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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
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                                                                                                                              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
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                                                                                                                              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
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                                                                                                                              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
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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.

   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
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                                                                                                                              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
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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.
                                                                                     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
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 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.




                                                                                                                                             Page 222 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


                                                                                                                           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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                                                                                                                              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.




                                                                                                                                             Page 225 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
                                                                                                  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




                                                                                                                                             Page 226 of 363
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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




                                                                                                                                             Page 227 of 363
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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!




                                                                                                                                             Page 228 of 363
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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




                                                                                                                                             Page 229 of 363
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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.




                                                                                                                                             Page 230 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 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




                                                                                                                                             Page 231 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 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
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 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
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                                                                                                                               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
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                                                                                                                              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




                                                                                                                                             Page 241 of 363
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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




                                                                                                                                             Page 242 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 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



                                                                                                                                             Page 243 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 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.




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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




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                                                                                                                              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.




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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.




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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
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                                                                                                                               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




                                                                                                                                             Page 273 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 5:25:00                                                                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




                                                                                                                                             Page 276 of 363
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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
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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 5:37:00                                                                 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
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                                                                                                                              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
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                                                                                                                               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
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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 5:41:00                                                                 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
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                                                                                                                               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



                                                                                                                                             Page 283 of 363
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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




                                                                                                                                             Page 284 of 363
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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.




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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




                                                                                                                                             Page 293 of 363
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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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                                                                                                                              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.




                                                                                                                                             Page 295 of 363
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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.




                                                                                                                                             Page 296 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


                                                                                                                           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.




                                                                                                                                             Page 300 of 363
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