Tom .org Growth
Practical Access to ELF
Problem - Existing lenders not providing loans under an ELF may have no incentive to consent, especially where there is no debt flexibility
under the existing credit agreement and considering the new loans would be secured by the same collateral on a pari passu basis.
Solution - Have the SPV pay a fee to any existing lenders whose consent is needed that consent to the ELF.
Problem - Many of the terms for an ELF will make it hard to utilize the program due to difficulties with including a new tranche in the existing
loan facility or providing the ability to have a new tranche in separate loan documentation. The issues include: (i) requirement to secure an
ELF by the same collateral, which can present intercreditor issues, (ii) potentially using a different interest rate in SOFR before LIBOR is
phased out or (iii) amortization potentially being different than the existing loans.
Association for Solution - One option would be to allow for a holdco structure where the debt is above the entity level where the existing loans sit (and clarify
4/16/2020 6:15:00 kcraven@acg Corporate that the borrower does not need to be an operating company).
PM PIO (Email from Bohn Tom .org Growth
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Main Street Lending Program Comments
The Association for Corporate Growth (ACG) represents 15,000 professionals who operate within the middle market, comprised of 200,000
companies that employ 45 million Americans. ACG received the news of the Main Street Lending Program with optimism because it appeared
to be more broadly available to private equity-sponsored businesses than the PPP. America cannot afford the continued exclusion of middle-
market companies from federal relief programs.
We appreciate the opportunity to comment on the Main Street Lending Program. ACG urges the Federal Reserve to be liberal in its
administration of the Main Street Lending Program and recommends solutions (individually submitted) to ten areas.
COVID-19 forces companies to face a profound confluence of concerns daily, at the forefront is the livelihood of their employees. The Federal
Reserve is the fabric that keeps this U.S. economy together - wedding consumer and business interests to make it stable and vibrant. We
urge the Federal Reserve to be liberal in allowing access to the relief loans intended to keep people employed and businesses operating and
to respect the judgment of business leaders who are willing to assume debt as a means to survive this crisis. Consumer confidence will never
rebound if Americans are not gainfully employed.
Respectfully,
Association for Thomas Bohn
4/16/2020 6:18:00 kcraven@acg Corporate President and CEO
PM PIO (Email from Bohn Tom .org Growth Association for Corporate Growth
Please consider how to establish this program in such a way that individuals not needing the aid will be excluded from participation. As an
example, the PPP Porgram has been wildly successful partly because some recipients have used it to support their payroll for staff that was
never in jeopardy of being reduced. As a result, a significant amount of the allocation has been made available and used by individuals and
corporations that did not need it. If this program is going to be successful, it must be targeted where there is true need (company's that
4/16/2020 6:19:00 ddiekmann@ First Federal have shut down or been materially impacted) and those that are getting preferential terms or are abusing the system must be excluded in
PM PIO (Email from Diekmann Douglas fbei.net Savings Bank order to accomplish the most good.
1. Please reaffirm that earnings before interest depreciation and amortization (EBITDA) will for financial services company will include interest
income, lease income and financing fees and exclude interest expense on credit facilities.
2. Please reaffirm that independent companies that are subsidiary holdings of a larger holding company may apply for the Main Street
program individually despite being part of a larger company.
3. Many middle market companies that are part of a larger holding company pay, in the normal course of business, certain fees for
"shared services" from the holding company. Please explicitly allow Main Street borrowers to use loan proceeds to pay such
regularly scheduled fees and other mandatory debt obligations that will sustain the company's operations. These expenses are as
important as payroll and operational expense, and indeed oftentimes these fees and costs defray administrative costs for payroll, shared
benefits systems, and certain operating expense categories, like intracompany IT and tech services.
4. Please reaffirm that the debt to EBITDA multiples quoted in the term sheets only take into account the debt of the program.
4/16/2020 6:22:00 Edg@vnf.co Van Ness 5. Please confirm that amended equipment loans and leases will qualify as eligible collateral under the TALF program and that the program
PM PIO (Email from Gehres Edward m Feldman will be expanded to include non-conforming mortgages, commission receivables, and other consumer loans?
Ascent Global Logistics is a Roadrunner Transportation Systems portfolio company. Ascent plays a vital role in our national supply chain. Our
trucks keep America's grocery stores stocked and our planes carry ventilators. Our teams work to keep factories operating by ensuring
critical supplies are there when needed.
Ascent is seeking clarification that we can apply for a Main Street loan. The term sheet appears to provide flexibility for either a portfolio
company or corporate parent to apply. Roadrunner portfolio companies have separate management teams and financial statements.
Roadrunner is investing in "Main Street" businesses consistent with the intent of the loan program. While Ascent is a successful
business with a history of positive EBITDA before COVID-19, Roadrunner's Less than Truckload (LTL) business has not had positive
cash flow. If Roadrunner were required to apply for the loan, LTL's EBITDA would negatively affect Ascent's ability to receive a
loan.
We urge the Fed to provide flexibility to banks in determining the period for EBITDA. The term sheets require banks to use 2019 EBITDA for
the size of a loan, however, there are circumstances where 2019 EBITDA is not representative. Our 2019 EBITDA was negatively affected by
the GM strike and the impact from the 2019 global trade war. Banks should be able to exercise discretion and consider 2018 EBITDA for
4/16/2020 6:23:00 pat.unzicker Ascent Global calculating the loan size and protecting against default.
PM PIO (Email from Unzicker Patrick @rrts.com Logistics
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Main Street Lending Program Comments
Non-profits are adapting during the crisis to meet increased needs while struggling with reduced donations, additional expenses, and the need
to modify government contracts due to changing and unprecedented needs. In addition, non-profits across the country employ 12.3 million
people and have a far-reaching, significant impact on the economy. Like small- and mid-sized businesses, non-profits can benefit from loans
through the proposed Main Street lending facility, particularly those not eligible for the Paycheck Protection Loans.
However, the program, that would offer 4-year loans to companies employing up to 10,000 workers or with revenues of less than $2.5 billion
to small- and mid-sized businesses in good financial standing before the crisis with deferred principal and interest for one year, is not open to
non-profits.
According to recent research from CalNonprofits, 60% of non-profits in California provide essential services. These non-profits, and those like
them across the country, are key to getting through this crisis and revitalizing the economy and should be included in this new lending
program. Philanthropy, like other sectors, is moving to provide enhanced support and funding to non-profits, but philanthropy alone cannot fill
rhiannon@sd the gap. San Diego Grantmakers believes the inclusion of non-profits in the eligibility criteria is key to ensuring our non-profits can continue to
4/16/2020 6:23:00 grantmakers. San Diego serve our most vulnerable communities throughout this crisis and beyond.
PM PIO (Email from McKeon Debbie org Grantmakers
Personal Main street needs broad access to reasonably priced credit especially if they have some form of collateral this will be catastrophic if not. This
4/16/2020 6:31:00 Email Address article in the WSJ frames well https : //www.wsj.com/articles/main-street-needs-more-fed-help-11587055459?mod=mhp
PM PIO (Email from cabrales Ana
Direct Lending would be better. Banks are difficult to deal with on loans that are not 100% guaranteed. Most importantly the term of the loans
4/16/2020 6:33:00 john@netcapi should be longer. 10- 30 year terms so that the debt does not have to be refinanced at a time when it might not be possible.
PM PIO (Email from Fanning John tal.com Netcapital
I am writing regarding the Main Street Lending program, and the current ineligibility of certain nonprofit organizations.
The CARES Act excluded certain nonprofits from accessing the vital Paycheck Protection Program (PPP). In a letter last week to the
congressional leadership, 80 local Chambers of Commerce in California wrote the following: "Our organizations have determined that if
we are not allowed to access the PPP or some similar type of relief, our only recourse will be staff layoffs; resulting in the immediate loss of
approximately 123 jobs, representing $4.8 million in payroll. Should economic conditions not improve, or stay at home orders continue past
June 30th, those numbers will increase significantly."
Now that the PPP is exhausted, it is more important than ever to include all nonprofits in the Main Street Lending Program. This
unprecedented public health challenge has upended life for nearly every citizen and business in America. Businesses and organizations of all
types and sizes require assistance and support.
Chambers of commerce are especially vital in light of the increasing needs of small businesses during this pandemic. Local chambers serve
as vital communication channels for small business assistance and community needs. Federal, state and local governments need us as
Greater partners now more than ever.
4/16/2020 6:34:00 nortiz@bakoc Bakersfield
PM PIO (Email from Ortiz Nicholas hamber.com Chamber We urge you to include all nonprofits in the Main Street Lending Program.
Dear Secretary Mnuchin:
The Community Clinic Association of Los Angeles County (CCALAC) is concerned that the new Main Street Lending Program is heavily
weighted in favor of businesses and will leave out non-profits that desperately need assistance. CCALAC represents 63 non-profit community
clinic and health center organizations in Los Angeles County. Our members are business that are drivers of their local economies; not only
are they on the front line caring for patients during this crisis, but they also employ a wide range of staff from medical providers and support
staff, to call center operators, security and janitorial personnel. Many non-profit organizations are too big to qualify for SBA Paycheck
Protection Loans; they are having difficulties with cash flow during this crisis and are struggling to keep their doors open and their staff
employed. The CARES Act includes a specific provision that asks Treasury to start a loan program for businesses and non-profits with 500 -
10,000 employees. Congressional intent is clear that non-profits should have access to low-interest loans at this difficult time. I implore you to
explicitly include non-profit organizations in the Main Street Lending Program and ensure that guidance to lenders encourages them to make
loans to non-profits in addition to for-profit businesses.
Community Thank you,
Clinic Louise McCarthy
Association of President and CEO
4/16/2020 6:35:00 jpreece@ccal Los Angeles Community Clinic Association of Los Angeles County
PM PIO (Email from McCarthy Louise ac.org County
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Main Street Lending Program Comments
I serve as the President of the Board for The Center for Children & Young Adults (CCYA), a 501c(3) non-profit that provides a home for
youth who have been abused, neglected, and/or abandoned by their caregivers. Our three-building campus offers four residential programs in
a dormitory setting for up to 42 youth at one time in need of shelter, treatment, care and guidance. I IMPLORE you to not exclude non-profits
from the Main Street Lending Program. CCYA and others like it provide critical care services 24/7 - much like a healthcare facility, we do not
'shut down'. Half of our funding comes from the state of Georgia - that funding is directly tied to the number of children in the
mike.dewitt@ The Center for Center. Those numbers have dropped for various reasons related to COVID-19. But our costs continue. Our private donations have also
4/16/2020 6:38:00 brightworth.c Children and dropped dramatically. We did not receive funding in the PPP program. Please do not exclude non-profits in the Main Street program.
PM PIO (Email from DeWitt Mike om Young Adults
On behalf of interested clients of Steptoe & Johnson LLP, we submit the following two comments:
Please confirm that American companies with negative EBITDA can participate in the Main Street Lending Program despite the maximum
loan size factors. This would allow retailers, start-ups, and companies who are early in their corporate development to participate in the
program. Similarly, restricting loan sizes pursuant to the other applicable factors would assist companies with misleading or low EBITDAs to
participate in the program. Access to Main Street loans based on the other borrower criteria would allow a large number of growing employers
to access capital, maintain workforce levels, and continue their pre-crisis growth.
Please clarify that certain tax distributions may still be made despite on dividends. The term sheets refer to the 4003(c)(3)(A)(ii) prohibition on
dividends. The statutory language related to mid-sized businesses, however, includes a similar prohibition in 4003(c)(3)(D)(i)(VII), with the
following exception: "except to the extent required in a contractual obligation that is in effect as of the date of enactment of this
Act." The Main Street Lending Facility, focused on small and mid-sized businesses, should adopt this language. In addition, many
4/16/2020 6:40:00 mkulkin@ste Steptoe & closely-held businesses make tax distributions without a contractual agreement. These distributions should be respected given that many
PM PIO (Email from Kulkin Matthew ptoe.com Johnson LLP business owners rely on such distributions for the liquidity to pay taxes.
Despite the complications with Small Business Administration (SBA) loans, the fact that almost all the funding has been distributed suggests
that businesses are able to access this liquidity. However, when talking to many of the businesses throughout the state who are too large to
apply for the small business loans, there is often confusion surrounding how to access the funds.
There are both practical concerns of how to apply for the funding in the first place, if they qualify for the loans, and if they will be able to meet
the requirements set out by the CARES Act.
While the Fed has been granted a lot of leeway by Congress to administer this program, and rightfully so, more clarity is needed for
businesses.
We ask that the Fed both work to finalize all rules as soon as possible and work to provide more information on how to access these funds.
Mid-sized businesses have an important role to play in both the American and Louisiana economies. If they cannot figure out how to access
4/16/2020 6:41:00 eric@pelicani the funds to survive an economic crisis that was not of their making, we hold grave concerns about the future of our state's economy.
PM PIO (Email from Peterson Eric nstitute.org Pelican Institute
In order to be eligible for loans, medium- and large-sized businesses must meet a host of both present and future requirements, as laid out by
the CARES act. It should be noted that these loans are not forgivable like many small business loans are. These loans will be paid back with
interest, though at a fairly low rate.
Some of these requirements include not being able to use the funds for stock buybacks or increasing compensation for already high-earning
employees. Both of these outcomes were unlikely, as high earners in large companies often forgo their paychecks entirely or take large
reductions. Additionally, companies tend to buy back stock when they feel strong about their future and want to invest more in the firm. Given
the circumstances, they will almost certainly hold onto higher cash reserves.
Other requirements, specifically labor decisions for their employees, are more concerning. As with the last economic crisis, companies did not
cause this current situation. Companies trying to keep their doors open and continuing to pay their employees are taking these loans with little
choice in the matter. Severely restricting the ability of companies to make the best labor decisions moving forward on a condition of taking the
4/16/2020 6:43:00 eric@pelicani Pelican Institute loan will not help the American economy get back on track. In fact, it will hinder it.
PM PIO (Email from Peterson Eric nstitute.org for Public Policy The Federal Reserve should do everything in its power to provide maximum labor flexibility to loan recipients.
As the CFO of a non-profit that serves as a funder to other non-profits, it's imperative that our non-profit sector is included in any type of
funding made available by the government. If it were not for the many social services provided by our sector, many of our citizens would not
have their essential needs met. Our resources are generated from the generous donors in our community. During this epidemic, some of
them are not able to give at the same level due to the stock market. Most non-profits do not have a large reserve to weather the type of storm
we are facing today. As a voting and contributing citizen, my husband and I want to see non-profits continue to thrive in our community to
help meet the needs of the less fortunate. Our family is trying to do its part, we want to see our government leaders step up and do their part
4/16/2020 6:46:00 tepting@cfbh by supporting non-profits in every funding opportunity made available to small businesses. Thank you.
PM PIO (Email from Epting Terri am.org
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Main Street Lending Program Comments
The wine and spirits wholesale industry could be impacted by the "committed but undrawn debt" restriction because use of that
credit method is widely used to finance inventory, and we would therefore ask that you consider removing that condition in its entirety from the
term sheets.
Otherwise we urge the Federal Reserve to consider modifying the Loan Facility Term sheets to allow borrowers to calculate their loan
amounts using only the amount of "committed but undrawn debt" that is available to them without punitive bank responses.
We propose the following modification for your consideration:
Substitute "available" for "committed" in item 5.
Add the following clarifying language: "For purposes of determining the eligible loan amount (or, for purposes of this provision), an
Wine & eligible borrower's existing outstanding and available but undrawn bank debt does not include any amount that, if drawn, would cause
Spirits the Borrower to suffer fees, penalties, restrictions, or limitations on its operations. Lease financing obligations are also excluded."
4/16/2020 6:46:00 ali@wswa.or Wholesalers of
PM PIO (Email from Hobbs Dawson g 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. I serve on the
Personal board of directors of Momentum for Mental Health, which provides mental and other health care to over 2,000 clients per year in the Santa
4/16/2020 6:49:00 Email Elite Realty Clara County area, with a staff of 400 employees. We need the funding for this non-profit now more than ever.
PM PIO (Email from Hernandez Fernando Address Sales
Please provide clarity on the two different loans, and if we can borrow on both.
Also seeking clarity on the MSNLF calculation of the maximum loan size as part 5(ii) is unclear.
Seeking clarification as to EBITDA/Leverage test: For the Main Street it asks about "undrawn debt" for the Expanded it asks about
"undrawn bank debt". As an example, we have project specific real estate loans that are not fully drawn. Do we need include these
amounts in our calculation?
When we calculated EBITDA, does the interest adjustment include capitalized interest amounts? Interest in WIP vs interest in COGS?
Is there a possibility to remove or change the restrictions on capital distributions - especially makes sense for the shareholders who use
4/16/2020 6:50:00 melanie@vill capital distributions in lieu or in addition to their salaries?
PM PIO (Email from Rudquist Melanie age-life.net Village Life 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.
4/16/2020 6:52:00 rebecca@gnt GNTV Media 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 McAleer Rebecca v.info Ministry this unprecedented crisis depends on the success of our nation's nonprofits.
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Main Street Lending Program Comments
To whom it may concern:
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. The nation's nonprofits typically serve those who are
more deeply impacted by such unprecedented times such as these and we must be able to able to continue those services to ensure
everyone is able to recover.
Habitat for
4/16/2020 7:01:00 ssteele@dek Humanity Best,
PM PIO (Email from Steele Sharon albhabitat.org DeKalb Sharon Steele
4/16/2020 7:04:00 mgunnin@es I am interested in learning more about the Main Street Lending for Small Businesses.
PM PIO (Email from Gunnin Matthew ports.one Esports One, Inc
Related to COVID 19
I am affiliated with a non-profit organization that provides behavioral health, child welfare services, housing support to individuals in
California.
I ask the Federal Reserve and Treasury Department to immediately issue guidance on a program, as directed under the CARES Act, to
provide financing to banks and other lenders to make loans to non-profits and other mid-size businesses (between 500-10,000 employees).
We request that the program include the following:
oInclude a 0.50% interest rate (50 basis points) for 501(c)(3) charitable nonprofits at a 5-year amortization
oProvide priority to 501(c)(3) charitable nonprofits responding to COVID-19 relief efforts
Hathaway- oPayments should not be due until two years after a direct loan is made
Sycamores Child oEmployee retention provisions should begin on the date that loan funding is received by the borrower
4/16/2020 7:04:00 msternberg@ and Family oIn any workforce restoration and retention provisions, "workforce" should be defined as full-time employees or full-time
PM PIO (Email from Sternberg Mollie hscfs.org Services equivalents
On behalf of BCD Travel, Travel Leaders Group, and Travel and Transport, some of the nation's largest travel management companies
(TMCs), please consider the following:
To recover from COVID-19, TMCs will need capital to maintain their infrastructure and bring back employees. TMCs work with companies
across the U.S. to manage travel programs, optimize budgets and help fulfill duty of care obligations that keep business travelers safe.?TMCs
will be at the forefront of nationwide recovery efforts because their services, including arranging safe travel itineraries and tracking travel
restrictions, will be needed to get the global economy safely moving again.
Travel bookings for TMCs have almost ceased entirely, and there will be a slow return once social distancing restrictions begin to ease. To
address these challenges, we urge the Federal Reserve to adopt the following policies:
- Extend loan repayment terms to 10 years to accommodate the travel sector's slow recovery. - - Consider raising maximum loan
amount for new loans to $100 million to provide greater flexibilities to respond to needs of distressed industries.?
- Be lenient on provisions requiring that a business must use reasonable effort to maintain payroll and employees; many TMCs will have little
stewart@mo business for the foreseeable future.
4/16/2020 7:05:00 numentadvoc Monument - Place a cap on loan origination fees and fees charged by lenders for amending existing facilities that may be required as a result of
PM PIO (Email from Verdery C. Stewart acy.com Advocacy participation in the program.
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Main Street Lending Program Comments
Mission City Community Network(MCCN), a Not-For-Profit 501 C(3) community clinic is deeply concerned to learn that nonprofits are
ineligible for the Federal Reserve's new "Main Street" lending facility, despite the fact that nonprofits are leading the effort to
respond to this pandemic. MCCN has been providing tele visits as well as video visits with very little funding to our low income community
patients. Nonprofits like ours need access to these government backed revenue streams and loan programs. The exclusion of non-profits is a
particularly devastating blow for larger nonprofits who are ineligible for the Paycheck Protection Program lending option. Given the current
Mission City financial crisis and loss of revenue, nonprofits, including critical health care entities, may be forced to shrink their services or even close,
4/16/2020 7:07:00 nikg@mccn.o Community meaning tens of thousands could go without care. We urge the Federal Reserve to expand the eligibility of this program to explicitly include
PM PIO (Email from Gupta Nik rg Network nonprofits.
Center for Family Health & Education is deeply concerned to learn that nonprofits are ineligible for the Federal Reserve's new
"Main Street" lending facility, despite the fact that nonprofits are leading the effort to respond to this pandemic. Despite a 60%
decrease in patient visits due to "Stay at Home" orders, our non-profit clinics have kept staff on the job, doing triage and
Coronavirus testing in tents to protect staff inside the facilities. We have switched chronically ill patients to telehealth visits and are keeping
faith with the community in our commitment to service. Nonprofits like ours need access to these government backed revenue streams and
loan programs. The exclusion of non-profits is a particularly devastating blow for larger nonprofits who are ineligible for the Paycheck
Protection Program lending option. Given the current financial crisis and loss of revenue, non-profits, including critical health care entities,
Center for Family may be forced to shrink their services or even close, meaning tens of thousands could go without care. We urge the Federal Reserve to
4/16/2020 7:09:00 dkashani@cff Health & expand the eligibility of this program to explicitly include nonprofits.
PM PIO (Email from Kashani Daryoush hae.org Education
As outside counsel to the YMCA of Greater Seattle, I am writing to urge that nonprofits, especially those with more than 500 employees are
deemed eligible for the Main Street Loan Program. Nonprofits have depleted their cash reserves addressing COVID-related community
lonnie@300d needs including for childcare for healthcare workers, shelters and nutrition programs, and need financial support to sustain operations during
4/16/2020 7:10:00 egreeslaw.co 300degrees, the COVID crisis. Nonprofit organizations should be granted loan forgiveness in the Main Street Lending program. Nonprofits are doing much
PM PIO (Email from Rosenwald Laura m PLLC of the relief work that the government would otherwise be responsible for.
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
brenna_bolge departments and drastically increasing health care costs. As such, it is imperative that the Main Street New Loan Facility eligibility include
4/16/2020 7:14:00 r@prxdigital.c nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
PM PIO (Email from bolger brenna om prxdigital
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 7:15:00 briana@prxdi eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
PM PIO (Email from Gallo Briana gital.com
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Main Street Lending Program Comments
On behalf of the Union for Reform Judaism, whose nearly 850 congregations across North America encompass 1.5 million Reform Jews, and
the Central Conference of American Rabbis, whose membership includes more than 2,000 Reform rabbis, we urge the Federal Reserve to
ensure nonprofits are eligible for support lending under the Main Street Lending Program during the COVID-19 emergency and economic
recession.
As Americans struggle with the impact of shuttered businesses, closed schools, and more, nonprofits are being called on more than ever to
provide critical aid while their own financial resources are greatly diminished. In this time of need, we urge the Federal Reserve to make
necessary improvements to the Main Street New Loan Facility and the Main Street Expanded Loan Facility and ensure that nonprofits are
able to sustain their critical work.
We are inspired by Jewish tradition and values that teach the importance of strong communal institutions that help individuals become self-
sufficient. The Jewish philosopher Moses Maimonides taught that the highest form of tzedakah, charity, was that which helped people to
Union for Reform become self-sufficient. America's nonprofits help community members become more self-sufficient every day. Now, in their own time of
Judaism, need, the Federal Reserve must help nonprofits continue their essential work.
Religious Action
4/16/2020 7:17:00 jjacoby@rac. Center of Reform Guided by our teachings, we strongly urge the Federal Reserve to support including eligibility for nonprofits in the Main Street Lending
PM PIO (Email from Pesner Rabbi Jonah Dov org Judaism Program.
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.
Coastal Empire
4/16/2020 7:17:00 bill.kovach@ Montessori 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 Kovach Bill cemco.org Charter School unprecedented crisis depends on the success of our nation's nonprofits.
On behalf of New York Institute of Technology, I ask that the Federal Reserve clarify if private, nonprofit universities are eligible for the Main
Street Lending program, and whether student workers are exempted for the purpose of the employee count.
These universities are major employers with significant impact in their communitied (ours is $634 M and over 5000 jobs).
We are facing a major cash flow crisis due to reduced revenue and increased spending resulting from the COVID-19 pandemic (room and
board refunds, investments in technologies for remote instruction, deep-cleaning of campus buildings, increased security, and revenue losses
due to cancellation of in-person events and summer programs).
Low-cost loan programs (Main Street Lending) would help New York Tech address the financial impact of the COVID-19 crisis. However, two
main issues may prevent our access to this and other programs: 1) we request that the Federal Reserve update the guidance to clarify
whether public and private nonprofit colleges and universities are eligible for the Main Street program; 2) we ask that student workerd be
New York exempted for tbe purpose of the employee threshold fir eligibilty (business under 10,000 employees).
4/16/2020 7:18:00 President@n Institute of Looking forward to working with you as the Federal Reserve responds to the COVID-19 crisis.
PM PIO (Email from Foley Henry (Hank) yit.edu Technology Dr. Foley
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 7:19:00 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 MacDonald Stephen this unprecedented crisis depends on the success of our nation's nonprofits.
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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
CSU campuses have moved classes to online instruction; revenue streams have decreased significantly and refunds have been made to
students in a number of areas, including student housing, parking, and student dining. In order to meet these challenges and keep personnel
employed, public universities and non-profit entities will require access to low-cost capital. The CSU notes: There has been confusion about
the eligibility of public universities and non-profits for this program. We ask for updated the guidance to clarify that non-profit entities and
public institutions of higher education with direct borrowing authority are eligible for the Main Street Lending program; and clarity is needed
with respect to the definition of employment of student workers. Specifically, the CSU asks that student workers be exempted for the purposes
of the employee threshold for eligibility (businesses with under 10,000 employees). We hope that future guidance from the Federal Reserve
will make it clear that institutions can exempt student workers from the employee count. Many of our campuses employ student workers as a
part of overall student financial support to help pay for college and to provide students with work experiences while keeping them close to
campus. With our campuses closed, all or most of these student employees are no longer present, and therefore should not be included for
4/16/2020 msidney@cs Chico State the purposes of the employee threshold. Thank you. Mary Sidney, CEO
12:00:00 AM PIO (Email from Sidney Mary uchico.edu Enterprises
CARSON It is important that funds for 501(c) 6 non-profit organizations be included in the extension to the initial CARES funding because they serve the
Leong@cars Chamber of nation in an important way by representing workers and businesses in a way that no other organization does.
4/16/2020 7:23:00 onchamber.c Commerce, Their role in furtherance of the community is also an important part of what they do.
PM PIO (Email from Chang Richard om California
I am affiliated with a non-profit organization that provides behavioral health, child welfare services, housing support to individuals in
California.
I ask the Federal Reserve and Treasury Department to immediately issue guidance on a program, as directed under the CARES Act, to
provide financing to banks and other lenders to make loans to non-profits and other mid-size businesses (between 500-10,000 employees).
We request that the program include the following:
oInclude a 0.50% interest rate (50 basis points) for 501(c)(3) charitable nonprofits at a 5-year amortization
oProvide priority to 501(c)(3) charitable nonprofits responding to COVID-19 relief efforts
oPayments should not be due until two years after a direct loan is made
oEmployee retention provisions should begin on the date that loan funding is received by the borrower
oIn any workforce restoration and retention provisions, "workforce" should be defined as full-time employees or full-time
equivalents
Hathaway Many non-profit organizations are not able to access the Paycheck Protection Program , which is critical to ensure the continued provision of
Sycamores Child essential services during this crisis
4/16/2020 7:28:00 aescamilla@ and Family Without increased access to loan programs intended to sustain payroll and retain employees, these mid-sized non-profit organizations are
PM PIO (Email from Escamilla Adrianna hscfs.org Services at financial risk, a circumstance that could leave thousands of individuals without timely access to needed care.
Pediatric & Family Medical Center, dba Eisner Health is deeply concerned to learn that nonprofits are ineligible for the Federal
Reserve's new "Main Street" lending facility, despite the fact that nonprofits are leading the effort to respond to this
pandemic. While hospitals provide emergency care to treat COVID-19, our health center addresses all of our community's other
healthcare needs that cannot be ignored. Today, we operate in 16 locations throughout Los Angeles County and serve over 50,000 patients,
which generates over 200,000 annual visits-ranging from primary care to dental services, among many others. Nonprofits like ours require
access to these government-backed revenue streams and loan programs. The exclusion of non-profits is a particularly devastating blow for
larger nonprofits who are ineligible for the Paycheck Protection Program lending option. Given the current financial crisis and loss of revenue,
nonprofits, including critical health care entities, may be forced to shrink their services or even close, meaning tens of thousands could go
without care, and hundreds of staff members will be unemployed. We urge the Federal Reserve to expand the eligibility of this program to
explicitly include nonprofits.
snavolnev@e
4/16/2020 7:33:00 isnerhealth.or Thank you very much for your consideration.
PM PIO (Email from Navolnev Sergey g Eisner Health Sergey Navolnev on behalf of Eisner Health.
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Main Street Lending Program Comments
Given the following restrictions under Sec. 4003(c)(3)(A)(ii)(II) and Sec. 4003(c)(3)(D)(i)(VII) of the CARES Act, which restriction applies to the
Main Street Lending Program?
Sec. 4003(c)(3)(A)(ii)- The Secretary may make a loan, loan guarantee, or other investment under subsection (b)(4) as part of a program or
facility that provides direct loans only if the applicable eligible businesses agree-
(II) until the date 12 months after the date on which the direct loan is no longer outstanding, not to pay dividends or make other capital
distributions with respect to the common stock of the eligible business; and
Sec. 4003(c)(3)(D)(i)(VII)- the recipient will not pay dividends with respect to the common stock of the eligible business, or repurchase an
equity security that is listed on a national securities exchange of the recipient or any parent company of the recipient while the direct loan is
4/16/2020 7:37:00 kathleen.sifer outstanding, except to the extent required under a contractual obligation that is in effect as of the date of enactment of this Act;
PM PIO (Email from Sifer Kathleen @us.gt.com Grant Thornton
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.
Email Address
4/16/2020 7:38:00 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 Deboer Dylan Good News TV this unprecedented crisis depends on the success of our nation's nonprofits.
4/16/2020 7:39:00 Info@abdent A&B Dental Hello, where and how soon can I apply for the Main Street lending program? Thank You.
PM PIO (Email from Singh Jivtesh alny.com PC
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 7:40:00 mcbeattie@jp eligibility include nonprofit organizations employing up to 10,000 employees or with 2019 annual revenue up to $2.5 billion.
PM PIO (Email from Beattie Martha s.net
Rakeem.Boy Support for the Main Street lending program to include non-profit organizations over 500 people is vital to our continued existence during this
4/16/2020 7:41:00 kins@Hearts crisis. We serve some of society's most vulnerable individuals -- children and adults with intellectual and developmental disabilities! We
PM PIO (Email from Boykins Rakeem hare.org Heartshare need your support!
Non-profits, including higher education organizations, employ millions of American workers, have a huge economic impact, and have a
massive impact generally on their local communities. Right now, they are providing essential services in those communities. Non-profits
should be eligible for loans through the proposed Main Street Lending program. To illustrate the point, I work for an arts and culture non-profit
in Providence, RI. Data compiled by the National Endowment of the Arts in 2018 found that the arts contribute $763.6 billion to the U.S.
economy, more than agriculture, transportation, or warehousing. The arts employ 4.9 million workers across the country with earnings of
more than $370 billion. Despite some temporary programmatic suspensions, my organization is still providing essential services such as
housing to low income resident artists and much needed stipends to youth in our community, including incarcerated and formerly incarcerated
youth, those who are pregnant and parenting, youth in foster care, and youth at high risk of school dropout and disconnection. Our services
are needed more than ever during the COVID-19 pandemic. There is no valid reason not to include non-profit businesses such as ours in the
4/16/2020 7:42:00 Paris@as220 Main Street Lending program, and not doing so potentially creates further financial burden on already chronically underfunded service
PM PIO (Email from Paris Paris .org AS220 providers.
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Main Street Lending Program Comments
General
Question: Could the Federal Reserve please provide clarification on the relationship between the CARES Act and the Federal Reserve term
sheets, including, but not limited to, the Main Street Lending Program's MSNLF and MSELF?
Question: How do the restrictions referenced under 4003(c)(3)(D)(i) apply to the Federal Reserve's term sheets, including, but not
limited to, the Main Street Lending Program's MSNLF and MSELF?
4/16/2020 7:43:00 kathleen.sifer Question: With respect to the restrictions under Sec. 4003(c)(3)(A)(ii)(II) and Sec. 4003(c)(3)(D)(i)(VII) of the CARES Act, which restrictions
PM PIO (Email from Sifer Kathleen @us.gt.com Grant Thornton apply to the Main Street Lending Program?
elizabeth.alva Support for the Main Street lending program to include non-profit organizations over 500 people is vital to our continued existence during this
rez- crisis. We serve some of society's most vulnerable individuals -- children and adults with intellectual and developmental disabilities! We
anchundia@ need your support!
4/16/2020 7:44:00 heartshare.or
PM PIO (Email from Anchundia Elizabeth g
Debt & Prepayment
The following questions are in regard to the MSNLF and MSELF Eligible Loans Section 5.
oQuestion: As such, can it be understood to mean that firms must max out their potential debt draws before they are eligible?
oQuestion: As such, if current debt alone already exceeds the amount noted in clause (I), can it be understood to mean that firms are not
eligible for the MSLP?
oQuestion: As such, can it be understood to mean that EBITDA negative firms are not eligible for the MSLP?
oQuestion: How is "existing outstanding but undrawn bank debt" defined and/or calculated?
4/16/2020 7:46:00 kathleen.sifer oQuestion: As such, can it be understood to mean the six times EBITDA leverage covenant applies to all types of debt, including mortgage
PM PIO (Email from Sifer Kathleen @us.gt.com Grant Thornton debt for firms with real estate assets?
Organizational Structures
The following questions are in regard to the MSELF/MSNLF Required Attestations Section.
oQuestion: Can you please define what it means for a company to "make reasonable efforts to maintain its payroll and retain its
employees"?
?How do such efforts pertain to hourly employees?
?How do such efforts pertain to employees who have already been laid off or partially furloughed?
?How do such efforts pertain to Eligible Borrowers who have made wage reductions across the entire firm?
According to the MSELF/MSNLF Eligible Borrowers Section, "each Eligible Borrower must be a business that is created or organized
in the United States or under the laws of the United States with significant operations in and a majority of its employees based in the United
States."
oQuestion: As such, can this be understood to mean United States' businesses with offshore companies are not considered separate
entities?
oQuestion: How is the "business of lobbying" defined?
4/16/2020 7:49:00 kathleen.sifer ?If the primary function of the organization is lobbying, are they in the "business of lobbying"?
PM PIO (Email from Sifer Kathleen @us.gt.com Grant Thornton ?If a trade association has a lobbyist on staff, but their organization's primary function is not lobbying, are they eligible?
Non-profits, including higher education organizations, employ millions of American workers, have a huge economic impact, and have a
massive impact generally on their local communities. Right now, they are providing essential services in those communities. Non-profits
should be eligible for loans through the proposed Main Street Lending program. To illustrate the point, I work for an arts and culture non-profit
in Providence, RI. Data compiled by the National Endowment of the Arts in 2018 found that the arts contribute $763.6 billion to the U.S.
economy, more than agriculture, transportation, or warehousing. The arts employ 4.9 million workers across the country with earnings of
more than $370 billion. Despite some temporary programmatic suspensions, my organization is still providing essential services such as
housing to low income resident artists and much needed stipends to youth in our community, including incarcerated and formerly incarcerated
youth, those who are pregnant and parenting, youth in foster care, and youth at high risk of school dropout and disconnection. Our services
Personal are needed more than ever during the COVID-19 pandemic. There is no valid reason not to include non-profit businesses such as ours in the
4/16/2020 7:50:00 Email Main Street Lending program, and not doing so potentially creates further financial burden on already chronically underfunded service
PM PIO (Email from Devlin Kaitlin Address AS220 providers.
Page 297 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
Use of Eligible Loan
According to the Federal Reserve's April 9th, 2020 press release on the Main Street Lending Program, "The Federal Reserve
established the Main Street Lending Program to enhance support for small and mid-sized businesses that were in good financial standing
before the crisis...Firms seeking Main Street loans must commit to make reasonable efforts to maintain payroll and retain workers. Borrowers
must also follow compensation, stock repurchase, and dividend restrictions that apply to direct loan programs under the CARES Act."
oQuestion: As such, can this be understood to mean Eligible Borrowers are not permitted to use Eligible Loans to make acquisitions?
According to the MSELF/MSNLF Required Attestations Section, "The Eligible Borrower must attest that it will follow compensation,
stock repurchase, and capital distribution restrictions that apply to direct loan programs under section 4003(c)(3)(A)(ii) of the CARES
Act"
oQuestion: As such, can this be understood to mean there are no exceptions for tax distributions of Eligible Borrowers who may be S-
corporations or other pass-through businesses?
oQuestion: As such, can this be understood to mean there are no exceptions for Eligible Borrowers who have an annual repurchase
obligation to buy-back Treasury stock?
4/16/2020 7:50:00 kathleen.sifer
PM PIO (Email from Sifer Kathleen @us.gt.com Grant Thornton
Main Street Lending
I am a small business owner as a landlord which owns retail spaces. Confidential Business Information
Confidential Business Information
I don't see where I can apply for The Main Street lending program ?
For the SBA or disaster relief fund programs I have reached out too many different banks and none of them can help me. They all suggest
that I just go online. With Wells Fargo they finally sent me an email indicating I can now apply online and after applying online I then received
a message saying they are out of funds on the SBA program and they suggest that I apply elsewhere.
Confidential
I do not have payroll per se, I am a K-1 recipient and deal with outside third party as far as management company and vendors. Business
Information
Any assistance or suggestions would be greatly appreciated of who I can talk to about Main Street Lending and other disaster relief programs
Confidential Business Information
that could be available to me,
Please advise.
Personal Village Property Thank you,
4/16/2020 Email Management, Todd Silver
12:00:00 AM PIO (Email from Silver Todd Address LLC
Page 298 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 employer with numerous manufacturing facilities across the United States, thyssenkrupp North America respectfully submits the
following recommendations in connection with the Main Street New Loan Facility ("MSNLF"):
1)Given the magnitude of the business interruptions and uncertainties facing middle market businesses with up to 10,000 employees in
connection with the Covid-19 pandemic, the existing Maximum Loan Size of $25 million is overly restrictive. We ask that the maximum loan
size be increased to $250 million.
2)Since the MSNLF does not include a payroll support grant (such as the SBA Paycheck Protection Program), it is not reasonable, or even
financially prudent, to require borrowers to make any specific payroll maintenance commitments.
3)The compensation limits with respect to employees whose total compensation exceeds $425,000 is overly restrictive, given the
importance to the business and extraordinary efforts of many such employees during this exceptional crisis.
Thank you for the chance to respond.
Respectfully submitted,
Joseph Weber
Vice President, Finance and Accounting
thyssenkrupp North America
111 West Jackson Blvd., Suite 2400
Chicago, IL 60604
joseph.weber Office: 312-525-2787
4/16/2020 7:53:00 @thyssenkru Thyssenkrupp Cell Phone Number
PM PIO (Email from Weber Joseph pp.com NA Email: joseph.weber@thyssenkrupp.com
Support in the form of forgivable or no-interest loans should be offered to nonprofits with over 500 employees. We have seen both a
decrease in funding and an increase in expenses, and our expectation is that this will continue. We already work on a slim budget and in
order to continue to offer much needed services, we must be able to maintain staffing. Confidential Business Information
mhallbick@b Additionally, we do not anticipate increases in future funding, and
4/16/2020 7:53:00 abcockcenter Babcock Center, it will take some time to recover from this crisis, so any additional expenses in the form of interest could be difficult to manage.
PM PIO (Email from Hallbick Melissa .org Inc.
On behalf of the University of Wisconsin System and our statewide Small Business Development Center (SBDCs) affiliates, we write with
enormous gratitude for the federal government's support through funding provided in the CARES Act, which provided much-needed
regulatory and financial assistance to our students and universities. Our SBDC units have also been able to assist in delivering Economic
Injury Disaster Loan and Paycheck Protection Program support to small- and medium-sized businesses. This has been a key driver in our
effort to extend a vital economic lifeline to business owners who rely on expertise from our business development professionals. The high
demand we have underscores the need for hardworking Americans to access relief as soon as possible. Unfortunately not every business is
eligible for the Disaster Loans or Paycheck Protection Program offerings. Under current guidelines, the Federal Reserve "Main
Street" lending facility excludes nonprofit entities, certain institutions of higher learning, and minority-serving institutions. These
omissions are significant since these entities are ineligible to participate in the Paycheck Protection Program. As the Federal Reserve
University of assesses eligibility requirements going forward, we strongly urge changes to make these programs more inclusive. We see such inclusion as
4/16/2020 7:53:00 rcross@uwsa Wisconsin a means to further energize and catalyze the prospects for recovery for a broader constituency of organizations represented in Wisconsin and
PM PIO (Email from Cross Ray .edu System nationwide.
Page 299 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 submit comments regarding the Federal Reserve's (FRB's) Main Street Lending Program facilities.
Under these facilities, U.S. taxpayers, through the Federal Reserve, will purchase 95% participations in loans to eligible businesses, i.e. those
w/ up to 10,000 employees or up to $2.5 billion in annual revenue. The taxpayer funds being put at risk, in the middle of an economic crisis,
must ultimately benefit Main Street, not be a means to fund executive bonuses or payouts to shareholders, investors or others with no benefit
to the real economy, which occurred too often during the 2008 financial crisis. At a minimum, FRB must ensure the following:
Transparency: FRB must ensure maximum transparency through prompt public disclosures of the terms, recipients and other beneficiaries of
funds under these facilities as well as all fees and profits. The public has a right to know who its taxpayer dollars are benefiting and how.
Compliance with key terms: FRB must require that participating banks have a robust process for ensuring that recipients comply with the
attestations required under the terms of the facilities, including that the funds be needed because of COVID-19, that they retain employees,
and that they comply with restrictions on compensation and capital distributions.
Accountability: FRB must hold accountable any banks and recipients that fail to comply with their obligations by swift, meaningful and publicly
jgrimes@bett disclosed penalties.
4/16/2020 7:57:00 ermarkets.co Better Markets,
PM PIO (Email from Kelleher Dennis m Inc.
AltaMed Health Services is deeply concerned to learn that nonprofits are ineligible for the Federal Reserve's new "Main
Street" lending facility, despite the fact that nonprofits are leading the effort to respond to this pandemic.
AltaMed is committed to protecting our patients' health and we are leading efforts in Southern California to ensure patients have access
to the testing they need during this pandemic at our clinics and urgent care centers. Our teams are in coordination with our local and state
departments of public health and are following their recommended guidance, along with the guidance provided by the CDC at all of our clinic
locations.
Nonprofits like ours need access to these governments backed revenue streams and loan programs. The exclusion of non-profits is a
particularly devastating blow for larger nonprofits who are ineligible for the Paycheck Protection Program lending option. Given the current
rocgonzalez financial crisis and loss of revenue, nonprofits, including critical health care entities, may be forced to shrink their services or even close,
4/16/2020 7:58:00 @altamed.or AltaMed Health meaning tens of thousands could go without care. We urge the Federal Reserve to expand the eligibility of this program to explicitly include
PM PIO (Email from Torres Marie g Services nonprofits.
As a key resource for businesses, we are concerned that the program will leave small businesses unable to access its benefits.In order to
better serve them, we recommend the following.The current thresholds of 10,000 employees and $2.5 billion in revenue are high for small
businesses, making it likely that they would be left out of the program.We recommend lowering the threshold to mirror SBA's size
standards.The set date of April 8 for this program should be adjusted and set to March 1.This is the point when businesses began to apply for
various loans and financial assistance.The proposal does not include CDFI's as lenders.However,they are crucial in supporting small
businesses.These institutions should also be included in the program along with FinTech companies.The threshold of the minimum loan size
of $1 million will also leave many small businesses ineligible.Most of these businesses do not have loans of this size or are unable to qualify
for them.As we look at making adjustments to this program to benefit small businesses the regulations for this program need to address
whether or not this program will be applicable to SBA loans.These suggestions will help this program truly benefit small businesses.Providing
cindyramosd El Paso Hispanic them with access to the capital they critically need will make all the difference as we look to economically recover from this crisis.If you have
4/16/2020 7:58:00 avidson@eph Chamber of any questions, please reach out to me at cindyramosdavidson@ephcc.org.Sincerely, El Paso Hispanic Chamber of Commerce.
PM PIO (Email from Ramos-DavidsCindy cc.org 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
uniquely endangered, and must be included in any and all relief packages available.
4/16/2020 7:59:00 Patrick@gntv Macon Urban 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 Shownes Patrick .info Ministry this unprecedented crisis depends on the success of our nation's nonprofits.
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